Since the machinery directive 2006/42/EC has been in force, there has been a lot of discussions about this issue. The machinery directive’s ADCO group has now published a new document about “Safety fences (safeguarding) as safety components according to the machinery directive 2006/42/EC.”
What is the ADCO group?
“The work of the Machinery Working Group is complemented by the activities of the Machinery Administrative Cooperation Group (Machinery ADCO Group). This is a forum for exchange of information between the market surveillance authorities of the Member States and the Commission. The Machinery ADCO Group usually meets twice a year and is chaired in turn by representatives of the Member States. The meetings are restricted to the representatives of the Member States and the Commission.”
In the document, there are three scenarios for placing safety fences on the market, which is clarified in the document.
Please read this quote from the document. This statement places the responsibility to whom it belong.
“It is emphasised that the question under which conditions safety fences (safeguarding) can be regarded as independently placed on the market does not change the fundamental principle of the Machinery Directive that all machinery must be supplied with all protective devices when first placed on the market. Furthermore, it is always the machinery manufacturer’s responsible for placing on the market only machinery in conformity which the relevant requirements of the Machinery Directive 2006/42/EC and to provide the EC Declaration of Conformity and to affix the CE-marking on the machine.”
This new document clarifies that a supplier of safety fence modular system should not CE mark the system. It’s not possible only to CE mark a post or a panel.
This document describes three scenarios.
All three scenarios deals with the possibility to CE mark and when you can’t CE mark Safety fences (safeguarding). More than 90% of the manufacturers of safety fences (safeguarding) can’t CE mark their systems or safeguarding in accordance to this document.
A lot of south European companies have used the CE marking as stickers on their safety fences (safeguarding). Because they used it as quality mark. On some companies’ websites, one of the first things you see are a lot PDF documents about standards and the machinery directive and not what they are selling.
I will under the next week write about the three scenarios one by one.