I recently spoke with health and safety professionals at an IOSH branch event. We discussed PUWER Regulation 10 and the importance of CE marking. This topic is crucial for workplace safety, ensuring machinery compliance, and protecting employees. My goal is to provide insights into the CE marking process, its importance, and practical implications for machinery risk assessment.
The Importance of PUWER Regulation 10
PUWER (read more) was established in the UK to ensure the safety of employees when using work equipment. PUWER Regulation 10 mandates that work equipment comply with essential requirements outlined in “community directives.” This means that machinery used within a facility must bear the CE mark, signifying compliance with European Union safety requirements. However, simply checking for a CE mark is not enough. While the CE mark indicates compliance, it is typically based on self-certification, meaning not all CE marks are created equal.
The Role of CE Marking in Machinery Safety
CE marking is a declaration by the manufacturer that a machine meets all legal requirements for CE marking and can be sold throughout the European Union. This process ensures that machinery is safe to use and meets specific safety standards. The UK government’s recent decision to indefinitely accept CE marking highlights its importance and reliability, easing the movement of goods between the UK and EU and rendering the UKCA certification mark obsolete.
Compliance with CE marking covers all safeguarding requirements within PUWER (Regulations 4, 7, 8, 11-16, 18-23, 26, 28, 29), saving HSQE managers time in recording hazards and implementing safety measures.
The CE Marking Process
Understanding the CE marking process is essential for anyone involved in procuring or using machinery. Here’s a breakdown of the steps:
- Identify Applicable Directives: Determine which EU directives or UK statutory instruments apply to the machine. This typically includes the Machinery Directive or its UK equivalent and the Low Voltage Directive or the UK’s Electrical Equipment (Safety) Regulation for electrical equipment.
- Compliance with Essential Requirements: The machine must comply with the essential requirements outlined in the applicable directives. Following harmonized standards provides a presumption of conformity with the directives.
- Design and Testing: Design the machine according to the standards and conduct necessary testing. Most industrial machinery components already meet required standards, simplifying this step.
- Technical File: Compile a technical file that includes design documentation, electrical diagrams, a bill of materials, and user manuals to justify compliance with the relevant standards and directives.
- Declaration of Conformity: Once compliance is achieved, the manufacturer generates a Declaration of Conformity and applies the CE mark to the machine.
Evaluating CE Marking Robustness
When procuring machinery, it’s essential to evaluate the robustness of the CE marking. Here are some tips:
- Check the Declaration of Conformity (DoC): Ensure it includes the manufacturer’s details, product identification, applicable directives, and harmonized standards. Any discrepancies or irrelevant standards should raise red flags.
- Consider the Origin: Be cautious with machinery from regions known for lower manufacturing standards. Some American and Chinese machines have been found to lack proper safety measures despite bearing the CE mark.
- Request Documentation: For high-value machinery, ask for additional documentation from the technical file to indicate the manufacturer’s understanding of CE marking requirements.
Practical Example: PUWER Assessment in a Distribution Warehouse
To illustrate the importance of proper machinery compliance, let me share an example from a recent PUWER assessment in a distribution warehouse. The client, concerned about potential non-compliance, invited us to inspect their facility. An extensive conveyor system, crucial to operations, lacked proper guarding and safety measures. Had this conveyor system been properly CE marked, it would have complied with numerous safety standards, including:
- EN 619: Continuous handling equipment and systems
- EN ISO 13857: Distances to prevent hazard zones from being reached
- EN ISO 13850: Emergency stop function
- EN ISO 13849: Safety-related parts of control systems
- EN ISO 13854: Minimum gaps to avoid crushing
- EN ISO 14118: Prevention of unexpected start-up
- EN ISO 14119: Interlocking devices associated with guards
- EN ISO 14120: Guards
- EN 60204-1: Electrical safety
- EN ISO 13855: Positioning of safeguards concerning approach speeds
Compliance with these standards would cover all the requirements for safeguarding measures within PUWER.
Using Standards as a Risk Assessment Tool
Risk assessment is crucial for ensuring machinery safety. Traditional risk assessments can be subjective, influenced by individual biases. To make this process more objective, I recommend using harmonized standards as a benchmark for hazard identification and risk mitigation.
For example, a parcel sorting machine in a mailing center lacked proper guarding interlocking with the process. By using applicable standards, we recommended safeguards that complied with CE marking requirements and enhanced overall safety.
Conclusion
Ensuring machinery safety through proper CE marking and compliance with PUWER Regulation 10 is paramount. Health and safety professionals must understand the CE certification process and conduct thorough audits of machinery compliance. Key takeaways include:
- Ensure Machinery is CE Marked: Verify that all machinery used in your facility bears the CE mark and is examined for compliance.
- Scrutinize the Declaration of Conformity: Review the DoC for completeness and relevance.
- Consider the Origin of the Machinery: Be cautious with machinery from regions with known lower manufacturing standards and request additional documentation if necessary.
- Use Harmonized Standards for Risk Assessment: Utilize applicable standards as benchmarks for assessing and mitigating risks.
By following these steps, you can enhance machinery safety, protect employees, and ensure compliance with essential regulations. Proper compliance is not just about meeting legal requirements—it’s about safeguarding lives and promoting a culture of safety within your organization.