When affixing the CE Mark and placing a product on the market you will want peace of mind that it is not going be responsible for any injury and/or subsequent law suits. This is where a risk assessment can be beneficial by identifying potential hazards associated with the use of the product. With products falling under some Directives, such as the Machinery Directive, it is a mandatory part of the CE marking process. However with other Directives such as the Low Voltage (LV) Directive for electrical products it is not a mandatory requirement.

Most people have heard of the urban legend concerning the old lady microwaving her dog in an attempt to dry it. Whilst the legitimacy of this tale may be questionable, it is a good example of how a risk assessment could be used to demonstrate that all types of potential hazards have been considered and mitigated (even the ones that are extreme cases of misuse!). The common approach for CE Marking electrical equipment is to apply a standard that will identify the more generic and obvious hazards associated with a product, but a risk assessment should help to identify the less obvious ones (that may not be within the product standard).

Whilst the Low Voltage Directive does not legally require a risk assessment to be undertaken, there seems to be an emerging trends of the suggestion to use a risk assessment in some of the more recently updated commonly applied harmonised electrical safety standards. Lets not forget that standards are voluntary, but offer an effective way to prove compliance to Directives. The utilisation of a risk assessment helps to mitigate any residual risks that may not be covered even by using a harmonised standard, ensuring that products are even safer. Some examples of harmonised electrical standards incorporating a risk assessment follow:

– EN 60204-1 for the safety of electrical machinery
– EN 61010-1 for the safety requirements for electrical equipment for measurement, control and laboratory use

There isn’t a defined process to follow for undertaking a risk assessment on electrical equipment however there are a number of methods that could be used; such as the HSE ‘5 steps’ and the preliminary hazard analysis method. The risk assessment process within the Machinery Directive is a good example of a process that can be followed and is illustrated below:

By using a risk assessment method, potential hazards can be easily identified and mitigated to limit hazardous occurrences and keep users safe during the expected usage and lifespan of the product. And if you were wondering about microwave ovens, if you read the instructions I am sure that you will find a statement along the lines of ‘Only heat food products’ in there somewhere.

If you need further help with undertaking a CE Marking Risk Assessment for your electrical product or machine, then please call the technical team on 01527 595066.

As you may well know, the CE Marking Association moved offices in 2013 to Wootton Park, and one of the great benefits of moving was to feature a larger electrical test lab. To celebrate the launch of our new lab, we are running a very special offer to the first 20 customers.

We are offering a 1/3 off our usual day rate, saving at least £250.00 a day! You can also combine this special discounted rate with funding to reduce the rate even further, saving up to £500.00 per day!

The discounted price is available for electrical safety testing and assessments carried out on products, machines and medical devices, for which there is an applicable harmonised electrical safety standard. The discount price will be a great benefit to those successful applicants who wish to CE mark under a self-declaration conformity route. There are hundreds of standards, to which the discount applies and we can’t list them all, but to give you an idea of costs, below are three popular standards (with the funding discount applied);

• EN 60204-1 (Electrical safety of machinery) From £250.00 (Saving £500.00)
• EN 60335-1 (Household and similar) From £750.00 (Saving £1500.00)
• EN 60601-1 (Medical Devices) From £1000.00 (Saving £2000.00)

The offer is only valid until the 31st March 2014. Quotes generated for this offer are only valid under 31st March 2014. Further terms and conditions apply and additional eligibility requirements apply should you wish to apply for funding. Full details are available on our offers page.

If you would like to find out more or to request a quote, then please call the CE Marking Association on 01527 595066.

We would like to wish everyone a very Merry Christmas and a happy new year. This year has been extremely important for the CE Marking Association, as we celebrated 20 years of supporting UK manufacturers with their CE Marking and other product conformity requirements. Also as part of our efforts to continuously improve and expand our services, we moved offices in September to our new facilities at Wootton Park, which provided us with the opportunity to open our  new larger electrical test lab and to provide better training facilities.

The office will be closed on Christmas eve and will reopen on Thursday 2nd January 2014. We hope you enjoy the festive break and we look forward to speaking to you in the new year.

The following lists of harmonised standards referenced on the European Commission’s Official Journal have been updated in December 2013:

– Machinery Directive
– Low Voltage Directive
– Eco-Design – Energy Labelling of Household Tumble Driers
– Eco-Design – Energy Labelling of Household Washing Machines
– Personal Protective Equipment (PPE)
– Recreational Craft Directive

Normally when you purchase equipment or machinery, you would expect the equipment to be safe and comply with all the relevant national and European requirements. Obviously the requirement is upon the person making the equipment available to ensure that they only place compliant and safe ‘products’ on the market. As a consumer, you wouldn’t find yourself going into your local DIY store to buy a new electric drill to then be expected to undertake your own machinery and electrical safety assessment and affix your own CE mark. Where ‘products’ are intended to be supplied/sold to other people then the roles and responsibilities are very clear, however who is responsible when a machine has been built for own use?

Clearly the responsibility must lie with the person who has made the machine, but many people mistakenly believe that ensuring the machine complies with ‘User Legislation’ (such as PUWER98) will be all that is required to allow them to put their machine into use! What most people do not realise is that machines built for own use must also be CE marked!

Where the equipment has an assembly of linked, powered parts and where at least one of them moves for a specific application, then it will be defined as a machine under the Machinery Directive (2006/42/EC). Actually there are seven categories of equipment in all that are covered by the Machinery Directive and it states that “before placing machinery on the market and/or putting it into service, the manufacturer must… affix the CE marking” (along with all of the other CE marking tasks). The key aspect for machines built for own use is whether they are being placed on the market or being put into service.

To place a machine on the market, the manufacturer must be making the machine available with a view for distribution or use and this is whether for reward or free of charge. Generally the act of placing a product on the market involves the product exchanging hands from one company to another person, which is not the case for machines built for own use. So the definition of ‘putting into service’ is very important for machinery built for own use. Luckily it is defined within the Directive which explains that putting into service “means the first use, for its intended purpose, in the Community.” The European Commission’s guide to the Machinery Directive provides further support for this definition and says that whilst persons manufacturing machines for own use have not ‘placed the machine on the market’, they have put the machine into service, which is covered by the Directive and therefore should be CE marked.

The Directive and the European guidance makes it very clear that Machinery built for own use must be CE marked, but the final question that usually raises it head is what’s the benefit of CE marking? Well let’s put the fact that the CE mark is a mandatory legal requirement to one side for just one moment, there are other considerations. For example the CE marking process will help you to design and construct a safe machine, therefore helping you to meet your user legislation requirements. Also non-CE marked machinery could invalidate your insurance policy and that one day the machine may find its way onto the market (i.e. being sold at a later date). Ultimately there is very little choice in the matter; if the equipment is in scope of the Machinery Directive, then it will be required to be CE marked.

If you need support to CE mark machinery that you have built for own use, then please contact the technical team on 01527 595066 to discuss how we can help you.

Source:

– Machinery Directive: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:157:0024:0086:EN:PDF

– European Guide to the Machinery Directive: http://ec.europa.eu/DocsRoom/documents/9483/attachments/1/translations/en/renditions/native