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Taking care of the paperwork

30 October 2013

At the Lifting Equipment Engineers Association (LEEA), we regularly receive calls from both end users and suppliers with questions regarding the documentation that should accompany overhead lifting equipment. Even though, in the UK at least, most of the relevant legislation has been in place since the 1990s, there is clearly still widespread confusion and misunderstanding surrounding this particular issue says LEEA regional manager - West Denis Hogan.

This can present a number of potential dangers for those concerned, including the consequences of failing to meet basic legal requirements. Furthermore, whilst it’s quite possible that equipment without the right paperwork is perfectly sound and fit for purpose, mistakes and omissions in the documentation provided by the supplier should at least raise some doubts in a buyer’s mind.

By far the most common misconception is the belief that a ‘test certificate’ is routinely needed when new lifting equipment is supplied. Indeed, the documentation that accompanies new lifting equipment is regularly and erroneously referred to as such. In fact, test certificates generally belong to a bygone era in which every new item of lifting equipment was routinely proof load tested with an overload to prove it could carry the rated SWL (Safe Working Load). Things have moved on and far greater emphasis is now placed on quality control during the manufacturing process. Sampling, non-destructive testing and other techniques have replaced a single (and often meaningless) proof load test. As a result, the ‘test certificate’ has been superseded by the ‘Manufacturer’s Certificate’. Along with the EC Declaration of Conformity and Report of Thorough Examination, it is one of the three key types of document that buyers and suppliers of lifting equipment should concern themselves with.

The information that should be contained in the Manufacturer’s Certificate is listed in, and a compulsory part of, the relevant product standard. Therefore a manufacturer claiming to comply with the product standard must issue the Manufacturer’s Certificate.

The manufacturer must also supply the document required by legislation. In Europe, this means an EC Declaration of Conformity. The requirements for this are contained in the Machinery Directive, the latest version of which came into force in 2009 and is implemented via national legislation in countries throughout Europe. In the UK, this is represented by The Supply of Machinery (Safety) Regulations 2008. According to the Machinery Directive, the EC Declaration of Conformity must be produced by the ‘responsible person’. If the item is made in the EEA (European Economic Area), then the responsible person is the manufacturer. However, if it is manufactured outside the EEA, the responsible person is the manufacturer’s authorised representative, or the importer. There are clear and detailed requirements for the content of the Declaration of Conformity, which can all be found in the relevant legislation. The Declaration of Conformity must accompany the item in question, and it should be noted that there will usually be some overlap of the information contained in this and the Manufacturer’s Certificate. Indeed, the manufacturer may choose to combine the two documents. This is perfectly acceptable, provided the information is clear.

The last of the three key documents is the Report of Thorough Examination. The UK requirement for Thorough Examination is found in Regulation 9 of the Lifting Operations and Lifting Equipment Regulations (LOLER). Under LOLER, the term thorough examination is used to describe high level, periodic inspection of lifting equipment. It includes any tests deemed necessary as part of the examination, such as functional, electrical, non-destructive and load tests. One of the major changes introduced by LOLER was that a report must be issued following every thorough examination, regardless of whether the equipment is found to be safe or not. Schedule 1 of LOLER clearly specifies the information that a Report of Thorough Examination must contain, but it should be noted that LEEA regularly comes across examples of incomplete reports.

One day training course offers an introduction to overhead lifting
The LEEA has added a one day course designed to offer staff with little or no technical expertise an introduction to the overhead lifting sector to its training portfolio. Led by LEEA’s team of specialist trainers, the Lifting Equipment Familiarisation Seminar will provide attendees with an overview of commonly used lifting equipment and accessories, and an outline of relevant UK legislation and regulations.
Open to all employees of LEEA member companies, the new course is ideally suited to staff working in administrative roles who would benefit from a better understanding of the products and services they deal with. For the more technically oriented, the course may also serve as the first step towards a long-term career in the test, examination and maintenance of overhead lifting equipment.

Beyond these three key documents, there may sometimes be contractual requirements on the supplier to issue additional certification. Examples include a Certificate of Test Load Applied, Certificate of Non Destructive Testing, or an EN10204 Certificate of Conformance (sometimes referred to as a mill certificate). However, it should be stressed that these have no direct legal status in relation to lifting equipment, although they may be needed to support the legal requirements for such equipment, for example in the compilation of a technical file.

Documentation and paperwork can sometimes be considered a distraction from the important business of ensuring safe and efficient overhead lifting. The good news is that the obligations are not unduly onerous. Indeed, they can provide a useful tool for buyers. Certainly, for the non-specialist buyer, it is often all but impossible to make a considered judgment on the quality of equipment being purchased. The EC Declaration of Conformity provides the main, if not only, physical evidence that the equipment complies with the requirements of the Machinery Directive. Furthermore, a supplier that clearly understands and adheres to the requirements for accompanying documentation should go at least some way towards assuring the buyer of their credibility and professionalism.