To get started, can you tell us a bit about your engineering background?
Before working for Certification Experts, I worked in the machinery industry for almost ten years. I worked hands-on as a mechanic and visited the factories of all sorts of companies, from food to high-tech to recycling. I eventually became project manager at an international asset management provider, and later general manager in the high-tech industry, until I joined Certification Experts about four years ago.
How does your experience as an engineer help when certifying machinery?
Since I started working in certification, I have come to realize that my technical background acts as a valuable link between our company and our clients. I know from my own experience how factories operate and how employees work in different surroundings. This gives a more rounded picture of what needs to be taken into account when CE marking machinery, to ensure that machines are put on the market in a safe and efficient way.
What classifies a product as a machine?
The first prerequisite for machinery is that it needs to have powered movement. However, this is a broad concept and can pose a challenge for making the right legal classification. To know whether your product should be legally classified as machinery, examine the specifications made in the Machinery Directive to see whether it falls under the scope of the directive. Once you have determined that your product is a machine, there are often additional standards to consider, depending on the properties of the machine (for example hydraulic or electronic features). Even then, it can still be tricky with borderline products to classify them as machines and this is where experience comes into play.
Which legislation is relevant to CE marking machinery?
The legislation you should use to check the conformity of your machine is determined by the specific characteristics that it has. All machinery must be CE marked using the ISO 12100. This is a type A standard, meaning that it outlines the basic principles for design, risk assessment and risk reduction that are relevant to all types of machinery.
Besides the ISO 12100, there is a range of standards that can be used to verify the compliance of machinery. For example, if your machine includes an emergency stop, the ISO 13849 provides requirements for the safety-related parts of the control system. IEC 60204 applies to the electrical, electronic, and programmable equipment of machines. Using a risk assessment software like Safexpert can be a huge help when determining which standards are relevant to your product.
What are added risks for machinery and how do you account for them?
The surroundings that a machine is placed in play a huge role in machinery safety. Machines are mostly placed in a designated space, and certain locations bear additional risks (such as operating a machine outside or in a dusty area).
Also, additional risks occur when placing machines together. If you integrate machines as a production line or a whole, ensuring safety goes beyond just testing each machine. You must test the entire production line to make sure that the machines function safely together as well. For example, if you have an emergency stop at the beginning of the line, it needs to function for the end of the line too, since all of the machines are linked (depending on the risks, of course).
Considering the environment that a machine will be placed in therefore plays a huge part in accounting for risks when manufacturing machinery. To ensure machine safety and account for added risks, it is crucial to work closely with the engineers, to envision the end-situation of the machine and to take into consideration as many factors as you can when designing the product.
What are pitfalls when CE marking machinery and how can you avoid them?
The greatest pitfall is to start too late with machinery certification. You should start thinking about the risks that can occur while engineering the product instead of afterwards. Certification can become a very costly trajectory if you have to add, for example, guards or electronic safety parts later on in the process.
The best way to avoid a costly CE marking process is to carry out risk assessments while engineering. When you account for compliance both during and after engineering, you avoid surprises in the final stage of production and ensure faster market access for machinery.
Do you have any final tips for manufacturing safe machinery?
Consider all of the life phases of the machine. Often, a lot of thought goes into determining the safety of a machine during ‘normal operation,’ but risks usually arise when a machine is not functioning properly and people start to use the machine differently to try to fix it. That’s why it is important to also consider the commissioning, decommissioning, and troubleshooting of machinery during a risk assessment.
Also, I recommend using a risk assessment software like Safexpert. Safexpert provides you with the standards to mitigate the risks you come across while engineering. The software is very thorough and accounts for all types of machinery, so that there is always a way to ensure the safe use of a machine, regardless of its features or design. Safexpert allows you to start carrying out risk assessments while engineering the machine, which is one of the best ways to ensure safety and a smooth certification process when CE marking machinery.
Ferry van Bergen Henegouw is a certification specialist with 10 years of engineering experience. Do you have questions about CE certification for machinery? Contact our experts today for CE marking assistance, Authorised Representative services and all compliance-related matters.
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Construction Products Regulation 2013
The lifts and safety components of lifts Directive 2014/33/EU
CETA, Trade agreement between the EU and Canada
Personal Protective Equipment (PPE) Regulation EU 2016/425
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