When the Provision and Use of Work Equipment Regulations (PUWER) first came into force in 1992 it included a very simplistic view on CE Marking: the end-user only has to check that the equipment concerned carried a CE Mark. If it did they were OK. PUWER was updated in 1998 and one of the more important, but easily overlooked, changes was that the onus was now put on the end-user to make sure that the equipment complies with all relevant legislation such as CE Marking.
This point has been further backed up in other guidance from HSE including Information sheet FIS 25. Even though this is specifically for flat bed conveyors for the food industry, the outlook is clear. This sheet
states: "Even when a machine is supplied CE Marked, users should not assume that it is safe. Users should check for themselves that all relevant Essential Requirements are met and that the machine supplied is in fact safe".
If this is the case, and the end-user should now check more thoroughly regarding the CE Marking of new equipment, what is the best way to do this?
To fully comply with PUWER, any new equipment should be inspected after installation and before it is put into use to make sure it is safe. This inspection, if carried out correctly, will highlight any safety issues, which may have an affect on the CE Marking of the equipment. Any issues that appear to relate to the CE Marking of the equipment should be raised with the manufacturer or supplier of the equipment. However, as the equipment has been installed it may be more difficult to deal with.
A solution to this may be to inspect or audit the equipment before it is shipped from the manufacturer or supplier. Any potential issues can be raised with the manufacturer and either dealt with before it is shipped or at least be planned into the installation process once the equipment has been shipped. Retrofitting is the more difficult method of compliance, it is always advisable to deal with safety as early as possible in the purchasing process, the design stage being preferable.
