Economic reality intrudes

The current Machinery Safety Directive, adopted on 17 May 2006 and transposed into national legislation on 29 June 1998, passes into a new phase as of 29 December this year and specialists warn that there is no transition period. "When the Machinery Directive 2006/42/EC becomes law on 29 December, the existing Directive will be repealed immediately and, unusually, there WON'T be a transition period," says Midlands-based Lorien Engineering Solutions. Lorien's compliance consultant, Tony Reynolds, explains: "On the face of it, the two Directives appear similar, but there are, in fact, some significant technical and administrative changes that will affect all machine manufacturers, system integrators and those importing machines from outside the European Union. "Manufacturers of partly completed machinery will have additional duties placed on them and must now formally issue a Declaration of Incorporation, create a technical file and supply comprehensive assembly instructions, stating how to incorporate the machine. "Duties on machine importers have also been expanded," he adds, "as they will need to have a technical file in Europe and the location must be identified on the Declaration of Conformity/Incorporation that they are responsible for issuing." Marlin, Wimborne, Dorset, a supplier of automated manufacturing systems, highlights some specifics related to the Essential Health and Safety Requirements (EHSRs), which are at the heart of the Directive. These, says the company, have been clarified and extended to include ergonomic considerations [and emissions]. Operator fatigue and discomfort, as well as physical and psychological stress, must be reduced to the minimum possible. In addition, the operator must be capable of checking any danger zones from every control position, not just the 'main' control position, as previously. Another change relates to fixed guards; the new Directive requires that the fixings used must remain attached to either the guards or the machinery when the guards are removed. The thinking behind the upgrade to the Directive is explained in a document available from here (1). But the current economic situation, which is forcing the delay of machine deliveries, will likely cause machine tool makers to fall foul of the new Directive, says Orgalime - the European Engineering Industries Association, which represents the interests of the mechanical, electrical, electronic, metalworking and metal articles industries. It says that the machines meet the existing directive requirements, but that manufacturers are now confronted with practical problems arising from the substantial stocks of undelivered machines, which are safe and in conformity with directive 98/37/EC, but may not fully comply with provisions of the new directive 2006/42/EC. The Manufacturing Technologies Association has called on its members to comment on a draft letter about the situation. It is anticipated that the European Machinery Working Group might pursue this matter at its forthcoming meeting scheduled for July 7 and 8, 2009 ,"with a view to releasing official guidance on how to proceed in such cases". A case of economic reality meets social desirability. (1) http://www.kan.de/uploads/ tx_kekandocs/2006-2_MRL_Fraser-e.pdf See also, http://ec.europa.eu/enterprise/mechan_equipment/machinery/revdir.htm First published in Machinery July 2009