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.

Ambassador for Safe Automation

“Every company needs a hierarchy. But what a company doesn’t need is hierarchical thinking”, stresses Renate Pilz, Managing Partner of the Pilz group. “That has always been my creed. And that’s how we do things here.”

Walking round the company with Renate Pilz it is obvious: her staff respect her and hold her in high regard, and vice versa: even when time is short she is prepared to listen, even to her employees’ personal problems.
That she is not only a respected but also a successful businesswoman is something that’s repeated time and time again within the industry; and it’s a fact that is supported by the company’s figures.

After her husband lost his life in a plane crash in 1975 and managers were appointed to run the company in the interim, Renate Pilz took over the management of the company in 1994. The company grew, but she recognized the potential that was not being used.

She developed Pilz from a national supplier into a company operating internationally, with 23 overseas subsidiaries in countries including USA, China and Brazil.

Pilz has been implementing the Takeda process optimization strategy. Although the company’s operations were already based on a CIP strategy (continuous improvement process), existing procedures had to be made more efficient to make the company fit for global competition. “The Takeda concept was brought to our attention by one of our very good customers, who had achieved significant improvements with it”, explains Renate Pilz.

The strategy, which Hiroshi Takeda calls “The synchronous production system” and which Pilz calls PPS, is relatively unknown. PPS stands for Pilz Production System; its aim is to involve all employees in the identification of potential improvements within the group and their subsequent implementation, and to promote customer-oriented thinking. Renate Pilz established a separate team for its implementation; the team reports directly to management and its members have in part been released from other work.

The Takeda philosophy is based on the CIP approach (continuous improvement process), but employees are much more closely involved – one reason why Renate Pilz immediately approved of the approach: “We are always searching for appropriate instruments. The concept seemed to be very good because it is a very in-depth system, which integrates people.”

Continuous process optimization is achieved through regular workshops. “The workshops stimulate the creativity of our staff”, the managing director has recognized, “and also strongly encourage interdepartmental working.”

The key difference from CIP lies in the immediate implementation of the results. “Immediate and consistent implementation”, summarizes Renate Pilz. “There are many optimization strategies where a great deal of effort goes into working something out – and then it is postponed until a suitable date can be found for its implementation”.

With PPS there is an understanding of the issue within the team, the working group is composed accordingly and deals with the issue, implementing the conclusions during the actual workshop. The groups are designed to be interdepartmental. “It is often the interfaces that are problematic, and this way they open up – purely through this type of co-operation”, says Renate Pilz. “The result is genuine co-operation, all staff members can have a say in these groups.”

The selection of workshop members depends on who is affected by the issue and whether they can contribute towards solving the problem. One example is the standardization of procedures. “With standardized procedures you can achieve better quality and greater flexibility” explains Renate Pilz. “So you can react more flexibly with the existing team, housekeeping is more readily understood – why the process must run in this way and no other.” Increased efficiency and easier work processes for staff are the result. “For example, if the workplace is made more ergonomic at the suggestion of a female staff member, thus making access to parts considerably easier, that lady’s work becomes more agreeable and she has been part of the process”, says the managing director, quoting a real example. “But first of all you need to become aware of the matter. For years she had fetched the parts from a box on the floor: nobody had the idea to simply place the box higher up – it had always been done like that.” The fact that it is her own design helps the measure to become accepted and increases efficiency and motivation, as well as improving quality.“When problems that have been recognized are resolved very quickly, then it is worth supporting such process improvements”, is the experience of Renate Pilz. “And when implementation is consistent and fast, the concept also establishes itself quickly. This doesn’t just encourage interdepartmental working, it makes it an absolute condition.”

One visible sign of this: the foreman’s office has gone. It has been turned into a team room for production, production technology, development, purchasing and the various fields. The group meets in the team room and deals with the issues there. There were no problems when the foreman’s office was removed. “The staff sees that it’s just part of the job. If there is any resistance, it is generally down to anxiety. And as executives, it is our job to ease such anxiety”, says Renate Pilz, demonstrating her approach to leadership.

The PPS strategy runs through all areas of the business. “Our aims are to substantially increase efficiency and delivery reliability, to optimize and standardize work processes and work equipment, to reduce pressure in the workplace and thereby improve quality”, says Renate Pilz. “Ultimately we are doing this to safeguard the site of course”.

She does not wish to comment on other companies abandoning their sites, but her opinion is reflected in her description of the Pilz strategy: “We don’t complain about the things we can’t do, but we do whatever is within the realms of possibility. And we do that by communicating openly with each other, internally and externally.”

That’s why customers and supplies are also included in the strategy: the former in particular set the tempo for production. “The better the information from the customer, the better we can be too”, says Renate Pilz.

Son Thomas Pilz manages the subsidiary in the USA and daughter Sabine Kunschert works as a manager in Ostfildern. “And so the foundations have been laid for a seamless transfer to the next generation”, says Renate Pilz, “and I am grateful that it all worked out so well.”

Not that she’s thinking of ending her business career just yet. She enjoys the job too much for that, despite the 60-hour week: “I get so much pleasure out of working with our staff and I have a lot of respect for what they do.”

Author:
Hajo Stotz
The Manufacturer