Since the machinery directive 2006/42/EC has been in force, there has been a lot of discussions about this issue. The machinery directive’s ADCO group has now published a new document about “Safety fences (safeguarding) as safety components according to the machinery directive 2006/42/EC.”
What is the ADCO group?
“The work of the Machinery Working Group is complemented by the activities of the Machinery Administrative Cooperation Group (Machinery ADCO Group). This is a forum for exchange of information between the market surveillance authorities of the Member States and the Commission. The Machinery ADCO Group usually meets twice a year and is chaired in turn by representatives of the Member States. The meetings are restricted to the representatives of the Member States and the Commission.”
In the document, there are three scenarios for placing safety fences on the market, which is clarified in the document.
Please read this quote from the document. This statement places the responsibility to whom it belong.
“It is emphasised that the question under which conditions safety fences (safeguarding) can be regarded as independently placed on the market does not change the fundamental principle of the Machinery Directive that all machinery must be supplied with all protective devices when first placed on the market. Furthermore, it is always the machinery manufacturer’s responsible for placing on the market only machinery in conformity which the relevant requirements of the Machinery Directive 2006/42/EC and to provide the EC Declaration of Conformity and to affix the CE-marking on the machine.”
This new document clarifies that a supplier of safety fence modular system should not CE mark the system. It’s not possible only to CE mark a post or a panel.
This document describes three scenarios.
All three scenarios deals with the possibility to CE mark and when you can’t CE mark Safety fences (safeguarding). More than 90% of the manufacturers of safety fences (safeguarding) can’t CE mark their systems or safeguarding in accordance to this document.
A lot of south European companies have used the CE marking as stickers on their safety fences (safeguarding). Because they used it as quality mark. On some companies’ websites, one of the first things you see are a lot PDF documents about standards and the machinery directive and not what they are selling.
I will under the next week write about the three scenarios one by one.
As promised yesterday a list of Australian Standards for safeguarding.
Safeguarding of machinery. Part 1: General principles
AS 4024.1101-2006 Terminology – General
AS 4024.1201-2014 Basic terminology and methodology
AS 4024.1202-2006 Technical principles
AS 4024.1301-2006 Principles of risk assessment
AS 4024.1302-2014 Reduction of risks to health and safety from
hazardous substances emitted by machinery
AS 4024.1401-2014 Design principles – Terminology and general principles
AS 4024.1501-2006 (R2014) Design of safety related parts of control systems – General principles
AS 4024.1502-2014 (R2014)Design of safety related parts of control systems – Validation
AS 4024.1601-2014 General requirements for the design and construction of fixed and movable guards
AS 4024.1602-2014 Principles for the design and selection of interlocks
AS 4024.1603-2006 (R2014) Prevention of unexpected start-up
AS 4024.1604-2014Emergency stop – Principles for design
AS 4024.1701-2014 Basic human body measurements for technological design
AS 4024.1702-2014 Principles for determining the dimensions required for openings for whole body access to machinery
AS 4024.1703-2014 Principles for determining the dimensions required for access openings
AS 4024.1704-2014 Anthropometric data
AS 4024.1801-2014 Safety distances – Upper limbs
AS 4024.1802-2014 Safety distances – Lower limbs
AS 4024.1803-2014 Minimum gaps to prevent crushing of parts of the human body
AS 4024.1901-2014 General principles for human interaction with displays and control actuators
AS 4024.1902-2014 Displays
AS 4024.1903-2014 Control actuators
AS 4024.1904-2014 Requirements for visual, auditory and tactile signs
AS 4024.1905-2014 Requirements for marking
AS 4024.1906-2014 Requirements for the location and operation of actuators
AS 4024.1907-2014 System of auditory and visual danger and information signals
Just some few word about standards in Australia. Australia has accepted nearly all A and B standards regarding machine safety from ISO. From my point of view it step close to acceptance of a global standard is better for all. If somebody thinks it’s money that keeping the world to spin. They are wrong it is standards that keep the world spinning. J
Standards Australia is give the standards there oven numbers. But never less they the same as ISO standards. I will try to find a converting table for you late on. If we look at future it will be more easy to for the Australian to export to Europe and the rest of the world because it’s the same standard we work after. The other way around it’s more easy for us to export to Australia because the standards is the same. This is a win situation for all. I can only just say welcome to the future of ISO standardisation.
I am sorry from the leak of blogging but a have not had the time to do it. I will try to blog at least ones a week. The last couple of months I have struggle with different standards around the world. And one question has shown of time after time. Is a standard a law?
No a standard is not a law. Standards is guidelines. E.g. ISO and EN standards that are harmonised to the machinery directive is the guidelines to apply to machinery directive. If you follow the harmonised standards you can be sure that you apply to machinery directive.
The machinery directive is the law in EU and the (EFTA countries Iceland, Norway and Liechtenstein) plus Switzerland and Turkey, Europa is quit unique about having a law that’s cover so many countries.
You can even have customer in some countries that not know anything about ISO standards even the standards is close to be global. At the map you can see which countries there are full members and which status they have in ISO cooperation.
There is also some countries where the law is different locally in the country.
If look at Europa there is no problem but when you get outside you can run into some problem even you follow the standards. It’s all was a good idea to contact the local working authorities’ and ask them if they have any local regulations you have to follow. Or you have a signed contract that exactly described that the machinery is manufactured according to following ISO standards ISO 12100, ISO 11161 etc. and buyer accept this otherwise you can run into some serious problems.
I will return with more about global standards Next week.
Best regards and have a safe day.
I have been working with standardisation for more than 10 years. I have seen the change from lacking of knowledge and refusing to use standards. To a growing need for standards, and requirements for developing functional and readable standards. We will I the upcoming years see that standards will changes the way we work. We have also to be aware of that standards is guidelines.
The last couple of years I have seen standards and the Machinery directive been misused as quality mark. Some companies use to say they are CE certified, but no documentation about the certification. Some clam they have patent but it’s not possible to find the patent when you search for it. In my daily work I often run into different rumours about something in standards has change over the night. e.g. one company is calming that the height 2200mm. is not allowed anymore regarding the new machinery directive. The machinery directive doesn’t describe any height’s for the Safeguarding (fixed guard) they are described in ISO 13857 Clause 22.214.171.124 Table 2. There is no height in ISO 13857 of 2300mm. there is a height of 2200mm. the next step is 2400mm so 2300m is between those to heights. Then you have to read ISO 13857 Clause 126.96.36.199.2 second subparagraph: There shall be no interpolation of the values given in Table 2. Consequently, when the known values of a, b or c are between two values in Table 2, the greater safety distance or higher protective structure or change in the height (higher or lower) of the hazard zone shall be used (Source ISO 13857 Clause 188.8.131.52.2 second subparagraph).
From my point of view we need to inform and marketing standards more in the future. We the people who is developing standards has to make them functional and readable for everyone.
I hope this will wake up a discussion about how to read and use standards/directives.
When all other has been on vacation I have been working. You don’t have to feel sorry about this, it’s self-chosen situation. Reason for this is simple, we like the silence when we are alone on vacation.
The last couple of weeks I have used my time solving some problems, about standards, directives and regulations. One of the things I has expired the last couple of weeks are the leak of knowledge around CE marking.
There is more than 20 different directives where it’s possible to CE mark against. Therefore we have a lot of misunderstanding of what there shall be CE mark or what shall not be CE mark.
I can give you one product that have to CE Mark against one directive but not against the Machinery directive. One example is a push pad or panic bar for escape. Those article has to be CE mark against the directive for building hardware EN 179 and EN 1125 none of those standards relate to the machine directive. So there is no requirement for a CE marking when they are used in combination with safeguarding for machinery. But the costumer can require we use CE mark products, but not in relation with the machinery directive. If you have to CE mark a product, you need to have something to CE mark it against. If you have to CE mark a product, you have to do it against a harmonized standard where there is description with test methods. Therefore it can be difficult to CE mark some products because it’s only spare parts, who are used to fulfil the requirements in other harmonized standards.
I am a little bit disappointed about how the standards and the machinery directives is interpreted. Something must be wrong when there is published a guide at 400 pages, to interpret the 64 pages of the machinery directive. Or maybe I am missing something?
I think this could be one of the reasons why people can’t agree about the interpretation of the machinery directive. I see a lot of people that work with machinery directive. Bending it in the direction that suits them best so they can earn money to consulting there customer. I would like to suggest that a new machinery directive should wider in its explanation. I would like a directive that didn’t need 400 pages of explanation and interpretation. I think we need to start at the work now, not in 5 0r 10 years. To many question about this Machinery directive has not been answer yet and it will never happen. Please start the project soon an give us a machinery directive we can interpret easily.
The sun is shining and the temperature are hopefully increasing to over 25°C and we feel the summer has arrived. Everybody need to disconnect from the real life and relax with you family and friends. Whenever you are walk around or are traveling by, bicycle, motorbikes, cars, boat or flights everything is working together or separate. The reason, why everything is working. Is that standards are used when we are developing, designing and constructing everything around us. Here is some samples, the information you get on the GPS, telephone or by the TIM system in you radio is done with a protocol described in a standard. For me, there is no doubt isn’t money that the keeps the world spinning around it’s standards. The quality is standardised in ISO 9001 and nearly everybody knows this standard. Our environment is standardised in ISO 14001. There I standards for Wi-Fi, Power supply etc.
Measurement is also standardised even somebody will clam the opposite. The way we measure is the same, even we measure in different system the imperial system or the metric system we have a standard way for converting the imperial system to the metric system and back again. Even power supply is standardised even we have different plugs to connect to the power supply. We measure in volt and ampere this is also a standard. We use different voltage, we use 220 V in Europe and America use 110 V this is actually a minor problem in the global prospect. My conclusion is that nearly wherever we are, standards have a big impact on our daily live. That’s my reason to participate in standardisation work.
For your information
The use of ISO 12100 and ISO 13849-1 has shown that readers have experienced difficulty in understanding how these two documents work together. This document has been prepared to guide readers in how the standards are to be used to achieve tolerable risk for a machine in general and for the safety-related parts of the control system, in particular.
This part of ISO/TR 22100 describes the general relationship between ISO 12100 and ISO 13849-1 used to reduce the risk of harm. It focuses on the use of safety-related parts of control systems in relation to risk assessment and the risk reduction process.