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Scope

In order for machinery to be placed on the European market and put into service in the EEA, the manufacturer, or his authorized representative in the community, must demonstrate its compliance with the Machinery Directive, 9837/EC, as amended. Typically, the machinery must also be compliant with the Low Voltage Directive (LVD), 73/23/EEC and the Electromagnetic Compatibility (EMC) Directive, 89/336/EEC, both as amended.

Machinery is defined by the directive as:

"...an assembly of linked parts or components, at least one of which moves, with the appropriate actuators, control and power circuits, etc. joined together for a specific application, in particular for the processing, treatment, moving or packaging of a material."
"...an assembly of machines which, in order to achieve the same end, are arranged and controlled so that they function as an integral whole."
"...interchangeable equipment modifying the function of a machine, which is placed on the market for the purpose of being assembled with a machine or a series of different machines ... in so far as this equipment is not a spare part or a tool."

AND

"...safety components, [meaning] a component, provided that it is not interchangeable equipment, which the manufacturer ... places on the market to fulfill a safety function when in use and the failure or malfunctioning of which endangers the safety or health of exposed persons."

Examples of safety components include, but are not limited to safety mats, safety light curtains, safety interlocks and guards.

Exclusions

Consistent with most European Directives, the MD provides a list of equipment which is considered to be outside the scope of this Directive. While this list contains equipment which may fit the definition of machinery, these items are regulated under other European legislation.

One key exclusion in Article 1, Paragraph 5 states, "Where, for machinery, the risks are mainly of electrical origin, such machinery shall be covered exclusively by [the Low Voltage Directive.]" If the risks are not mainly electrical, then the equipment must be evaluated for compliance with the MD. This exclusion requires a decision to be made by the manufacturer as to the main hazards associated with their product.

Annex I

"Machinery or safety components covered by this directive may be placed on the market, and put into service only if they do not endanger the health or safety of persons and, where appropriate, domestic animals or property, when properly installed and maintained and used for its their intended purpose."

To that end, machinery shall satisfy Annex I of the MD titled, "Essential Health and Safety Requirements Relating to the Design and Construction of Machinery and Safety Components".

Annex I begins with three Preliminary Observations, and are summarized as follows:

  1. The obligations laid down by the EHSRs apply only when the corresponding hazard exists. The requirements relating to Principles of Safety Integration, Marking and Instructions are mandated for all machinery, regardless of the means for determining compliance.
  2. The EHSRs are mandatory. Taking into account the state of the art, machinery must, as far as possible, be designed and constructed with the purpose of approaching compliance.
  3. The EHSRs are grouped according to types of hazards. The manufacturer is under an obligation to assess the hazards which apply to his machine.

Only one subclause of Annex I addresses electrical safety. Clause 1.5.1 states, "Where machinery has an electricity supply, it must be designed, constructed and equipped so that all hazards of an electrical nature are or can be prevented.

The remainder of Annex I is concerned with other types of hazards (e.g., mechanical, chemical, etc.), instructions, markings and general engineering practices. The safety of the machine in all phases of its life are considered. The manufacturers must ensure personnel safety during installation, adjustment, cleaning, operation, maintenance and dismantling.

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