Have you ever encountered the term “essential requirements for machinery”? This phrase frequently arises when discussing older machines, particularly those in use before Poland joined the European Union. However, it’s crucial to distinguish these from minimal requirements. Machines must meet essential requirements to be legally marketed and operated within the EU.
Essential requirements for machinery refer to the regulations outlined in the Machinery Directive 2006/42/EC and the new Machinery Regulation 2023/1230/EU. These requirements must be fulfilled to conduct a conformity assessment, such as for a new production line, in compliance with European Union regulations. But what does this entail? Imagine purchasing a new production line. The machine must meet the appropriate safety standards before it can be installed in your facility. But what about older machines purchased before Poland’s EU accession or those imported from outside the EU?
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Essential Requirements for Machinery: Adjusting Older Machines and Imports from Outside the EU
Example: During a safety audit at a company, we discovered an intriguing situation involving a machine imported from China. This machine bore the so-called “Chinese CE” mark, which can easily be mistaken for the EU’s CE mark by the untrained eye, but it did not meet EU standards. The section of the line where a manual press was installed was protected by a safety curtain. At first glance, everything seemed fine—after all, a curtain was installed! But the devil is in the details.
Upon closer inspection, it turned out that the safety system was far from meeting the essential requirements. Firstly, no studies were conducted regarding the machine’s stopping distance and the necessary distances to prevent operator crushing. The EN ISO 13855 standard clearly specifies the minimum distances required based on the machine’s reaction time, which was not considered here. The safety curtain’s distance was too short, and the reaction time was too long, meaning the operator could be crushed before the machine actually stopped.
Secondly, the safety curtain had an inadequate resolution, meaning it could not detect the operator’s hand, posing a real threat. The EN ISO 13857 standard precisely defines the requirements for protective gaps and the minimum resolution of safety devices based on the body parts to be protected (e.g., fingers, hands). In this case, the curtain’s resolution was too low to provide effective protection for the operator’s hands.
The result? It was necessary not only to replace the curtain with an appropriate model but also to rebuild the entire workstation to maintain appropriate distances and adapt the system to essential requirements. This adaptation included both a risk analysis and an improvement of the entire safety system, which, of course, involved additional costs and production downtime.
CE Marking Does Not Always Guarantee Safety
Companies often proudly present machines with CE marking, which theoretically confirms compliance with EU regulations. Unfortunately, this is only part of the truth. The CE mark can be awarded based on the manufacturer’s declaration, but it does not always mean that everything was done according to standards.
Example: In one Polish company, we conducted an audit of a production line built by a domestic manufacturer. On paper, everything seemed flawless—the machine had a Declaration of Conformity and a CE mark. However, a detailed analysis revealed that the safety functions were improperly designed, potentially leading to serious hazards.
One of the key issues was the emergency stop function. According to the PN-EN ISO 13850 standard, emergency stop systems must ensure the machine’s safe halt in a threat situation. In this line, after activating the e-stop (emergency stop), the pneumatic actuator responsible for material transport was not secured with appropriate mechanisms to maintain pressure in the chamber. In practice, this meant that the material could fall after triggering the emergency stop, potentially causing serious injuries to operators.
This issue also stemmed from a flawed risk analysis. According to EN – ISO 12100, risk assessment must consider all potential sources of hazards, including potential energy, which was a threat in this case. The falling material transported by the pneumatic actuator posed a risk of crushing operators, resulting from improperly designed safety functions. The EN – ISO 12100 standard clearly states that potential energy stored in machine elements must be controlled to prevent its uncontrolled release.
Another problem involved the saw. In an emergency stop situation, its inertia caused the saw to be damaged, and fragments could pose a threat to employees. This highlights the importance of considering all aspects of inertia and machine reactions during emergency stops. Without proper protection, an emergency stop can itself generate new risks instead of eliminating them.
Although the manufacturer was formally responsible for the errors, the company unfortunately went bankrupt, meaning the user had to independently adapt the line to essential requirements. It was necessary to redesign the safety functions and modify the line to meet all relevant standards, which involved significant costs and production downtime.
As a result of this process, it was necessary to:
- Implement appropriate pressure locks in pneumatic actuators, securing the material from uncontrolled descent.
- Develop a system that accounted for the saw’s inertia to prevent damage during an emergency stop, thereby reducing the risk of fragment ejection.
Adapting Machines to Essential Requirements – What Does It Mean?
Adapting a machine to essential requirements is not just about changing a few components. It is a comprehensive process that may include:
- Recreating or updating technical documentation.
- Re-conducting strength calculations to ensure the machine meets safety requirements.
- Designing new safety functions, such as emergency stop systems, guards, or safety curtains.
- Conducting a risk analysis to precisely determine what hazards may occur during machine operation and what measures should be taken to eliminate them.
The costs of such a process can be significant, especially for machines imported from outside the EU, which often do not meet even basic machine safety requirements. However, investing in employee safety and regulatory compliance is not only a legal obligation but also a way to ensure production continuity and avoid potential accidents that can lead to serious legal and financial consequences.
Essential requirements for machinery are not just a formality that can be ignored. Every machine, whether new or used, must meet specific safety standards before being approved for use within the European Union. The process of adapting machines to these requirements can be complex and costly, but it is essential for ensuring employee safety and avoiding serious legal consequences.
Cases like the “Chinese CE” or the line built by a Polish manufacturer show that one cannot always rely on manufacturers’ declarations. Audits, risk analysis, and proper adaptation of machines to essential requirements are crucial steps that must be taken to protect people’s health and lives and ensure compliance with regulations.