RRC Technical Update Supply of Machinery (Safety) Regulations 2008

RRC Technical Update - The Supply of Machinery (Safety) Regulations 2008

Never send a human to do a machines job

(Agent Smith. The Matrix (1999), Wachowski Brothers)

These regulations mainly apply to machinery manufacturers, but we all benefit. They sound fairly dull, detailed and technical and, mostly, they are. This updateprovides a simple overview of the Regulations to maintain the illusion of accessibility. They bring to us the wonderful world of CE marking, with its (alliterative) relatively robust and realistic reassurance of safety. If they sound familiar, thats because they revoke, replace and modify all previous regulations of the same name. Legislators are not terribly imaginative. They do introduce a few new things (thats progress for you) but also clarify and consolidate. They came into force right at the end of 2009 a kind of late Christmas present. Since they implement the Machinery Directive (2006/42/EC), youll find lots of references to (and wholesale copying of) parts of the directive. So, what are they about? Clearly, they are about machinery and related equipment (defined within the regulations, with some exclusions). They aim to remove technical barriers to trade by harmonising requirements throughout the European Economic Area (EEA) much like many similar CE marking enactments over recent years. Sounds nice. As you would expect, they also require machinery to be safe.

Thats a bit vague, so, ignoring, for the most part, the anorak detail, these regulations require the responsible person (i.e. the manufacturer) to complete some specific basic steps before making a machine available:

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RRC Technical Update - The Supply of Machinery (Safety) Regulations 2008

The manufacturer cannot just assume things are safe. He has to carry out research and testing to make sure that the machine is safe and complies. Well look more closely now at some of these elements to see how this is done: Essential Health and Safety Requirements (EHSRs) This is a very long list of general principles and safety points with supplements for specific cases (such as lifting equipment). Not all will apply to every machine. Whilst a manufacturer can go through this general list, attempting to interpret its requirements in the context of his machinery, there is another way. If the machine already conforms to one or more published harmonised standards, there is a presumption of conformity with the EHSR (to the extent that they are covered by those harmonised standards). Published refers to specific EN standards (typically covering specific types of machines), references to which are published in the Official Journal of the European Communities. Nice if you can find one. Technical File This is a compilation of all the evidence relied upon for declaring that the product conforms with any requirements that apply to it. It will contain items such as descriptions, drawings, test details, reference to applicable EHSRs and/or published harmonised standards, operating instructions, and the EC declaration of conformity. Its not exactly a Booker Prize winner but think of the work that goes into it. Conformity Assessment There are three basic conformity assessment procedures and, depending on the machinery, the choice of which one to follow may be up to the manufacturer. These are commonly referred to as: self-assessment, EC typeexamination and full quality assurance procedures, respectively.

Self-Assessment: If you havent guessed already, self-assessment simply involves the manufacturer drawing up a technical file. The manufacturer also needs to make sure he checks and controls the manufacturing process so that the machines that roll off the production line always comply with the information in the technical file and the directive (i.e. some basic quality assurance).

EC Type-Examination This requires a third party (though music and alcoholic drinks are noticeably absent!). The manufacturer has to submit an example of the machine to a notified body, which carries out the conformity assessment and, if successful, certifies that the machine complies. You even get a certificate (a nice touch). The notified body is independent and officially accredited and authorised to perform these tasks on behalf of the government. The technical file must also be compiled and submitted at the same time.

Full Quality Assurance This also requires third party intervention. The manufacturer has to operate a Quality System (covering design, manufacture, inspection and testing) which has been assessed and approved (and subject to ongoing surveillance) by a notified body. The technical file is also examined as part of the approval process.

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RRC Technical Update - The Supply of Machinery (Safety) Regulations 2008

Everything begins with Choice

(Morpheus. The Matrix Reloaded (2003), Wachowski Brothers)

No. Wrong. Choice is an illusion, created between those with power and those without
(Merovingian. The Matrix Reloaded (2003), Wachowski Brothers)

So, what determines the choices you have? Certain dangerous machinery (listed in the regulations) that is manufactured wholly to (and covered wholly by) published harmonised standards gets the widest choice the manufacturer can choose any of the three methods. Dangerous machinery only partially covered (or not covered at all) by such published standards must choose either of the third-party interventions (i.e. EC type-examination or full QA). All other cases (most general machines) go the selfassessment route. EC Declaration of Conformity As it says, a declaration that the machine complies with all applicable requirements of all relevant directives (typically, a machine might fall under the requirements of several directives). The declaration must contain specific information such as the machine type and model, as well as the declaration itself. CE Marking Once all the other bits are in place, the manufacturer is entitled to put the familiar CE mark on the machine. When accompanied by an EC declaration of conformity, it is presumed that the machine is fully compliant (unless there is a strong suspicion to the contrary). Its not the only marking on the machine. The EHSRs also require things like manufacturer details and year of construction. So there you have it in a nutshell. It is pretty complicated, but its also very important (and so exciting!).

We are still alive

(Morpheus. The Matrix Reloaded (2003), Wachowski Brothers)

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