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MACHINE BUILDING & AUTOMATION
Getting to grips with the Machinery Directive’s third amendment When the reworked Machinery Directive comes into force in December, will your business still be compliant, asks Paul Laidler, MD of Laidler Associates
Vision Technology Exhibition
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he Machinery Directive has been around for a long time. It was originally implemented in the UK by the Supply of Machinery (Safety) Regulations 1992 and the Supply of Machinery (Safety) (Amendment) Regulations 1994. Seven years later, proposals for a Third Amendment to the Machinery Directive – improvements designed to simplify and clarify the existing one – were published, and in June 2006 the new Directive was published. The date on which we should all be focused, however, is 29 December 2009, as this is when the Directive becomes enforceable. And unlike previous amendments, there is no transitional period for compliance. This new Directive has some radical changes of which machine builders and users may not yet be aware, issues that will need to be addressed quickly if the December compliance deadline is to be hit. To assess how your particular business is to be affected, it’s useful to look more closely at what constitutes a machine under the directive. A rather dry but comprehensive
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definition such as “an assembly of linked parts or components at least one of which moves, with the appropriate actuator, control and power circuits, joined together for a specific application, in particular for the processing, treatment, moving or packaging of a material,” covers most applications. Incidentally, machinery moved by directly applied manual effort is excluded. The term machinery also covers an assembly of machines, which are controlled so that they function as an integral whole, such as a production line.
Expanded scope This would appear to be fairly straightforward, but reading the Scope of the Directive soon changes your opinion. The Scope includes terms such as safety components, lifting accessories and chains, ropes and webbing. New inclusions further expand the scope to include devices for the lifting of persons with reduced mobility and construction site hoists amongst others. It goes without saying that the physical care and protection of employees and customers should
Cameras and components Image processing systems Associated identification and inspection technology Photonics and optical technologies
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INDUSTRIAL TECHNOLOGY • February 2009
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Machinery Safety
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...save time! be the first consideration when business owners install and operate machinery. So it’s forgivable here to concentrate on the business implications of the various and sometimes quite stringent demands of the rules and regulations imposed by the Directive. So when you ask the question: “Why do we have to comply?” it’s best to take as a given the answer: “Because if we don’t, our employees may be horribly injured.” Instead, think of the business answer, which is: “Because all of the European directives are brought into UK law by the issue of Regulations, which means that if you don’t comply you are committing a criminal offence punishable by fines and possibly imprisonment.”
Demonstrating compliance Better, then, to ask: “How do we comply?” The quick answer is: G Demonstrate compliance with the essential health and safety requirements G Carry out the appropriate conformity assessment procedure G Draw up and issue the Declaration of Conformity or Incorporation. G Apply the CE Mark. If you are creating a complex assembly, such as a production line, by interlinking a series of existing machines, you are in effect creating something new – so the whole assembly must comply with the Directive. Similarly, altering the function or performance of a machine or complex assembly is also essentially creating a new machine, which must comply. The new Directive comes into play for this scenario if you are at the start of a project building an assembly, where the finish date is either towards the end of the year or into the New
Answers to your questions As with all new legislation, this latest amendment to the Machinery Directive places a necessary yet still burdensome requirement on businesses of all sizes and in all sorts of sectors. At Industrial Technology we are always keen to hear our readers’ views, so do let us know what you think of the latest changes to the Machinery Directive. Is it a welcome move, in that anything that improves health and safety can only be a good thing if it protects employees AND enhances your company’s reputation? Or is it simply more red tape? Do you have the expertise in-house to carry out the necessary risk assessments and make the changes you need, or would you prefer to outsource the task of making sure that you’re completely up to date, properly informed and ultimately compliant? We will be covering Machinery Directive in later issues too, so let us have your questions and views. Contact us by email via
[email protected]. Year. If this is the case, you may need to start the project now using the new Directive as you will not be able to produce a final declaration under the current Directive after December 29th. A second scenario that will affect the validity of your company’s compliance is where products have been series manufactured, having been CE Marked at the start of the series production. The Declarations will no longer be valid so whole product ranges will need to be recertified in time for the changeover of Directives. MORE INFORMATION:
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Enter M425 or visit ‘latest issue stories’ at www.industrialtechnology.co.uk for further details from Laidler Associates
February 2009 • INDUSTRIAL TECHNOLOGY
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