Hot Spot Machinery Directive 2006/42/EC

CEIR and BVAA have given diligent and careful consideration to the interpretation of the requirements of the Machinery directive relative to its application to industrial valves, valve actuators and actuated valves. Both organisations have separately reached the same conclusions and issued their interpretation of the requirements of the directive in separate documents outlining the following:

• Manual valves, valves without actuating device and check valves are excluded from the scope of Machinery Directive 2006/42/EC

• In general all valves (including actuated valves and valve actuators) should not be considered as machinery in accordance to the Machinery Directive 2006/42/EC

• Safety valves are not considered to be “safety components” which have special status under Directive 2006/42/EC

• Actuated valves and valve actuators should be considered as Partially Completed Machinery (PCM), but only when they are manufactured to be incorporated into machinery. Therefore actuated valves and valve actuators should be considered as PCM only when they are explicitly intended to be incorporated into machinery and issued with a Declaration of Incorporation.

• Each manufacturer has to decide which products will have to fulfil the requirements of Directive 2006/42/EC, and will specifically indicate it in the sales documents with a declaration of incorporation.

For more than 3 years now these statements of the requirements of the Machinery Directive have been accepted as correct interpretations by valve/actuator manufacturers and European users alike.

However BASF in Germany are now refusing to accept these interpretations and are insisting that actuated valves are machines and subject to the requirements of Machinery Directive 2006/42/EC.

German manufacturers have identified this problem and representation has been made to the European Commission, CEN and CEIR to resolve this issue.

CEN TC/69 has re-confirmed the CEIR and BVAA interpretation and are seeking meetings with BASF in an effort to resolve this issue.

Published: 5th March 2014