CE Marking of Plant and Machinery, The Basics

According to the Machinery Directive, a machine manufacturer is anyone who assembles machines or machine parts of various origins and places them on the market. A manufacturer may be the actual machine builder or – where a machine is modified – the operator. In the case of assembled machinery, it may be the manufacturer, an assembler, the project manager, an engineering company or the operator himself, who assembles a new installation from various machines, so that the different machine parts constitute a new machine.

However, according to the Machinery Directive, only one manufacturer is responsible for the design and manufacture of the machine. This manufacturer or his authorized representative takes responsibility for implementing the administrative procedures for the entire plant. The manufacturer may appoint an authorized representative, who must be established in the EU, to assume responsibility for the necessary procedures for placing the product on the market:

• Compiling the plant’s technical documentation
• Complying with the technical annex
• Providing operating instructions for the plant
• Affixing the CE mark in a suitable position on the plant and drawing up a declaration of conformity for the entire plant

Using Resources Carefully: Comprehensive environmental protection at Pilz

Whether we are talking about energy engineering, hazardous substances or instrument engineering: at Pilz, looking after the environment is a core part of the corporate philosophy. With the solar-powered building climate control system taken into operation last autumn, the company now also has sustainable ways to use energy.

At Pilz, sparing use of natural resources starts in the Central Purchasing department. Here, right at the start of the logistics chain, the company lays the foundations for active environmental protection. Purchasing guidelines designed to comply with the environmental requirements laid out in REACH (the future European Community Regulation on chemicals and their safe use) and RoHS (European Restriction of Hazardous Substances Directive) and evaluation of suppliers also on the basis of their environmental performance ensure that components and parts satisfy the relevant environmental standards.

Concern for the environment is also very much to the fore in the development of products. Already during development, issues are addressed such as whether a product can be designed more compactly so that, ultimately, energy and materials can be saved.

It is easy to think that this should be a simple matter, but once components start to get very compact they must not consume large amounts of energy. Otherwise they would get too hot. The PNOZsigma, for example, has been designed according to these criteria. The relay only uses increased amounts of energy during start-up, but during operation the energy saving circuitry comes into play. This ensures that overheating is impossible, and the desired energy saving effect is achieved.

Environmentally friendly manufacturing

Designing products to be environmentally friendly is just one side of the coin. The other is to manufacture them in a way which is environmentally sound. At Pilz, the implementation of environmentally aware production guidelines starts in the Production Engineering area: auxiliary materials are carefully selected according to their environmental compatibility. The use of unleaded solder for example is implemented on a voluntary basis in accordance with the RoHS guidelines. The alcohol-free, water-based flux materials for cleaning the circuit boards also contribute to this. In terms of environmental protection, this also means that fewer hazardous substances are stored in the company. Overflow troughs safeguard this storage so that potential risk of ground contamination is eliminated from the start.

Production itself is designed to be environmentally friendly, with sparing use of resources. For example, waste heat is used to operate the ventilation and air conditioning system. With the aid of heat exchangers, large amounts of energy can be saved in this case.

CO2 under control

Pilz is doing a number of things to reduce the company's carbon footprint: focusing lighting is one way to reduce CO2 emissions – without compromising the minimum brightness requirements stipulated for the workplace. Presence monitors ensure that the light is only switched on when it is actually needed. However, the biggest savings in terms of CO2 emissions have been made with the climate control technology which was taken into operation in 2008 and features state-of-the art engineering. The entire Peter Pilz Technology Centre is both heated and cooled via a solar heat plant. Energy efficiency has been significantly improved with the new system. Another measure is the gas heating which has been optimized with a new condensing boiler, which is now capable of heating two buildings at the same time.

Protecting the environment means taking responsibility

Today, every company also has a responsibility to other people and to the environment. Pilz understands this responsibility. This is why Pilz employees are sensitized for environmental concerns with the aid of various media, including for example the Intranet and special training sessions. This is because efficient environmental protection measures must be comprehensive.

What is a Machine?

For the purpose of the Machinery Directive, a machine is:

• "An assembly of linked parts or components, at least one of which moves, and which are joined together for a specific application.”

The following are also considered machines for the purposes of the Machinery Directive:

• "An assembly of machines or complex plants (complex plants include production lines and special purpose machinery made up of several machines"
• "Safety components, such as light curtains, safety mats, etc."
• "Interchangeable equipment that can modify the basic functions of a machine."

Click here for more information about the Pilz Safety Compendium and the Machinery Directive.

An introduction to CE Marking.

The CE mark stands for "Communauté Européenne". A manufacturer uses this mark to document the fact that he has considered all the European internal market directives that are relevant to his product and applied all the appropriate conformity assessment procedures. Products that carry the CE mark may be imported and sold without considering national regulations. That’s why the CE mark is also referred to as the "Passport to Europe". Generally speaking, all directives in accordance with the new concept ("new approach") provide for CE marking. Where a product falls under the scope of several directives which provide for CE marking, the marking indicates that the product is assumed to conform to the provisions of all these directives.

A Brief Note About EU Standards

On their own, standards have no direct legal relevance until they are published in the Official Journal of the EU or are referenced in domestic laws and provisions. These are the publications by which a standard can acquire "presumption of conformity". Presumption of conformity means that a manufacturer can assume he has met the requirements of the corresponding directive provided he has complied with the specifications in the standard. So presumption of conformity confirms proper conduct. In a formal, legal context this is called a reversal of the burden of proof. Where the manufacturer applies a harmonized standard, if there is any doubt, misconduct will ned to be proven. Where the manufacturer has not applied a harmonized standard, he will need to prove that he has acted in compliance with the directives.

If a manufacturer does not comply with a standard, it does not necessarily mean that he has acted incorrectly. Particularly in innovative industries, relevant standards either may not exist or may be inadequate. The manufacturer must then demonstrate independently that he has taken the necessary care to comply with the safety objectives of the relevant directives. Such a route is usually more complex, but, in an innovative industry, it is often unavoidable.

It's important to stress that the EU does not publish every standard in the Official Journal, so many are still not harmonized. Even if such a standard is deemed to have considerable technical relevance, it will still not have presumption of conformity. However, sometimes a standard that has not been listed in the EU Official Journal does achieve a status that's comparable with harmonization. This is the case, for example, when a standard that's already been harmonized refers to the relevant standard. The standard that is not listed in the EU Official Journal is then essentially grandfathered into harmonization.

Pilz CE Marks Machines for Saint-Gobain Performance Plastics

Pilz Automation Safety L.P. provides technical consulting services such as CE Marking, engineering, risk assessment and training, in addition to producing automation and safety products. Saint-Gobain Performance Plastics chose to utilize Pilz’s experience and expertise in the CE marking of several pieces of equipment including, Sani-Tech Fusion Welder, SaniPro Flange Former and SaniSeal Label Molder.  This equipment is used to work with and install performance plastic products. For instance, the Flange Former is used to thermally form a flange on the end of a plastic pipe, the label molder is used to seal a label and a color code panel onto a pipe section and the welder joins sections of pipe. All of these tasks are critical to Saint-Gobain’s customer base to properly use and install its products. Pilz Automation Safety L.P. identified the various CE Marking directives that apply to each of the machines and selected the standards associated with the relevant directives to ensure conformance as required by law for CE certification.

The process of CE marking, as required by EU law, is designed to ensure that a product has met consumer safety, health and environmental requirements. By bringing Pilz in as consultants Saint-Gobain was able to leverage Pilz’s expertise and experience in CE marking, shortening the time the overall process took while allowing their specialized staff to continue to focus on core competencies. The out-sourcing process also allowed them to bring in highly skilled and competent engineering teams to conduct governmentally required work while still maintaining their own high level of customer satisfaction and support.