Guide to application of the Machinery Directive, edition 2.2

The European Commission has published Guide to application of the Machinery Directive 2006/42/EC, edition 2.2. This update to the second edition of the official guidance was endorsed by the Machinery Committee and issued in October 2019, superseding edition 2.1 of July 2017. The new edition runs to 465 pages, which compares with 457 pages for edition 2.1.

This is not a major rewrite of the guidance, just corrections and clarifications of certain points. It also includes amendments for coherence with the LVD (Low Voltage Directive) guidance.

Two new annexes have been added to the guide and, to avoid confusion with the annexes of the Machinery Directive, these are shown in the guide as Annex I (to the Guide) and Annex II (to the Guide).

Annex I (to the Guide) - Status of machinery control units under the Machinery Directive

Control units for machines, which in some cases may be no more than circuit boards, often perform a safety function either as a primary or secondary function. Control units can be placed on the market in a number of different ways and this can affect their status within the context of the Machinery Directive. To clarify when such control units do and do NOT need to be CE marked under the Machinery Directive, this new Annex to the Guide contains a table showing different compliance scenarios as follows:

  1. Control unit delivering safety functions within a complete machine when placed on market
  2. Control unit delivering safety functions with actuator/motor placed on market as single product (need not be in same enclosure, just marketed as a single product)
  3. Control unit delivering safety functions, independently placed on market so meet definition of 'Safety Component'
  4. Control unit delivering safety functions that meet the definition of 'Safety Component' but supplied by OEM as a spare part
  5. Control unit placed independently on the market but not delivering any safety functions

For each scenario the table provides definitions, identifies the applicable Directive, states which EHSRs (Essential Health and Safety Requirements) must be met, indicates what type of declaration is required (incorporation, conformity or none) and whether instructions need to be provided.

Annex II (to the Guide) - Table of safety components which are considered to be logic units

This second new Annex to the Guide provides a non-exhaustive list of safety components that are considered to be and NOT to be logic units to ensure safety functions in the scope of Annex IV, item 21 (Annex IV is 'Categories of machinery to which one of the procedures referred to in Article 12(3) and (4) must be applied' and item 21 is 'Logic units to ensure safety functions'). Note that Annex II to the Guide refers to 'Annex VI' but this is a typo, as the relevant Annex to the Machinery Directive is Annex IV.

Annex II not only lists a large number of different types of safety components, but it also makes it clear that other criteria must be met if the component is to be classified as a 'safety component'.

Conclusion

Some people may feel the new annexes do not say anything that readers could not work out for themselves, but most people will probably welcome the clarification provided. Given the other edits, clarifications and corrections contained in edition 2.2, this latest version of the official guidance is a 'must have' for anyone with responsibility for CE marking a machine or for any aspect of a machine's design or documentation that impacts on CE marking to the Machinery Directive. Follow the link to download a PDF of the Guide to application of the Machinery Directive 2006/42/EC, Edition 2.2.

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