2024/03/26
An assembly of machineries is included in the scope of machinery Directive, as described by article 2 a) forth indent:
— assemblies of machinery referred to in the first, second and third indents or partly completed machinery referred to in point (g) which, in order to achieve the same end, are arranged and controlled so that they function as an integral whole;
Because of the generic nature of the definition, it is necessary refer to the official guide of machinery Directive (https://ec.europa.eu/docsroom/documents/38022).
At §38 it is explained that an assembly of machineries is so considered if:
- the constituent units are assembled together in order to carry out a common function, for example, the production of a given product;
- the constituent units are functionally linked in such a way that the operation of each unit directly affects the operation of other units or of the assembly as a whole, so that a risk assessment is necessary for the whole assembly;
- the constituent units have a common control system.
In this sense a production line where more than one machine with a common scope and a unique command position and a common electrical scheme, corresponds to an assembly and therefore within the scope of Directive 2006/42/CE, looking at the assembly as a single unique machine, hence complying to all the Essential Health and Safety Requirements listed in the annex I of Directive.
The official guide clarifies and details the “assemblies of machinery” leaving however enough freedom to the manufacturer to define the limits of such assembly.
Depending on the situation this translates to a technical aspect, or a purely documental matter.
Because of this is not always straightforward define unambiguously the status of assembly for a group of machineries. Indeed:
A group of machines that are connected to each other but where each machine functions independently of the others is not considered as an assembly of machinery in the above sense
Therefore a manufacturer can consider machinery or assembly according to his convenience. In this sense the official guide states:
Even a single production line may be divided into separate assemblies and/or machines if there is no safety related connection between constituent assemblies or machinery.
This means that if from a safety point of view there are no additional risks arising from machinery interfaces, it is possible consider the assembly composed by single components as independent “machinery”.
Obviously, every machinery (single or assembly) shall be accompanied by all documents that state the compliance to Directive 2006/42/CE, namely:
- declaration of conformity;
- marking plate with CE marking;
- instruction of use and maintenance;
- schemes of machinery.
Coherence shall be guarantee between these documents, meaning that they must refer to uniquely to the considered machinery.
This means that the assembly will be assessed as unique “machinery”, namely with a marking plate with CE mark referred to the entire assembly and accompanied by the declaration of conformity.
The electrical, pneumatic, hydraulic schemes, etc…shall, in the same manner, refers uniquely to the considered object, being this single machinery or assemblies of machinery.
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