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CE and Product Lifecycle Management
How to deal with changing (CE) safety requirements?
When the same tool or machine is ordered after many years since its first introduction, e.g. for replacement or expansion purposes, the new to be delivered product should comply with the latest level of safety, legislation and standards. Proper Lifecycle Management with respect to product safety and compliance is crucial to prevent disturbances in the customers operational processes. But what is the “latest Level of Safety”? And how to make sure your product remains up-to-date?
Over time the perception of “what is safe” is changing continuously. In the past we drove our cars without seatbelts, ABS, ESP and airbags and did not feel unsafe. Now we will find a new car without all these – and more – safety measures unacceptable. This collective perception of safety stretches out to everything we do, see, use, build, drive, operate, etc. etc.
Following our perception of safety is the formal legislation – the law – prescribing the mandatory safety measures for the world around us. So the level of safety is evolving. It increases over time. Perception changes, legislation changes and standards change. And also the interpretation of legislation and these standards changes (how to read the law).
That means that products delivered years ago might not be perceived as safe anymore or might even not be within the limits of the law anymore. Next to that, the law also states that every individual product introduced to the market must comply with the actual legislation and standards, especially when union harmonisation legislation on products is applicable.
And since this union harmonisation legislation is applicable on the vast majority of the products developed and manufactured by BKL, it’s important for BKL to have accurate knowledge of the law, mainly the Machine Directive, and applicable standards.
From experience BKL knows that in a period of 5 years the level of safety, including legislation and standards will have changed significantly. This 5-year-period is also recognized by all international experts in the field of safety.
To ensure that products delivered by BKL are always according the latest safety standards, BKL has a process in place called Product Quality Update (PQU). This PQU process is triggered by our ERP system during our product ordering process. When a product is ordered by a customer, a check is done on the date the last Safety Analysis was performed. When this is 5 years or longer ago, the PQU process is started.
There is another trigger of the PQU process and that is when legislation changes, for example a new version of the Machine Directive is introduced, or when standards change.
In this process we re-evaluate the safety level of the product. A new Safety Risk Analysis is performed and checklists of applicable standards are used to verify if the product is still compliant. When the answer here is “YES”, no further actions are needed and the product is delivered to our customer as requested. However when the answer is “NO”, the product is not compliant to the current legislation and standards anymore, formally the product is then “End Of Life”. Without any changes BKL is not allowed by law to deliver the product anymore.
A redesign is then needed to get the product up to the current level of safety. But this shall be the decision of our customer. Is he willing to invest in the required product redesign or not?
After the redesign the product can be delivered to our customer for the next 5 years after which a new PQU process will be triggered and started.
Guaranteed product safety and CE compliancy
With this process we offer our customers the guarantee that all products delivered by BKL are safe to use, always according the latest level of safety and fully CE compliant.
Please feel free to contact us with specific questions about our safety and CE related processes. We are very happy to answer all of these.