A steelworks rarely buys a machine. It buys a furnace, a conveying system, a cooling bed and a control system from different suppliers, and assembles them into a line none of them delivered. The rules have an answer for who is responsible for that line, and it is seldom the party expecting to be.
What keeps coming up in the steel industry
- Assemblies of machinery: when several deliveries become one machine, and who then has to CE mark the whole.
- Rebuilding while in operation — when an upgrade to an existing line is a substantial modification and when it is not.
- High temperatures, heavy loads and long conveying distances mean the risk assessment rarely looks like the textbook examples.
- Partly completed machinery, and what the assembly instructions have to contain when you receive some.
- Where the line is drawn against older equipment that predates both the regulation and the directive.
The rebuild is more common than the new build
Most CE questions in a steelworks arise not on a new plant project but on the fifth rebuild of a line that has been there for thirty years. That is where the assessment of substantial modification makes all the difference.
Questions from the steel industry
- We are replacing the control system on an old line. Does it become a new machine?
- It depends on what the replacement does to the machine's function and safety. A replacement that adds functions or changes the safety functions points towards a substantial modification; a like-for-like swap normally does not. The course covers how that assessment is made and documented.
- Who CE marks a line with four suppliers?
- Whoever assembles them into a working whole. If that is you or your contractor, that party is the manufacturer of the assembly, with a technical file and a declaration for the whole.
The course for the steel industry
The same regulation as in the general course, but the examples are the steelworks'.
See the courses