Bill et al,
Concerning the Declaration of Incorporation.
1. Does it replace a Declaration of Conformance for a particular machine?
No, the DofInc does not replace the DoC – it supports the DoC by claiming
compliance (as specified in the details) for particular parts of the final
machine. It is a building block in showing full compliance for the machine
2. How do you use the Declaration of Incorporation; do you specify
compliance
steps required to ensure the entire system is compliant, or is it that overall
compliance simply recommended by the D of I?
By carefully laying out which specific parts of the requirements with the
component complies it then is clear to the machine manufacturer what they have
to do to finish the evaluation.
3. Does it have any application outside of the machinery directive? I think
it's only referenced in the Annex of that directive.
Unfortunately, the MD is the only Directive that specifies the DofInc. From
my experience with the CE marking system (more than 15 years), the developers
of this system never envisioned that the marking would apply to anything but
completed equipment. This would require that some declaration/paper would
have to be passed from component supplier to OEM for every part included in
the final equipment in order know that it complies rather than looking for a
mark so that the equipment can be CE marked. We still collect the paper to
build the TF and, hopefully, confirm that the component meets the appropriate
requirements when it is used (although some folks don’t seem to pay careful
enough attention to these details, in my experience). For electrical
equipment under the LVD (which was developed in the 1970s) this model
doesn’t work very well – the industry is too specialized and split into a
large number of tiered suppliers. Suppliers started CE marking components
early on in spite of any specific direction to do so (and the rabbit is out of
the hat so it seems impossible to reverse). Too bad that the EU folks
didn’t develop another mark for components –like the backwards UR mark
that UL uses – so that equipment certifications could be easily
distinguished from component certifications.
The MD has good guidance in this area. Equipment which is complete except for
the power source (e.g. mower assemblies which are attached to a PTO) must be
marked (my analogy is electrical equipment which is attached to the power
system and then is fully ready to run needs to be CE marked – all else is a
component and is not generally CE marked). Equipment which is a safety
related device must not be marked (e.g. a pop-off valve attached to a hot
water heater to relieve the pressure if it boils) so that purchasers won’t
believe that the entire unit is adequate according to the requirements. (Two
analogies here: UL stopped putting labels on lamp wire years ago because
companies were buying the wire and snipping it up so that each piece had a UL
label and consumers thought that the entire lamp assembly complied to lamp
requirements (this wire is printed with the certification info today); and
again, the application of CE to circuit breakers or other protective devices
parallels the pressure relief valve situation and, I believe, that they should
not be CE marked.) So, a separate marking would work better.
4. Can you point me to an on-line reference on this subject?
I think that you have found the on-line source for info on this subject –
this group of hundreds of experienced folks who deal with this regularly.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201 fone/fax
[email protected]
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