During acquisition talks with customers, technical issues related to the interpretation and interaction of European directives, regulations and standards are being discussed controversially in many cases. To be able to react at short notice and give qualified statements a Standing Committee "Technical Regulations" was established by EUnited Metallurgy.
Construction Products Regulation versus Machinery Directive
This has been triggered by different interpretations of the Construction Products Regulation (CPR). Usually customers require a certification according to the CPR, while plant suppliers do not consider the necessity. The Standing Committee verified that the CPR does not apply for the plant manufacturers as long as they follow the Machinery Directive and C-Type Standards. A position paper was released which helps to gain clarity in discussions and to save several ten thousand euros on certification costs for equipment suppliers.
Machinery Directive and Modernization
Sometimes the expectations regarding plant modernization between plant operators and plant constructors are quite different. In the near future it is not very likely that "greenfield projects" will be developed in Europe but it is very likely that existing plants will be modernized and adapted to the state of the art. Inevitably this brings up the question of a major or minor change of the metallurgical machinery. The Machinery Directive only serves as a guideline but does not answer this question. Based on official statements, e.g. national ministries, a position paper was developed which clearly takes a position for the modernization of metallurgical machinery and plants and delimits thus to single machines.
Machinery Directive and Commissioning
Metallurgical machinery/plants are assembled and commissioned on site. In this context, the question of who is responsible for the commissioning phase and "putting into service" (CE marking) always needs to be answered. "Is production allowed during commissioning" and if so, "under which conditions"? This might be a very critical issue since safety devices are not/partly not in operation during this phase. Especially regarding the MD the consequences are often discussed controversially. EUnited Metallurgy developed a position paper which clearly presents our point of view.
Machinery Directive and Instructions
According to the MD 2006/42/EC, Annex I, Part 1, 1.7.4, all machinery must be accompanied by instructions in the official Community language or languages of the Member State in which it is placed on the market and/or put into service. The instructions accompanying the machinery must be either ‘Original instructions’ or a ‘Translation of the original’ accompanied by the original instructions. In this case the question arises if every single information has to be translated or is it sufficient to translate the key documents such as drawings, descriptions and explanations regarding normal operation (incl. maintenance and repair)? These questions are matter of controversial discussions between manufacturer and user. EUnited Metallurgy will develop a position paper to outline the position of the manufacturers of metallurgical machinery/plants.