Machinery Directive:

Changes Explained
with Examples

By Jason Ayers, a diversified Engineer with 18 years

of Manufacturing and Product expertise.
 Introduction
This white paper is intended to inform machine manufacturers of the changes in the
Machinery Directive. The revised directive takes effect December 29, 2009, all changes
are mandatory and there is no transition period. If exporting machines to Europe, it is
important to understand the substantive changes determined by the new law.

This white paper

Why is a new Machinery Directive needed? The safety industry is evolving every day as
is intended for customers demand faster and more complex machines. These demands create new
machine builders
who export their scenarios that must be adhered to through evolving safety systems. Therefore, it is
products to
Europe impossible for a single safety document to be a one-time one-size-fits-all for this
industry. The Machinery Directive takes changes into account, evolving because:
o Gaps and loopholes are discovered in our current safety standards
o Updates in business and workplace operating procedures
o Industry and society expectations
o Technology improvements
o Changes in the use of machinery

Cumulatively the changes provide a new framework that creates a higher level of safety.
Changes in the new directive include:
o Expanded types of products and machinery covered
o Definitions and statement clarification
o Roles and Responsibilities defined and clarified
o Documentation changes and who is required to retain/provide these documents.
o Introduction and formalizing of the risk assessment procedure
o New certification option—Self Certification—residency requirement for the
Authorized Representative
o Expanded machine shutdown procedures—including a “total system” shutdown
requirement
o CE Tag—Machinery Certifier can now have the company name on the
certification tag

This paper covers the following Machinery Directive sections:

1. What the machinery directive is and how to comply
2. A brief history of the machinery directive with milestones
3. Summary of changes in the machinery directive
4. Details of changes—outlines structural differences of the two directives, contains
detailed information regarding the changes, and compares “before and after”
sentences and sections
5. Seven scenarios provide examples of real-life situations machine builders may
encounter. These scenarios are accompanied with a compliance approach and a
recommendation of a company that can help you navigate this process as well the
European Commission’s methodology
6. Summary

The CE mark Section 1: What is the Machinery Directive and How to Comply
declares that
machines are in
compliance with
either the present
or future
Machinery
Directive
 In order for machines exported to Europe to be found in compliance
with both the current and the revised, soon-to-be enacted Machinery
Directive, they must contain the CE Mark. This mark declares that your
machines meet the essential requirements of all relevant EU Directives.
Assemblies of machines such as robot cells and production lines also fall under this
obligation.

The aim of the EU in introducing the Machinery Directive (MD) was to ensure the free
movement of machinery by guaranteeing a high and common level of protection in the
areas of health and safety. In the twenty years since enactment of the original directive,
many economic, political, technology and societal changes impacting European
workplaces have occurred, necessitating a revision to the existing directive.

Thus, there are significant changes from Machinery Directive 89/392/EEC to the current
directive, Machinery Directive 2006/42/EC, to the new Machinery Directive which takes
effect December 29, 2009.

The directive is law in Europe, therefore, failure to build compliant machines will prevent
manufacturers from exporting machinery to European markets.

Section 2: A Brief History of the Machinery Directive with Milestones

In order to understand the Machinery Directive, it’s useful to look at key milestones.
When changes occur to the directive, they are substantial.

• July 8, 1985: Council Directive 86/374/EEC concerning liability for defective

products (Product Liability) is published.
• June 14, 1989: Machinery Directive 89/392/EEC is published, outlining specific
requirements for machinery.
o “New Approach Directive”
o Freedom of movement within single market
o Common and high standard of machinery safety
o Defined conformity assessment procedures
o Market for harmonization and standardization
o Also published in 1989:
o Directive 89/391/EEC on the introduction of measures to encourage
improvements in the safety and health of workers
o Directive 89/655/EEC concerning the use of work equipment by workers
at work
o January 1, 1992: Machinery Directive enacted into law
o May 12, 1993: Machinery Directive applied nationally
o June 22, 1998: Machinery Directive 98/37/EC is published
o Other laws that impact the directive and safety in Europe:
o December 3, 2001 Product Safety Directive put into effect
o May 1, 2004 Device and Product Safety Law put into effect
Machinery o June 29, 2006 the Machinery Directive 2006/42/EC distributed for comment
Directive
2006/42/EC takes
effect Dec 2009
and must be
applied from that
day forward-no
exceptions
 o December 19, 2006 mandate to the European Committee for Electrotechnical
Standardization “CENELEC” for overhauling the harmonized standards in
regards to the Machinery Directive 2006/42/EC
o The CENELEC was created in 1973, as a result of the merger of two
previous European organizations: CENELCOM and CENEL. CENELEC
is a non-profit technical organization operating under Belgian law and
composed of the National Electrotechnical Committees of 30 European
countries.
§ The CENELEC’s mission is to prepare voluntary electrotechnical
standards that help develop the Single European Market/European
Economic Area for electrical and electronic goods and services
removing barriers to trade, creating new markets and cutting
compliance costs.
o June 29, 2008 Device and Product Safety Law changed
o December 28, 2009 Machinery Directive 98/37/EC applicable for the last time.
o December 29, 2009 Machinery Directive 2006/42/EC commences. All machinery
operating in the European Union must be in compliance.

Section 3: Summary of Changes

The new Machinery Directive provides users and suppliers of machinery with a pathway
to serious injury prevention. Significant updates and changes from the previous directive
include:
§ Process of risk assessment
o Machine manufacturers are obligated to complete a risk assessment which
is defined as an iterative process of hazard identification, risk estimation,
hazard elimination or risk reduction.
§ Safety system requirements
A goal of the new
Machinery o Machine designers are obligated to design control systems in such a way
Directive is to
provide greater
that a fault in the hardware or software of the control system and/or
legal security reasonably foreseeable human error does not lead to hazardous situations.
§ Harmonized standards
o The standard governing the design and implementation of the safety-
related parts of control systems on machinery (EN 954-1) becomes
Scope and obsolete on December 29, 2009. Machine builders must adhere to EN ISO
contents of the
new Machinery 13849 or EN/IEC 62061 to achieve compliance with the new directive.
Directive have
been expressed § Administrative and assessment procedures
more precisely
o New assessment procedures are defined for machines listed in Annex IV
of the directive and for “partly completed machines.” For manufacturers
of Annex IV machines self-certification is now possible.
Ambiguities that
§ Machine builders outside the EU
resulted in a o Machine builders outside the EU must authorize a person who must be
variety of
interpretations established in the EU Community to compile the technical file for the
have been
removed machine. Machine builders without an operation in the EU can appoint an
“Authorized Representative.”
 Section 4: Details of Changes
The following summarizes the structural changes to the document:

Revisions in essential requirements and administrative procedures include:

• Changes in the Essential Health and Safety Requirements
o Risk Assessment
§ The iterative process of risk assessment defined in standards such
as EN ISO 14121 is now clearly stated in the directive. The current
obligation “…to assess the hazards ….” is replaced with the
stronger statement:
Machinery
Directive • The manufacturer of machinery … must ensure that a risk
2006/42/EC
contains stronger
assessment is carried out …. By the iterative process of risk
statements like assessment and risk reduction …, the manufacturer …
those in the Risk
Assessment shall: eliminate the hazards or reduce the risks associated
section
with these hazards by application of protective measures,
in the order of priority established…
§ Machine risk assessment is part qualitative/part quantitative
requiring judgment by competent persons. Companies
manufacturing machines must ensure that the iterative process
defined is carried out effectively and the results are demonstrably
incorporated in the machine design, recorded in the technical file
and reflected in the instructions for use.

• Instructions
o Safe operation of machinery depends on clear instructions. The obligations
on machine designers to provide clear information on machine use as well
as the hazards to be expected in operating and using machines are further
elaborated. The contents of the instructions must cover, not only the
intended use of the machinery, but also take into account any reasonably
foreseeable misuse.

• Control Systems and Devices

o The obligations on machine control system designers are more explicitly
and, in some cases, more stringently defined. The requirement to consider
“foreseeable human error” is new. The design of the safety system must be
considered in a manner where machine operators do not benefit or gain
Machinery
Directive incentive from bypassing safety systems. Recognizing advances in
2006/42/EC often
contains more
technology, the new directive introduces the obligation to consider control
stringent systems and protective devices to automatically prevent start-up if it
definitions and
greater clarity detects somebody in a danger zone.

• Harmonized Standards
o The new Machinery Directive contains a specific new article relating to
the “presumption of conformity” which emphasizes the benefit of seeking
compliance through standards. The previous standard governing the
design and implementation of the safety-related parts of control systems
 on machinery becomes obsolete in December 2009. Consequently
machine builders must use one of the replacement standards—EN ISO
13849 -1 or EN IEC 62061—to achieve compliance with the new
directive. The new standard reflects the increased tendency to use
electronic and programmable systems for safety.

• Changes in scope and Administrative Procedures

o To achieve their objectives, those drafting the new Machinery Directive
provided new or refined definitions of machinery and other essential
concepts and clarified the boundaries between the machinery directive and
other directives.

• Boundary with Low Voltage Directive

o The interpretation of the “Low Voltage Directive” (“LVD”) and the
existing “Machinery Directive” resulted in the unintentional exclusion
from the previous directive of machines on which it could be claimed that
Machinery the hazards were primarily electrical. In certain cases such an
Directive
2006/42/EC has a
interpretation resulted in only the LVD being applied. This “loophole” is
different set of closed by specifically listing in the new MD the electrical and electronic
electronic
products in the products which are covered by the LVD, as opposed to the new directive,
Low Voltage
Directive as follows:
§ household appliances intended for domestic use
§ audio and video equipment
§ information technology equipment
§ ordinary office machinery
§ low-voltage switchgear and control gear
§ electric motors
§ switch gear, control-gear and transformers
o Machinery builders making products not covered by the above exclusions
and who previously elected to apply the LVD will now have to apply the
new Machinery Directive as well as the LVD. There is further clarification
in relation to other legal requirements such as the lifts directive.

• Definitions of Machinery
o The existing machinery directive has a number of definitions for the
concept of a machine. Those of ‘Machinery’ and ‘Assemblies of
Machines’ (for example in automated production lines) are refined. The
core definition of a machine is now:
§ “An assembly, fitted with or intended to be fitted with a drive
system other than directly applied human or animal effort,
consisting of linked parts or components, at least one of which
moves, and which are joined together for a specific application”
o Definitions covering machinery without a drive system, machinery to be
mounted on means of transport, assemblies of machines, lifting machinery
operated by manual effort, interchangeable equipment (no significant
 change in this definition) and a revised definition of a Safety Component
are included.
o To clarify essential requirements and eliminate ambiguities, the concept of
“partly completed” machines is introduced. A partly completed assembly
§ “…. means an assembly which is almost machinery but which
cannot in itself perform a specific application. A drive system is
partly completed machinery. Partly completed machinery is only
intended to be incorporated into or assembled with other
machinery or other partly completed machinery or equipment,
thereby forming machinery to which this Directive applies”
o Manufacturers of “partly completed” machinery such as robots are
required to follow specific CE marking procedures related to the nature of
their machinery as opposed to a completed machine. The placement of a
CE marking on a “partly completed” machine is not allowed.
o Users of production lines and automated production cells must now take
great care in planning the acquisition and installation of their plant and
consider who is taking responsibility to CE mark.

• Administrative and Assessment Procedures

o New assessment procedures are defined for machines listed in Annex IV
of the directive and for “partly completed machines.” For manufacturers
of Annex IV machines, self-certification is now possible. The clarification
on procedures for “partly completed machines” provides security to
machinery builders and users in relation to the obligations on
manufacturers while providing clarity on the safe integration of such
products in machines or assemblies of machines.

• Machine Builders Outside the EU

Machine builders
must now o The single market provides no barriers to suppliers from outside the EU
authorize a
person who must
placing their products on the market. However, there is an important
be established in change in the procedures for machine manufacturers exporting into
the European
Community to Europe. Such suppliers must authorize a person who must be established
compile the
technical file for in the Community to compile the technical file for the machine. For
the machine. machine builders without an operation in the EU the most effective means
of meeting this requirement is to appoint an “authorized representative.”
Through this procedure there is more traceability for authorities and
machine users with identification of persons that can be enforced against,
if necessary, through market surveillance.
Sample Language Change:
Machinery Directive 98/37/EC
(Old Machinery Directive)
• Annex I 1.2.2 Principles of safety
integration (d)
o Under the intended
conditions of use the
discomfort, fatigue and
psychological stress faced
by the operator must be
reduced to the minimum
possible taking ergonomic
principles into account
Machinery Directive 2006/42/EC
(New Machinery Directive)
• Annex I 1.1.6 Ergonomics
o Under the intended conditions of
use, the discomfort, fatigue and
physical and psychological stress
faced by the operator must be
reduced to the minimum possible,
taking into account ergonomic
principles such as:
§ allowing for the variability
of the operator’s physical
dimensions, strength and
stamina
§ providing enough space for
movements of the parts of
the operator’s body…
§ avoiding monitoring that
requires lengthy
concentration
§ adapting the man/machinery
interface…

The additions and changes to the Machinery Directive, as you can see can be both
lengthy and add significant requirements for machine builders.

Section 5: Examples and Solutions

Now that we have reviewed what the Machinery Directive is, the history of the
machinery directive, the changes and some detailed examples of the extent of the
changes, it is time to consider some of these changes in real-world applications.

In this section real situations will be presented, what the Machinery Directive says about
this situation, a compliance strategy and how a vendor will help with compliance. Each
scenario will include:
• interpretation of requirements
• compliance strategies
• how a company that has technical competence in the Machinery Directive and
other international standards can help
 The company chosen for this exercise is Pilz, a globally known company respected for
safe automation components and services.

Scenario
Compliance Strategy Pilz Service
Machinery Directive
2006/42/EC

Scenario 1: Assembly of production line

A manufacturer of packaging products for the food and beverage industry is upgrading a
production line. Commission is scheduled for 2010. The production requires a continuous
process whereby two sheets of plastic are unrolled, treated and formed. The line will
comprise of existing machines, new machines and new robotic cells (partly completed
machines). With the adoption of lean manufacturing operations, operators will conduct
routine cleaning. Maintenance operations will enter danger zones as required.

§ What the new Machinery Directive says:

o Under the new MD, this production line is considered an assembly of
machines and partly-completed machines. The machine-user integrating
the line becomes the manufacturer and must conduct a risk assessment on
the overall line.

§ Suggested compliance approach:

o A safety concept for the line compliant with the essential requirements of
the directive is required. It must ensure: the safety-related parts of the
control system must apply in a coherent way to the whole of an assembly
of machinery and/or partly completed machinery. As operators enter the
danger zone and not all parts of the line are visible from all control
stations, the safety concept should automatically prevent start-up if it
detects somebody in a danger zone. On completion of the installation, the
necessary assessment and validation of the machine safety should be
conducted by competent persons and the necessary technical files created.
o The manufacturer of the complete assembly or his authorized
representative must issue a CE certificate of conformity for the complete
assembly.

Pilz Service
Pilz is qualified by the EU to act as an authorized representative. It can support you with
the assessment and validation of production line safety systems and the creation of the
necessary technical files. New sensing technologies such as SafetyEye® can be
considered.
 Scenario 2: Machine imported from outside the EU through a parent company.
A medical device producer imports a machine that is designed to apply a proprietary
process in the production of medical devices. The machine, which is not CE marked, is
supplied by a Special Purpose Machine Builder through the parent company of the device
manufacturer. As the machine operator must observe the process carefully—and
intervene regularly to assure product quality—a number of machine operating modes are
required.
The upgrade
designs must be
documented in a
technical file and § What the new Machinery Directive says:
a person
“established in the
o The local company becomes the machine manufacturer and must CE mark
community”
designated to
the machine.
issue a
declaration of
conformance and § Suggested compliance approach:
prepare a CE
marking plate o A risk assessment of the machine should be conducted to:
§ identify the hazards
§ estimate the risks, taking into account the severity of the possible
injury or damage to health and the probability of its occurrence
§ evaluate the risks, with a view to determining whether risk
reduction is required
§ eliminate the hazards or reduce the risks
o If the machine design does not comply with the essential requirements of
the directive it must be upgraded. In doing so, particular attention should
be given to creating intelligent safety concepts for mode selection and to
ensure that operators can observe processes without bypassing the safety
systems.
o The upgrade-designs must be documented in a technical file and a person
established in the community must be designated to issue a declaration of
conformance and prepare a CE marking plate.

Pilz Service
Pilz is qualified to develop and document the upgraded designs and legally act as an
“authorized representative” in order to issue a declaration of conformance and prepare a
CE marking plate.

Scenario 3: Existing machine listed under the Annex IV of the Machinery Directive.
A manufacturer produces a metal-forming machine which is manually loaded and
unloaded. The machine is type-certified through a third-party-notified body in accordance
with the existing machinery directive using harmonized standards including EN 954-1.

§ What the new Machinery Directive says:

o The existing type-certification and associated declarations of conformance
are not valid under the new Machinery Directive. A new type-certification
must be issued or one of the new procedures of self-certification or quality
inspection applied.
 § Suggested compliance approach:
o The machine builder should conduct an assessment of the machine to
determine if it complies with the essential health and safety requirements
of the new Machinery Directive. It must also be determined if the machine
fully conforms to the European standards harmonized with the new
machinery directive. With the above assessments, the manufacturer can
determine the optimum administrative procedures by which the machine
can be certified.
o The safety related control system must be assessed in accordance with EN
The safety related
control system ISO 13849-1 or EN IEC 62061 as appropriate. With this standard, the
must be assessed
in accordance
safety integrity of a system is classified into 5 Performance Levels which
with EN ISO are evaluated taking the following factors into account:
13849-1 or EN
IEC 62061 as § STRUCTURE – given as ‘designated architectures’
appropriate
§ MTTFd – mean-time-to-dangerous failure
§ DC – diagnostic coverage
§ CCF – common cause failures
§ Behavior under fault conditions
§ Software
§ Systematic failures
§ Environmental conditions

Pilz Service
Pilz provides Safety Services, training, and tools such as PAScal to help machine builders
determine if safety-related control systems meet performance levels deemed appropriate
as a result of a machine risk assessment.

Scenario 4: Machine builder exporting machines into the EU

A machine manufacturer produces machines here in the US for export directly into the
European Market. Until now, the machines were supplied directly to machine importers
and users.

• What the new Machinery Directive says:

o Under the new Machinery Directive the machine manufacturer must
identify a person, authorized to compile the technical file, who must be
established in the community.

• Suggested compliance approach:

o The machine must be designed to comply with the essential health and
safety requirements of the new MD and fully conform to European
harmonized standards. It is critical that the instructions provide clear
information on machine use. In addition, the hazards to be expected in
operating and using machines must be fully explained. The contents of the
instructions should cover, not only the intended use of the machinery, but
 also take into account any reasonably foreseeable misuse. Other essential
contents include:
§ information about the residual risks that remain despite the
inherent safe-design measures, safeguarding, and protective
measures adopted
§ instructions on the protective measures to be taken by the user,
including, where appropriate and the personal protective
equipment to be provided
§ operating method to be followed in the event of accident or
breakdown and the unblocking of a machine

Pilz Service
As an authorized representative, Pilz ensures the adequacy of risk assessment, safety
design, and the documentation of hazards that remain despite the inherent safe-design
measures. Pilz can be the authority established in the community qualified to take
responsibility for the required administrative procedures.

Scenario 5: Pharmaceutical plant machinery and equipment subject to other

directive.
A company manufacturing active pharmaceutical ingredients is introducing a new
product. Their management of change procedure (MoC) indicates that the change is
significant with new ingredients having low flash points. A new flatbed granulator-drier
will be installed and integrated with existing reactor plant and equipment. The clean in-
place (CIP) system is being upgraded as is the instrumentation and control system.

• What the new Machinery Directive says:

o The granulator-drier is a machine and the combined plant is an assembly
of machines under the directives. Such a plant must comply with all
relevant European directives including the ATEX directive, Pressure
Equipment Directive Low Voltage Directive and AUWED.
A structured
approach to the
allocation of • Suggested compliance approach:
prevention and
mitigation layers o A hazard and operability study (HAZOP) should be conducted on the new
bases for each
cause-
process and the plant, machinery, and equipment should be designed in
consequence accordance with the findings. A structured approach to the allocation of
prevention and mitigation layers bases for each cause-consequence. Where
safety depends on an instrumented system such as a vessel interlock,
nitrogen blanking or Emergency Shutdown, the Safety Integrity Level
(SIL) must be defined in conformance with accepted international and
European standards such as EN IEC 61511. The explosion protection
document (EPD) including Explosion Risk Assessment and Hazardous
Area Classification should be updated in compliance with the ATEX
directive.

Pilz Service
 Pilz is qualified to guide you through the above compliance approach.

Scenario 6: Industrial robot supplier.

A manufacturer of industrial robots produces machines supplied to the European market.
Typically robotic system integrators add jigs, fixtures and other elements to adapt the
robots for specific applications and integrate the robots in automatic cells or production
lines.

• What the new Machinery Directive says:

o Under the new MD the robots are considered “partly completed machines”
under the definition:
§ ‘partly completed machinery’ means an assembly which is almost
machinery but which cannot in itself perform a specific
application. … Partly completed machinery is only intended to be
incorporated into or assembled with other machinery or other
partly completed machinery or equipment, thereby forming
machinery to which this Directive applies;.

• Suggested compliance approach:

o The manufacturer must conduct a risk assessment on the machine to
The manufacturer determine which essential requirements apply and design the robot to
must conduct a
risk assessment
fulfill such requirements. Assembly instructions for the robot must be
on the machine to prepared. These must comply with the requirements set down in the
determine which
essential directive and include a description of the conditions which must be met
requirements
apply and design with a view to correct-incorporation in the final machinery, so as not to
the robot to fulfill
the requirements.
compromise safety and health.
o The objective is to provide security to machinery builders and users in
relation to the obligations on manufacturers of partly built machines while
providing clarity on the safe integration of such products in machines or,
assemblies of machines.

Pilz Service
Pilz is qualified to conduct a risk assessment and support in both the concept and the
design of the robot to insure that it meets all new MD requirements.

Scenario 7: Refurbishment of machinery.

A company manufacturing air filters had planned to replace an existing assembly and test
machine to increase volumes and productivity. However due to the economic climate the
capital budget was reduced. Instead, an existing machine will be refurbished and put into
service in January 2010. A stepper-motor driven system will be used to semi-
automatically load and unload the machine. Additionally the “PLC” used in machine
control system and the drive systems will be upgraded and replaced doubling the process
speed of the machine. The safety systems including the fitting of new guards will be
changed to prevent access to moving parts.

• What the new Machinery Directive says:

 o Under the directive the machine is undergoing a substantial refurbishment
which changes the limits of the machines and must be CE marked with a
new risk assessment and updated technical file. The end-user becomes the
manufacturer.

• Suggested compliance approach:

The instructions
for safe use must
be re-written, as
should any
operator and
maintenance
training material
based on the
existing machine.
o The function responsible for upgrading the machine must ensure that a
risk assessment is conducted and that the risks in the refurbished machine
are reduced in an appropriated manner. The instructions for safe use must
be re-written, as should any operator and/or maintenance-training material
based on the existing machine.
o A technical file representing the refurbished machine must be made
available. Some harmonized standards used in designing the original
machines for example EN954-1 relating to the safety control system.
The appropriate new standards must be used to gain a presumption of
conformance in particular EN ISO 13849 which uses a data-driven
approach to determine the required Performance Level (PL) and calculate
the achieved PL of the safety system. The expected lifetime of existing
electronic components used in the safety-system and not replaced must be
de-rated when calculating the mean-time-to-dangerous failure (MTTFd) of
the safety-related control system.

Pilz Service
Pilz is intricately familiar with the international standards mentioned above and can
conduct the risk assessment to ensure machines meet the requirements of the new
Machinery Directive.

Summary
As you can see the changes to the Machinery Directive are extensive. Upon review of
both documents and the changes, it is clear that the scenarios to be covered are almost
limitless. This white paper reviewed:
These changes in 1. What the machinery directive is and how to comply.
the Machinery
Directive become
2. A brief history of the machinery directive with milestones.
mandatory
th
3. Summary of changes in the machinery directive.
December 29 ,
2009 with no 4. Changes in terms of structure, summary of changes in Section Four and
transition period.
examples of changes in before-and-after language.
5. Seven scenarios to show examples of situations machine builders may
encounter, a compliance approach and a recommendation of a company that can
help navigate the process and the directive methodology.

The safety industry is constantly evolving and it is important for safety ambassadors to
design, build and maintain machinery that is safety-compliant. As technology advances,
machinery becomes more complex and machine operators find alternative ways to by-
pass safety systems, change becomes imperative. However, the European Union’s new
safety framework will create a higher level of safety for machinery. This new Machinery
Directive provides greater legal security by providing better definitions, clarifying
statements and ensuring consistent safety-application practices.

These changes in the Machinery Directive become mandatory on December 29, 2009
with no transition period. Furthermore, changes to this directive do not happen often, but
when they do it is important to not only understand them, but to find a trusted source who
can guide you through the changes.