Question:
This is a fully automatic machine that is normally placed on the market with a CE mark. The machine has an operator control station on both sides, each of which is fitted with an emergency stop pushbutton (red-yellow).
Is it possible to replace the emergency stop pushbuttons with "operational stop pushbuttons" (black/grey) and then place the machine on the market as partly completed machinery with a declaration of incorporation and assembly instructions?
Answer:
In accordance with EN ISO 13850, an emergency stop device must be located at each operator control station. Exception: if the risk assessment indicates that this is not necessary.
In accordance with the Machinery Directive (MD), partly completed machinery is an assembly which is almost machinery, but which cannot in itself perform a specific application.
A drive system is partly completed machinery. Partly completed machinery is only intended to be incorporated into or assembled with other machinery or other partly completed machinery or equipment, thereby forming machinery in the context of the MD.
As the machine in question has two operator control stations, it is probably not incomplete machinery in the context of the MD.
Compliance with all relevant standards is required in order to achieve presumption of conformity. For this reason it probably makes more sense to supply the machine as "partly completed machinery" with a declaration of incorporation and to use the assembly instructions to define all the conditions that still need to be met for the machine to be placed on the market properly, without compromising health and safety.