Last edit: 01/08/2023
THE QUESTION
Often the manufacturer has doubts about what should be indicated in the Instruction manual.
One of the aspects is whether it is necessary to report the spare parts list. What obligation does the manufacturer have in this regard?
CONSIDERATIONS
The drawing up machinery instructions is an obligation of the manufacturer. Point 1.7.4 of the Machinery Directive 2006/42/EC deals with the obligations to be met regarding the Instructions for Use, before the machine is placed on the market and/or put into service.
RESS 1.7.4.2 details the contents of the instructions for safe use of the machine. The letter t) specifies that the User Manual must contain:
t) the specifications of the spare parts to be used, when these affect the health and safety of operators;
The following is defined in the Guideline of Directive 2006/42/EC:
“Section 1.7.4.2 (t) refers to information about spare parts. In general, the supply of spare parts and the supply of a spare parts list are not covered by the provisions of the Machinery Directive and is thus a matter for contractual agreement between the manufacturer and the user. However, where parts subject to wear and tear need to be replaced in order to protect the health and safety of users, the specifications of the appropriate spare parts must be given in the instructions.
Examples of such spare parts include:
• guards for removable mechanical transmission devices;
• flexible guards subject to wear and tear;
• comments on section;
• filters for systems to provide clean air to operating positions;
• load bearing components on lifting machinery;
• guards and their fixing systems used to retain ejected objects or parts of machinery.”
CONCLUSION
Therefore, the spare parts list is mandatory to issue the CE certification of a machine if they are parts subject to wear and that could affect the safety.