Revamping, Machinery Directive, CE marking. A general overview

A way to achieve energy savings. The replacement of part of a line to raise the automation level. Or, an operation driven by the desire to expand the product range: the reasons for revamping a production line can be many. These may include the need to adhere to new safety standards.

Revamping may be preferred over buying a new plant: 
- to reduce the cost of the investment;
- in order not to lose unique features of the existing plant;
- because of the lack of space to add additional equipment;
- because existing parts are still efficient (and perhaps subject to revamping themselves in former times).

In any case, new plant parts must follow the machinery directive. That raises the question of whether or not the entire system needs to be CE-marked, bearing in mind that integrating components from different manufacturers is often necessary.

Recertification of the whole plant?

New machines must be certified according to the Machinery Directive, we said. 
But within the same production line, you can find parts built to current standards and others made to standards, say, 30 or 40 years ago, that are not CE marked. CE marking has only been active in Europe since the 1990s. What to do in such cases?
Let's start with definitions.

Machinery or partly completed machinery?

The directive provides for two distinct cases:
• machinery
• partly completed machinery.

A partly completed piece of machinery is a unit that is not capable of performing a task on its own, but is intended to be incorporated into another machine, a partly completed machine, or a combination thereof.
The manufacturer can declare that a certain device is ‘partly completed machinery’ if they cannot check all the safety conditions because the object does not work alone, but it is placed in a line with other machines - which may not be CE marked.

The contractor, at that point, is responsible for analyzing relationships and interference between the various units and demanding that the builder of the new part share the risk analysis.

Therefore, according to the directive, the 'new' machines that we will introduce could be defined as 'partly completed machinery', if we intend to integrate them into a machine that is not certified because it is obsolete.

The criterion for deciding whether the 'old' part should also be CE marked is that of 'substantial modification’, which must be assessed on a case-by-case basis. Not every modification leads to the obligation of CE certification.

Another consideration that obligates certification of the 'old' plant is whether the intended use is changed.

Completing the CE marking procedure may also result in tax benefits. If you can access these benefits, they may offset much of the cost of upgrading your old system.

The Directive and the directives

The Machinery Directive is an obligation, but it does not preclude that, in addition, the machine or its parts may be framed differently and fall under different legal frameworks. 
That is the case with pressurized equipment, which may fall under the appropriate directive called PED - Pressure Equipment Directive. The same applies if there are ATEX (i.e., explosion hazard) zones. 
An additional contingency. Lifting equipment, subject to dedicated declarations and procedures, may be configured within certified machines. For example, mobile barriers, depending on the weight criteria, may be subject to a periodic inspection similar to that of overhead gantries.
In general, a 'machine' could also fall under the definition of 'plant' as present in other laws. Therefore, it's not possible to exclude the need to submit plans with the stamp and signature of a certified engineer, even if the machine is CE-marked.

The operation and maintenance manual

The first thing to check is whether the manual refers to the machine or 'partly completed machinery' you have purchased. It is common to see manuals that feature copy-pasted texts of user guides designed for other systems. A quick and easy way to conduct an initial check is to make sure the emergency buttons listed in the manual are physically present in the same locations on the machine. 
How deep should the manual be studied? Doesn't going into it and asking for changes and insights 'trespass' into the territory of the plant manufacturer?

Plant operation involves operational practices and maintenance plans. The practices and plans must be consistent with the manufacturer's documentation. If the documentation is not correct, two scenarios may arise:

- the resulting maintenance plans are not correct;
- the maintenance plans are drawn up correctly but are not consistent with the indication of the manufacturer.

In either case, the documentation needs to be studied carefully, and the manufacturer needs to be involved. Subsequent in-house maintenance practices must not contradict the manufacturer's manual.

In conclusion, the possible circumstances are numerous, and each case of revamping is its own project. The culture and knowledge of the Machinery Directive are, to date, not fully absorbed, and often the words of the text are used to push responsibilities away to the opposite side of the table. On the other hand, the diligent application of the Directive and standards is of vital importance and is a decisive factor in accident prevention.

Author info:
Jacopo Grassino is a consultant with 20 years of experience as a plant manager in steel and other industries. His specializations include management control, production start-up, strategy, and team management. If you want to know more, please call him at +39 3396821463, email [email protected], or follow him on LinkedIn.

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