FAQs

General purpose wire rope, with one of those purposes intended for lifting, is within the scope of the Supply of Machinery (Safety) Regulations 2008 (SOMR) and Machinery Directive 2006/42/EC. Therefore the bulk supply or reel should be issued with the appropriate Declaration of Conformity documents and marking and a manufacturer’s certificate, as defined in the EN 12385 series of standards. Instructions for use are also required and will simply contain information as to the intended use, the limits of use and instructions for handling, cutting, storing, assembly, use and maintenance.

The distributor or user does not become a manufacturer in the sense of the supply legislation by cutting individual lengths for incorporation into lifting machinery or lifting accessories. Therefore the obligations set out above do not apply again to lengths of wire cut from products already placed on the market by the wire rope manufacturer. Such lengths are to be considered as components of the lifting machinery or the lifting accessories into which they are incorporated.

However distributors of wire ropes must ensure that the relevant declaration of conformity, the reference of the certificate setting out the characteristics of the wire rope and the manufacturer’s instructions, are supplied with the cut length of wire rope to the manufacturers of lifting machinery or lifting accessories or to users.

The above is also true of cut lengths of other lifting media, such as chain or webbing.

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Based on standards and legisaltion, LEEA requires the competent person to be sufficiently independent and impartial to allow objective decisions to be made. With this in mind the question should really be, ‘can you check your own work?’ It is LEEA’s view that the answer to this question would depend on the complexity of the thorough examination.

For example the thorough examination of a mechanically assembled chain sling following a repair is not a complicated task for a competent person to ascertain whether or not it has been assembled correctly. Whereas a thorough examination of a hoist following an overhaul of the lifting and braking mechanism is.

Therefore the duty holder or the employer of persons doing the thorough examination should assess the risks in terms of complexity of the maintenance and subsequent thorough examination. The risk assessment should consider whether or not the examiner could be considered as being impartial bearing in mind that the examiner is likely to assume that they have done a great job and as a result perhaps not be as thorough as they ought to be. Sometimes a second pair of eyes will be better placed to act impartial and see defects associated with the maintenance.

Note, human error is the root cause of a significant proportion of incidents.

It is also important to note the BS 7121-2 series of standards state, ‘it is essential that the person that does the thorough examination is not the same person that did the maintenance. Therefore with cranes in the UK it would perhaps be advisable to follow the guidance given in the standard’

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The answer to this is that they are all correct and the choice of which to use is really dependant on the use of the equipment, as the following information will explain.

The working load limit, or maximum working load as defined in the Supply legislation, is the load value assigned to the ‘maximum’ safe working load under ideal conditions and in most cases the working load limit and the safe working load will be the same. However, depending upon the conditions of use, it may be necessary for the competent person to reduce this to a lower safe working value and it is in these cases that the working load limit and safe working load will differ.

The rated capacity is the same as working load limit and is a term used for some cranes where the rating varies with configuration.

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Use legislation uses the term ‘lifting equipment’ to describe work equipment for lifting or lowering loads and includes its attachments used for anchoring, fixing or supporting it. However this is not true with regards to the supply legislation and associated harmonised standards.

To this end the specific documentation would depend on the type of lifting equipment being supplied. Therefore to answer this question for generic forms of lifting equipment, LEEA has produced best practice guidance which specifies the specific documentation required.

The guidance documents can be downloaded for free from the LEEA Library - https://leeaint.com/documents 

Note that regulation 10 of PUWER requires every employer to ensure that an item of work equipment conforms at all times with any essential requirements. The only evidence the employer can have to fulfil this requirement is to obtain and accept the correct documentation.

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LEEA has many members with a wide range of products and services on offer.

You can search our members by location here - https://leeaint.com/find-a-member-near-me 

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Supply legislation does not require a manufacturer of lifting equipment to give it a unique identification. It simply requires them to mark one on the product if they have specified one.

Use legislation on the other hand requires the duty holder to have lifting equipment Inspected and/or thoroughly examined and issued with a report inpsection or thorough examination. This report must identify the equipment without ambiguity so that defects can be remedied efficiently.

In the case where a duty holder has many items of a similar generic form of lifting equipment it is considered best practice to give each piece its own unique identification number, which is then recorded on each thorough examination report, thus ensuring the report is traceable to the equipment without ambiguity.

However, it is important to note that there are other methods of ensuring that the equipment on a report can be identified correctly, such as location for single items, or colour coding for multiple items grouped in a specific area.

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In general, there are two types of master links/master assemblies on the European market

1. Master links/Master assemblies placed on the market for use as a component of a sling assembly. These may or may not be conformity marked, but they should be compliant with EN1677-4 or other relevant standards.
2. Master links/Master assemblies placed on the market for USE as an individual lifting accessory. These are to be conformity marked. They should be marked with the requirements of the legislation and will show the WLL, grade of material and traceable serial number. A Declaration of Conformity and Instructions for use must also be supplied. These instructions would not necessarily prohibit the use of these master links as components of a sling assembly, but it is the responsibility of the Distributor/Assembler to give the correct information with the completed product to ensure that is not overloaded.

Understanding the supply chain is critical as the roles and responsibilities of each participant change:

• The Manufacturer is the company making and supplying the components or accessory to the market for the first time. They take the responsibility of ensuring that the products are fit for purpose and comply with the standards and legislation and issue the appropriate certification.
• The Assembler of a completed lifting accessory (machine) takes on the responsibility of a manufacturer and is responsible for placing the completed product on to the market for the first time, and as such, by ensuring that the equipment is compliant with current legislation. They are also to issue the correct documentation and safe use instructions with the product.
• A Distributor may also be an importer of accessories/components to an assembler of slings. They may place complete assemblies or components to the market. In the case of supplying individual master links to a customer, where possible, the distributer should enquire how the link is to be used to assess what is required for marking and user instructions and documentation.

Note: The Assembler may also be a Distributer and vice versa.

• The Duty holder/End User has the responsibility of fully assessing and using the item according to the to the manufacturer’s instruction for use.

LEEA’s advice on master links is:

• Manufacturers of master links can choose to conformity mark the links, or not, dependent on the intended use. In either case the instructions are to be clear as to their specific use i.e. as a complete lifting accessory, as a component, or both, as certification and marking is different in each case.
• Master links should be marked with a traceability code as per EN 1677-1 or other relevant standard.
• If assembling a sling, the assembler can use master links that are either conformity marked or not. The assembler of the sling should affix a metal tag to the master link/assembly, which must, as a minimum show the conformity mark, the individual serial number of the assembly and the WLL of assembly at 0° degrees, or in the case of a multi leg sling, at 0-45° and 45° to 60° degrees. In the case of chain slings, the diameter of the chain being used should also be shown.
• The Duty holder/End User must have a fully documented risk assessment and lifting plan. They also have the responsibility of ensuring not only that the equipment is well maintained, inspected before use and complies with current legislation, but also that the person(s) using the equipment are suitably trained to do so.
• If using master links in their own right as a completed lifting accessory, the user should select master links that have been conformity marked as the foreseeable risks associated with the expected use have been addressed by the manufacturer. The limitations of use would be specified in the instructions for use which should be followed by the user.
• If using CE marked master links that have a WLL marked on them, the WLL of the assembly must be made clear by affixing a metal tag or other approved marking method as per the applicable standard for the type of sling (Chain, SWR, Textile). The WLL marked on the master link must never be less than the WLL of the final assembly and this information must be supported in the instructions for Use.
• If using non- CE marked master links as a lifting accessory, the duty holder/user is to be aware that they would take on the responsibility and risk of the manufacturer for use in this manner.
• Equipment should be examined for each lift according to the lift plan.
• Master links in storage are treated as components
• As with all lifting equipment, master links that are conformity marked and/or used as an accessory should be subject to a thorough examination at least 6/12monthly depending on location. If in any doubt it is advisable to contact a competent person for advice and clarification.

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