Essential health and safety requirements (EHSRs) of the Machinery Directive
The UK has left the EU, new rules from January 2021
The transition period after Brexit comes to an end this year.
Annex 1 of the Directive details the EHSRs for machinery (it is reproduced in full at schedule 2 of the UK regulations). The EHSRs are comprehensive and cover all aspects of the health and safety of machine users, and also others who may be affected (eg the safety of products used by consumers processed by certain machinery).
They are laid out in six sections:
- general remarks common to all products in scope. They include: safety principles, design to facilitate handling, ergonomics, control systems, protection against mechanical hazards, other hazards such as from electricity and other forms of energy, temperature, fire and explosion, emissions from noise, vibration, radiation and hazardous substances, maintenance, cleaning and information (including sales literature) and markings / warnings
- those relating to certain classes of machines, including machinery for foodstuffs, cosmetics and pharmaceuticals (eg to prevent cross contamination of the materials processed), for portable hand-held and hand-guided machinery (particularly information about vibration emissions), and machinery for working wood and materials with similar characteristics
- requirements to offset hazards due to the mobility of work equipment, including operating / seating positions, controls, roll-over, turning over, falling object protection, means of access, power transmission between machinery, and towing
- requirements to offset hazards due to lifting operations, including stability, lifting accessories, information and marking
- requirements for machinery intended to work underground, and
- requirements for machinery lifting persons, including for greater strength / safety margins, and risks to persons being carried
Machinery, and other products in scope, must meet all relevant EHSRs where the corresponding hazard exists when the machine is used under conditions foreseen by the responsible person or in foreseeable abnormal situations. So for example a mobile elevating work access platform (MEWP) must meet all those relevant in sections 1, 3, 4 & 6 (and if it was intended for use underground then the EHSRs in section 5 would also apply).
The key EHSRs 1.1.2 Principles of safety integration, 1.7.3 Marking and 1.7.4 Instructions must be met for all products in scope of the Directive. However, taking account of the state of the art, it may not be possible to meet all of the objectives set by the EHSRs. Where this is not possible machinery must, as far as possible, be designed and constructed with the purpose of approaching the objectives of the EHSRs.
These principles are set out in EHSR 1.1.2 and in the 'General Principles' which are stated at the beginning of Annex 1. The iterative process of risk assessment and risk reduction in designing and constructing safe and complaint machinery is described there. EHSR 1.1.2 builds on this with the following fundamental principles:
- In selecting the most appropriate methods, the manufacturer or his authorised representative must apply the following principles, in the order given:
- eliminate or reduce risks as far as possible (inherently safe machinery design and construction),
- take the necessary protective measures in relation to risks that cannot be eliminated,
- inform users of the residual risks due to any shortcomings of the protective measures adopted, indicate whether any particular training is required and specify any need to provide personal protective equipment
Whilst its use is not compulsory, the harmonised standard BS EN ISO 12100:2010 Safety of machinery - General principles for design - Risk assessment and risk reduction (available from BSI) provides fundamental guidance and an overall framework for designers making decisions during the development of machinery to enable them to design machines that are safe for their intended use.