Application of the directive 94/9/EC to Fork lifts trucks - revised version
Fork lift trucks intended for use in potentially explosive atmospheres (revised version)
Fork lift trucks intended to be placed on the Community market for use in a potentially explosive atmosphere are considered assemblies (see chapter 3.7.5 of the Guidelines to ATEX Directive 94/9/EC). They must also, where relevant, comply with other applicable directives (e.g. Machinery 98/37/EC, Electromagnetic Compatibility 89/336/EEC).
A fork lift truck, which complies with all applicable directives, must be placed on the market by a single responsible person. More than one CE marking, EC-declaration of conformity, etc. makes it unclear who is responsible for the compliance of the final product and is not acceptable.
The responsible person must have the means to show that there is full compliance with all applicable directives, also those dealt with by possible subcontractors.
Selection of the conformity assessment procedures
The conformity assessment procedure according to directive 94/9/EC depends on the category of the product. In the all well-known cases explosion-proof fork-lift-trucks are to be assigned to the categories 2 or 3.
Fork lift trucks can be regarded for the selection of the conformity assessment procedure as combined equipment which if necessary contains a internal combustion engine, as well as different electrical and non electric devices.
Fork lift trucks category 2:
- Internal combustion engines and the electrical equipment must be submitted to the conformity assessment procedure in accordance with Art. 8.1 (b) i of the directive 94/9/EC; for both, the procedure of the EC conformity assessment procedure according to the Art. 8.1 (b) i is to be accomplished by an notified body in any case.
- The manufacturer has to ascertain that there are no additional ignition risks due to the combination of electrical equipment. This means for example a change of the temperature class. Usually the combination of components (EC Type Examination Certificate of components) does not fulfil these requirements.
- The combined equipment (fork-lift truck) is neither electrical equipment nor another internal combustion engine, therefore Art. 8.1 (b) ii of directive 94/9/EC applies to the conformity assessment procedure for the category 2: The manufacturer must use the internal production control in accordance with appendix VIII (including design and production) and deposit the technical documentation with a notified body in accordance with Art. 8.1 (b) ii ; the notified body has to confirm the receipt of these documents immediately.
Fork lift trucks category 3:
For category 3 the manufacturer must use the procedure of the internal production control in accordance with Annex VIII to Directive 94/9/EC.
All fork lift trucks categories:
In all categories, the manufacturer can choose to use the procedure of the EC individual examination according to Annex IX to Directive 94/9/EC.
Other directives applying
The manufacturer has to fulfil the requirements of all directives appropriate to his product. In particular, the manufacturer has to guarantee that the fork lift truck complies with the essential health and safety requirements of the Machinery Directive 98/37/EC in the case of conversion to an explosion proof fork lift truck.
EC declaration of Conformity
Preferably the manufacturer should draw up a conformity declaration which summarizes the conformity declarations for all directives applying. Alternatively the conformity declaration according to Directive 98/37/EC and/or EMC guideline can be issued separately.