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Thread: Machinery Directive v. ATEX

  1. #1
    Peter Brown Guest

    Machinery Directive v. ATEX

    If a manufacturer makes and supplies a machine to be used as part of a materials handling system it is normal for such a machine to be supplied with a 'Declaration of Incorporation' rather than a ‘Declaration of Conformity’ under the Machinery Directive and so does not have a ‘CE’ mark. This is because it forms only part of the system and is not a ‘Stand Alone’ item (typically screw conveyors, rotary valves, slide valves etc supplied on an individual machine basis). The ‘Declaration of Conformity’ and ‘CE’ mark has to apply to the whole system.

    However, as I read the ATEX documentation, the marking of an individual machine under ATEX requires the manufacturer to include the ‘CE’.

    But putting a ‘CE’ mark on the machine is a statement of Conformity for ALL relevant directives.

    There seems to be a conflict here, would anyone like to offer comment?

  2. #2
    boursr Guest

    Arrow

    The European Directives of the "new approach" do not make specific technical requirements available but only specify esential safety requirements to be complied with. Both the Machinery Directive, The ATEX Directive and for example the Pressure Equipment Directive (or Low Voltage Directive, or ElectroMagnetic Compatibility Directive) are of this style.
    Indeed trying to comply to those directives that matter is not easy and requires some studying. The European Commission has made available a comprehensive guide to assist in determining what has prelevance. Please visit http://europa.eu.int/comm/enterprise...egulation.html for more details or check with me if additional assistance is needed.

    roger.bours@fike.com

  3. #3
    Peter Brown Guest
    Re your response the following is an extract from :-

    http://europa.eu.int/comm/enterprise...ide/annex2.htm

    ….. This declaration of incorporation has been specially designed for incomplete machinery. "Incomplete" machinery may be ordinary machinery from which the safety devices have been removed for the purpose of integrating them into a complex assembly. Safety is built in by the manufacturer of the complete machinery or by the acquirer, at the site. Subassemblies, motors, etc., may also be the subject of a declaration of incorporation. …..

    Thus it is usual for individual materials handling machines to be supplied with a declaration of incorporation since in the case of, say, a rotary valve even if supplied fitted with a motor, the inlet and outlet chutework is essential for safety (to keep hands etc from being trapped by the rotor) but would not normally be supplied as part of the rotary valve but by those incorporating the rotary valve into the overall system.


    However from :-
    http://www.dti.gov.uk/strd/exatps02.pdf

    …..Other Directives: where equipment and protective systems covered by the Directive are subject to other Directives, CE marking indicates that the equipment and protective systems also fulfill the appropriate requirements of those Directives. …..

    and the HSE have confirmed that equipment conforming to ATEX has to be CE marked.


    So ATEX requires a CE mark (with no option for incorporation), but fixing a CE mark confirms conformity with all relevant directives.

    I suppose it will be necessary to include in the instructions for use some form of words to get over this difference.

  4. #4
    enginayyars Guest
    We are manufacturers of grain/cereal handling machinery e.g. bucket elevators,chain&flight conveyors, screw conveyors,and electro pneumatic slides. All these products are CE compliant and we have CE mark. They already have mechanical features for prevention / suppression of dust explosion / rupture disc relief.I would wish to Know how do we get ATEX. As much as I can understand from various web sites the only thing required is to ensure that all electricals fitted on to this machinery be ATEX approved and we automatically claim ATEX compliance.
    I request distinguished readers to educate me on this.

  5. #5
    Join Date
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    1,641
    Should you be CE marking individual machines? CE marking is confirmation that the machine is safe to use as supplied.

    Do you supply the necessary supports for your machines and established they are safe?
    Do you supply all necessary interconnecting chutework which while allowing passage of material into and out of the machines also provides a physical guard to the internals of the machines?
    Do you supply the necessary electrical control systems to ensure the safe operation of the machines in relation to all other equipment?
    Do you install all the equipment to ensure it is safe to use?

    If you do, then you may CE mark the equipment supplying a Declaration of Conformity.

    If not, relying on others to make supports - interconnecting chutework - integrate the machines into a control system, then you should NOT CE mark (under the Machinery Directive) the machines but supply a Declaration of Incorporation stating that the equipment is safe when incorporated into equipment by others but to your instructions.

    You are incorrect to say "the only thing required is to ensure that all electricals fitted on to this machinery be ATEX approved". ATEX requires you to consider ALL possible sources of ignition and this is both electrical AND mechanical sources, and take action to eliminate or reduce them. If you purchase electrical equipment to be incorporated into your machines than this must be ATEX compliant for the appropriate ATEX Zone.

    For mechanical equipment to comply with Zone 22 you you carry out a risk analysis, identify the risks under normal operation and eliminate them keeping an internal record (techincal file). For Zone 21 you you carry out a risk analysis, identify the risks under normal and malfunction operation and eliminate them lodging your record (techincal file) with a notified body.

    For fuller information visit the various official web sites.

  6. #6
    enginayyars Guest
    Thanks designer.Without any offence meant,However, the reply is as confusing as are the various directive commentries and explanations on this.
    I wish to state as under
    We design , manufacture and supply only such individual machines which have been declared CE compliant and we give declaration of conformity.This has been done in strict compliance of the Blue book of Europa.eu.int.These machines have undergone risk analysis as per machinery directive and have all safety features i.e. dust aspiration connections , explosion vents, rotation detectors,Over load protection and relief gates, UHMWPE flights and linerswhere spark can ignite dust etc.All electricals are CE compliant and CE marked.
    We do not give any supports, chutes nor do we integrate the machines into the system and all of Which the purchaser has to do at site.
    Now please correct me once again. Whenever a customer asks for ATEX compliant / marked machine then what do we do? As much as I under stand I shall ensure that apart from my mechanical features being safe, I shall only incorporate ATEX marked electricals .What Zone to be considered for wheat / paddy/brown and white rice / barley / maize etc.
    If not then Kindly advise. I am unable to understand the matter.As the directives do not clearly explain all such eventualities in detail.Do we need to go to a notified body. or self declaration can be done.
    You will do a big service to all such confused people like me who are perplexed with these querries.Please explain in detail
    I shall appreciate if all could contribute with their views and save us from this dillemma.

  7. #7
    Join Date
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    Regarding the Machinery Directive, it is well established in the UK that single pieces of materials handling machinery are not CE marked nor provided with a Declaration of Conformity. They are provided with Declaration of Incorporation. This is because they must, of necessity, be incorporated into an overall system by someone else. You say you do not supply supports, interconnecting chutework or integrate the machines into control systems. So how can you ensure the machine is safe? The installer might provide defective supports alowing the machine to fall, inadequate chutework may not prevent access to the internals of your machines, poor system integration may result in unintended startup during maintenance. As a supplier of only a machine these things are out of your control which is why there is a Declaration of Incorporation referred to in my previous post.

    It is quite clear that a safe installation is the responsibility of those providing the installation and it is they that must provide the CE mark for the installation together with a Declaration of Conformity.


    ATEX is an EU directive related to the health and safety of employed persons. It is the responsibility of those who employ persons to ensure that the workplace is safe. To this end the employer is required to carry out a risk analysis of his workplace and if necessary to allocate ATEX Zones according to the degree of risk.

    When purchasing new equipment for installation in an ATEX Zone the purchaser MUST advise the supplier of the ATEX Zone in which the equipment is to be installed, together with the characteristics of the dust (or gases/vapours) that causes the risk e.g. Kst, dust cloud ignition temperature, dust layer ignition temperature etc.

    When receiving a request for equipment for an ATEX Zone the equipment supplier must supply equipment suitable for the Zone advised to him. IT IS NOT FOR THE SUPPLIER TO DETERMINE THE ZONE. If your customer does not include this it is for you ask him specifically for this information. He is required to provide this information when enquiring for ATEX compliant equipment.


    There are significant sources of information on various official web sites that spell out the requirements for an manufacturer :-

    http://europa.eu.int/comm/enterprise...uide/index.htm
    (particularly the 2nd edition guidelines)

    http://www.dti.gov.uk/strd/exatps02.pdf
    (the UK guidelines)

    You should follow this information.

    Have you a trade body you can raise your concerns with? Have you attended any seminars on the ATEX directive? If not, I would suggest you must do at the earliest opportunity as you will get information on the current interpretations of the directive.

    If all else fails then you may need to employ a consultant to assist you.

  8. #8
    enginayyars Guest
    your interpretation is in stark variance to the various commentries available on the web and being successfully followed.The EUdirective is crystal clear in saying that what ever an equipment supplier wants the installer to do to ensure a safe installation if that is not to be in the supplier's scope than adequate and clear instructions be provided in a safety,installation, operation and maintenance instructions manual. We are doing it for the installer / user to ensure the same.Thus our marking the equipment with CE mark and giving a declaration of conformity is in line with EU recommended practices and directives.
    My question is very simple and straight forward.
    1)How do I ensure ATEX compliance for my CE marked equipment.
    Is it by ensuring incorporation of relevent ATEX marked components and further doing Enhanced Risk Analysis for ensuring ATEX compliance???
    2)How will I be able to Declare my such equipment ATEX compliantand mark it ATEX???
    3)Since the installation of such machinery is the onus of the installar / user hence Finally ATEX for installation is their responsibility.So what compliance document to be GIVEN by us whichdeclares ATEX compliance.
    I repeat that I am yet to come across a straight forward approach for my problem
    CAN ANY BODY HELP
    Thanks

  9. #9
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    Extract regarding declaration of incorporation taken from the official UK government web site :-

    http://www.hse.gov.uk/pubns/indg270.htm

    " 20 When is a declaration of incorporation appropriate rather than a declaration of conformity?

    If the machinery is intended for:

    incorporation into other machinery; or
    assembly with other machinery;
    and if certain other conditions are met, the manufacturer may issue a declaration of incorporation instead of a declaration of conformity. The declaration should contain similar information to that contained in the declaration of conformity, but importantly, it must state that the machinery should not be used until:

    the machinery into which has been incorporated; or
    the assembly to which it has been added has been declared to conform fully with the legal requirements.
    In practice, this means that the machinery should not be used until the final product has been manufactured, all relevant essential health and safety requirements met, and a declaration of conformity issued - by the final installer or assembler.

    The machinery should not be CE marked if it has a declaration of incorporation; CE marking should only take place at the end of incorporation or assembly. "

    Regarding ATEX, if you follow the information in the links provided earlier then for Zone 21 & 22 (Cat 2 & 3 equipment) then you can self certify for mechanical equipment. The situation is different for electrical equipment, but I presume any electrical equipment you use is purchased and so you will purchase for the appropriate Zone.

  10. #10
    enginayyars Guest
    Thank you for this clarification.Please permit me to sum up this thread as under:
    CE+CE is not equal to CE .However, for the end product to be CE it is always and always better if the parts making it are CE
    1) Individual parts / sub assemblies going into a machine need to be CE marked too but with a DECLARATION OF CONFORMITY which clearly mentions that these should not be INDEPENDENTLY used untill the final product INTO WHICH THESE ARE INTENDED TO BE ADDED has been manufactured and declared CE compliant vide a declaration of conformity by the manufacturer.
    For example sub assemblies and items like geared motors / rotation detectors/micro switches /alignment sensors being incorporated into machines like bucket elevator / chain conveyor /screw conveyor, intended to be CE marked,must be CE marked too and declared CE compliant vide a declaration of conformity by the manufacturer.However their declaration of conformity must mention above caution that doubles it up as a certificate of incorporation.
    2) After incorporating these subassemblies / parts into the machine the machine manufacturer will ensure the compliance of this assembled machine to various applicable directives and declare it CE marked .This manufacturer will once again issue a declaration of conformity and incorporate the caution that this machinery may/should not be used untill the final integrated plant / installation has been completed and declared CE compliant vide a declaration of conformity by the installer /assembler.
    Regarding ATEX for above machinery once again follow above and ensure that the parts are ATEX marked / compliant suitable for appropriate zone for which the end product / installation is ATEX intended.For Mechanical equipment, SELF CERTIFICATION For ATEX is possible by following above.
    I SHALL ALWAYS WELCOME IF ANY FURTHER ENLIGHTENMENT COMES THRU FROM OTHER DISTINGUISHED READERS
    THANKS & REGARDS

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