Should a component be conformity marked and bear a WLL ?

For several years the status of sling components within the scope of Machinery Directive and now Machinery Regulation has been debated. There are two sides to the argument;

Apr 11th,2025 527 Views

Key legislation updates
For several years the status of sling components within the scope of Machinery Directive and now Machinery Regulation has been debated. There are two sides to the argument;

1. Manufacturers of sling components must consider the essential health and safety requirements of the legislation such that when assembled a sling will be compliant. Therefore, the assumption is that the components is considered as partly completed machinery and is within scope. As partly completed machinery it would not need to be CE marked, but would require the standards covering them to be harmonised. A further note would be that any item that can be used individually, e.g. a shackle, would be considered a lifting accessory and CE marked accordingly.

2. There are many forms of machinery types assembled from huge amount of component parts. Many cannot be used individually and are not considered as being within scope of the legislation, e.g. a gear cog. They cannot be considered as partly completed machinery as the definition of which applies only to partly completed machinery in the ‘strict sense’. Lifting accessories are considered as machinery in the broad sense and therefore this definition does not extend to their sub-assemblies and component parts. Machinery Regulation does include some components within its scope, but these are termed safety components and the definition of which is quite clear with respect to what they are. These are devices that perform a safety function, i.e. a limiting device. Component standards for sling should therefore be de-harmonised.

LEEA has always maintained that point 2 is the correct position, but unfortunately has struggled against large manufacturers who maintain their position on the subject.

It may seem a little pedantic to the layman, but the issue of having a harmonised standard causes much confusion in the industry. Notable, we see a variance in marking, in particular the conformity mark and the working load limit (WLL). The latter is considered to have potential safety implications.

However, last year at the plenary of CEN TC 168 we agreed to seek guidance from those responsible for interpretation of the legislation and that whatever the response is would be the agreeable position moving forward.

LEEA took the lead on this and approached AdCo for opinion. AdCo discussed this in much detail, and it took several months to get a response. However, the majority vote aligns with the LEEA stance and point 2 above.

As a result of the above we see no reason why the sling component standards should not now be deharmonised. The components themselves should not be conformity marked and should not bear a WLL.

However, LEEA does remain sympathetic to one reason behind the need to maintain harmonised status of these standards. This is that they are often used by manufacturers to produce bespoke components/accessories that are not covered by other standards. To address this issue LEEA intends to propose to CEN TC 168 at their next meeting in May 2025 the development of a standard(s) that cover such devices.

Key Standards Updates

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