Grey Imports & The Machinery Directive

Unfortunately people can’t resist a cheap deal and plant & machinery is no exception.

Many machines and other plant were sold off when we hit the end of the boom, now that we are on the up again, people are investing in plant & machinery again.

Many if you have seen the Ads for auctioned plant every month or so, and everyone wants a good deal.

Now the thing with auctions is there is no “come back” it’s a case of buyer beware
……now before we go any further, some auctioned plant is top quality and safe, knowledge is key here.

So what is the problem? Generally there is no history of the item or what environments they operated in, quarry? lifting duties? chemical plants.

So what should I do? Would you recognise what a ‘greyimport?

Grey imported goods are products sourced from outside the normal European distribution channels, usually from as far off as Asia or the sub continent, either shipped in directly to specific customers or imported  for resale.
The potential pitfalls of buying a Grey Import are costly if you do not have the knowledge to know what to look for or the legal standing of this plant according to the relevant Regulations.

So let’s start there;
All plant sold in the EU must have a declaration of conformity, a CE mark.
This is a mark of build quality and guarantee.
It is illegal to have a machine without this mark and it is illegal to sell a machine without one, but like many Regulations, there is not enough enforcement, but you could fall foul of your insurance cover.

Safe plant;
Do you know what you are buying, was it ex-stock,? ex-rental? a bank repossession?
There could be potential Safety issues here, was the item even serviced and looked after, was it every involved in an accident or a product alert?

I have seen on first hand the manufacturers data plate & SWL markings removed, would you buy a car with no owners cert and no licence plates? so do your homework or get professional advice….remember as the owner of the plant, you are ultimately & legally responsible for it.

The regulations that govern this are the Machinery Directive 2006/42/EC


Are you Inspection Ready?

One thing that surprises me is the poor readiness of some items that require a ‘Statutory’ Inspection.


Here are a few tips on helping you avoid the dreaded ‘must be forwarded to the HSA’ conversation. (This is a basic guide and should not be taken as a full & comprehensive guide on preparation for inspection)



Have a look your machine/ item yourself prior to the Inspection I’m going to be doing…this should be part of a daily routine anyhow.

Firstly allow some time for the inspection, it takes time to carry out any safety inspection, don’t rush us…your life or someone else’s could depend on what we see or don’t see

Check all safety systems, lights, cameras, mirrors, load sensors, and tilt sensors and limits.

Clean the items, nothing worse than having to clear, muck, grease, dust etc from an item for 10 mins before you can even assess it. (Time is money for both of us)

Is the manufacturer’s data plate visible, Serial number, SWL. – No data plate is like have no number plate or name. It has no history.

Appropriate and clear signage



Is it maintained? You’d be surprised. I came across a client who thought the maintenance was too expensive, so they stopped doing it….you always need maintenance.

Read and understand the Reports, if you don’t understand them, get some who does.

Have you completed all outstanding issues from the previous report? When you don’t observations become problems, problems become safety issues and that’s when it gets reported to the HSA.

Emergency lights and emergency call systems, are they operational….assess the risks

Appropriate and clear signage

Escalators/ Travelators


Again, is it maintained? Appropriate and clear signage?

Handrails must be in good condition, travel at the same speed as the steps, no stalling.

Steps and pallets should be in good order, no broken vanes.

These machines are very dangerous if not maintained, there should not be chipped or broken teeth on the complates, and these are the vaned plates the steps slide under at the start and end of the escalator / travelator.

Lights, there must be adequate lighting over the whole length and ends.

Emergency stops, are they visible?

Are there adequate anti-climbing guards in place?

Are there signs nearby for the lifts, if people have buggies, wheelchairs etc….amazing amount of people still bring buggies up escalators, please don’t.

Do not EVER let your children sit down on the steps or pallets.



Is it maintained and serviced? (by a FLT service company)

Check all safety systems, rollover cage tyres, brakes, seatbelts (if fitted) lights, mirrors, sensors and horn.

Is the Serial number and SWL clearly marked?

Is it relatively clean, nothing worse than having to clear, muck, grease, dust, been clean also helps find potential problems.

Are the forks and chains in good order, you should know there limits.

MEWPs (cherry pickers etc)


Again, is it maintained? Appropriate and clear signage?

Is there an operators Manual with the item, there should be.

Is the Serial number and SWL clearly marked?

Are you trained in its use?

Check all safety systems, tyres, tracks, levers, tilt sensors, emergency stops, emergency lowering and horn.

Is the gate and handrails in good condition, no missing pins.

There are too many types of plant to list them all, but one thing to remember, it must always operate safely.

Should you have any queries on specific items, please get intouch. or visit our website

Retro-fitted door Photocells

As Inspection Engineers we often come across something that makes you wonder , this is one of these times….

I’ve come across this set-up on a couple of Passenger Lifts, which have had retrospectively fitted full length door photocells mounted on the outside of the leading edge of the car doors.

By been mounted here some of them may inadvertently cause the landing doors at the floor beneath the lift to be opened, as some of these lifts will automatically cycle open and close the doors when a fault occurs or the lift stopped out of the floor zone,   I have taken a few photos and added some highlights, but as always Lifts should be inspected by a suitably Qualified & Competent person every 6 months. (like us)


Fig. 1

Fig 1


In Fig. 1 We see the mounted photocell (A) and front door roller of the landing beneath the car (B) and the rear door roller of the door beneath the car (C)


Fig. 2

Fig 2

Fig. 2 Shows the photocells mounted to the outside of the car doors leading edge, if photocells can only be mounted this way, they should be mounted behind the skate (green arrow) and well away from the area of the landing door rollers.


Fig. 3

fig 3

Fig. 3 By placing the photocell here (Circle D) it reduces the car door clearance (G) to the landing door sill (circle E) you can see that the photocell is hitting the front landing door roller of the floor beneath the lift.

NOTE: If the photocell had hit the rear roller in circle F, it would have caused the landing doors to open and they would create an unprotected opening and a unacceptable risk to the public.

Also there is a high risk of damage to the photocells, when hit by the door rollers under power.

As for the installation was it tested for safe operation?? Does it fail SAFE??

If you are concerned about your Passenger/ Goods lift, Please contact us and let us keep you safe and compliant.

Man-Baskets (a non-integrated platform)

Man baskets are a piece of equipment I dread seeing, they are usually homemade and not fit for purpose.

I personally won’t use one, why?   Well there are a number of very good reasons.

They are generally are not the most suitable equipment for the job, more than likely a MEWP, (Mobile Elevating Work Platform) would be  much safer and better.


Use the right equipment for the job

They should only be used when there is “exceptional circumstances”  that should be addressed immediately for safety reasons and no other suitable equipment is available i.e. where a light fitting is about to fall.

My inspections are usually planned well in advance and therefore do not fit the criteria for use in “exceptional circumstances” . The use of a MEWP, boom or scissors type or even mobile scaffolding maybe a safer method.

So what does this mean for you? A risk assessment should always be carried out, is the work planned? Is the lifting equipment the most appropriate for the job and user? Is the item certified and safe to use? Can more suitable equipment be hired or purchased? An assessment of ground conditions.

Tele 2
Ground conditions??


Safe to use, a professionally manufactured basket will have a number is safety features, it will have (a) a suitable SWL marked for kg and persons, (b)
a self locking, inward opening gate, (c) a harness anchor points, (d) a suitable means of safe attachment to a telehandler (e) clear communication with the machine operator.



The Machine itself: (a) anti-fork tilt on a telehandler, a lock out switch or usually a pin that is inserted beside the lifting controls to isolate the function (b) are check valves fitted to the hydraulics of the lifting ram (c) if used for man lifting the machine should have a 6 monthly Thorough Examination certificate, Reg 52.

There is a plan for the evacuation of persons from the basket in the event of mechanical failure or other difficulty such as an injury etc.




Regulation 48(1) deals with lifting people using machines that are designed for lifting loads

Regulation 48(2) does not allow people to be lifted by devices which permit a free fall mode to be engaged while lifting people.



Niall Scully  EngTech, MSOE, MBES.

SWLs and Load Testing, Truths v’s Myths


SWL: (Safe Working Load) and

WLL: (Working Load Limit) are the commonly used terms in Load testing.

Load testing is a means of assessing the SWL or WLL of a piece of plant or item.

It is the maximum limit that a particular piece of equipment or plant can operate at without having an adverse effect or without fear of breaking

Manufacturers are responsible for marking the appropriate SWL on their equipment and plant, all manufacturers will have it marked on a plate or load charts.


Overloading  An SWL is not a guide but a limit; there is no lee way….
Example,  a shackle marked SWL 500kg, is not allowed lift a 600kg Load, not even once, if it is used this way it could fail immediately or have unseen effects and fail next time it is used in a lift.

There is no one rule, if overloaded , an item could fail immediately or it could have a cumulative effect,
Also to note each manufacturer builds their equipment and plant different, so overloading can have different effects, visible and invisible.

Regular load testing is not recommended for most items, unless there is a good reason, Passenger lifts, Forklifts, MEWPs, Overhead Cranes, Chain Hoists, do not require  regular load tests, but some plant do….

Mobile Cranes and Lorry-loader Cranes do, every 4 years or if major repairs are undertaken, this is in the Regulations.

A tower Crane is another piece of plant that requires a load test, before its first use at a site or if the configuration is changed and every 4 years if on the same site.
If you change chains or ropes or forks on items such as forklifts, passenger lifts, or vehicle lifting tables there is no need to retest, but you must replace ‘like for like’ and in-line with the manufacturers guidance on this.

NEW plant– the fact that a piece of equipment or plant is new does not mean it does not need certification. Unless it is actually supplied with a certificate showing this, it must be certified before it is used for the first time.

Load tests and calibration intervals should be carried out in-line with the manufacturers guidance on the frequency and Regulations, An Engineer can choose to reduce that frequency but it can never be increased beyond the manufacturer’s or Regulations  time frequency.

The Relevant Regulations:

Regulation 55: Safe working loads for excavators, draglines, telehandlers, loaders or combined excavators and loaders when used as cranes

(2) An employer shall ensure that—

(a) before a machine to which this Regulation applies is first used, a competent person—

(d) specifies the safe working load or loads and the outrigger position and the length of jib or boom to which the safe working loads relate is either plainly marked on the machine or a copy of the table relating safe working loads to the distance worked is affixed in a clearly visible position in the driver’s cab,

(e) (a)(ii), a machine undergoes any substantial alteration or repair likely to affect the specified safe working loads, that certificate is cancelled and a new certificate is obtained,

(j) machines to which this Regulation applies are examined and tested periodically in accordance with Parts B and C of Schedule 1.

Part C — Circumstances requiring testing of lifting equipment as part of a thorough examination


Column 1 Column 2
Description of Equipment Period within which or conditions
  under which testing is required
All Lifting equipment After any substantial alteration or
  repair affecting its strength or stability
Fixed lifting equipment Before first use
Tower crane after every assembly
Mobile Crane Every 4 years
Winch Every 4 years
Self erecting crane After erection and before first use on site
   and after any change in configueration
  or support conditions
Pulley block, gin wheel or sheer legs  
or supporting systems for same, used Before first use
the rising or lowering of any load  
weighing 1,000 kg or more  

Load Testing of Excavators Over the last few years this practice has become popular with site plant, it is simply ignorance of the regulations, but mostly as a result of service providers who provide this service for commercial reasons only and therefore promote it as being a necessity under the regulations….in short it nonsense and a waste of money, but if a Council or Contractor (incorrectly) insist on one, what can you do!!

Over testing can be detrimental or damaging to the item and you are not proving anything with it.

Need more advice or Inspection Services,

Contact or 087 9147899

VLT’s (Vehicle Lifting Tables)

Vehicle lifting tables

I have found that there is a common misconception that vehicle lifting tables (VLTs) are exempt from Statutory examinations and I believe the confusion lies with a person mistaking Vehicle Lifts (wheelchair lift on a Taxi) for a Vehicle lifting Table (found in garages) when they look at the H&S Regulations.

If not sure, Email the HSA or even us.

A Vehicle Lifting Table is NOT exempt from Regulation 52, but a vehicle lift is exempt from Regulation 52, but not Regulation 30….know the difference.

Vehicle lifting tables- (VLTs’) there are 1000s of them out there and unfortunately they are one of the items with the highest number of defects found during an examination.

Why is this?

Bad maintenance, poor installations, user repairs, poor quality, well let’s look at each of these

  1. Bad Maintenance– A few weeks ago, We carried out Examinations of 4 VLTs, which up to the date we took over, were been maintained and inspected by a VLT installation company.

The defects we found were very worrying, along with the quality of maintanance.

It’s easy to generally guess how well maintained equipment is within a few minutes by a company’s  housekeeping “more mess, more problems”

  1. Poor Installation– Are the floor bolts loose, are you always tightening them? Is the concrete suitable for mounting a VLT on? Are there cracks on the floor around the floor bolts?

2 post vehicle lifting tables are generally mounted with retaining bolts in the concrete floor, do you know if the concrete is deep enough or strong enough for the forces applied by the lift to the floor bolts?

Scissor Vehicle lifting tables are fitted into the ground, make sure there is room for the hydraulic hoses, so none get damaged.

Safety limits- have the limits been adjusted correctly to suit your site.

If you find that your floor bolts are coming loose on a regular interval, this could be an indicator of poor quality of concrete, also if there are cracks running through where the bolt is anchored in the floor.

If you find these issues you should really be asking questions.

  1. User repairs– I once was looking at a screw type VLT which didn’t want to go up, now this generally triggers a question on safety devices, but before I could go any further a employee of the garage showed me how he had bypassed the switch with a bit of wire, “give this a pull here”!!!,                                                                                                 When the load nut wears to a certain point, it triggers a safety switch which will allow the lift to be lowered be not raised again until the load nut is replaced, this lift was running on the safety nut, which is like climbing a mountain with a piece of twine.

Never bypass any safety devices, they are there to protect you from harm or even death.

  1. Poor quality– With today’s ability to buy almost anything on-line, people are now buying more and more directly from manufacturer, thereby saving moneyBut where are they buying these from? Mainly outside Europe.

    Now here lays problems such as build quality, rope quality, and chain quality, steel quality…and does it comply with European standards?

    If you or a company import any machinery from outside the EU, the importer must make sure that it is compliant to European standards and have it CE marked along with a Declaration of Conformity.

    All VLT’s should come with a “Declaration of conformity” make sure you get one from the installer….and read the manual, especially the parts about correct installation and set-up. Also make sure your site is suitable for the type of lift been installed.

    As for repairs, use a suitably qualified company, file the paper work after every repair or maintenance call, never allow your employees to carry out repairs or modifications- EVER. If you find a safety issue do not continue to work with the equipment, no one can be fired for highlighting a safety concern.

    All the VLTs functions should still work even 10 years after installation, if you maintain your equipment adequately.

    My own advice is, never have your maintenance company carry out your “Statutory Examinations” we found numerous defects in all 4 VLTS, the maintenance company found none, we highlighted this and a number of bad maintenance practices to the owner.

    Remember these Examinations are here to check that the equipment is safe to use and also that the maintenance is adequate too.


Maintenance V’s Inspection

This was actually found on a clients site during an inspection…..good maintenance??

Often business owners and Companies are unaware that they require both of these and best practice according to ISO/IEC 17020 is that they should be independent of each other.

(The requirement for the independence of inspection bodies may vary according to legislation and market needs. There may be a requirement to have inspections carried out by an Inspection Body having third party status i.e. that are independent relative to the seller/producer and purchaser.)

What actually is maintenance and what should it cover?
The best form of maintenance is preventive maintenance, routine down time for assessing critical components for wear, serviceability and safety.
During maintenance proper repairs and replacements can be carried out, tested and commissioned, there by reducing downtime due to faults and more importantly less chance of an accident.

Like all services, choose your maintenance people/company for their competency not ‘cheapest I could find’

What exactly is Inspection and what does it cover?
An inspection or its more official name in the H&S Regs “Statutory Examination” is a snapshot of the condition of the whole machine/item and its environment, be it a lift, crane, excavator or shackle, the inspection report should reflect what is seen and found at “the time of inspection” for all the world it is an nct/mot for your plant.

And the report can be very handy to guide you in your maintenance program….and if you are getting a clear report every-time, someone is not doing their job.

The Dangers                                                                                                                                                        When both maintenance and Inspections are carried out at the same time, you run the risk of rushed repairs and possibly not assessing a possible fault fully and may lead to more breakdowns and at the worst case potentially allowing a more dangerous condition to manifest itself.

Saving money is great, but at what cost. A life or a big insurance claim?…                                     I often find that some companies carry out the Thorough Inspections during a maintenance visit, great for the client, who is getting two jobs for the price of one and less down time…..but is it a good deal??
Well that depends on a lot of things, age of the item, how often does it get used, number of breakdowns….ask yourself this?
If the person/ company who sold me this item, installed it and maintains it…finds a problem with its installation, will they tell you? After all it’s them that will have to take the cost on to themselves…An independent company would because they have no ‘vested interests’ and are impartial.

Like all goods deals…look at it carefully, not only the price!….check out their competency for carrying out the inspection service.

Money spend on safety is never a bad investment.

What exactly do I do?

Engineer Surveyor

Its great when you meet someone who actually understands what I do, Many give me that look…you know it, we all do…I call it the “Airtricity Look”

Yes, I admit it, I am a sales man, I try to sell you my expertise….but more importantly I can possibly save your life, or prevent you from having a life changing accident…can “Airtricity” do that??

So, What do I do…I am the *Competent Person that carries out Examinations of Work Equipment

(Guide to the Safety, Health and Welfare at Work (General Application) Regulation 30: Inspection of work equipment-An employer shall ensure that— (a) where the safety of work equipment depends on the installation conditions— (i) an initial inspection is carried out after installation is completed and before it is first put into service, and (ii) an inspection is carried out after assembly at any new site or in any new location, and that the work equipment is installed correctly and is operating properly- 

and certain types of Plant,

Regulation 52: Examination and testing of lifting equipment 52. (1) An employer shall ensure that, without prejudice to Regulation 30, (a) fixed work equipment for lifting loads, including rail mounted work equipment for lifting loads, is not taken into use for the first time unless— (i) it has been tested and thoroughly examined by a *Competent person

Our health and Safety Regulations dictate that ‘ALL’ work equipment must be examined, when was the last time someone at work said to you “Leave that equipment off this morning, we are getting it examined for your safety”…Unfortunately not often enough.




Safety: Acts,Regulations and Orders


Thanks for taking the time to drop by, My blog is intended to reflect what I see and witness as I carry out my Job as an Engineer Surveyor In Ireland…What exactly is an Engineer Surveyor you ask?

Well, I carry out General and Statutory Examinations of equipment Under the “The Safety, Health and Welfare Act 2005 (No. 10 of 2005)”

Such equipment as, Passenger & Goods Lifts, Escalators, Forklifts, Mobile Cranes Excavators, Patients hoists and many more….in fact all working equipment should be routinely examined.

There are many Regulations and Orders under this Act, some are listed below,

Safety, Health and Welfare at Work (General Application) Amendment) Regulations 2016 (S.I. No. 36 of 2016)

Safety Health and Welfare at Work (Construction) Regulations 2013 (S.I. No. 291 of 2013)

Safety Health and Welfare at Work (General Application) (Amendment) Regulations 2012 (S.I. No.445 of 2012)

Safety, Health and Welfare at Work (General Application) Regulations 2007 (S.I. No. 299 of 2007)

When have you ever looked through one of these Acts or Regulations to see if you are compliant?

Most of you, Never I bet or only when something has gone wrong and by then its too late, and more than likely its going to cost you money…sometimes a lot of money.

Start now…you could save a life 🙂


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