Vacuum and compressor automation

[davesparks]

I'm still surprised because I know that people who custom build control panels have too but you can buy ce marked push button assemblies etc.
n.

Just using CE marked components doesn't automatically mean that you have built something compliant.

 

[Blaspark]

OK maybe an example would help.

If I had a lv commercial installation using all schneider gear with a key switch controlling an acti 9 relay controlling lights. All wiring installed to bs7671. Do I need to worry about ce certification?

 

[netblindpaul]

OK maybe an example would help.

If I had a lv commercial installation using all schneider gear with a key switch controlling an acti 9 relay controlling lights. All wiring installed to bs7671. Do I need to worry about ce certification?

If this is a stand alone control panel, then yes, and BS 7671 would not be the relevant standard. If it is for lighting it would be the EN 61439 series, and you must CE mark in accordance with the Low Voltage Directive.
If it is to control machinery then the design and build standard would be EN 60204-1 (for general machinery, there are a couple of specific machine types that are outside this).
Using all CE marked components does not make the assembly CE marked.
I can take you through every reason if you like, but we'll be here a very long time, and I'm off to China Saturday for a few weeks, to advise a Chinese machinery builder on CE marking of their machinery and electrical panels.
I do much more of this now than I do electrical works, as my background is in machinery, and I used to do this before redundancy and self-employment.
What Rob has said is correct.

If you are designing and building electrical panels, there is a lot more involved, as the panel becomes a product in its own right, and that must be CE marked.

If it is controlling machinery, then the assembly of panel and machine must comply with the Machinery Directive.

This is the same concept as when you mix and match MCB's in a distribution board, like it or not, when you do that, you become the manufacturer of the assembly in the eyes of the law.

Oh, and as of the end of March no matter what happens, the only thing that changes will be CE being becoming UKCA marking for the UK market.

 

[davesparks]

If this is a stand alone control panel, then yes, and BS 7671 would not be the relevant standard.

Is there a simple guide available as to what does/doesn't require CE marking?

Being required to CE mark a single relay in an enclosure controlling lights seems to be over the top and somewhat unenforceable.

 

[Shoei]

Is there a simple guide available as to what does/doesn't require CE marking?

Being required to CE mark a single relay in an enclosure controlling lights seems to be over the top and somewhat unenforceable.

It can be tricky to know what applies but the using the relay example, if you put the bits together for yourself for use in your own premises then no CE mark is needed. I'd apply that if you did a job for a customer who, for practical purposes, might have bought the parts on your advice and you fit them. If you put the relay in a box and sold it on Amazon as a lighting contactor then it would need certification.

From the UK government guidance..

Using electrical equipment on your own premises
Electrical equipment that is intended for use by you in your own premises is controlled by the Electrical Equipment (Safety) Regulations 1994. Such equipment must satisfy the safety requirements of the regulations, but need not have CE marking.

However, should you subsequently decide to supply the equipment - eg by selling it or hiring it out - it will be subject to the relevant provisions of the regulations, including the CE marking requirements.

 

[netblindpaul]

It can be tricky to know what applies but the using the relay example, if you put the bits together for yourself for use in your own premises then no CE mark is needed. I'd apply that if you did a job for a customer who, for practical purposes, might have bought the parts on your advice and you fit them. If you put the relay in a box and sold it on Amazon as a lighting contactor then it would need certification.

From the UK government guidance..

Using electrical equipment on your own premises
Electrical equipment that is intended for use by you in your own premises is controlled by the Electrical Equipment (Safety) Regulations 1994. Such equipment must satisfy the safety requirements of the regulations, but need not have CE marking.

However, should you subsequently decide to supply the equipment - eg by selling it or hiring it out - it will be subject to the relevant provisions of the regulations, including the CE marking requirements.

Just realise that this caveat does not apply to the Machinery Directive, and that includes any electrical panels controlling the machinery.
Also, forgot, if the company changes hands then there is the chance that that would be looked on as selling the equipment.
Whilst electrical equipment doesn't have to bear the CE mark, it still has to comply as if it did.
The mark is simply the last step in the process, which starts as soon as a design begins.

 

[Blaspark]

Refurbished and modified machinery - Work equipment and machinery - http://www.hse.gov.uk/work-equipment-machinery/refurbished-modified-machinery.htm

This page say something about "existing products which are so substantially modified as to be considered new"

I think the simple example I gave would be fine because the products are being used exactly as intended and the switch can be fixed to a wall with cables ran in conduit to them the relay is din rail mounted.

Not sure though.

Also to make the example simple I used only one manufacturers equipment. If you make a control panel with all siemens gear they have a tool that helps with ce certification as well but there seems to be requirements beyond their tool.

Thanks for the information so far!

 

[netblindpaul]

Is there a simple guide available as to what does/doesn't require CE marking?

Being required to CE mark a single relay in an enclosure controlling lights seems to be over the top and somewhat unenforceable.

There is no simple guide unfortunately, but if you are placing an assembly of products on the market for sale, rental hire etc in the course of a business or to be used in the course of a business, then it must comply with the relevant product safety laws.
A DOL starter must comply with the LVD, and must be CE marked as a product.
Enforcement is a mute point, there is little, which is why we see so many dangerous white goods, phone chargers etc which catch fire being on sale.

 

[netblindpaul]

Refurbished and modified machinery - Work equipment and machinery - http://www.hse.gov.uk/work-equipment-machinery/refurbished-modified-machinery.htm

This page say something about "existing products which are so substantially modified as to be considered new"

I think the simple example I gave would be fine because the products are being used exactly as intended and the switch can be fixed to a wall with cables ran in conduit to them the relay is din rail mounted.

Not sure though.

Also to make the example simple I used only one manufacturers equipment. If you make a control panel with all siemens gear they have a tool that helps with ce certification as well but there seems to be requirements beyond their tool.

Thanks for the information so far!

If you modify something then you make a new product, unless it does exactly the same thing. but, remember, for example, that some products require type testing to meet the standard, if you modify such as to breach the type test, then that would be significant.
It's nothing to do with sticking with one manufacturer, unless you are talking about compliance with the EN 61439 series, or other equipment which is type tested.

You don't "need" a tool to CE mark, it can be done long hand. There is a LOT more to machinery controls, and designing and building electrical panels than is involved in BS 7671, and if you think that is expensive, then think again, most of the standards that need to be complied with to take a presumption of conformity cost 4 - 5 times what BS 7671 does.

If you go and fix a machine, and you take out a Siemens relay from a safety circuit, and fit a Schneider one, because that is your van stock, then you have invalidated the CE mark on the equipment and absolved the manufacturer of any liability. You then become liable as the manufacturer should your modification result in loss, injury or death. The same would apply to an e-stop button, or a safety door switch, door interlock etc.
It's a minefield, because you are straying into product law, and product liability, how many of you carry product liability insurance for products you manufacture?

 

[Blaspark]

netblindpaul - you said about enforcement for white goods, I'm more interested in automation integration using plc's or just switches, signalling lights and relays. It's starting to seem there's not much enforcement there either.

Do hse have people capable of inspecting and making decisions on this type of thing?

 

[Blaspark]

If you modify something then you make a new product, unless it does exactly the same thing. but, remember, for example, that some products require type testing to meet the standard, if you modify such as to breach the type test, then that would be significant.
It's nothing to do with sticking with one manufacturer, unless you are talking about compliance with the EN 61439 series, or other equipment which is type tested.

You don't "need" a tool to CE mark, it can be done long hand. There is a LOT more to machinery controls, and designing and building electrical panels than is involved in BS 7671, and if you think that is expensive, then think again, most of the standards that need to be complied with to take a presumption of conformity cost 4 - 5 times what BS 7671 does.

If you go and fix a machine, and you take out a Siemens relay from a safety circuit, and fit a Schneider one, because that is your van stock, then you have invalidated the CE mark on the equipment and absolved the manufacturer of any liability. You then become liable as the manufacturer should your modification result in loss, injury or death. The same would apply to an e-stop button, or a safety door switch, door interlock etc.
It's a minefield, because you are straying into product law, and product liability, how many of you carry product liability insurance for products you manufacture?

Yeah I guess that's reasonable. I'd like to know how far I could push my simple example though?

Since now I've said that the switch is surface mounted on a wall and the relay is din rail mounted can I do that without any further efforts to achieve compliance?

My insurance won't cover machine building no.

 

[davesparks]

Is there anything we do which is not putting an assembly of products on the market?

Does installing a grid switch count as putting an assembly on the market or does the manufacturer of the grid switch system take responsibility as they designed it all to work together?

In which case where would we stand fitting a GET switch onto a BG pattress put us?

I realise these are possibly slightly ridiculous questions, but I'm just trying to get an idea of how far this goes.

 

[netblindpaul]

netblindpaul - you said about enforcement for white goods, I'm more interested in automation integration using plc's or just switches, signalling lights and relays. It's starting to seem there's not much enforcement there either.

Do hse have people capable of inspecting and making decisions on this type of thing?

Oh yes they blinking do, and they know the science, engineering and technology behind it too!
They have a whole laboratory full of engineers and scientists who are specialists in their field.
They will know the law, the standards, and the fundamental engineering and science behind what is needed.
They tend only to roll these people out when deaths or major incidents are involved.
The HSE "inspector" that turns up at a factory gate un-announced will likely not know the details, but, they will know how to get a specialist involved if necessary.

However, there is little resource to police this, the insurance companies will be doing this without companies realising it, because unless they are fully compliant with the law, their insurance policy is null and void, it's in the small print.
It's often ignored until there is an issue...
You know what the old saying is "if you think safety is expensive try having an accident".

 

[netblindpaul]

Is there anything we do which is not putting an assembly of products on the market?

Does installing a grid switch count as putting an assembly on the market or does the manufacturer of the grid switch system take responsibility as they designed it all to work together?

In which case where would we stand fitting a GET switch onto a BG pattress put us?

I realise these are possibly slightly ridiculous questions, but I'm just trying to get an idea of how far this goes.

An MK grid switch assembly is covered by MK, if it is done in accordance with their instructions.
Devices such as a GET light switch and a BG patress back box, are designed and the standards are written in such a way that they can be assembled in an ad-hoc manner, as long as they fit together correctly.
Metal clad sockets and switches often have "custom" back boxes and one make of socket won't fit another makes back box correctly, then the product law would kick in, and you would be in breach of it, because they were not designed to be as one assembly.

 

[Blaspark]

Is there anything we do which is not putting an assembly of products on the market?

Does installing a grid switch count as putting an assembly on the market or does the manufacturer of the grid switch system take responsibility as they designed it all to work together?

In which case where would we stand fitting a GET switch onto a BG pattress put us?

I realise these are possibly slightly ridiculous questions, but I'm just trying to get an idea of how far this goes.

"I'm just trying to get an idea of how far this goes"

Me too seems we could come close in commercial installations fairly regularly