Lifting Accessories Manufacturers and User Responsibilities
The range of lifting equipment covered by EU requirements is very wide and the Machinery Directive can apply across all industry sectors; from healthcare to construction, most industries and commercial activity will use some kind of lifting equipment.
Technological progress has meant that innovative, often complex and powerful lifting equipment is now available for use. Nevertheless, whether it is modern and complex or more traditional lifting equipment, Machinery Directive will apply if it is used for lifting purposes.
Although a lifting accessories is not a machine they falls within the scope of the Machinery Directive Article 1(1) (d)
‘Lifting Accessory’ means a component or equipment not attached to the lifting machinery, allowing the load to be held, which is placed between the machinery and the load or on the load itself, or which is intended to constitute an integral part of the load and which is independently placed on the market; slings and their components are also regarded as lifting accessories;
This meaning has cause many an argument following discussion with the industry the EU has up-dated the meaning in the blue guide, relating to Lifting Accessories referred to in Article 1 (1) (d) are defined in Article 2 (d). It should be noted that lifting accessories are also designated by the term ‘machinery’ used in the broad sense Lifting machinery usually has a device for holding the load such as, for example, a hook. Such load holding devices incorporated into lifting machinery are not to be considered as lifting accessories.
However given the varied shape, size and nature of the loads to be lifted, equipment is often placed between the holding device (hook) of the lifting machinery and the load, or on the load itself, in order to hold the load during the lifting operation. Such equipment is referred to as a lifting accessory. Products that are independently placed on the market to be incorporated into loads for this purpose are also considered as lifting accessories.
So in simple terms a lifting accessory is pieces of equipment that are used to attach the load to the lifting equipment
Common examples of lifting accessories include:
• fibre or rope slings
• chains (single or multiple leg)
• lifting fixtures
• spreader beams
• vacuum devices
Note: in all cases the equipment is detachable, if the equipment is welded or permanently fixed to the load it then becomes part of the load.
Important Note: Any lifting accessories used between lifting equipment and the load may need to be taken into account in determining the overall weight of the load.
Placing on the market and putting into service
Before placing machinery on the market and/or putting it into service, the manufacturer or his authorised representative shall:
(a) ensure that it satisfies the relevant essential health and safety requirements set out in Annex I of the Directive
(b) ensure that the technical file referred to in Annex VII, part A is available;
(c) provide, in particular, the necessary information, such as instructions;
(d) carry out the appropriate procedures for assessing conformity in accordance with Article 12;
(e) draw up the EC declaration of conformity and ensure that it accompanies the lifting accessory;
(f) produce a test certificate or a current record of inspection
(g) affix the CE marking in accordance with Article 16.
Technical Construction File
The technical file provides the relevant technical documentation which enables a manufacturer to explain the measures he has taken to deal with the risks associated with the lifting accessory in order to comply with the applicable essential health and safety requirements.
Therefore, the manufacturer’s technical construction file is both a means to enable the market surveillance authorities to check the conformity of lifting accessory after it has been placed on the market and a means for the manufacturer to demonstrate the conformity of his product
The technical file shall comprise the following:
(a) a technical construction file including:
• a design risk assessment to ISO 12100:2010 the risk assessment demonstrating the procedure followed, including:
o a list of the essential health and safety requirements which apply to the lifting accessory,
o the description of the protective measures implemented to eliminate identified hazards or to reduce risks and, when appropriate, the indication of the residual risks associated with the lifting accessory,
• a general description of the lifting accessory,
• full detailed drawings, accompanied by any calculation notes, test results, certificates, etc., required to check the conformity of the lifting accessory with the essential health and safety requirements,
• the standards and other technical specifications used, indicating the essential health and safety requirements covered by these standards if not using a 'C' Type standard,
• any technical report giving the results of the tests carried out either by the manufacturer or by a body chosen by the manufacturer or his authorised representative,
• a copy of the instructions for the lifting accessory,
• where appropriate, copies of the EC declaration of conformity of the lifting accessory
• a copy of the EC declaration of conformity;
(b) for series manufacture, the internal measures that will be implemented to ensure that the machinery remains in conformity with the provisions of this Directive.
The manufacturer must carry out necessary research and tests on components, fittings or the completed lifting accessory to determine whether by its design or construction it is capable of being assembled and put into service safely. The relevant reports and results shall be included in the technical file.
A technical file is required for each model or type of lifting accessory. The terms 'model' or 'type' designate lifting accessory with a given design, technical characteristics and application. A type of lifting accessory may be produced in series or as a single unit. One type of lifting accessory may have variants; however, to be considered as belonging to the same type, variants must have the same basic design, present similar hazards and require similar protective measures. The description of the lifting accessory in the technical file must specify any variants of the model or type concerned.
The EC declaration of conformity must contain the following particulars:
1. business name and full address of the manufacturer and, where appropriate, his authorised representative;
2. name and address of the person authorised to compile the technical file, who must be established in the Community;
3. description and identification of the lifting accessory, including generic denomination, function, model, type, serial number and commercial name;
4. a sentence expressly declaring that the lifting accessory fulfils all the relevant provisions of this Directive and where appropriate, a similar sentence declaring the conformity with other Directives and/or relevant provisions with which the lifting accessory complies. These references must be those of the texts published in the Official Journal of the European Union;
5. reference to the examination certificate;
6. where appropriate, a reference to the harmonised standards used, as referred to in Article 7(2);
7. where appropriate, the reference to other technical standards and specifications used;
8. the place and date of the declaration;
9. the identity and signature of the person empowered to draw up the declaration on
behalf of the manufacturer or his authorised representative.
In addition to CE Marking in the UK lifting accessories are covered by the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER)
In practice, LOLER regulations require all lifting operations to be properly planned and supervised by a ‘competent person'. LOLER also requires that all lifting accessories must undergo regular examinations by an independent competent person to ensure that it is fit for purpose — it is the responsibility of the business who own or rent the equipment to make sure these examinations take place. The lifting accessories must then be appropriately marked and records of each examination must be kept, with any defects being reported to the person responsible for the equipment and the relevant enforcing authority
LOLER testing must be performed by what is known officially as a ‘competent person’: someone qualified to perform the thorough examination.
LOLER ACOP defines a competent person as someone who “has such appropriate practical and theoretical knowledge and experience of the lifting equipment to be thoroughly examined as will enable them to detect defects or weaknesses and to assess their importance in relation to the safety and continued use of the lifting equipment”. This person must also be impartial so they can be sufficiently objective in their review of the equipment, so it is recommended you hire an external contractor to perform your LOLER inspections. This will ensure there is no doubting the validity of your LOLER inspections should there be an accident on your site.
LOLER inspection, known officially as a ‘thorough examination’ and inspection which are key requirements of the Regulations, to meet these requirements, duty holder must have lifting accessories thoroughly examined:
• Before using a lifting accessory for the first time – unless the equipment has an EC Declaration of Conformity less than one year old
• Regularly in service if the lifting accessory is exposed to conditions causing deterioration that is likely to result in dangerous situations.
Accessories for lifting must be thoroughly examined by a competent person at least every 6 months or in accordance with an examination scheme.
HOW WE CAN HELP:
Our customers contact us because they need help and advice on how to apply the UKCA or CE Mark to their products.
The CE Marking Authority have a positive attitude and approach regulatory compliance by looking at the opportunities rather than seeing them as an inconvenience and meddling with your practices. We specialise in staying ahead of the game by using our technical knowledge (skills) conducting the necessary assessments to help our clients demonstrate their technical files meet the requirements of the regulations
Our expert team is here to help you meet the UKCA and CE Marking the requirements
• Free initial consultation to assess your requirements and plan the CE marking of your product.
• Identify the statutory instruments, the essential safety requirements, and harmonised standards, which apply to the product.
• Perform design risk assessments and clause by clause assessments against the designated standards
• Conduct a product compliance report to the applicable requirements outlining areas of non-compliance and advice on how to close out any gaps found.
• Assist in the compilation of the technical construction file, which contains the information required by the EU safety regulations.
• Provide a draft EU Declaration of Conformity and help you complete it.
• Offer follow up advice on changes in requirements for the life cycle of the product
• Act as your Authorised Representative in the UK or EU via or European office if required.
The many benefits of compliance range from brand and reputation, revenue enhancement, asset protection, higher profitability and lower costs, improved workforce performance, the provision of better data for better-made business decisions, and allows for a total harmonisation of your systems