Approval Requirements–Safety-related Directives

In addition to EMC approvals, there may be other CE marking directives that relate to a given product. The policy of the MoD is very clear when health and safety are concerned and has been highlighted by successive politicians in the House of Commons. In a nutshell it is as follows:- “Like all employers, MoD and the Armed Forces must comply with legislation and, as a Department of State, comply with policies defined by Government or other lead Departments. The Secretary of State for Defence requires that MoD and the Armed Forces comply with all health and safety, environmental protection and fire legislation so far as is reasonably practicable, and must apply equivalent standards where it does not apply, or when operating abroad outside the jurisdiction of UK law.”

It is therefore clear that any CE marking directive that is safety related must be applied to products supplied to the MoD. A non-exhaustive list of relevant directives is as follows:-
• Machinery Safety Directive (98/37/EC)
• Low Voltage Directive (2006/95/EC)
• Personnel Protective Equipment (89/686/EC)
• Potentially Explosive Atmospheres – ATEX (94/9/EC)

Compliance with these directives, as well as the EMC Directive (2004/108/EC), is typically demonstrated by the application of Harmonised Standards. Harmonised Standards are published in the Official Journal of the European Union and give a

presumption of conformity to the directive. In some cases, mainly safety critical equipment, a Notified Body may have a voluntary or mandatory involvement to ensure that the correct assessments have been carried out and the product is suitable for the environment for which it is intended.

To sum up, it is important that manufacturers of products supplied to the MoD are aware of CE marking and which directives are applicable. It is both the product and the environment in which it is intended to operate that dictate what the compliance requirements are.

Many tender documents supplied by the MoD have a clear requirement indicating which directives are relevant. However, there are other cases in which broad statements such as ‘must comply with all relevant CE marking directives’ are made. In these circumstances, dependant on the knowledge of the manufacturer, products submitted through the tender process will yield differing performance.
TRL Compliance is a supplier to the MoD for EMC services and provides advice and guidance to other suppliers and manufacturers wishing to tender for business on approval requirements. TRL Compliance has expertise in the fields CE marking and military approvals and is able to advise on how the requirements interface with one another.

For further information and advice, contact TRL Compliance on +44 (0)1684 571 700.