If you are part of the booster set supply chain, you have legal obligations to ensure that the products which you place on the market are fully compliant with EU legislation. In this article, Steve Schofield urges users to buy with confidence.
The European pump sector, through its network of national trade associations and Europump (the European Pump Manufacturers Association), has been working with the European Commission to ensure the introduction of appropriate legislation covering health and safety; the environment; and energy reduction. Europump has led much of this work, especially on the energy front through its Ecopump initiative and the BPMA along with its members has been at the forefront of this work.
Companies have invested a great deal of time and money to ensure the success of the legislative process in protecting users and the environment. It is therefore no surprise that our sector is keen to ensure, both directly and via appropriate market surveillance, that products being placed on the UK market are compliant.
To enhance this process, BPMA member companies have joined together under its ‘Buy with confidence’ initiative to ensure that its members are fully compliant, and in doing so, provide a professional advisory service detailing the legislative implementation process. However, there remains a significant number of suppliers outside of this group who continue to feed illegal booster sets into the UK market. If you are buying from these organisations, you not only put at risk the safety of users, but you may be acting illegally.
What to look out for
A number of booster set suppliers believe that it is acceptable to simply bring together components such as pumps, drives and controls and rely on the CE marking placed on those individual items as compliance for the set.
But this is not the case. The complete set is a machine in its own right and must therefore have a label affixed with a CE mark and be supported by all the appropriate documentation, including a Declaration of Conformity (see image below).
Compliance of individual components is not enough
As a complete machine, the booster set will need to have its own identification label affixed with an appropriate CE mark and will need to comply with the correct legislation. The label will need to carry a minimum amount of information such as a serial number, product type, supply voltage, and performance data along with details of the manufacturer and where the set was manufactured. But this is only the start of the process as other vital assessments need to be made and documents provided.
The paper chain
Each set will need to be supplied with a full and comprehensive instruction manual. The set will also need to be supplied with a Declaration of Conformity referencing the appropriate legislation and standards where applicable. Most importantly however, the set manufacturer will need to prepare a technical file.
This file, although not published externally, will need to cover a great deal of material including risk evaluation, product data, product features, production methodology and health and safety considerations. The typical file runs to 168 pages and benefits from independent scrutiny during its preparation.
Because of the pump sectors huge capital investment and the time its experts have spent on these issues, the BPMA is keen to ensure that all pumps and booster sets placed on the UK market are fully compliant.
This is not only to protect the safety of users, but also to ensure the integrity of our environment and protect our sector and its employees from those who seek to undermine the legal process and bypass the cost and impact of proper implementation.
The BPMA through its ‘buy with confidence’ programme helps to give users a benchmark and will seek to ensure that illegal products are brought to the attention of the authorities and removed from the market.
Steve Scholfield is director and chief executive of the British Pump Manufacturers Association