Drives & Controls Magazine November/December 2022

34 n SAFETY November/December 2022 www.drivesncontrols.com Ensuring machinery safety under UKCA S ince 1995 it has been a requirement that all machines supplied within the European Economic Area (EEA) comply with the Machinery Directive. In the UK, the Supply of Machinery (Safety) Regulations 2008 now aligns with the Machinery Directive , with amendments within Schedule 12 of The Product Safety andMetrology etc. (Amendment etc.) (EU Exit) Regulations 2019 . Before machinery and other products in the Regulation’s scope are placed on the market, or put into service for the first time, they must be safe, have appropriate markings, and the manufacturer must have a technical file. Under the new regime, UKCA will be the marking applied under the Regulation. Such equipment must also be supplied with instructions in English and a Declaration of Conformity, or assembly instructions and a Declaration of Incorporation for partly completed machinery. The following persons or companies are responsible for compliance with the Supply of Machinery (Safety) Regulations : n machine-builders; n assemblers of machine parts or installations; n manufacturers of special-purpose tools, skids and rigs; n machinery importers located in the UK; and n machinery distributors or dealers that buy from a UK-based manufacturer or importer have the obligation to verify that the conformity assessment was performed and that the necessary documentation and information is available. UK regulations define a responsible person as one who holds a position of sufficient responsibility to ensure machinery safety. This can be the manufacturer or the authorised representative. However, they do not have to be an expert and are allowed to seek the appropriate advice. The responsible person must ensure that all the necessary research and tests are conducted so that machinery can be assembled and put into service safely. The responsible person must also ensure that a suitable technical file is compiled and remains available for inspection by a competent national authority for a period of ten years after the last product type was manufactured and placed onto the market. The appropriate conformity assessment procedure must also be followed. The three methods available are: n Part 8 of Schedule 2: The conformity assessment procedure with internal checks on the manufacture of machinery n Part 9 of Schedule 2 & Part 8 of Schedule 2, point 3: Type-examination and the internal checks on the manufacture of machinery n Part 10 of Schedule 2: Full quality assurance. Regulation 10 applies to machinery that does not fall within a category referred to in Part 4 of Schedule 2. In this case, the conformity assessment procedure that should be applied is Part 8: The conformity assessment procedure with internal checks. Regulation 11 applies to machinery that falls within a category listed in Part 4 of Schedule 2. The machinery must be manufactured in accordance with standards that cover all the applicable health and safety requirements. In this case, one of these conformity assessment procedures can be applied: n Part 8: The conformity assessment procedure with internal checks. n Part 9 and Part 8, point 3: Type-examination and the internal checks on the manufacture of machinery. n Part 10: Full quality assurance. Regulation 12 applies to machinery that falls within a category listed in Part 4 of Schedule 2. This is where the machinery is not manufactured fully in accordance with designated standards; or is only partly manufactured in accordance with the standards which relate to it; or the designated standards in accordance with which the machinery is manufactured do not cover all the applicable health and safety requirements; or no designated standards exist for the machinery. In this case, one of these assessment procedures can be applied: n Part 9 & Part 8, point 3: Type-examination and the internal checks on the manufacture of machinery n Part 10: Full quality assurance Where Type Examination or Full Quality Assurance is used as a procedure for assessing conformity, they must be carried out by a UK Approved Body for UKCA or a Notified Body for CE marking. UK Approved Bodies are also Notified Bodies though UKAS for Northern Ireland and can provide Type-Examinations and Full Quality Asurance for UKNI+CE marks. The responsible person must also ensure that appropriate instructions are made available to operate machinery safely, that a declaration of conformity is drawn up, and that the UKCA marking is affixed. There has recently been an extension allowing the continued use of CE marking until 1 January 2025, after which the UKCA marking requirements will be a mandatory and a legal requirement. n The UK’s Supply of Machinery (Safety) Regulations 2008 now aligns with the EU’s Machinery Directive. Darren Hugheston-Roberts, head of machinery safety at the product testing and certification organisation, TÜV SÜD, outlines who is responsible for complying with the Regulations under UKCA, and the types of machinery covered.