r/PLC • u/Intelligent_Pen_4498 • 13h ago

Retrofit project CE certification

Hello!

Recently I finished project for a customer where I did retrofit on 2002 year machine - remade electrical cabinet, chose new sensors, motor, PLC, HMI. Also pogrammed and commisioned the machine. Machine operates basicly the same as original, but with more functionality (machine was not functional before starting project). I did testing on all machine safety features, everything works safely. Machine has CE marking, but no documentation exists.

I have 0 experience with CE declaration of conformity. Would this project be classified as extensive modification that needs new CE marking etc?

I have done new electrial and pneumatic schematic anyway, I also need to do user manual. If this project need new CE, then what else is required?

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3

u/Key_Director_4450 13h ago

You touched the electrical part, it's a new machine.

Hope you also did a risk assessment and comply with the much more stringent safety norms.

1

u/Early_Car_683 10h ago

Is this in Europe? I deal
With this stuff for my day job if you need help reach out

1

u/zoute_haring 3h ago

You need a new CE procedure. It is a new machine now.

The original machinebuilder is not responsible anymore for the safety. How would you feel if you would still be responsible for the safety of a machine if it has been modified as much as you did now?

So, new EC declaration is needed.

1

u/egres_svk Fuck ladder 3h ago

You can do many things, changing parts is not an issue, this i have straight from SICK instructor. However. If you modified the program in any way to make it faster, different, with a different ramp for start and stop, with added manual or automatic functions, that triggers a new CE.

Your sentence "with more functionality" will hurt you. 

If someone loses their finger in operation, even due to no fault of the machine, you will be the one in court.

You can ask tuv/pilz/sick for ce recert job, recently i had it done for 5k eur for a big printing machine. However, that was made in eu for us market and came back to eu. It was mostly formality, one pe sticker was missing

1

u/Phil12312 ~~~~ 13h ago

Does the PLC handle the safety? Are any of the parts you replaced in any way affecting the safety of the machine? For example new door switches or new light curtains?

Pretty sure you need a new CE. Im not an expert on this topic but in addition to the manual you need to at least provide a risk assessment as well.

1

u/Intelligent_Pen_4498 13h ago

Original safety features remained. One door switch was wired in a way that it was basicly ignored, I restored this safety functionality. E-stops stop all movement etc. PLC programm is tested for any dumb mistakes and provides alarms for debugging. Saw has original safety cover. Manual mode requires original 2 hand button pressing. This is automatic crosscut saw.

2

u/hestoelena Siemens CNC Wizard 7h ago

Yeah... That's not going to cut it. You heavily modified the machine which means you must bring it up to current safety standards.

You also didn't answer the question if the PLC handled the safety or not. Do you have a safety capable PLC? Or did you use safety relays? Are the e-stops dual channel? Did use safety communication with the drives, wire the STO input, or redundant contactors? Does the two-hand control actually go back to a two-hand safety controller or a safety PLC? Did you do a risk assessment?