LAWR

SAFETY EQUIPMENT Ensuring your MRF complies with the Machinery Directive Paul Laidler gives an overview of the Machinery Directive and what machinery operators should be aware of. ll new machinery in scope of the Machinery Directive has to be designed and constructed to meet common minimum European requirements for safety. The outward signs of compliance are CE marking on the equipment and a Declaration of Conformity, which is normally issued by the manufacturer. The current Machinery Directive (2006/42/EC) came into full effect four years ago, with an extended scope which now goes beyond what might once have be considered a 'machine', to include lifting accessories and chains, ropes and webbing and an indicative list of safety components. The designer must also take into consideration the full lifecycle of the machine. It is therefore vital for purchasers of Materials Recovery Facility (MRF) machinery to be aware of the legal requirements with which their suppliers must comply to ensure that the correct design and certification processes have been followed. Also, design engineers creating a production line by linking two or more machines must consider the Directive's requirements for complex assemblies. Even if each individual machine complies with the Machinery Directive, it is the assembly that is now considered to be the machine and must itself comply. Similarly, if modifications are carried out that alter the performance or function of a machine or complex assembly, this is also considered to be creating a new machine, which once again must be shown to comply with the Directive. The Directive's Essential Health and Safety Requirements (EHSRs) cover aspects such as guarding and other safety features that must be built into a machine before it can carry the CE marking to show that it conforms to EU requirements. While previous incarnations of the Directive referred only to 'safety components', the latest edition gives an indicative list of what those safety components are, one of which is guarding. One key requirement is that all fixed guards must be removable only with the aid of tools, that guards should be incapable of remaining in position when their fixings have been removed, and that their fixings need to remain attached to the guard when it is removed from the machine. This means that ordinary machine screws and bolts can no longer be used as a means of attaching guards, unless provision is made for the screws or bolts to be held captive when the guard is removed. The Essential Health Safety Requirements also deal in some detail with operator controls, for example requiring that manual controls are designed to prevent hazardous conditions arising. It also states that manual controls must be clearly visible and identifiable and that the use of pictograms is recommended. Some machine engineers may well take this as a cue for moving to the use of computerised human machine interfaces (HMI) devices, where high visibility is easy to achieve and virtually any type of pictogram, or combination of pictograms and words, can be implemented. The Directive also covers the positioning of machinery control stations. These must be sited so that the operator can see that there are no persons in the danger zone and measures must be taken to ensure that the machine can only be controlled from predetermined locations. Also, each control station must be provided with a full set of control devices, which is possibly another argument in favour of using computerised HMI devices rather than conventional pushbuttons, switches and indicator lights. The right instructions All machines must now be accompanied by instructions in an official European Community language. If these instructions are supplied in the language in which they were originally written, they must be marked 'Original Instructions'. If, however, they are a translation, they must be marked 'Translation of Original Instructions' and they must be accompanied by a copy of the instructions in their original language. Clearly the Machinery Directive's requirements are sometimes complex and those responsible for the safety of MRF machinery must therefore familiarise themselves with the full text as the penalties for getting it wrong can be severe. A February 2014 Local Authority Waste & Recycling 23 Paul Laidler is business director for machinery safety at TÜV SÜD Product Service, a global product testing and certification organisation.

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