This SIM advises inspectors about the safety requirements for front end loaders and the potential hazards when they are fitted to tractors with programmable hydraulic functions.
This issue came to light during a routine complaint investigation about a tractor and loader.
The tractor had a programmable hydraulic system - commonly called a headland sequencing function and normally used to carry out several hydraulic operations when moving complex machines in and out of work positions.
The loader was fitted to the tractor as original equipment and operated through a secondary mid-mounted valve block using the on-board joystick control which could be programmed via a touch screen. This allowed the loader to be programmed to automatically carry out an action, or series of actions, with a single touch on the joystick.
This effectively would defeat the ‘hold-to-run’ function required by the Machinery Directive and specified the harmonised European standard EN12525:2000 ‘Agricultural machinery – Front loaders – safety’. Programmable sequences (such as repetitive loading functions) that still require ‘hold-to-run’ control are acceptable.
In this particular case it was possible to have up to three functions (lift, tilt and auxiliary) operating sequentially for up to 30 seconds each after initial activation. It did not require continual operator presence to do this (i.e. hold-to-run). This increases the risks from uncontrolled operation and meant that the operator could potentially leave the operator position and enter the danger area around the loader.
Any loader that operates through the tractor on-board auxiliary spool valves and is programmable is potentially affected. This will include loaders that are supplied both as original equipment and as after-market accessories.
Loaders and tractors that do not have programmable functions are not affected.
The Sector has approached the AEA (Agricultural Engineers Association), as the UK manufacturers and importers representative, to raise this with relevant members who include most of the major tractor and loader manufacturers.
HSE has advised relevant members of AEA to carry out the following actions;
Inspectors are asked to note this information and raise with dutyholders at relevant inspections or pursue during investigation of injury or complaint.
Where the supplier has failed to take the action outlined above enforcement action may be appropriate. Inspectors should follow the guidance in the ‘HSE guide to inspection of manufacture and supply’ and product safety intranet website
Details of any enforcement action should be relayed to the product safety team and copied to Safety Unit as Safeguard Notification may be required to the European Commission.
The benchmark is nil or negligible where the loader controls are hold-to-run. Where the controls can be programmed there is a remote possibility that the operator could enter the danger zone and a substantial risk gap is indicated by the EMM.
