CE marking on a product is a manufacturer's declaration that the product complies with the essential requirements of the relevant European health, safety, and environmental protection legislation
We live in an age where there is a tension between a Government that would like to pursue a 'hands-off' approach to capitalist endevour in our economy, while at the same time wanting to control every breath we take. Indeed, a couple of critical documents landed on my desk that highlight this issue.
In my universe, they come under the category of ‘where the hell did that come from?’ I have already a while ago alerted BSGA members to both, so they can be prepared, but now is the time for others in the industry to be made aware of things that may save them a lot of angst further down the line.
The first issue involves portal frame (gantry/goalpost type) flatbed CNC routers and protective guarding.
At the time of writing, the British standard for these machines states: “Where only an impact hazard is foreseeable and the maximum axis speed is below 25m/min -1, no additional protective device is required where partial movable enclosure corners are rounded to at least 20mm radius and no hazards exist from projecting parts e.g. screws.”
Sign businesses have been given notices of contravention when their routers, although being CE marked, were said to be dangerous. Pictured: Esko Kongsberg V, an example of a flatbed router
This is applicable to practically every flatbed router used in the sign industry. If the machine is CE marked, it will conform to these requirements with the manufacturer having the documentation to back this up. Any further additional safety equipment that comes with the kit is, currently, a choice rather than a requirement.
Recently, several sign businesses I work with have received an unannounced visit from HSE and, after inspection, handed a notice of contravention when their router which, although being CE marked, was deemed by the inspector to be dangerous.
The contravention concerns the Health and Safety at Work Act 1974, Section2 (1)—Provision and Use of Work Equipment Regulations 1998, Regulation 1. This requires you as an employer to ensure, so far as is reasonably practicable, the health, safety, and welfare at work of your employees. In this case, preventing access to ‘dangerous’ moving machinery. So, this is not the BSGA having a ‘pop’ at the small sign-maker, this is real and legal.
During the inspection, “it was noted that there is nothing to prevent operators from accessing the table and encountering the moving head. Whilst (the inspector) appreciates that the machine is CE marked and was supplied in its current position, the machine currently permits access to dangerous parts whilst in operation and is therefore not compliant with the above legal provisions.”
To help you to take extra steps to guard the machine, HSE advise studying Woodworking Information Sheet 22. My question is how many of you out there knew that in addition to buying a machine that meets CE requirements—thereby giving you assurance of conformity to current standards and legislation—you then should go and trawl through HSE guidance to see if there is anything extra you should do to avoid fines (sorry, intervention fees) and seemingly having to buy extra kit because HSE say so?
I certainly was carrying on my life safe in the knowledge that if something carried a CE mark, it had been tested to make my life safe. Does this now extend to washing machines, kettles, and toasters that are CE marked? Makes you wonder where it goes next, as that marking has as its preface ‘compliance to the standard is one way to meet the essential safety requirements’ to assure us all, but the HSE seem to want a bit more.
I certainly was carrying on my life safe in the knowledge that if something carried a CE mark, it had been tested to make my life safe”
A cynic might say that this all comes about as a result of HSE moving away from employing industry experienced staff to going to ‘tick boxes’. They will accept that a CE marked product complies with the standard, but they then state in the next breath they do not consider the product meets the ‘essential safety requirements’. I did say the cynic might say that, did I not? The angel on my other shoulder says that it is important that businesses recognise that safety in any manufacturing process is paramount and it should not be a second thought to do things in a safe way.
Yours to interpret and act accordingly. This is not a ‘health and safety gone mad’ rant.
Providing clarity
We (the BSGA) continue a dialogue of sorts with HSE to help sort this out so that there is clarity, if clarity and guidance is necessary/available.
We (the BSGA) continue a dialogue of sorts with HSE to help sort this out so that there is clarity, if clarity and guidance is necessary/available”
The second concern is not as much a day to day issue, but one that is more prominent following the Grenfell Tower tragedy—vis a vis fire related risks concerning materials that are used to attach signs to buildings.
A sign company recently provided a ‘wrap’ fixed to scaffold around a building undergoing renovation. The material used conformed to the DIN standard (Deutsches Institut für Normung e.V.—the German Institute for Standardisation) and was therefore considered appropriate for the use in this application.
However, the insurers of the building under renovation disagreed and insisted that another material is used i.e. one that conforms to another and completely different standard which is devised by the Association of British Insurers, the Chief Fire Officers Association, the London Fire Brigade, and the Contractors Legal Group.
This standard also includes the characteristics of the inks used to print images onto the material meeting the standard.
The BSGA organises the British Sign Awards every year, which was held at the East Midlands Conference Centre in 2016
So, despite using materials that conform to an internationally recognised benchmark, some insurers are refusing to insure buildings that are ‘wrapped’ using a material that does not conform to their requirements. The bottom line is, it seems, if you want your building insured Mr and Mrs Customer, check that the material used is satisfactory to the insurers’ terms and conditions as well as other internationally recognised standards. Again, BSGA members have been given a guidance note with further details.
The cynic in me senses that this may be the thin edge of the wedge, whereby in future, if you want to fix a sign to any building, not only do you have to manufacture and install to standards (and provide maintenance guidance) that satisfy and conform to both regulations and HSE requirements, in addition to planning permission, you should check with insurers if the material specification is acceptable to them for their policy cover to be in force. I am conjecturing of course and the angel on the other shoulder is keeping shtum for now.
The BSGA say a membership with them, first and foremost, delivers a powerful signal to sign buyers of a professional, company
So, there you have it dear reader. On the one hand you are given the impression you are a in a capitalist version of the wild west. On the other you must have a full HSE approval before you head out to the gunfight.
Public Notice:
- Currently, if the machine is CE marked, it will conform to safety requirements
- Recently, sign businesses’ routers have been deemed dangerous even with CE marking
- HSE have their own information sheet (woodworking information sheet 22)
- There are concerns over fire related risks involving materials used to make signs attached to buildings
The British Sign and Graphics Association (BSGA) history dates back more than 70 years when a group of leading sign-makers formed the Master Sign Makers Association (MSMA) with the aim of promoting the sign industry and defending its interests. For more information on the issues discussed in this article visit www.bsga.co.uk or tel: 0845 338 3016
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