230V control circuit

Chemenger said:

But the panel has 2 start/stop buttons for pump motors, an activation switch for a temperature controller, and an overtemperature interlock. Doesn't this preclude that exception? 

We don't know what the manufacturer classifies as control circuits. 

Because of the Supply of Machinery (Safety) Regulations and Section 6 of H&S@W etc. Act, I would be inclined to discuss any queries about conformity with the supplier and manufacturer in the first instance.

But ... it is the right thing to do: check if things are not clear. In this case, it is very important for safety during maintenance.

Thanks.

Sadly the the supplier is less than happy we're questioning their work. But yes, safety is priority.

Chemenger said:

Sadly the the supplier is less than happy we're questioning their work.

Understandable, but since this is a safety-related question according to Section 6(1) of the H&S@W etc. Act, I'm sure they would be more than happy to cooperate.

Well, if their documentation as to how it is to be used and which standards apply to make it safe to do so, is so unclear you have to ask for clarification, perhaps you could suggest if they really can't get that data to you, maybe because they have not created it, then they should should not be putting stuff on the UK market at all and would they prefer to give a refund and take it back plus consequential damages for your loss of time/ business.

Or maybe reserve that for when they really rub you up the wrong way..

While thinking of paper trails and so on,  I presume there is a UKCA or CE declaration about which standards they have applied and designed to meet in the documentation you received  for starters,  as that is required by law, though it may be pretty basic. - e.g.

"We declare his product is designed to meet all relevant clauses of  the low voltage directive and the basic EMC directive" and an illegible  signature from a technical director or similar. 
Delving deeper expect to find 

LVD met by following principles of EIC 60204 plus use of components tested to EN 61439 or other specific  product standards.

EMC met by tests to IEC 61000  part something or even a slightly dodgy sum of parts reasoning that all the bought in bits are already CE marked.

A box of switches and relays and little else does not need very much more. .
If no such statement is available at all, then perhaps there should be a distant alarm ringing.

So parts that remain live with the door open need to be shrouded or otherwise inaccessible, and all the active bits inside need to themselves either have been tested by the assembler, or more likely bought from suppliers who already have declared compliance, and there needs to be a clear ADS (think fuses and circuit breakers) approach and clarity about  if those protective measures are in the box or must be provided by the user.

Mike.

Well, if their documentation as to how it is to be used and which standards apply to make it safe to do so, is so unclear you have to ask for clarification, perhaps you could suggest if they really can't get that data to you, maybe because they have not created it, then they should should not be putting stuff on the UK market at all and would they prefer to give a refund and take it back plus consequential damages for your loss of time/ business.

Or maybe reserve that for when they really rub you up the wrong way..

While thinking of paper trails and so on,  I presume there is a UKCA or CE declaration about which standards they have applied and designed to meet in the documentation you received  for starters,  as that is required by law, though it may be pretty basic. - e.g.

"We declare his product is designed to meet all relevant clauses of  the low voltage directive and the basic EMC directive" and an illegible  signature from a technical director or similar. 
Delving deeper expect to find 

LVD met by following principles of EIC 60204 plus use of components tested to EN 61439 or other specific  product standards.

EMC met by tests to IEC 61000  part something or even a slightly dodgy sum of parts reasoning that all the bought in bits are already CE marked.

A box of switches and relays and little else does not need very much more. .
If no such statement is available at all, then perhaps there should be a distant alarm ringing.

So parts that remain live with the door open need to be shrouded or otherwise inaccessible, and all the active bits inside need to themselves either have been tested by the assembler, or more likely bought from suppliers who already have declared compliance, and there needs to be a clear ADS (think fuses and circuit breakers) approach and clarity about  if those protective measures are in the box or must be provided by the user.

Mike.

further, this Germanic interpretation on who can CE mark what, and when they should do so is particularly clear.
https://www.gt-engineering.it/en/insights/machinery-directive/datoredilavoro-marcatura-ce/

I'm less sure this happens in practice.
Mike.