Non-compliant pumping equipment in packaged plant solutions is a major problem in the UK market. M&E consultants that specify pumping equipment should ensure the complete set is CE Marked and included within the technical tender specification.
However, a growing number of packaged plant suppliers in the UK believe it is acceptable to simply bring together various components – such as pumps, drives, controls, pipework, valves, tanks, baseplates and so on – from different suppliers, and rely on the CE Marking on these individual items as compliance for their packaged set. This is not the case.
CE Marking of the packaged plant system is a legal requirement, so many consultants are breaking the law and risking prosecution, heavy fines, and possibly even imprisonment. They are also, potentially, putting the final user of the unit in breach of health and safety rules. The complete unit is a machine in its own right, so must have a CE Mark affixed and be supported by all the appropriate documentation, including a Declaration of Conformity (DoC).
The British Pump Manufacturers’ Association (BPMA) is keen to ensure all assembled equipment, especially those with pumps incorporated within the build, are placed on the market and put into service correctly.
Original pump manufacturers incur large costs ensuring they implement the required legislative programmes correctly, so the products they bring to market meet all appropriate certifications. So the BPMA and its members are calling on consultants, M&E contractors, design and build, distribution and installers to work together to use and install only CE Marked equipment.
Any equipment not meeting this criterion should be rejected, with costs associated with this rejection – plus any negative publicity that might ensue for the company and brand – borne by the contractor.
The complete unit is a machine in its own right, so must have a CE Mark affixed and be supported by all the appropriate documentation
Existing in its present form since 1985, CE Marking is a certification mark that indicates conformity with health and safety and good environmental protection standards for products sold in the UK and the European Economic Area (EEA). It is not just the manufacturer of pumping equipment that is responsible for compliance, but the assemblers, suppliers and installers.
If assemblers market the products under their own brand names, they take over the manufacturers’ responsibilities and assume legal responsibility for CE Marking of the products they build.
As a complete set, packaged plant will need its own identification label affixed, with an appropriate CE Mark, and must comply with the correct legislation. The label has to carry a serial number, product type, supply voltage and performance data, along with contact details of the system builder and where the packaged plant was manufactured.
Several environmental and sustainability directives should also be considered, such as Waste Electrical and Electronic Equipment (WEEE), Restriction of Hazardous Substances 2, and Packaging Waste. In addition, local standards – such as the Water Regulations Advisory Scheme (WRAS) and the Water Supply (water fittings) Regulations 1999 – will still apply.
Each assembled system should have a comprehensive instruction manual, as well as a DoC referencing the appropriate legislation and EN standards where applicable. The set assembler will need to prepare a technical file that includes risk evaluation, product data, product features, production methodology, and health and safety considerations.
In the UK, enforcement or market surveillance is undertaken by Trading Standards, the Health and Safety Executive, and the National Measurement and Regulation Office within the Department for Business, Energy and Industrial Strategy (BEIS).
If a supplier fails to give full details of the CE Marking of their products, it may be obliged to take the product off the market, or face a heavy fine if successfully prosecuted.
Packaged pump system builders must play their part when placing products onto the UK market to comply with the law. So it makes sense to only specify, purchase and install CE Marked equipment.
- Most CE Marking legislation is already written into UK law, so its obligations will not change in the event of a ‘no deal’ Brexit.
- Gary Wilde is a technical services officer at the British Pump Manufacturers’ Association