Making a late move to the new Machinery Directive

Rockwell Automation recently organised a machinery safety event to promote compliance with the functional safety standards for machinery and the new Machinery Directive 2006/42/EC. According to Rockwell Automation, many of the UK's machine builders are still working to EN 954-1 (Safety of Machinery - Design of safety related control systems), even though this standard will be withdrawn at the end of 2011 (see EN 954-1 extension confirmed as two years). Moreover, there are sound reasons for using the newer functional safety standards instead (see this article EN 954-1 and ten reasons NOT to use it).

If you are a machine builder working to EN 954-1, it is essential that you migrate to one of these two functional machinery safety standards before the end of 2011:

• EN 62061 (IEC 62061), Safety of machinery, Functional safety of safety-related electrical, electronic and programmable electronic control systems
• EN ISO 13849-1, Safety of machinery, Safety-related parts of control systems, Part 1: General principles for design

Furthermore, some machine builders may also be CE marking to the old Machinery Directive - or be claiming compliance to the new Machinery Directive (2006/42/EC) without checking that they are, indeed, compliance with all of the new requirements relating to the Essential Health and Safety Requirements (EHSRs) and documentation.

This article therefore seeks to provide a roadmap to assist machine builders in assessing their current position and, if action is required, what to do in order to migrate from EN 954-1 to one of the newer functional safety standards and, if necessary, meet the requirements of the new Machinery Directive.

Do you need to CE mark?

New machines need to be CE marked if they are to be placed on the market in the EEA (ie the EU plus a few other countries). The same is true whether the machine is sold or built in-house for use solely by the manufacturing company. In addition, the machine may be classed as 'new' (and therefore need CE marking) if it is significantly modified or upgraded (eg by upgrading a manual machine tool to CNC operation).

If the machine does not need to be CE marked, is it being built to EN 954-1? If so, the machine builder needs to establish which machinery safety standards are appropriate to the type of machine and the geographical market into which it is to be sold (which may or may not include IEC 62061 and ISO 13849-1). Similarly, if the machine is not being built to EN 954-1, the machine builder needs to establish which are the appropriate international and/or national standards.

Which Directive?

If the machine is being CE marked, is it being CE marked to the old or new Machinery Directive? Or is compliance with the new Directive being claimed, even though no thorough assessment has been carried out? To help machine builders check their level of compliance, MachineBuilding.net has published a free Guide to the New Machinery Directive that highlights the differences between the Directives and discusses the implications.

EN 954-1 remains Harmonised to the New Machinery Directive until the end of 2011 and, as such, provides a presumption of conformity with the relevant ESHRs of the new Machinery Directive. However, if the machine is to be placed on the market on or after 1 January 2012, then by law it cannot be CE marked by using EN 954-1. For more information, see the article EN 954-1 and ten reasons NOT to use it.

If EN 954-1 is still being used, the machine builder needs to decide which of the functional safety standards to use instead. Having decided on the best standard to use for the machine in question, it will be necessary to update the design documentation. In some cases small changes to the design of the safety-related control system may also be necessary.

On the other hand, if the machine is being CE marked and one of the functional safety standards is being used, then it is only necessary to check what other standards are applicable, whether any other Directives are applicable, that the correct procedures are being followed, and that the documentation is in order as required by the new Machinery Directive.

Resources and support

While the foregoing provides a roadmap, taking any necessary action may require the use of various resources, many of which are available free of charge, though some will have to be paid for.

• IEC/TR 62061-1 ed1.0 Guidance on the application of ISO 13849-1 and IEC 62061 in the design of safety-related control systems for machinery. This document describes which standards can and cannot be used in different scenarios, and discusses the ways in which one standard may be preferred over another.
• Free books have been published by Rockwell Automation, Pilz, Laidler Associates, Sick and others
• Dedicated machinery safety websites have been created by Rockwell Automation, Wieland Electric and others
• Free and paid-for training courses and seminars are available from many providers, including Rockwell Automation, Pilz, Laidler Associates, Sick, Wieland Electric, Leuze electronic, Health & Safety Compliance Engineering, PPMA (Processing & Packaging Machinery Association), Health and Safety Laboratory (HSL), Festo, ISS Safety, Oxeta and others.
• Procter Machine Guarding offers a number of Free downloads including A Designer's Guide to Machinery Guarding Standards, a Risk Assessment Calculator, a Safety Distance Calculator, and two White Papers, one on the Machinery Directive and Fixings for Fixed Guards and the other on CE Marking of Guards.
• Pilz offers its PAScal Safety Calculator for calculating the PL (Performance Level) and SIL (Safety Integrity Level) when working to EN/IEC 62061 and ISO 13849-1, respectively.
• SISTEMA, which is maintained by Germany's IFA, is a free software utility for applying EN ISO 13849-1