Declaration of Conformity

[vjr0512]

In one of the project, the supplier of the Air compressor does not provide us the DOC but only agreeing to provide Declaration of Incorporation. The reason stated is as below

The air compressor skid item was delivered without starter and control / command cubicle for the regulation and the security management. These equipments are not in our scope of supply according to your order. So we confirm you that the air compressors skid are a quasi machines in regard of 2006/42 EC directive. So in accordance with it, an integration certificate can only be provided for each equipment.

But we are arguing as below

"
Machinery Directive 2006/42EC : Article 1(1) 1 (a) to (f)
• Machinery means an assembly referred to in the first indent missing only the components to connect it on site or to sources of energy and motion.
• Machinery that can in itself perform its specific application but which only lacks the necessary protective means or safety components is not to be considered as partly completed machinery.
• Partly completed machinery must undergo further construction in order to become final machinery that can perform its specific application.

Starter and Control cubicle for the regulation and the security management can not be considered as a further construction and are therefore not required to obtain a Complete machinery as per this definition.

For these justifications, Air compressor shall not be considered as a partly completed machinery delivered with a declaration of incorporation.

As necessary, vendor to detail the needed information to fulfil its contractual obligations and provide an EC Declaration of Conformity as per 2006/42EC and hence
• Apply the CE-marking for the whole equipment
• Declaration of conformity
• Placing on the community market
• Documentation
"

But the vendor still come with the same stand. Thanks to guide how to come out of this situation??

 

[BrianPetersen]

The information for use that goes together with that declaration of incorporation should state the need for the additional control systems over and above what was supplied, and what they must include.

You don't state the nature of the functions in the missing "starter and command / control cubicle". That wording, and that this apparatus was mounted on a "skid", suggests that it is rather large, and if so, the relevant standards that the equipment has to meet probably require that "starter and command / control cubicle" to perform certain functions that they can not be responsible for since they didn't supply it. From that point of view, it seems correct to issue a declaration of incorporation, and whoever completes the construction with whatever that "starter and command / control cubicle" is supposed to do, must issue the declaration of conformity and apply the CE marking.

Since you didn't tell us what functions are in that "starter and command / control cubicle", let me make an assumption which may be wrong, but will serve for illustration. Suppose that "starter and command / control cubicle" is required by the applicable standards to include an "emergency stop" function. Since the standard requires it but they didn't supply it, they cannot declare conformity. Whoever DOES end up supplying it must declare conformity, of course in the process they will also refer to the declaration of incorporation that the compressor manufacturer did supply.

If my assumption or example is not correct, please explain. The rest of us need to know what functions that "starter and command / control cubicle" has to provide.

 

[vjr0512]

Dear Brain Petersen

We appreciate the explanation provided. Actually in case of this Air compressor package the entire control is executed through the platform DCS. But same is the case with many other equipments and as part of project philosophy the Local control stations (LCS) housing the emergency stop / local start stop for the motors are not included in the pump vendors scope. Similarly the pumps include seal systems which have instruments and the same are connected and controlled through the platform DCS. In case of these pumps the vendors have issued DOC even though the LCS and control system is not included in vendors scope. Any idea why this logic is not being followed for the air compressor skid

 

[BrianPetersen]

I would suggest that the air compressor manufacturer is the one following the intent of the "declaration of incorporation" versus "declaration of conformity" properly, and it is the manufacturers of the other equipment that may not be.

It is also possible that they are both correct, but the exact standards that the equipment is being built to is different in some subtle way, which allows the one manufacturer of one type of equipment to do it one way while the other manufacturer of the other equipment (to which a different standard may apply) has to do it another way.

The European body of standards is an enormous, complicated, intricate mess, to put it bluntly. Very open to interpretation, very easy to miss something or make a mistake.

I have a video that I made, which I will most certainly not share publicly, of a CE-marked machine squashing up and chewing up the handle of a little brush that I found lying around. The little brush was used because I would rather have the machine chew that up, than chew up my hand, which could very easily have been inserted in place of the brush. One wonders how that was handled in the risk assessment ...

 

[geesamand]

Both are correct in some way.

When the safety of the machine is strongly dependent on items not within the manufacturer's scope, then declaring it to be Partially Completed Machinery (with Dec of Inc) is appropriate. This places more burden on the buyer to ensure the incorporation is done properly as a complete assessment of the finished machine is still required. No CE mark is provided with the Partially Completed Machine - only when the final assessment is performed can this be marked. Review the manufacturer's documentation and see that they are providing strong documentation for how to incorporate the PCM safely and correctly - they certainly owe you that and you will need it.

When the machine is complete except for a power source and appropriate controls, or complete except for a mounting surface, then a C of Conformity can be issued and CE mark provided. Any safety issues having to do with the power source, etc are completely of the buyer.

The decision to choose belongs to the manufacturer. If they believe it's a PCM and their competitors do too, it's for the good of the workers who will be using the equipment. A lot of plant builders think that safety is a simple matter of buying everything with CE marks and C of Cs. It's not true, and the plant builder must understand that sometimes the "machine" requiring CE certification is in their scope.

Asking them to change the certificate is not a small matter - even if they agree to the new classification, they must rewrite their entire technical file for the machine. Are you offering to pay for that?

David