It's important not to generalise the requirements of the various
directives and their UK implementation. For example, while the UK's
Electrical Equipment (Safety) Regulations 1994 contain an exclusion
>from the CE marking requirements for equipment which is built (or
imported) for the manufacturer's own use, the same is not true of the
Supply of Machinery (Safety) Regulations 1992. Thus, machinery must
be subjected to the full CE marking requirements, but the same is not
true of electrical equipment.
PUWER does not say that equipment must be CE marked - it says that
equipment must meet any applicable EHSRs from the CE marking
directives. Normally, an employer meets this requirement by
specifying CE marked equipment and using it according to the
manufacturer's instructions, but this need not necessarily be the
case. In the absence of CE marking, PUWER sets out minimum safety
requirements which must be adhered to by an employer, but these
obligations are are essentially independent of the obligations that a
manufacturer or importer has under the CE marking directives.
It's important to realise that the requirements of PUWER and the
requirements of the CE marking directives come from different treaty
clauses. The CE marking directives are based in article 100a of the
Treaty of Rome and are the maximum which a member state government
may require in order for products to be legitimately placed on their
domestic market. Workplace safety requirements such as PUWER come
>from article 118a of the Treaty and Member States are free to augment
them with additional requirements if they choose to.
To summarise, under PUWER it is always necessary to apply the
applicable EHSRs of the Directives but this does not mean that the CE
marking must always be applied - whether or not CE marking is
required for equipment manufactured for the manufacturer's own use is
a matter for the applicable CE marking directives, not PUWER. In
fact, PUWER may even require the application of EHSRs to products
which are outside the scope of the CE marking directives.
It sounds complex, but in fact its not only clear but also logical
once you differentiate between the safety requirements which apply to
both equipment supplied by employers to their employees ("brought
into service" and to equipment sold by a supplier to a customer
("placed on the market"), and the administrative requirements which
are intended to promote free trade; and realise that PUWER is
universal but the CE marking directives are each subtly different
>from one another.
Nick.
At 12:00 +0100 11/9/08, [email protected] wrote:
>The generally perceived wisdom is that equipment for own or in-house
>use, does not require CE marking, but must still comply with the
>essential safety and EMC requirements.
>
>However in the UK, we have the Provision and Use of Work Equipment
>(PUWER98) regulations and these have been interpreted to require
>that such own or in-house equipment, must also be CE marked.
>
>This contradicts the UK implementation of the Low Voltage Directive,
>The Electrical Equipment Safety Regulations, which specifically
>states that electrical equipment manufactured for the maker's own
>use need not carry the CE logo.
>
>Has anyone formed an opinion on the subject that they care to share?
>
>Best Regards,
>Dave Coleman AIIRSM
>SELEX Communications
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