Getting to Grips with the Machinery Directive

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  • 8/14/2019 Getting to Grips with the Machinery Directive

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    MACHINE BUILDING & AUTOMATION

    INDUSTRIALTECHNOLOGY February 20

    When the reworked Machinery Directive

    comes into force in December, will your

    business still be compliant, asks Paul

    Laidler, MD of Laidler Associates

    T

    he Machinery Directive has

    been around for a long time.

    It was originally implemented

    in the UK by the Supply of

    Machinery (Safety) Regulations 1992

    and the Supply of Machinery (Safety)

    (Amendment) Regulations 1994.

    Seven years later, proposals for a

    Third Amendment to the Machinery

    Directive improvements designed to

    simplify and clarify the existing one

    were published, and in June 2006 the

    new Directive was published.

    The date on which we should all

    be focused, however, is 29 December

    2009, as this is when the Directive

    becomes enforceable. And unlike

    previous amendments, there is no

    transitional period for compliance.

    This new Directive has some radicalchanges of which machine builders

    and users may not yet be aware,

    issues that will need to be addressed

    quickly if the December compliance

    deadline is to be hit.

    To assess how your particular

    business is to be affected, its useful to

    look more closely at what constitutes

    a machine under the directive. A

    rather dry but comprehensive

    definition such as an assembly o

    linked parts or components at leas

    one of which moves, with the

    appropriate actuator, control and

    power circuits, joined together for

    specific application, in particular fo

    the processing, treatment, moving o

    packaging of a material, covers mos

    applications. Incidentally, machiner

    moved by directly applied manua

    effort is excluded. The term machinery

    also covers an assembly of machines

    which are controlled so that they

    function as an integral whole, such a

    a production line.

    Expanded scopeThis would appear to be fairl

    straightforward, but reading the Scope

    of the Directive soon changes youopinion. The Scope includes term

    such as safety components, lifting

    accessories and chains, ropes and

    webbing. New inclusions furthe

    expand the scope to include device

    for the lifting of persons with reduced

    mobility and construction site hoist

    amongst others. It goes without saying

    that the physical care and protectio

    of employees and customers should

    Getting to grips

    with the Machinery

    Directives third

    amendment

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    Machinery Safety

    February 2009 INDUSTRIALTECHNOLOGY

    be the first consideration when

    business owners install and operate

    machinery. So its forgivable here to

    concentrate on the business

    implications of the various and

    sometimes quite stringent demands of

    the rules and regulations imposed by

    the Directive.

    So when you ask the question:

    Why do we have to comply? its best

    to take as a given the answer:

    Because if we dont, our employees

    may be horribly injured. Instead,

    think of the business answer, which is:

    Because all of the European directives

    are brought into UK law by the issue of

    Regulations, which means that if you

    dont comply you are committing a

    criminal offence punishable by fines

    and possibly imprisonment.

    Demonstrating complianceBetter, then, to ask: How do we

    comply? The quick answer is:

    G Demonstrate compliance with the

    essential health and safety

    requirements

    G Carry out the appropriate

    conformity assessment procedure

    G Draw up and issue the Declaration

    of Conformity or Incorporation.

    G Apply the CE Mark.

    If you are creating a complex

    assembly, such as a production line,

    by interlinking a series of existing

    machines, you are in effect creating

    something new so the whole

    assembly must comply with the

    Directive. Similarly, altering the

    function or performance of a machine

    or complex assembly is also essentially

    creating a new machine, which must

    comply.

    The new Directive comes into play

    for this scenario if you are at the start

    of a project building an assembly,

    where the finish date is either towards

    the end of the year or into the New

    Year. If this is the case, you may need

    to start the project now using the new

    Directive as you will not be able to

    produce a final declaration under the

    current Directive after December 29th.

    A second scenario that will affect

    the validity of your companys

    compliance is where products have

    been series manufactured, having

    been CE Marked at the start of the

    series production. The Declarations

    will no longer be valid so whole

    product ranges will need to be

    recertified in time for the

    changeover of Directives.

    MORE INFORMATION:

    Enter M425 or visit latest issue stories at

    www.industrialtechnology.co.uk for further

    details from Laidler Associates

    As with all new legislation, this latest

    amendment to the Machinery Directive places

    a necessary yet still burdensome requirement

    on businesses of all sizes and in all sorts of

    sectors. At Industrial Technology we are

    always keen to hear our readers views, so do

    let us know what you think of the latest

    changes to the Machinery Directive.

    Is it a welcome move, in that anything

    that improves health and safety can only be a

    good thing if it protects employees AND

    enhances your companys reputation? Or is it

    simply more red tape? Do you have the

    expertise in-house to carry out the necessary

    risk assessments and make the changes you

    need, or would you prefer to outsource thetask of making sure that youre completely up

    to date, properly informed and ultimately

    compliant?

    We will be covering Machinery Directive

    in later issues too, so let us have your

    questions and views. Contact us by email via

    [email protected].

    Answers to

    your questions

    More details: Write in 430 on the free information card

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