Changes in the air for machine safety
Paul Laidler of Laidler Associates, a safety and compliance consultant, looks at the implications of changes to the EU Machinery Directive for electrical engineers.
The new machinery directive, which is officially designated 2006/42/EC, introduces radical changes. When it comes into force on 29th everyone involved with the supply and use of machinery will have to be able to demonstrate compliance immediately. Non-compliance is not an option – like all EU Directives, the new machinery directive is brought into UK law by regulations that make failure to comply a criminal offence punishable by fines and/or imprisonment.
Interestingly, one of the stipulations is that member states should provide penalties that are ‘effective and dissuasive’. In the UK, the Statutory Instruments states that this means: ‘(a) on summary conviction, a fine not exceeding the statutory maximum or to imprisonment for a term not exceeding 3 months, or to both and… (b) on conviction on indictment, to a fine or imprisonment for a term not exceeding 2 years or to both’.
With these penalties in mind, it is probably a good idea to look a little more closely at the new directive. The first thing to consider is its scope. There have been a number of important changes, and the scope now includes terms such lifting accessories and chains, ropes and webbing and an indicative list of safety components. New inclusions further expand the scope to include devices such as construction site hoists and for lifting people with reduced mobility.
From the point of view of electrical and design engineers, however, the most significant change is that the new directive no longer concentrates on just one item of equipment at a time. If a complex assembly, such as a production line, is created by interlinking a series of existing machines, the whole assembly is considered as a new machine that must itself comply with the requirements of the directive. This applies irrespective of the age of the machines that have been brought together.
Similarly, if modifications are carried out that alter the performance or function of machine or complex assembly, this is considered as creating a new machine, which must comply with the directive. An important implication is that that work on current projects should have been carried out in line with the requirements of the new directive if the project will be completed after 28th December, as it will not be possible to issue a final declaration under the old directive after this date.
The new directive embodies many changes to the Essential Health and Safety Requirements (ESHRs) for machinery. There are so many of these that it is impossible to look at more than a few examples here.
The new ESHRs deal in some detail with operator controls. Section 1.2.1, for example, requires that manual controls are designed so as to prevent hazardous conditions arising. This is, of course, reasonable and logical but it may not be as easy to achieve as it sounds, as this section goes on to stipulate, among other things, that faults in the hardware or software and errors in the control logic must not lead to hazardous situations.
Section 1.2.2 also deals with manual controls. It states that they must be clearly visible and identifiable and that the use of pictograms is recommended. Some machine suppliers may well take this as a cue for moving to the use of electronic HMI (human machine interface) devices, where high visibility is easy to achieve and virtually any type of pictogram, or combination of pictograms and words, can be implemented.
The positioning of control stations is also covered. They must be sited so that the operator can ensure that there are no persons in the danger zone and, where appropriate, measures must be taken to ensure that the machine can only be controlled from predetermined locations. This could possibly limit the use of control stations suspended from articulated mounts.
Machines are permitted to have multiple control stations at predetermined locations, but these must be arranged so that the machine is only controlled from one of them at a time, other than for stop and emergency stop functions. Also each control station must be provided with a full set of control devices, which is possibly another argument in favour of using electronic HMI devices rather than conventional pushbuttons, switches and indicator lights.
The new directive also gives special attention to the instructions supplied with the machine. All machines must be supplied with instructions in the community language or languages of the member states in which they are sold, and the instructions are required to be very detailed.
Section 1.7.4.2, which gives details of the essential contents, runs to no fewer than 22 sub sections, including such items as drawings, diagrams, descriptions and explanations necessary for the use, maintenance and repair of the machinery and for checking its correct functioning.
Preparing satisfactory documentation is going to be a big task, and it may well be challenging when existing machines are incorporated into a new production line for which overall compliance must be declared.
There are, of course, very many other provisions in the new Machinery Directive, and it is essential for anyone with a professional interest to study the whole document, if they have not already done so. It can be downloaded free of charge by following the links on the Health and Safety Executive website www.hse.gov.uk
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