Change To Machinery Directive 2009
- 1. New Machinery Directive 2006/42/ECDerek Coulson
- 2. Laidler Associates is a UK machinery safety consulting company. We are based in the North East of England, but work around the world assisting companies with the CE marking of machinery under different Directives including Machinery, Low Voltage and Electro Magnetic Compatibility . Laidler Certification is a United Kingdom Notified Body for the Machinery Directive and EMC Directive.
- 3. Most machinery is ‘self certification’, not requiring any assistance with the CE marking process. Certain equipment such as Power Presses, Injection Moulding Machines etc. comes under Annex IV of the Machinery Directive and requires a Notified Body to be involved.
- 4. Changes to the New Directive Machinery Directive 2006/42/ECThe Directive applies in full from 29th December 2009 There is not time to go through every change in detail, this is intended as an overview. The text of the latest Directive is available as a download from http://ec.europa.eu/enterprise/mechan_equipment/machinery/revdir.htm
- 5. The Machinery Directive is made up of Essential Health and Safety Requirements. These are similar to ones in the existing Directive that has been in force since 1993.It is the Manufacturers Responsibility to ensure that they meet these requirements before applying the CE marking.Laidler Associates experience is that few manufacturers do this, and that many new machines fall far short of compliance.
- 6. In the event of an accident following non compliance, the most likely prosecution is to the end user under the Provision and Use of Work Equipment Regulations 1998, Regulation 10.Every employer shall ensure that an item of work equipment has been designed and constructed in compliance with any essential requirements, that is to say requirements relating to its design or construction in any of the instruments listed in Schedule 1 (being instruments which give effect to Community directives concerning the safety of products).
- 7. Common problems occur where complex assemblies are created by linking machines from a number of suppliers without anyone addressing the CE marking of the complex assembly;Also where manufacturers supply equipment with ‘options’ for specific markets; an example is an ‘interlock override switch’ that literally just overrides the interlock without any additional safety device such as hold to run, reduced speed or power etc.
- 8. Changes to Definitions There are a number of new definitions in the Directive, defining risk, guard, protective device, intended use and reasonably foreseeable misuse. As an example ,“operator” means the person or persons installing, operating, adjusting, maintaining, cleaning, repairing or moving machinery;
- 9. Changes to EHSR’sThere are updated Ergonomic requirements, which specify there must be sufficient space for operators, these also bring in the requirement not to allow the machine to set the work rate, but to allow the operator to set the work rate.Some of the requirements relating to mobile equipment have been moved to the basic principles section, i.e. need for cabs, safe exits, seating etc.
- 10. Changes to EHSR’sControl Systems must be designed so that ‘reasonably foreseen human error’ must not lead to a dangerous situation.Stability has to be considered through the whole life of the machine, including assembly and dismantling.Fixings should remain attached to guards when the guard is removed ** This is already a requirement of the guarding standard BS EN 953; 1997
- 11. Changes to EHSR’sExplosion hazards must be assessed to determine if DSEAR or ATEX applies. ATEX often requires Notified Body input.
- 12. Where people have to move around on machinery, safe means of access must be provided, and as a minimum, additional handholds must be provided . Maintenance access is often forgotten.
- 13. The requirement to take into account lightning strikes has been introduced.Changes to EHSR’sWarnings should be pictograms where possible, if in a language, it has to be any one of the official community languages, not necessarily the language of the country the machine is in.The CE marking must be affixed in the immediate vicinity of the name of the manufacturer or his authorised representative, using the same technique. (Annex III)
- 14. Changes to EHSR’sThe Instructions must be in one or more of the official Community Languages, the words ‘Original instructions’ must appear. Where no original instructions are available, a translation must be supplied, marked with the words ‘translation of original instructions’.The authorised representative should be identified on the manufacturers plate
- 15. Changes to EHSR’sThe Declaration of Conformity must contain the name and address of the person authorised to compile the technical file, and must form part of the Instructions** “authorised representative” means any natural and legal person in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this directive.
- 16. Changes to the Machinery DirectiveAnnex V has additional Safety Components defined.
- 17. There is a definition of ‘partly completed machinery’
- 18. Partly completed machinery must be supplied with a Declaration showing which EHSR’s have been fulfilled.ConclusionThe above is for the first section of the Essential Health and Safety requirements, which apply to all machinery. The other sections have changes too. These are Food Machinery, Hand Guided Machinery, Woodworking Machinery, Mobile Machinery, Lifting Machinery, Underground Work Equipment and Machinery for Lifting of Persons.
- 19. When buying new machinery remember= CHECK EVERYTHING
- 20. If there are any further queries, please do not hesitate to contact myself or any of my colleagues on +44 (0) 333 123 777, or enquire@laidler.euEND