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performance of a machine or complex assembly is also essentially creating a new machine, which must comply. Also, if you are at the start of a project where the finish date is towards the end of 2009 or the beginning of 2010, you may need to start using the new Directive now, as you will not be able to produce a final declaration under the current Directive after December 29th. Alterations to the EHSRs are too numerous to detail here, but affect issues such as: ergonomics, operating positions, seating, lighting, manual controls, starting machinery, stability of machinery, protection devices, machinery instructions, plus machinery for foodstuffs and for cosmetic and pharmaceutical products. There are also key changes to the Declaration of Conformity and the person who is authorised to compile the Technical File must be established in the European Community. Where appropriate there must be a statement confirming declaration of conformity with other applicable directives and there is no longer a separate declaration for safety components. Control systems, says the Directive, must be designed and constructed in a way that will prevent a hazardous situation arising. Manual controls must be clearly visible and identifiable; the use of pictograms is recommended. And an operator must, from each control position, be able to ensure that no one is in the danger zone – even if that means that the machinery can be controlled only from positions in one or more predetermined zones or locations. There are obviously many more issues contained within the new Machinery Directive, and it is vital that business organisations move in good time to make sure that they comply. The new Machinery Directive is a necessary move forward in this day and age, with increasing movement of businesses and their plant within the European community, and with growing importance placed on the health, safety and wellbeing of the people that work with or near the machinery. But it still places a demanding requirement on a vast range of businesses. The decision that needs to be made is whether there is sufficient manpower, let alone expertise, in-house to carry out the necessary risk assessments and make changes - or whether the task should be outsourced. Either way, companies need to make sure that they are completely up to date, properly informed and ultimately compliant. • Laidler Associates specialises in helping organisations comply with directives and obtain CE marking.
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Prepare for a new Directive
The new Machinery Directive comes into operation on 29 December this year. Its implications are far reaching, affecting most businesses in one way or another, and the penalties for non-compliance are serious. Paul Laidler of Laidler Associates explains
or the purposes of the directive, a machine is defined as ‘an assembly of linked parts or components at least one of which moves, with the appropriate actuator, control and power circuits, joined together for a specific application, in particular for the processing, treatment, moving or packaging of a material’. The term machinery also covers an assembly of machines, which are controlled so that they function as an integral whole, w such as a production line. • 29 December – ne ive The scope also includes items Machinery Direct operation such as safety components, comes into and lifting accessories and • Affects processes chains, ropes and webbing, systems as well as construction site hoists and hines and safety devices for the lifting of mac persons with reduced components mobility. e • Key changes to th When asked the question: ‘Why do we have Declaration of to comply?’ the answer Conformity should really be ‘because if we



don’t, our employees may be injured.’ However, another answer is that all the European directives are brought into UK law by the issue of Regulations, which mean that if you don’t comply you are committing a criminal offence punishable by fines and possibly imprisonment. So how do you comply?’ The short answer is: • Demonstrate compliance with the essential health and safety requirements • Carry out the appropriate conformity assessment procedure • Draw up and issue the Declaration of Conformity or Incorporation. • Apply the CE Mark. It isn’t just machines and safety components that are affected, though. Processes and systems are also involved, and if you are creating a complex assembly, such as a production line, by interlinking a series of existing machines you are in effect creating something new – so the whole assembly must comply with the Directive. Similarly, altering the function or



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