The instructions for your production line

For machine builders, system integrators and manufacturers who have combined machines from several suppliers into a single line.

Does this sound familiar?

You have had machines from several suppliers combined into one production line. You have a stack of supplier manuals and not one document covering the whole. Handover is scheduled and the documentation is still nobody’s job.

Every machine in the line carries a CE mark. The line itself usually does not.

What the law asks of you

Once machines are arranged and controlled so that they function as an integral whole, they are together one machine. The Machinery Regulation (EU) 2023/1230 sets this out in Article 3(1)(d). Whoever brings that whole together is the manufacturer of that whole, even if they built none of the machines themselves.

That means you have to take the line as a whole through the same route as a single machine. It starts with a risk assessment of the line to ISO 12100, because everything else follows from it. That risk assessment goes into the technical file together with the instructions. On that basis you draw up the EU declaration of conformity and affix the CE marking.

Do you also operate the line yourself? Then Directive 2009/104/EC on the use of work equipment applies as well. Your operators must have access to adequate information about the installation they work with; that is an obligation of the employer, not of the supplier.

Surely that is my supplier’s job?

This is the thought that holds most projects up, and it is an understandable one. Your suppliers all delivered properly, after all.

Your supplier’s obligation stops at their machine. If they supply partly completed machinery, you receive a declaration of incorporation and assembly instructions, and those explicitly do not cover your line. If they supply a complete CE-marked machine, that declaration covers their machine in the configuration they assessed, not the configuration you have placed it in.

Nobody is contractually responsible for the whole. Except you.

What we deliver

The content that appears in no supplier manual, because it only comes into existence once the machines are coupled together:

• the emergency stop architecture across the whole line: which stop halts which section, and what keeps running
• isolating the line for each intervention: which energy sources you disconnect, in what order, and what stays pressurised or live further down the line
• the interfaces between the machines: signals, interlocks, buffers, and what happens when a neighbouring machine drops out
• the start-up and shutdown sequence for the line, including restart after a fault
• fault finding at line level, where a fault in machine A shows itself in machine C
• the maintenance plan at line level, referring to supplier documents by chapter rather than re-translating them

What you get is a set of instructions for the line as a whole that meets the requirements Annex III, point 1.7.4 of the Machinery Regulation places on them, drafted to EN ISO 20607 and EN IEC/IEEE 82079-1 and derived from your risk assessment. It is the documentation you need in order to CE mark the line as a whole, and it is ready to go into your technical file.

In our experience the fault-finding table is where the gap shows up fastest. A sensor that trips in module one and stops the discharge three machines further along appears in no supplier manual, because no supplier knew that combination.

What we do not do

We are not a notified body. We do not carry out conformity assessment and we do not run a full CE process. We write the instructions for the line and build the structure that puts your supplier documentation in its place within them.

The risk assessment and the declaration of conformity stay with you or with your safety engineer. If you have neither in house, we will put you in touch with someone who carries out the assessment. We work on that basis, and that is not modesty: a set of instructions that does not follow from the risk assessment does not meet ISO 12100, however well written it is. More on what a compliant machinery manual involves is in our guide to the CE manual.

How it runs

Five steps with a lead time attached, so a project manager can judge whether it fits the schedule.

1. Establishing the legal framework: 2 weeks
2. Analysis of the existing documentation and interviews with your specialists: 2 weeks
3. Technical writing, resulting in a draft for review: 2 to 6 months, depending on the size of the project and the number of writers we put on it
4. Producing illustrations: 2 to 4 weeks
5. Delivering the final output: 1 week

More about how we work is on our technical writing agency page.

What you need to supply

This also costs your people time, mainly in interviews and reviews.

• existing relevant documentation and the supplier documentation
• the risk assessment or risk assessments
• the declarations of conformity where available, or an overview of the main directives and standards where known
• 3D files, preferably as .step
• logos and brand guidelines
• availability of your operators and maintenance technicians for interviews and review

Price and lead time

You get a price indication after a one-hour intake, and that intake costs you nothing.

There is no fixed rate on this page, because the difference between two lines is large. The number of machines, the number of languages and the state of the supplier documentation together account for most of the work.

CALL NOW: +31 492 792175

What this looks like in practice

Morssinkhof Plastics developed an installation for washing recycled plastic granulate. What existed was a folder of documentation for individual machine parts, in various languages and formats. What was missing were operating procedures and a maintenance overview for the installation as a whole.

We produced procedures for operation from start-up to shutdown, maintenance procedures for the technical department, and a structure that refers each part of the installation to the right supplier document and chapter. Maintenance can now be carried out systematically, the installation has become presentable to the market and it meets its CE obligations.

Read the full case: Morssinkhof Plastics.

The next step

Would your current documentation get an operator through a fault that does not start in one machine? Is there one maintenance plan for the whole line, or five separate schedules from five suppliers?

You do not need to enter a quotation process for that. A one-hour intake is enough to establish what is missing and what it costs to put it right.

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