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Advice On Imported Chinese Machinery With No Documentation.
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<blockquote data-quote="Sidewinder" data-source="post: 360957" data-attributes="member: 9512"><p>Onoff,</p><p></p><p>The only requirement for lodging the technical file with an NB is if the machine falls under Annexe 4, then it has to be checked by them also for compliance.</p><p></p><p>If it is not an Annexe 4 machine then you can self certify and compile a technical file as required.</p><p></p><p>The only persons who can demand to see the technical file are the relevant HSE enforcement body, e.g. HSE in the UK.</p><p></p><p>You also have a reasonable time to generate this file, as it does not have to be compiled prior to it being required.</p><p></p><p>For serial build machines the information must be held on file for a period after the last of the serial build machines is completed &amp; sold.</p><p></p><p>If the company goes into liquidation, all information etc. is lost.</p><p></p><p>There is and can be no recourse to generate the technical file, or provide the information.</p><p></p><p>A word to the user.</p><p></p><p>HSE WILL go after the employer using the equipment under PUWER98, rather than after the machine importer or builder.</p><p></p><p>It is easier for them to prove and enforce non compliance with UK regulations against a UK company, than perhaps an overseas company against international laws.</p><p></p><p>How do I know?</p><p></p><p>From meetings with the HSE on exactly this topic.</p><p></p><p>CE marking was part of my job at my last employer, (A Global "Blue Chip" industrial controls manufacturer) and PUWER98 &amp; CE marking is and is becoming more of a part of my current business.</p></blockquote><p></p>
[QUOTE="Sidewinder, post: 360957, member: 9512"] Onoff, The only requirement for lodging the technical file with an NB is if the machine falls under Annexe 4, then it has to be checked by them also for compliance. If it is not an Annexe 4 machine then you can self certify and compile a technical file as required. The only persons who can demand to see the technical file are the relevant HSE enforcement body, e.g. HSE in the UK. You also have a reasonable time to generate this file, as it does not have to be compiled prior to it being required. For serial build machines the information must be held on file for a period after the last of the serial build machines is completed & sold. If the company goes into liquidation, all information etc. is lost. There is and can be no recourse to generate the technical file, or provide the information. A word to the user. HSE WILL go after the employer using the equipment under PUWER98, rather than after the machine importer or builder. It is easier for them to prove and enforce non compliance with UK regulations against a UK company, than perhaps an overseas company against international laws. How do I know? From meetings with the HSE on exactly this topic. CE marking was part of my job at my last employer, (A Global "Blue Chip" industrial controls manufacturer) and PUWER98 & CE marking is and is becoming more of a part of my current business. [/QUOTE]
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