By Neil Dyson
All new machinery within the scope of the Machinery Directive has to be designed and constructed to meet common minimum European requirements for safety. It must also meet the requirements of the EMC Directive (2004/108/EC).
All electric devices or installations influence each other, or cause interference, when interconnected or close to each other. The purpose of EMC (electromagnetic compatibility) is to keep such side effects under reasonable control:
The only machines that are not subjected to conformity assessment with the essential requirements of the EMC Directive are fixed installations. The European Commission’s Guide for the EMC Directive 2004/108/EC (8th February 2010) defines a fixed installation as “a particular combination of several types of apparatus and, where applicable, other devices, which are assembled, installed and intended to be used permanently at a predefined location.”
The guide also states that the term ‘fixed installation’ also applies to large machines, such as production lines. Often the presumption is that if machinery is screwed to the floor it can be considered a fixed installation. However, if such a machine, or assembly of machines into a production line, is moved and modified at any time, it ceases to become a fixed installation. It is therefore very rare that something that is presumed to be a fixed installation actually is.
The Provision and Use of Work Equipment Regulations 1998 (PUWER) describes what an employer needs to do to protect employees in the workplace. Section 10 states that “every employer shall ensure that an item of work equipment has been designed and constructed in compliance with any essential requirements”.
This means that machinery owners must ensure that the equipment which their employees use is EMC compliant. For example, if the control system of a machine experiences electromagnetic interference it may malfunction and create a dangerous situation. Conversely, if the electrical and electronic systems fitted to a machine generate a high level of interference, it may also cause other equipment nearby to malfunction.
The Health and Safety Executive considers that “if it is reasonably practicable to carry out testing for immunity to electromagnetic disturbances, then the Health & Safety at Work Act requires that such testing is carried out. Testing would only be considered as not being ‘reasonably practicable’ if the costs of testing were grossly disproportionate to the resulting reduction in risk.”
The reality is that a fixed installation in a manufacturing plant could still electromagnetically interfere or be interfered by other machinery, potentially creating a health and safety hazard. A best practice approach would therefore be to conduct onsite pre-compliance EMC tests, even if machinery might fall within the fixed installation definition. While full compliance is not required, such test results would demonstrate a machine is not susceptible to or giving out electromagnetic interference.
For manufacturers of machinery, they may wish to consider the independent support of a Notified Body to prove due diligence. For most machinery, the Responsible Person (the manufacturer or their authorised representative) can self-certify a product’s conformity. However, for higher risk machinery, the Responsible Person has to follow a different conformity assessment procedure that requires the direct involvement of an accredited Notified Body to verify independently the product’s compliance and in some cases the manufacturer’s quality and manufacturing system.
While fixed installations are not required to be covered in this way, their EMC assessment could be ‘bolted on’ to a wider assessment programme that a Notified Body is conducting on site. There will of course be a charge, but it will be a relatively small cost as part of the overall assessment and provide significant evidence that due diligence has been adhered to.
While some machinery owners presume that they have a fixed installation, we often discover otherwise as an assembly is usually not truly fixed and therefore subject to conformity assessment with the essential requirements of the EMC Directive. Even if a genuine fixed installation is in place, machinery safety sense would dictate that a simple EMC test process should be conducted to assure the safety of employees operating equipment.
Neil Dyson is business line manager for Machinery Safety at TÜV SÜD Product Service
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