Feature Machine Safety
hen the latest version of the Machinery Directive was pub- lished in 2006, a number of changes were made to both the procedural and documentation requirements. However, more than six years on, these ‘updated’ legal responsi- bilities are still regularly overlooked. Before any item of machinery can be legally placed on the market in the EU, it must bear the CE marking. This cannot be applied unless the machine has been proven to meet the require- ments of the Machinery Directive and any other applicable directives. An essential element in demonstrating that these requirements have been met is the production of a technical file which must conform to the provisions set out in the Machinery Directive. However, it would appear that many machinery manufacturers are still not aware of the changes, particularly those which affect the contents of the technical file.
Annex VII of the Machinery Directive states, in paragraph 1(a), that the technical file must now include ‘documentation on risk assessment demonstrating the procedure fol- lowed, including:
i. a list of the essential health and safety requirements (EHSRs) which apply to the machinery.
ii. the description of the protective measures implemented to eliminate identified hazards or to reduce risks and, when appropriate, the indication of the residual risks associated with the machinery.
In addition, EHSR 1.1.2 states ‘machinery must be designed and con- structed so that it is fitted for its function, taking into account foreseeable misuse’ and ‘the aim of measures taken must be to eliminate any risk throughout the fore- seeable lifetime of the machinery’.
In summary
The process of meeting the requirements of the Machinery Directive, and hence being able to apply CE marking, now places greater emphasis on performing and documenting risk assessments, as these are the only way to prove that the correct procedures have been followed. As it is easier to design safety in than to engineer hazards out, this process must start at the product design phase. Risk assessments are not only required by the Machinery Directive, they are also an essential ingredient
Automation APRIL 2013
Getting everything in order W
Above: Paul Laidler, business director for Machinery Safety at TÜV SÜD Product Service
As Paul Laidler of TÜV SÜD Product Service explains, some machinery manufacturers still overlook the legal responsibilities of the Machinery Directive
in meeting the Provision and Use of Work Equipment Regulations (PUWER). So, while carrying out one risk assessment is not a particularly onerous task, carrying out dozens, possibly involving more than one department or division of a company, presents rather more of a challenge. One of the challenges is to introduce a company wide standardised approach to risk assessment. Another is ensuring that nothing is missed when carrying out the risk assessments. Finally, ways must also be found to present the docu- mentation in a convenient format, archive it securely so that it cannot be lost or damaged, and ensure that it can be retrieved easily as needed.
Above and below: for machinery manufacturers, compiling the technical files needed for CE marking and the documentation required by the Provision and Use of Work Equipment Regulations
(PUWER) appears to be a
straightforward task
The risk assessment solution There are software solutions that have been specifically designed for machin- ery compliance risk management. Whatever software is chosen, it is essen- tial that it reflects current legislation. It should also allow users to decide whether they work to ISO EN 13849-1 or EN 62061 for safety related parts of the control system. As a minimum, the software should also cover the require- ments of CE marking and PUWER 98. The best packages will guide users through the steps necessary for compli- ance using a simple Q&A approach that ensures everything is properly com- pleted and nothing is missed. It will then generate detailed reports in a uniform format, making it easy to document fully the risk assessment processes and, in the case of CE marking, to produce the essential technical files. If non-compliances are found, the software will create a ‘to do’ list that ranks items in order of risk. It will also make provi- sion for storing reports electronically, so that back-up copies can be made. If your machinery supplier has made the right choice of software, the techni- cal files relating to their equipment should be accurate. With the PUWER regulations and the UK’s Health & Safety Executive requiring machinery pur- chasers to check that a machine is safe before it is used, it is important to take this into account when choosing a soft- ware supplier, one that can demonstrate that it has the experience and expertise needed to provide this vital back-up.
TÜV SÜD Product Service
www.tuv-sud.co.uk T: 01489 558 100
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