Changes for lifting equipment in line with the new EU Machinery Directive

Changes for lifting equipment in line with the new EU Machinery Directive

The previous Machinery Directive 98/37/EU ceased to be valid on 29.12.2009. The provisions of the new Machinery Directive 2006/42/EU must now be implemented. The new Machinery Directive has been binding since 29.12.2009. This also includes what are known as risk assessments, which replace the risk analyses.
Has only the name changed? Or has the content been altered? How must we use lifting equipment in the future?

The risk assessment replaces the previous risk analysis.

The risk assessment replaces the previous risk analysis in the new Machinery Directive 2006/42/EU.
In a risk assessment, all the potential hazards that could occur in the machine operator's working environment are taken into account. In the older risk analyses, only the hazards that could be caused by the machine were evaluated.

Risk assessment as a design guideline

In accordance with the new Machinery Directive, the manufacturer or its authorised representative* must ensure "that a risk assessment is carried out to establish which health & and safety requirements the machine is subject to. The machine must then be designed and constructed within the scope of the conclusions drawn from the risk assessment."
As part of a risk assessment, each individual health & safety requirement must be determined for a certain machine before being implemented. The risk assessment demanded in the General Principles of Annex I no. 1 must also be part of the development and manufacturing process.
The risk assessment is not a post-construction process to establish what risks are associated with a finished machine. Hazards which only become apparent at this stage can only be eliminated or reduced at great expense.

Risks continue to exist over the entire product life cycle

Risks assessed in line with the new Machinery Directive are not just limited to initial assembly and normal operation. The risk assessment must account for so much more, including during the design planning phase and all product life cycles of the machine. This includes in particular:

  • Assembly
  • Setup
  • Normal operation
  • Maintenance
  • Repair
  • Decommissioning
  • Disassembly

Even potential operator error has to be considered!

When determining and reducing risk, much more than just the intended use of the machine must be taken into account. The risk assessment must also account for all possible misuse scenarios that are reasonably foreseeable. This can be understood as every possible use of a machine imaginable, even uses that are not specified or not intended by the manufacturer.
For example, if a certain machine could be used for lifting loads, even though the machine was not designed for this purpose, then the very possibility alone requires that the resulting risks are still taken into account.

Carrying out a risk assessment

The new Machinery Directive outlines how a risk assessment is to be performed. Carrying out a risk assessment is not a simple process and requires specially trained personnel, especially with respect to lifting equipment.
While the previous Machinery Directive 98/37/EU did not provide any detailed instructions on carrying out the risk analysis that it required, the new Machinery Directive details procedural notes in Annex I. Therefore the following steps must be completed in a repetitive fashion when performing a risk assessment:

  • Determine the limits of the machine (intended use and every reasonably foreseeable misuse must be considered)
  • Determine the hazards that the machine could present, and the corresponding hazardous situations (consciously work through every working step of the machine)
  • Estimate risks in light of the severity of possible injuries or damage to health and the probability of each scenario occurring
  • Evaluate risks in order to determine the measures necessary to reduce risk
  • Eliminate or reduce hazards by implementing protective measures

Priority of possible protective measures

A simple list of the risks identified, for example in the operating instructions, is not sufficient. Protective measures must be implemented, for which the new Machinery Directive specifies a clear order of priority:

1. Risk reduction through design measures
2. Implement additional protective measures against the remaining risks that cannot be eliminated through design or constructional alterations to the machine
3. List risks that still remain after steps 1 and 2 in the user information, including notes on requisite specialist training, induction measures and personal protective equipment alongside regular inspections on behalf of the machine owner to ensure the operator is following the correct procedure

Technical documentation

In accordance with the new Machinery Directive, the technical documentation for each piece of lifting equipment must include information on the risk assessment process, safety requirements, the protective measures taken and any remaining risks.
The technical documentation for lifting equipment must now be much more detailed, and close cooperation between the manufacturer, on-site application consultant and the user is of fundamental importance. Individual processes have to be visually represented and particular risks covered in depth.
Occasionally, the operating instructions require updating after the machine is used for the first time (e.g. application photos, procedural notes).

Consequences

  • Risk assessments for lifting equipment may only be carried out by specially trained experts or by the manufacturer.
  • If every risk has not been identified, then the lifting equipment must not be manufactured.
  • Technical documentation is much more time-intensive to create and results in higher costs.

Author: Boris Franke (Managing Director Axzion GKS Stahl- & Maschinenbau GmbH)

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