While reading the new Guide to application of the Machinery Directive 2006/42/EC, Edition 2.1, I was interested to see that the last sentence in section 42, dealing with Safety Components and their status under the Machinery Directive, is this:
Specific guidance on safety fences as a safety component is given in §411.
I found this interesting for two reasons:
- There is no mention of the term “Safety Fences” in Edition 2.0. (see above picture).
- Section 411 is an addition to Edition 2.1, it is not revised.
Section 411 describes that safety fences are safety components per 2006/42/EC, Article 1 (1) (c). Additionally, three common scenarios that are faced by machinery manufacturers are detailed. Below, I have summarized the scenarios and what the Machinery Working Group says about them in section 411.
Scenario 1 – the safety fence is not considered a Safety Component per Article 1 (1) (c).
- The machinery manufacturer either designs and builds a proprietary safety fence for a specific machine or completely designs the safety fence and hires a fence manufacturer to make the safety fence from the manufacturer’s design.
Scenario 2 – the safety fence is considered a Safety Component per Article 1 (1) (c).
- The fence manufacturer performs the design and build function for a safety fence for a third party’s machine. That is to say, the machinery manufacturer hires a fence manufacturer to look at the machine, design the safety fence, and deliver the safety fence to the machinery manufacturer. In scenario 2 the machinery manufacturer must require a CE marking on the delivered safety fence and a declaration of conformity (and everything else required by the Machinery Directive 2006/42/EC per Article 5 (1)).
Scenario 3 – the safety fence is not considered a Safety Component per Article 1 (1) (c).
- A supplier or manufacturer supplies a safety fence component to a machine builder or as a replacement part for an existing fence in service on EU soil. In scenario 3 it is defined that safety fence components are not to be considered as safety components under the Machinery Directive. However, section 411 does clarify that an individual component of a safety fence that has a direct safety function, such as a gate, could be considered as a safety component on its own.
If you are sending a machine to the EU, or preparing a bid to build one for a European customer: please call us. We will sort out the requirements beforehand and will give you an accurate price for the CE marking evaluation and testing services that you will need. Many of our projects start this way, a year or more before we start any compliance work.
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