CE and Warning Labels

[CurtB]

Question concerning warning labels and making a battery electric machine conform to the applicable EU machinery standard EN 292-2 and 98/37/EC. We are applying the following:
ANNEX I of DIRECTIVE 98/37/EC
In selecting the most appropriate methods, the manufacturer must apply the following principles, in the order given:
— eliminate or reduce risks as far as possible (inherently safe machinery design and construction),
— take the necessary protection measures in relation to risks that cannot be eliminated,
— inform users of the residual risks due to any shortcomings of the protection measures adopted, indicate whether any particular training is required and specify any need to provide personal protection equipment.

We have a machine that is sold in the US and Europe. We would like to include the same labels on the machine in both locations. However, our European facility has requested that we remove the US warning labels since it draws attention to risk areas and may fail inspection. Your suggestions?

CurtB

 

[buzzp]

Well if it fails inspection then the product should not have any CE marks or others on it. If the label will draw attention to the weak part of the design, the part not able to pass inspection, then the design should be changed. Their reasoning is not acceptable. The end user should be kept in mind and safety should be number one.

 

[senglish]

buzzp is completely right. Your European facility appears to be recommending removing the last-resort measure in the list you quote.

Consider this: I wouldn't like to be the person who has to tell an accident investigator "Well, I decided to remove the warning label for sale in Europe because we didn't want to draw attention to the hazard".

The designers have a duty to design out risks (and the person bringing the product into the Eurpean market place has a duty to ensure that this is done). If this means considering another interlock or mechanical guard, then that's what they should do. If designing out the risk is not a practical solution, then you'll need to follow the list of principles you quoted - protective equipment and labels are the next two levels of protection.