Cracking the new safety code

By John McAuliffe, Managing Director, Pilz Ireland.

John McAuliffe, Managing Director Pilz Ireland

On December 31st 2009, the new European machinery directive 2006/42/EC came into force. (So did the corresponding revision to Irish legislation “Machinery Regulations 2008 (SI 407/08)”). For some it will be considered as more Eurocentric red tape, but those who use the framework of the regulations in a positive process will find a code for preventing serious injury in the workplace.

Twenty years ago the EU introduced the Machinery Directive with the aim of ensuring the free movement of machinery by guaranteeing a high and a common level of protection in the areas of health and safety. Despite improvements, accidents relating to the use of machinery still remain a tragic and costly reality today. In the EU each year more than 500 million workdays, and 3% of member countries’ GDP, are estimated to be lost to workplace accidents, while research by the Health and Safety Authority in Ireland shows that 11% of workplace accidents related to “machine problems” – Health and Safety Workplace Accidents (2005) – the majority within the manufacturing sector. Research here by the Personal Injuries Assessment Board (PIAB), meanwhile, showed that out of eleven awards of compensation for personal injury in excess of €100,000 granted in 2008 seven related to machinery accidents.

The new safety directive takes into account extensive work into uncovering the nature of such accidents, such as research carried out by The BG Institute for Occupational Safety and Health in Germany (BGIA) and the Swiss Agency SUVA. Such studies show for instance, that once automated systems became the norm, accidents decreased due to less human machine interaction. However occupational accident incidence reached a plateau and did not decline any further.

In 25% of accidents studied, workers’ bypassing safety systems is a contributory cause of the accident, with research showing that workers do so because there is a benefit for them and because management supported such behavior. Similarly, safety concepts that do not hinder the working process are usually not tampered with, while those that do are more likely to be bypassed.

To counter such behaviours, and reflect new thinking in workplace safety, under the new directive manufacturers are required to consider “the hazards that exist … in the conditions foreseen by the manufacturer… or in foreseeable abnormal situations”. New prevention methods and technologies need to be considered to ensure a safe intervention if for certain operations, the machinery must be operated with a protective device removed or disabled.

Risk assessment as an ongoing, iterative process is now enshrined unambiguously in the new directive, with the previous obligation “… to assess the hazards ….” replaced with a much stronger statement:

  • “The manufacturer of machinery … must ensure that a risk assessment is carried out …. By the iterative process of risk assessment and risk reduction …, the manufacturer … shall: eliminate the hazards or reduce the risks associated with these hazards by application of protective measures…”

In practical terms, companies manufacturing machines will therefore need to ensure that a defined iterative process is carried out effectively and that the results are demonstrably incorporated in the machine design, recorded in the technical file and reflected in the instructions for use.

Some of the other most significant changes include:

  • there is a requirement to consider foreseeable human error
  • a new definitions of machinery including the introduction of the new concept, that of partly completed machinery
  • instructions on the use of machines must not only take account of the intended use of a machine, but also any reasonably foreseeable misuse
  • there is an obligation to consider control systems and protective devices to automatically prevent start up if it detects somebody in a danger zone.

For manufacturers and users alike the implementation of the new safety directives will prove challenging initially. Ultimately the effort will be rewarded when the new directive is used in a collaborative effort involving the manufacturer of the machine, the machine user and those responsible for developing the machine safety concepts to prevent serious injury.

The author, John McAuliffe is Managing Director of Pilz Ireland – experts in the safety of human, machine and the environment.

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