Report on the market surveillance campaign for portable lifting equipment

Transcription

1 Report on the market surveillance campaign for portable lifting equipment Photo: PSA A joint project by the Petroleum Safety Authority Norway and the Norwegian Labour Inspection Authority Petroleumstilsynet

2 Contents 1 Introduction Goal Planning and execution Background Summing up Extracts from the machinery regulations Preparing user instructions Compiling a conformity declaration Use of standards Documentation requirements Results from the document review Responses from the companies involved User instructions assessed in relation the machinery regulations Steel rope Steel rope slings Chain Chain slings Companies and attainment of maximum points Six important sub-sections of (literas d, g, h, k, r and s) Supplementary information Limitations Participants from the PSA Participants from the NLIA Documents

3 Report Report title Market surveillance campaign, portable lifting equipment subject to the machinery regulations Activity number Security grading Public Not publicly available Restricted Confidential Strictly confidential Involved Main group P-Market surveillance Assignment leader Sigmund Andreassen Members of the audit team Bjørn Lerstad (NLIA), Jan Ketil Moberg and Linda Halvorsen 9 June 2017 Date 1 Introduction Regulations on market surveillance (MS) are pursuant to the European Economic Area (EEA) trade law (Act of 12 April 2013 no 13) and to relevant sector product directives such as the machinery directive. MS means follow-up by national authorities to ensure that products placed on the Norwegian market are safe and comply with the provisions in the Norwegian regulations which have incorporated the harmonised EEA product regulations. This work is intended to contribute to a level playing field for participants in the EEA market. The Petroleum Safety Authority Norway (PSA) and the Norwegian Labour Inspection Authority (NLIA) are the MS authorities in their respective areas of responsibility and supervise compliance with Norway s machinery regulations (regulations of 20 May 2009 no 544). 2 Goal The PSA and the NLIA decided to conduct a joint MS campaign to verify compliance with the formal documentation requirements in the machinery regulations for selected equipment types. This campaign covered portable lifting equipment, such as simple lifting appliances, covered by section 1 of the machinery regulations, cf. section 2 litera a (machinery lifting appliance), section 2 litera d (lifting accessories) and section 2 litera e (chains, ropes and webbing). This MS campaign was limited to verifying compliance with the formal requirements for documentation and contents. We did not verify the technical contents or assess the quality of the contents. MS is accordingly not a conformity assessment or approval of documents pursuant to the machinery regulations. 3 Planning and execution The companies contacted are ones which fall into the category of manufacturers, their representatives, importers, suppliers and other dealers in machinery and products covered by the machinery regulations. These all have a responsibility for ensuring that the equipment complies with the harmonised EEA product regulations. The assignment was to identify the condition of the market by verifying the following: 3

4 o Conformity declarations preparation of a conformity declaration or possible assembly declaration use made of references to standards, etc. attachment of CE marking o User instructions preparation in relation the machinery regulation requirements use of language translation of user instructions from the original language to Norwegian o Use of certificates as technical documentation use of forms contents of the certificates Twenty-one companies were covered by this MS campaign. All were asked to submit examples of conformity declarations and user instructions for types of equipment in the following categories: steel rope slings steel ropes chain slings chains manual chain hoists manual trolleys beam clamps eye bolts 4

5 Documentation from the various companies was systematised and evaluated using this form. In addition, user instructions were assessed on the basis of the requirements of annex I to the machinery regulations, sub-section literas a to v on the contents of the instructions plus supplementary requirements for lifting accessories in sub-section The latter states: Each lifting accessory or each commercially indivisible batch of lifting accessories must be accompanied by instructions setting out at least the following particulars: literas a to d. (litera-texts omitted here) Sub-section on lifting machinery states: Lifting machinery must be accompanied by instructions containing information on literas a to e. (litera-texts omitted here) The following scale was utilised in the evaluation: N/A = not applicable 0 = not covered/included in the user instructions 1 = inadequately covered in the user instructions 2 = partly covered in the user instructions 3 = the cranes are considered to be covered by the user instructions

6 The evaluation was confined to an overall assessment of how far the user instructions contain information required by the machinery regulations. This assessment was not a verification of the actual technical contents or the quality of the information in the instructions. 4 Background The PSA has conducted audits for a number of years to check that safety-critical equipment possesses the documentation required for it to be used in an acceptable manner. Necessary documentation includes user instructions and declarations which show that the equipment has been produced in conformity with the EU s harmonised product regulations. User instructions for lifting equipment must provide guidance for employer and employees on training, areas of application, restrictions on use, maintenance and control, and is thereby an important tool for ensuring proper organisation of its use. A number of the audits have shown fairly substantial deficiencies in the documentation required for portable lifting equipment used offshore. The term portable lifting equipment here means lifting equipment which can be moved and used in several locations. It is divided into two main categories appliances and accessories. Accessory means equipment used between the appliance s hook and load. Appliance means an assembled unit used to lift loads, with or without horizontal movement. Most portable lifting equipment takes the form of accessories such as beam clamps and eye bolts, but some also rank as appliances. Chain hoists are an example. In addition comes equipment used as part of a lifting appliance, such as steel ropes and chains. Examples of audits which have checked documentation related to portable lifting equipment are: 2013 Teekay Petrojarl Knarr FPSO 2013 Statoil Veslefrikk A/B 2013 Odfjell Drilling Island Innovator 2013 BP Skarv FPSO 2014 Statoil Gullfaks A 2014 ConocoPhillips Eldfisk 2014 Exxon Mobil Jotun A 2014 Gassco TSP Statoil Kårstø 2015 BP Valhall 2015 Det Norske Alvheim 2015 Wintershall Brage 2016 Esso Slagentangen 2016 Statoil Gullfaks C 2016 Statoil Tjeldbergodden As a result of offshore findings, this campaign has focused on suppliers of portable lifting equipment. This is because audits have shown that a number of the offshore findings do not relate to a single operator company, a single contractor or a single equipment supplier. Most of the equipment suppliers deliver corresponding products to land-based industry. The NLIA has conducted a number of MS checks on manufacturers and importers of other types of work equipment covered by the machinery regulations, with the same experience as the PSA. 6

7 Examples of deficiencies identified offshore and on land are use of certificates instead of conformity declarations for lifting equipment references to incorrect standards in the conformity declaration lack of conformity declaration for CE marking inadequate user instructions o the instructions merely provide a description of the equipment and give little information on safe use, misuse, maintenance and control pursuant to annex of the machinery regulations with supplement 4.4 no translation of the manufacturer s user instructions to Norwegian 5 Summing up Communication among a number of the players involved during the campaign, was good. Most supplied the documentation requested by the deadline, and for those products they had in their product range. No further detail is given on the documentation provided by each supplier. All comments relate to the evaluation as a whole. While some of the suppliers provided complete documentation for some products, documentation for a large part of the equipment from a number of the suppliers revealed fairly substantial deficiencies. Examples of these are listed below. Deficiencies for user instructions related to the structure and contents of the instructions how the equipment is to be used how users are to be trained the description of user control and how this should be carried out information on how 12-monthly control should be carried out and criteria for it Where conformity declarations were concerned, there was inadequate understanding of what these declarations should contain inadequate use of references to harmonised EN standards We also found that translations of the original user instructions are not always complete, and that some companies have chosen to translate only parts of them. A number of the international manufacturers have prepared complete instructions, but the campaign revealed that the industry must improve its production of documentation intended to contribute to safe lifting operations. 6 Extracts from the machinery regulations The machinery regulations clarify the manufacturer s responsibility and the processes which apply when preparing user instructions for machinery. The purpose of the machinery regulations is to ensure that machinery and safety components are designed and constructed so that workers and consumers are protected against injury and damage to health, and are not exposed to undesirable stress. The regulations are limited to the 7

8 design and construction of machinery. They are therefore directed at manufacturers, importers, suppliers and other dealers. Use of machinery in an enterprise is not covered by the regulations. The regulations apply to the design, construction and placing on the market of the following products: a) machinery b) interchangeable equipment c) safety components d) lifting accessories e) chains, ropes and webbing f) removable mechanical transmission devices g) partly completed machinery Definitions of a machine, lifting accessories, manufacturer, placing on the market and the manufacturer s representative are provided in section 2 of the regulations. The manufacturer or his representative must ensure that a risk assessment is conducted to determine which requirements apply to the relevant machinery in order to protect against hazards to life and health. Results of this assessment must be taken into account when the machinery is designed and constructed. By the iterative process of risk assessment and in choosing risk-reducing measures, the manufacturer or his representative shall determine the machinery s limits, both in its intended use and in misuse which could reasonably be anticipated identify the hazards which could be posed by the machinery and the hazardous circumstances which could arise in connection with it calculate risk by taking account of the seriousness of possible injury and damage to health, and the probability of this occurring assess calculated risk in relation to the basic health and safety requirements in these regulations in order to determine whether the risk must be reduced remove hazards or limit risk in relation to these by adopting protective measures The text of the Norwegian machinery regulations is largely based on the EU machinery directive. Go here for more details: The Norwegian regulations can be found at Preparing user instructions Definitions and the contents of user instructions are specified in annex I, section of the machinery regulations, with the contents listed in section It is also included in section 4 on supplementary requirements to offset hazards due to lifting operations. A more detailed description appears in section 4.4 on instructions. 8

9 8 Compiling a conformity declaration The contents and preparation of a conformity declaration is described in annex II to the machinery regulations. A declaration and any translations of this must be compiled in the same way as the user instructions (cf. annex I, sub-section literas a and b). A conformity declaration must contain the following information: Name and address of manufacturer and, where relevant, his representative in the EEA. Name and address of the physical or legal person in the EEA with the authority to prepare technical documentation. Description and identification of the machinery, including its generic designation, function, model, type, serial number and trade name. An express declaration that the machinery fulfils the requirements of these regulations and, where relevant, an express declaration that it fulfils the requirements in other regulations or relevant provisions. Reference must be made where relevant to the corresponding directives published in the EU official journal. Where relevant, the name, address and identification number of the notified body which has carried out type approval pursuant to annex IX, and the number of the type approval certificate. Where relevant, the name, address and identification number of the notified body which has certified full quality assurance pursuant to annex X. Where relevant, references to the harmonised standards used. Where relevant, references to other technical standards and specifications used. Place and date of the declaration. Identity and signature of the person authorised to draw up the declaration on behalf of the manufacturer or his representative. 9 Use of standards The directives leave it to the manufacturer to choose how the basic health and safety requirements are to be met in purely technical terms. Many utilise harmonised EN standards because these provide practical guidelines on how equipment can be designed and produced. It is acceptable to meet the directive requirements in other ways, providing the manufacturer can document that the product fulfils the basic health and safety requirements in the relevant directive in this case, the machinery regulations. Go here for more information on the use of harmonised standards: 10 Documentation requirements The requirements specified below are those found in the machinery regulations. The campaign concentrated on portable lifting equipment and simple lifting appliances covered by section 1; cf. section 2 on definitions litera a machinery/lifting appliances litera d lifting accessories litera e chains, ropes and webbing 9

10 Requirements for documentation to accompany the machinery, are enshrined in section 8 of the machinery regulations, and in section 9 if the machinery is not ready for use. Section 8 of the regulations, on placing on the market and putting into service, states that Before placing machinery on the market and/or putting it into service, the manufacturer or his authorised representative shall a) ensure that it satisfies the relevant essential health and safety requirements set out in Annex I b) ensure that the technical file, cf. annex VII part A, is available c) provide, in particular, the necessary information, such as instructions d) carry out the appropriate procedures for assessing conformity, cf. section 10 e) draw up the EC declaration of conformity, cf. annex II number 1 part A, and ensure that it accompanies the machinery f) affix the CE marking in accordance with section 13, cf. annex III, and noise marking in accordance with annex XIII. For the purposes of the procedures referred to in section 10, the manufacturer or his authorised representative shall have, or shall have access to, the necessary means of ensuring that the machinery satisfies the essential health and safety requirements set out in annex I. Internal combustion engines designed and built for use in portable machinery must fulfil the requirements in annex XII on environmental requirements for exhaust fumes from internal combustion engines. (underlined by us) Section 9 on placing on the market and putting into service of partly completed machinery states that Before placing partly completed machinery on the market, the manufacturer or his authorised representative shall ensure that a) the relevant technical documentation is prepared, cf. annex VII part B b) assembly instructions are prepared, cf. annex VI c) a declaration of incorporation has been drawn up, cf. annex II number 1 part B The assembly instructions and the declaration of incorporation shall accompany the partly completed machinery until it is incorporated into the final machinery, and shall then form part of the technical file for the completed machinery. (underlined by us) 11 Results from the document review Our results provide an indication of the way the market complies with the criteria established in the machinery regulations. They are not a quality assurance of the contents. These results could be useful for those preparing the documentation importers of machinery from outside the EU/EEA the buyer of the machinery the owner of the machinery the authorities following up the use of machinery companies providing competent control accident investigations wanting to gain an impression of information given to the user educational institutions 10

11 In order to check whether each company provided the products covered by the documentation request, we looked at what was on offer in relevant catalogues or on the Internet. The contents of user instructions has not been assessed, so room for improvement may exist even if a company has received maximum points for the aspects addressed by us. Tables and graphs are constructed randomly and vary. Responses from individual companies cannot be identified 11.1 Responses from the companies involved The overview below shows that a number of companies have not provided documentation, and the evaluation of these is based on what was available on the Internet during the campaign. The following colour codes have been used: Has the product, but has not provided documentation Not in the product range Documentation received Key: (column heads) Steel rope slings Steel rope Chain slings Chain Manual chain hoists Manual trolleys Beam clamps Eye bolts (column texts) levert = provided; ikke i sortimentet = not in product range; ikke levert = not provided 11.2 User instructions assessed in relation the machinery regulations During the evaluation, account was taken of the fact that not all the companies had all the products in their range. Account has also been taken of the fact that not all the requirements in the above-mentioned sub-section are relevant for every product. 11

12 Results for all the companies are cumulative and measured collectively for the individual products, since this gives an overview of the condition of user instructions accompanying lifting accessories delivered in Norway Assessment in relation to the requirements in sub-section of the machinery regulations: Key: (Column headings) Steel rope slings Steel rope Chain slings Chain Manual chain hoists Manual trolleys Beam clamps Eye bolts. (Colours) Max points per product; Average points The table below shows points in per cent for each product (see above for key). Steel rope and chain are usually delivered as piece goods for use in lifting appliances, and therefore emerge poorly from the campaign. Steel rope is incorporated in most cranes, winches and hoists. Its safe use depends on adequate maintenance and inspection. 12

13 Internet searches showed that most European manufacturers, and some outside Europe, have good user instructions in English, but importers/suppliers choose not to translate these to Norwegian when making deliveries in Norway Steel rope Only two of the nineteen companies which supply this product, have produced instructions of the necessary quality. Eight have not provided documentation for the product, so compliance with the requirement varies from 2.1 to 94 per cent. See the table below. Key: Company no; Steel rope max points; Company points obtained; Attained in per cent Conformity declarations and/or certificates from some of the companies are from respected European manufacturers with English instructions, but the latter are not supplied with the product. The machinery regulations summarise what must accompany steel rope. See also the EN :2008 standard on steel rope information concerning use and maintenance, which refers in turn to ISO 4309:2010 on cranes, steel rope maintenance and control. The great bulk of the products have referred to EN as the manufacturing standard in the accompanying conformity declaration or certificate Steel rope slings Most steel rope slings are produced by Norwegian manufacturers. Some of the companies covered by this campaign, are distributors for the Norwegian manufacturers. Large quantities of steel rope slings are often produced in China and imported to Norway. Compliance with the requirements for user instructions varies from 27 to 94 per cent. See the table below. Key: see table above. The biggest deficiency here relates to information about the individual components included in the slings Chain Viewed in isolation, chain is the product with the poorest performance in the campaign. This is a relatively straightforward commodity, with plenty of good information available about it, and only ten variant dimensions are normally used for a product like grade 80, for example. Nine companies in this category have failed to provide user instructions. Compliance with the requirements for instructions varies from 11 to 100 per cent. See the table below. 13

14 Key: see first table on preceding page. In addition to the machinery regulations, EN 818-4:2008 provides information on what information users must receive. Virtually all manufacturers refer to this as the manufacturing standard for this product in the documentation provided to us Chain slings Chain slings are largely assembled by the company which sells them. In this case, Norwegian companies are the manufacturers of the completed lifting accessories. Where this product is concerned, the lifting accessory user will in some cases buy individual components and assembly the chain accessories in-house. When users assemble chain slings themselves, they are to be considered the manufacturer of the finished lifting accessory and under a duty to comply with the machinery regulations. Compliance with the requirements for user instructions varies from 8 to 100 per cent. See the graph below. Key: see first table on preceding page. Once again, it emerges that components are not described Companies and attainment of maximum points The companies are measured in the graph below by their maximum total points for the products they sell. Some of the companies do not carry all the products covered by the request for user instructions. This is reflected in a lower maximum column for these companies. The maximum number of points attainable by companies which provided user instructions as requested, is 363. Some of the observations we made when reviewing the user instructions, related to - descriptions of the marking which can be found on the actual product - descriptions of warnings about restrictions on use - descriptions of residual risk in use - descriptions of the way the equipment is to be used - what is to be controlled and how measurements are to be made - reproduction of the conformity declaration in the actual user instructions 14

15 Points No of companies SUM tot pr selskap Maks oppnåelig Key: Sum total per company; Max attainable 11.4 Six important sub-sections of (literas d, g, h, k, r and s) We looked at those sub-sections of which were considered to represent the most important information for inclusion in user instructions. These were literas d, g, h, k, r and s, which concern information about the machinery, restrictions on its use, training, in-house inspection and maintenance, and competent control. Litera d is a general description of the machinery. This sub-section describes the actual machinery. Litera g is a description of the intended use of the machinery. This sub-section describes what the machinery is to be used for. Litera h provides warnings concerning ways in which the machinery must not be used that experience has shown might occur. This sub-section gives the user information about hazards arising from misuse of the machinery. Litera k covers instructions for the putting into service and use of the machinery and, if necessary, instructions for the training of operators. This sub-section deals with user-specific training on the machinery. Litera r describes the adjustment and maintenance operations that should be carried out by the user and the preventive maintenance measures that should be observed This sub-section provides the basis for the user s pre-use check in order to ensure themselves that the machinery s condition complies with the regulations when brought into use or when its use ceases. 15

16 Litera s specifies instructions designed to enable adjustment and maintenance to be carried out safely, including the protective measures that should be taken during these operations. This sub-section provides guidelines for maintenance and for competent control of the equipment. It will provide the relevant personnel with the information needed for maintenance and inspection, such as check points and tolerances as well as maximum permitted wear. We chose to investigate the companies which are manufacturers and direct importers, and which have lifting as a product. That covers 16 of those included in the campaign. With an average value for the individual products of per cent, the results here show some improvement. The responses have not been quality-assured in terms of contents, but are only processed within the four assessment areas. 30,00 25,00 20,00 Summary for 16 of 21 companies Points 15,00 10,00 5,00 0,00 d g h k r s Literas under Gjennomsnitt fra alle involverte Maks oppnåelige poeng Key: Average for everyone involved; Max obtainable points. Literas d, g, h, k, r and s in the acquired data are also used here. The blue column shows average points obtained for the 16 companies selected, while the red column present the maximum points attained for the individual sub-sections. 12 Supplementary information Where eye bolts are concerned, for example, it can be seen that many of those who provided documentation, delivered from the same manufacturer. The latter has developed good user instructions for this product. The same applies to chain hoists, where many suppliers deliver with documentation from another manufacturer with a reputation for providing good user instructions. 13 Limitations One of the companies involved opted not to provide any form of documentation. It reported that this type of equipment was not carried, but an Internet search showed that its range included all types of product covered by the campaign as a distributor subject to the machinery regulations when equipment that is covered by the regulations, is delivered. 16

17 We have not included a review of the physical marking of the equipment, since it has only been provided with conformity declarations and user instructions. Nor have we carried out an assessment of conformity declarations in relation to annex II part 1 concerning the contents of such documents. In the case of conformity declarations, we have looked at references to standards and descriptions of type of accessory. 14 Participants from the PSA Sigmund Andreassen logistics and emergency preparedness (assignment leader) The following have contributed to technical assessments: Jan Ketil Moberg logistics and emergency preparedness Linda Halvorsen P-market surveillance 15 Participants from the NLIA Bjørn Lerstad NLIA mid-norway 16 Documents The following documents were used in planning and conducting the audit: Conformity declaration, user instructions, and possible technical files from the individual company. Eleven companies provided documentation for all eight products covered. Nine of the companies have not provided documentation for all eight categories even though catalogues and websites showed that they carried the products concerned. One company responded that it did not have these types of products in its range, but an Internet search showed that it was a distributor/dealer. An overview of the information provided, can also be found in chapter