Thursday 2 August 2012

Beware the CE Mark

Some people facetiously say that CE stands for “Check Everything”.  Unfortunately, there is some truth in this.  Whilst the intention is to indicate that the equipment meets certain safety standards, there is no absolute assurance that this is so.
The intention of this blog is to draw people’s attention to the CE mark, it’s function and pitfalls.  It describes how the procedure is intended to work, where the obligations are and typical examples where it goes wrong.  It finishes with steps that a purchaser should include.

This article is available in more depth on .

To what does CE Marking apply?

This applies to all equipment supplied for first time use in the EU after 1st January 1995.   
Normally,  the manufacturer is accountable for the process, but agents or importers would be accountable for equipment which originates outside the EU.  Though we normally think of the process being applied to new machines, it applies to old machines if they were introduced into the EU after January 1995. Similarly, though it is intended to ease trading, it applies even if the equipment is for self-use.

Who polices CE Marking?

The short answer is nobody.  Apart from specific machinery, there is no organisation that either certifies the machine, or licences the supplier as being able to certify his machine. Be aware that the process is one of pure trust on the supplier.  

Where does the buck stop?

The company who puts the equipment into use (ie the employer) has obligations and it is he who has the final accountability for ensuring that the equipment is safe.  

What goes wrong?

In my experience, the key points to look for are:
  • Gross non-conformities (major faults with guards)
  • Minor non-conformities (compromises made to prevent features making safety worse)
  • Lack of awareness (not being aware of the requirements of safety-related control systems)

What should the purchaser do?

The two main actions a purchaser should take are:
Include clear specifications in your order, including statements that the safety related control system must be downstream of the PLC.  One company with whom I work has a set of specifications to which supplier must adhere.  You might consider a clause where you hold back final payment until it has been checked and any faults corrected.
Be aware that when equipment arrives, the presence of the CE mark does not necessarily mean it is safe.  You must carry out a thorough risk assessment. Where there are major faults, then you could take this up with the supplier; they are the ones who should supply equipment which is fit for purpose.

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