FEATURE MACHINE BUILDING, FRAMEWORKS & SAFETY
MACHINERY RISK MANAGEMENT
In the UK, the Supply of Machinery (Safety) Regulations implement the EU’s Machinery Directive (2006/42/EC2), and contain detailed requirements for the manufacture of safe new machinery for
both the UK and European markets. Paul Taylor, business director for Industrial Services at TÜV SÜD, comments
A
ll machines supplied in the European Economic Area (EEA) from 1 January 1995 must comply with the Machinery Directive
(2006/42/EC) and be safe. The Essential Health and Safety Requirements (EHSR) lay down the minimum compliance criteria. While the use of standards is not mandatory, if a standard is applied correctly, conformance with the relevant EHSRs of a directive may be presumed. They therefore represent the surest way to compliance for machine builders. Machinery must be able to satisfy the EHSRs
for any corresponding hazard which may apply to it. The EHSR requirements are wide ranging, taking into account potential dangers to operators and other persons who may be at risk. A typical example of an EHSR is the requirement to provide adequate warning labels where there are moving parts that might trap parts of the body of personnel using the machine. Another would be the requirement to provide safety guards to machine tools. However, taking into account the state of art,
it may not be possible to meet all the objectives set by EHSRs, as technologies often move more quickly than the standards trying to catch up with them. With this in mind, the machinery must be designed and constructed with the purpose of approaching these objectives. The preferred way to comply with EHSRs is
by risk assessment and the application of harmonised EN standards. Risk assessment is therefore a vital step in ensuring compliance and a fundamental starting point for designers of machinery under the Machinery (Safety) Regulations. Some useful references include the
standard EN ISO 12100 ’Safety of Machinery – Risk Assessment’, which defines risk assessment as: “a series of logical steps to enable, in a systematic way, the analysis and evaluation of the risks associated with machinery”. EN ISO 12100 continues: “Risk assessment is
followed, whenever necessary, by risk reduction. Iteration of this process can be necessary to eliminate hazards as far as practicable and to adequately reduce risks by the implementation of protective measures”.
RISK ASSESSMENT
A risk assessment must therefore be carried out to examine any potential hazards associated with the machinery. This provides information for a risk evaluation, in which a decision is made on the safety of that machinery, so that risks can be reduced where necessary. EN ISO 12100 outlines the hazard analysis/risk
assessment procedure as follows: • Determination of the limits of the machinery • Hazard identification • Risk estimation and risk evaluation. EN ISO 12100 also provides guidance
on the safety of machinery and the type of documentation required in verifying a risk assessment. The first step in the risk assessment process is to identify anything that has the potential to cause harm. Secondly, an assessment must be made of the likelihood of a person encountering these hazards and how much damage it would cause. Examples of hazards that have the potential
to do harm include: • Crushing due to moving elements
10 DESIGN SOLUTIONS DECEMBER/JANUARY 2022
• Electrical shock or electrocution due to faulty parts which become live
• Permanent hearing loss due to prolonged exposure to noise caused by stamping of parts. A risk assessment would normally be
carried out for each hazard identified. Control measures can then be applied to mitigate the risk. Once these have been implemented, a re-assessment must then be actioned to ensure that they provide an adequate level of safety. The process is repeated until an adequate level of safety is achieved. The technical file for a machine will prove due
diligence and provide the evidence of compliance. However, it does not have to include detailed information such as the sub-assemblies of the machine, unless a knowledge of them is essential for verification and compliance with the EHSRs. The technical file must remain available for
inspection by a competent national authority, such as the Health & Safety Executive, for a period of ten years. One of the items that a technical file must contain is the risk assessment documentation demonstrating the procedure followed. This must include a list of the EHSRs which apply to the machinery, and a description of the protective measures implemented to eliminate identified hazards, or to reduce risks, and an indication of any residual risks. The technical file can be a traditional paper file, or stored electronically, with hyperlinks to documents, and it must be updated as the product is adapted and updated.
TÜV SÜD
www.tuvsud.com/uk
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