How to comply with the EHSRs

Schedule 2 to the Supply of Machinery (Safety) Regulations 2008, contains the Essential Health and Safety Requirements (EHSRs) that are considered necessary to be complied with before the machine or product can be placed on the market or put into use within the European Economic Area.

Preliminary observations

The starting point is Part 1 Preliminary observations – which determine how the rest of the EHSRs should be interpreted. These give three main directions that control the way the rest of the EHSRs should be dealt with.

  • The EHSRs only apply when the corresponding hazards exist, but these requirements: apply to every machine.
    • 1.1.2 (Principles of safety integration)
    • 1.7.3 (Marking)
    • 1.7.4 (Instructions)
  • There should be a risk assessment carried out for each identified hazard.
  • Every effort should be made to comply with the absolute nature of the Essential Health and Safety Requirements. If it is not possible to meet the objectives set by the EHSRs, the machines should at least be designed with the purpose of approaching these objectives, taking into account the state of the art.

Principles of safety integration

When producing a safe machine, the Principles of Safety Integration are the core of the Machinery Regulations and should be fully understood before any work is started on the design of a relevant product.

EHSR 1.1.2 – the Principles of Safety Integration – gives the basic approach to be used in the assessment of all risks to health and safety for any machine. It includes all stages of the machine's use, from assembly to scrapping, under conditions of foreseeable use and misuse. Designers should:

  • Identify all hazards to health and safety; then
  • Do a risk assessment; and, on the basis of the risk assessment
  • Eliminate or minimise the risks by (in order of precedence) :
    • design measures.
    • provision of protective devices.
    • provision of information on residual risks and the precautions needed to deal with them.

Marking and identification

EHSR 1.7.3 – Marking – requires that:

  • all machines are marked so that the manufacturer and the machine type can be identified;
  • any special operating limits are given; and
  • the CE mark is fixed to the machine or product.

Operator instructions

EHSR 1.7.4 – Instructions – requires the supplier to provide operating instructions and sales literature. This should contain information about the safe use of the machine including transporting, installation, operation and maintenance,  through to scrapping. There are particular requirements for information on noise and vibration, depending on the level emitted by the machine under stated test conditions.

Remaining EHSRs

The rest of the EHSRs can then be evaluated to see if they are relevant and the Principles of Safety Integration applied.

If properly done, the above procedure will ensure that machines will be placed on the market that are safe for the intended use. To achieve this, the designer must have a clear understanding of:

  • the performance requirements of the machine;
  • how the machine will be used (not always the same as the performance requirements);
  • the accident history of similar machines;
  • the legal requirements applied to the machine or industry; and
  • sources of information, including national standards, and professional publications.

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