Members of the CE Marking Association frequently send questions into the Technical Team for support on Product Compliance. Where the dilemma may be of interest to a wider audience we like to publish the questions and answers as guidance for other manufacturers. Please note that the question and answer may have been altered for confidentiality reasons.
Question
We supply generators to turbine manufacturers, therefore a machine without a drive unit. My understanding is that we cannot declare the generator as a partly completed machine due to only the drive system being absent. However, according to the guidance on the Machinery Directive we are obliged to carry out a risk assessment on the complete assembly to include another manufacturers turbine. Would you advise on where our obligations lie and whether we are actually supplying a partly completed machine?
Answer
Thank you for your query.
Firstly, electrical motor-generators in the voltage limits of the Low Voltage Directive 2006/95/EC ( 50-1000V AC, 75-1500V DC) are exempt from the Machinery Directive, see Article 1 Scope indent 2k. If this is not the case with your generators then the following points should be noted;
I believe the point you reference in the guidance notes is at bottom of page 29. This paragraph is referring to machines that are in scope of the Machinery Directive that have been supplied without a drive system. The point of the discussion is that the machinery is NOT partly completed machinery but IS complete machinery albeit without a drive system. Which then goes on to say on page 30 that it is complete machinery and must ALSO be supplied with;
For machinery to be supplied without a drive system:
– the manufacturer’s risk assessment must take into account all the risks associated with the machinery, including those relating to the drive system to be fitted to the machinery – see §158: comments on General Principle 1 of Annex I;
– the machinery manufacturer must set out in his instructions all the necessary specifications for the drive system to be fitted such as the type, power and means of connection, and provide precise fitting instructions for the drive system – see §264: comments on section 1.7.4.2 (i) of Annex I;
– the conformity assessment of the machinery must cover the specifications of the drive system to be fitted and the fitting instructions;
– the CE-marking on the machinery and the EC Declaration of Conformity that accompanies the machinery must cover the specifications and instructions relating to the drive system to be fitted.
If the above conditions are not fulfilled, machinery without a fully specified drive system must be considered as partly completed machinery – see §46: comments on Article 2 (g). In that case, the combination of such partly completely machinery and the drive system must be considered as the final machinery and must be subject to a specific conformity assessment – see §38: comments on the fourth indent of Article 2 (a).
On the above basis, I conclude that turbine is the “Drive System”, albeit a Partly Completed Machinery as well, and your generator is the “Machine”, unless the above conditions have been met then the generator will be considered “Partly Completed Machinery”
REFERENCES
Machinery Directive 2006/42/EC; http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:157:0024:0086:EN:PDF
EU Guidance Notes; http://ec.europa.eu/DocsRoom/documents/9483/attachments/1/translations/en/renditions/native
