Leaf chain and The Machinery Directive 2006/42We would make the following comments in the context of the leaf chain that is part of a  forklift truck or similar lifting equipment.  

A machine is defined in Article 2 of the Directive, and the obligations relating to the placing on the market and putting into service of machines can be found in Article 5. We are of the view that forklift chain does not constitute a machine and as such does not need to meet the requirements of Article 5, this includes the need to bear a CE mark.

The specific requirements within the Directive with regard to chains, rope and webbing that we consider would be applicable to forklift chain are:

 

Annex 1 4.1.2.4. Pulleys, drums, wheels, ropes and chains

Pulleys, drums and wheels must have a diameter commensurate with the size of the ropes or chains with which they can be fitted

Drums and wheels must be designed, constructed and installed in such a way that the ropes or chains with which they are equipped can be wound without coming off.

Complete ropes and their endings must have a working coefficient chosen in such a way as to guarantee an adequate level of safety. As a general rule, this coefficient is equal to 5.

Lifting chains must have a working coefficient chosen in such a way as to guarantee an adequate level of safety. As a general rule, this coefficient is equal to 4.

In order to verify that an adequate working coefficient has been attained, the manufacturer or his authorised representative must, for each type of chain and rope used directly for lifting the load and for the rope ends, perform the appropriate tests or have such tests performed.

 

Annex 1 4.3.1 – Information and marking. Chains, Ropes and Webbing

Each length of lifting chain, rope or webbing not forming part of an assembly must bear a mark or, where this is not possible, a plate or irremovable ring bearing the name and address of the manufacturer or his authorised representative and the identifying reference of the relevant certificate.

 The certificate mentioned above must show at least the following information:

(a) the name and address of the manufacturer and, if appropriate, his authorised representative;

(b) a description of the chain or rope which includes:

- its nominal size,

- its construction,

- the material from which it is made, and

- any special metallurgical treatment applied to the material;

(c) the test method used; (d) the maximum load to which the chain or rope should be subjected in service. A range of values may be give on the basis of intended applications

 

In conclusion we believe that leaf chain used on forklift type lifting equipment, must meet the requirements above but is not covered by Article 5 of the Directive and would not need to directly bear a CE mark.