CE marking - Operation and maintenance manual

[3940michael]

Good morning,

I have a supplier of a new purified water plant who, at the end of the install, has identified that they do not intend to provide either an operation or maintenacne manual. I was under the impression that even if they were assembling differnet sub-assemblies of third party equipment to make one plant they would need to provide this basic level of documentation for the operation/maintenace of the whole system they are installing. As it stands they are effectivly providing a file of data sheets or offering the manuals to us as an option for a considerable fee.
Under the CE marking directive are they obliged to provied either of the documents?

Kind regards,
Michael

 

[XL83NL]

Under the CE marking directive are they obliged to provied either of the documents?

Yes. Even if an assembler uses equipment (like vessels, relief valves and piping) who have their own CE-mark and their own IOM (Installation, Operationg & Maintenance manual)), and even if they use subassemblies like CE-marked package units, they still need to do a risk analysis on the whole assembly, as the whole assembly may (and probably will) introduce new risks which need to be evaluated accounted for. As such, the item falls unders the PED (and probably also under the Machine directive), and thus needs CE-marking on the whole assmeble PLUS an IOM for the whole assembly.

 

[DSB123]

The whole plant being assembled needs to be provided with a CE mark which is the responsibility of the Contractor assembling the plant. They also need to provide O&M manuals as well.

 

[Caloooomi]

Personally, I'd raise the issue with their notified body

 

[BrianPetersen]

Or threaten to, and see what happens. And do it if they don't react.

 

[micalbrch]

CE marking acc. to the European Machine Directive is only about safety, nothing else. The supplier must provide a documentation which allows a safe installation, start-up, operation, shut down and maintenance. If there are no safety issues which have to be considered during maintenance, he will not have to provide one. But it is very unlikely that there are no safety issues to be considered during operation.

 

[BrianPetersen]

It's very unlikely that there are no safety issues to be considered during installation and start-up, either.