8/14/2019 The 2009 Machinery Directive: will you still comply?

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The Machinery Directive has been through severalincarnations since it was first implemented in the UK by theSupply of Machinery (Safety) Regulations 1992 and the

Supply of Machinery (Safety) (Amendment) Regulations 1994. In2001, improvements designed to simplify and clarify the existingDirective were published as proposals for a third amendment,

and the new Directive was published in 2006. This version willbecome enforceable on 29 December 2009, and unlike previous

amendments, there is no transitional period for compliance.There are radical changes to some parts of the Directive.

Affected parties will have to act quickly to address additions tothe Declaration and alterations to the essential health and safety

requirements (EHSRs), including where they affect controlsystems, if they are to hit the December compliance deadline.

To help organisations of all sizes work out how they will be

affected, there are useful definitions set out under the Directive.For example, a comprehensive definition of a machine describesan assembly of linked parts or components at least one of

which moves, with the appropriate actuator, control and powercircuits, joined together for a specific application, in particular forthe processing, treatment, moving or packaging of a material.

And a control system is one that responds to input signals fromthe machine, or from the operator, and generates output signals,which make the machine operate in a desired manner. So if, for

example, an operator presses a start button, the control systemmay respond by closing a contactor and energising a motor.

A further definition is that of a safety-related control system,which is described as one that contributes to reducing any riskto an acceptable level or if it is required to function correctly to

maintain or achieve safety.Incidentally, machinery moved by directly-applied manual effort

is excluded from the terms of the Directive. The term

machinery also covers an assembly of machines, which arecontrolled so that they function as an integral whole such as aproduction line.

> Expanded scope

It all seems fairly straightforward, but the Scope of the Directive

shows otherwise. The Scope includes terms such as safetycomponents, lifting accessories and chains, ropes and webbing.New inclusions further expand the scope to include devices for

construction site hoists, and for lifting people with reduced mobility.Obviously, the physical care and protection of employees and

customers should be the first consideration when business

owners install and operate machinery. But, as far as the businessimplications are concerned, the rules and regulations imposed bythe Directive are various and sometimes quite stringent.

All of the European directives are brought into UK law by theissue of Regulations, which means that if you dont comply youare committing a criminal offence punishable by fines and,

possibly, imprisonment.In fact, the European Commission has underlined the

importance of the new directive by instructing that penalties fornon-compliance should be effective and dissuasive. And in theUK that means a 20,000 fine and/or three months

imprisonment for a summary conviction, and a 20,000 fineand/or an even more dissuasive two years imprisonment forconviction on indictment.

Compliance clearly needs vigorous attention but, in short, itinvolves four key requirements:

demonstrating compliance with the essential health and safetyrequirements; carrying out the appropriate conformity assessment procedure; drawing up and issue the Declaration of Conformity or

Incorporation; and applying the CE Mark.

Bear in mind that the Directivedoesnt concentrate simply onone item at a time processes

and systems are also involved.If you are creating a complexassembly, such as a

production line, byinterlinking a series ofexisting machines, you are

effectively creating somethingnew so the whole assemblymust comply with the Directive.

Similarly, altering the function orperformance of a machine or complexassembly is also essentially creating a

new machine, which must comply. If,for example, you are at the start of a

project to build an assembly wherethe finish date is either towards theend of 2009 or in early 2010, you may need to start the project

now using the new Directive as you will not be able to produce afinal declaration under the current Directive after 29 December.

Similarly, if your products have been series manufactured,

having been CE Marked at the start of the series production, theDeclarations will no longer be valid, so whole product ranges willneed to be recertified in time for the changeover of Directives.

Alterations to the EHSRs are too numerous to detail here, butthey affect issues such as ergonomics, operating positions, seating,lighting, manual controls, starting machinery, stability of machinery,

protection devices, machinery instructions, plus machinery forfoodstuffs and for cosmetic and pharmaceutical products.

> The need to conform

There are also key changes to the Declaration of Conformity. Theperson who is authorised to compile the Technical File must be

established in the European Community. Where appropriate, theremust be a statement confirming Declaration of Conformity with

A new version of the Machinery Directive comes into force at the end of 2009.

Unlike previous versions, there will be no transitional period for compliance.Paul Laidler, managing director of Laidler Associates (right), warns that companiesneed to start planning now.

The revised Machinery

Directive incorporates some

radical changes that affect

shopfloor equipment.

MA

CHINE-BUILDING

The 2009 Machinery Directive:will you still comply?

8/14/2019 The 2009 Machinery Directive: will you still comply?

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CHINEBUILDING

other applicable directives. And there is no longer a separate

declaration for safety components, and the declaration must betypewritten or handwritten in capital letters

There are also significant additions and changes to the EHSRs

that will affect machine design, including requirements forguarding and control systems. Some of the safety devices thatfall under the scope of the Directive include, as already

mentioned, control devices for calling lifting appliances and anti-fall devices for hoists, plus monitoring devices for loading andmovement control in lifting machinery as well as solenoid

valves controlling dangerous movements of machinery.Control systems, says the Directive, must be designed and

constructed in a way that will prevent a hazardous situation

arising. Manual controls must be clearly visible and identifiable,and the use of pictograms is recommended. And an operatormust, from each control position, be able to ensure that no one

is in the danger zone even if that means that the machinerycan be controlled only from positions in one or morepredetermined zones or locations.

Starting is covered too. The Directive states that it must bepossible to start machinery only by the voluntary action of a

manual control provided for that purpose. The restarting of amachine or a change in operating conditions may however beeffected by the voluntary action of a device other than themanual control provided for that purpose, unless this would lead

to a dangerous situation.There are obviously many more issues contained within the

new Machinery Directive, and it is vital that business

organisations move in good time to make sure that they comply.But it is worth underlining here that in terms of control integrity,

there are other European Standards in force that are also

relevant.

EN 954-1 Safety of Machinery Safety Related Parts of ControlSystems, the standard that previously applied to all safety-relatedparts of control systems, will be replaced by two standards thatco-exist. The original standard will remain valid until 2010 toprovide a period of transition to the new version. People that

design and install electronic safety systems can choose betweenthe requirements of either EN ISO 13849-1 or EN/IEC 62061, andstill fully comply with the European Machinery Directive.

In general terms, EN ISO 13849-1 takes a four-stage approachto the design of safety-related control systems:1. Perform a risk assessment (EN ISO 14121).

2. For the identified risks, allocate the safety measure(Performance Level or PL).

3. Devise a system architecture that is suitable for the PL.

4. Validate the design to check that it meets the requirements ofthe initial risk assessment.The new Machinery Directive is a necessary move forward with

the increasing movement of businesses and their plant within theEuropean Community, and with the growing importance placed

on the health, safety and well-being of the people that workwith or near the machinery. But it still places a demandingrequirement on a vast range of businesses.

The decision that needs to be made in every quarter is

whether there is sufficient manpower, let alone expertise, in-house to carry out the necessary risk assessments and makechanges or whether it is necessary to outsource the task. Either

way, companies need to make sure that they are completely up-to-date, properly informed and ultimately compliant. D&C

University Certificate in

Professional Development:

Machinery SafetyAn award of the University of Teesside, delivered in

partnership with Laidler Associates

Dates for 2009Bolton - w/c March 23rd & September 28Solihull - w/c April 27th & October 26th

Newbury - w/c May 18th & November 23rd

W/c June 29th - Billingham

Part of the Laidler Associates Group

www.laidler.co.uk Email: enquire@laidler.co.uk

Tel: 08700 111375 Fax: 08700 111395