PLANT & MACHINERY SAFETY
DEVIL’S IN THE DETAIL
Neil Dyson, Business Line Manager for Machinery Safety at TÜV SÜD Product Service, unpicks the regulations around modifying machinery to keep workers safe during and after equipment upgrades.
Tight budgets mean that many end users of machinery upgrade existing equipment instead of investing in new systems. It is vital to realise that if substantial changes are made, a new conformity assessment may be required.
There are two key areas of guidance to help machinery end users identify if the modifications they have made will be considered substantial by the regulatory authorities. The first is from the Health & Safety Executive (HSE). It states that if changes “are very substantial (e.g. significant new hazards and risks are introduced or new methods of control of the machine replace those previously provided, it may amount to being considered a ‘new’ machine (or new assembly), for which you must undertake conformity assessment”.
HSE GUIDANCE To help identify what constitutes a ‘substantial change’, the HSE also outlines the different situations involving modifications to machinery where the requirements of the Machinery Directive are likely to apply and action must be taken:
• Machinery is modified so much that it should be considered ‘new’ machinery: an example is the fitting of a computer control to a manually operated machine as it substantially changes its original mode of operation.
• Machinery refurbishment with a different safety package: if a substantially different safety
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strategy is put in place, even if the original machine was not CE marked because it pre-dated the Machinery Directive.
• An existing assembly of machines is modified: if it impacts substantially on the operation or safety of the whole assembly of machines.
• Machinery modified before it is first put into service: for machinery that is sold to an importer or a distributor who then modifies the machinery before it is put into service for the first time.
GUIDE FOR INSPECTION A second reference guide is the CEOC International document ‘Modification of Machinery in Service – Guide for Inspection’. This is a relatively short document, which has explicit modification guidelines that gives machinery owners some incisive answers on the best approach to take.
As well as including an outline of the relevant legal aspects, the document gives clear guidance on what constitutes a ‘non substantial’ and a ‘substantial’ modification, helping the machinery owner to identify the correct path for them. It also outlines a useful procedure for the modification of machines that are both standalone and within an assembly.
It defines substantial modifications in the following situations:
• If the original machinery has been used as a source of parts in order to make something new or if the original machinery is not identifiable
(e.g. it is completely “stripped down” and only a few original parts remain)
• If the originally intended function has been changed in a way that new or other hazards are created which demand a new risk assessment (e.g. the modification of a lifting table for use as a vehicle servicing lift or a fork lift truck for use as a lift with defined levels)
• If machinery intended to work in normal atmosphere is transferred to dangerous environment (e.g. explosive atmosphere, underground) or into places with specific requirements (e.g. hospital)
• If the intended user group for the modified machinery changes, in particular in case of specific machinery for experts (e.g. in laboratories)
• If original machinery is assembled with other machinery to an integrated unit, functioning in this combination as one new whole machine (see Annex pt.2.2 Assembly - “complex combination”)
The CEOC International guidelines therefore leave no doubt as to what constitutes a ‘substantial’ change and the action that should be taken. If your machine is shown to have had a substantial change made, a full CE marking and Provision and Use of Work Equipment Regulations (PUWER) assessment must be completed before that machine can be returned to service.
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