Introduction to the NEW EU Machinery Safety Regulation 2023/1230

European Machinery Regulation (EU) 2023/1230 replaces Machinery Directive 2006/42/EC. Although the Regulation has entered into force, a transitional period permits continued CE marking under the previous Directive while stakeholders adapt to new requirements.

This guide summarizes the principal distinctions between the Directive and the Regulation. It is not a procedural manual for CE marking under the new Regulation. Manufacturers and responsible parties retain full responsibility for ensuring compliance with the Machinery Regulation and any other applicable European Directives or Regulations relevant to their products.

In addition, it has become necessary to bring aspects of the Machinery Regulation into alignment with the EU’s New Legislative Framework (NLF) comprising Regulation (EC) 765/2008 (accreditation and market surveillance of products), Decision 768/2008 (common framework for the marketing of products) and Regulation (EU) 2019/1020 (market surveillance and compliance of products).

The assessment of whether machinery is safe requires detailed mechanical knowledge and a solid grasp of the technical requirements as laid out in the EU Machinery Regulation 2023/1230 – to be legally binding from 2027), corresponding harmonised Standards or other relevant Standards and replaces the old EU Machinery Directive 2006/42/EC.

Standards applicable in the European Union are EN, which are regularly reviewed and updated by the relevant technical committees. There are other standards published by other bodies (e.g. ISO, BSI, ASTM) which can be useful references.

Determining what is relevant to the machinery in question demands knowledge of e.g. the difference between standard types.

• Type A Standards set out concepts, design principles etc that can be applied to all machinery.

• Type B Standards cover safety aspects or one safeguard type which can be used across a wide range of machinery.

• Type C Standards (also known as harmonised standards) set out safety requirements for a particular machine or group of machines. These standards have a presumption of conformity with the essential health and safety requirements listed in the machinery regulation.

When a Type C Standard deviates from Types A or B Standard, the Type C Standard takes precedence. Another aspect is whether the technical requirements outlined in a standard are normative (prescriptive/mandatory) or informative (descriptive/guidance). 

An important aspect of machinery safety is guarding. The fundamental principle is to fully enclose all dangerous parts and only have parts exposed which are essential to the required function of the machine. For example, a fan will have a motor drive shafts etc fully enclosed. A large portion of the rotating fan blades will require guard ensuring the fan blades cannot be touched when in operation. Other safety measures must be implemented, for example operational measures such as the use of interlocks or two handed controls There are of course many other aspects to machinery design which relate to personnel safety e.g. safety distances. To protect the operator from the risk of entanglement, crushing and shearing, all moving parts are protected by enclosures or guards. In line with EN ISO 14120: and EN ISO 13857:

Note: that, as with the old Directive, the definitions are similar to but not identical to those in, for example, IEC 62061:2021 (Safety f machinery. Functional safety of safety-related systems), ISO 12100:2010 (Safety of machinery. General principles for design. Risk assessment and risk reduction)

ANNEX II - INDICATIVE LIST OF SAFETY COMPONENTS

The list of safety components in the Regulation contains 20 points. The first 17 are essentially the same as those in the old Directive (which contained just 17 points). In addition, the following three safety devices are listed in Annex II of the Regulation: Software ensuring safety functions; Safety components with fully or partially self evolving behaviour using machine learning approaches ensuring safety functions; and Filtration systems intended to be integrated into machinery cabins in order to protect operators or other persons against hazardous materials and substances, including plant protection products, and filters for such filtration systems.

The inclusion of software shows that it is to be treated in the same way as other safety components, while the second new point is another instance of the Regulation addressing the hazards associated with machine learning, often referred to as artificial intelligence (AI).

1. Guards for removable mechanical transmission devices.

2. Protective devices designed to detect the presence of persons.

3. Power-operated interlocking movable guards designed to be used as safeguards in machinery referred to in points 9, 10 and 11 of Annex I, Part B.

4. Logic units to ensure safety functions.

5. Valves with additional means for failure detection intended for the control of dangerous movements of machinery.

6. Extraction systems for machinery emissions.

7. Guards and protective devices designed to protect persons against moving parts involved in the process of the machinery.

8. Monitoring devices for loading and movement control in lifting machinery.

9. Restraint systems to keep persons in their seats.

10. Emergency stop devices.

11. Discharging systems to prevent the build-up of potentially dangerous electrostatic charges.

12. Energy limiters and relief devices referred to in sections 1.5.7, 3.4.7 and 4.1.2.6 of Annex III.

13. Systems and devices to reduce the emission of noise and vibrations.

14. Roll-over protective structures (ROPS).

15. Falling-object protective structures (FOPS).

16. Two-hand control devices.

17. The following components for machinery designed for lifting and/or lowering persons between different landings:

(a) devices for locking landing doors;

(b) devices to prevent the load-carrying unit from falling or unchecked upwards movement;

(c) overspeed limitation

(d) devices; energy-accumulating shock absorbers, non-linear or with damping of the return movement;

(e) energy-dissipating shock absorbers;

(f)  safety devices fitted to jacks of hydraulic power circuits and used to prevent falls;

(g) safety switches containing electronic components.

18. Software ensuring safety functions.

19. Safety components with fully or partially self-evolving behavior using machine learning approaches ensuring safety functions.

20. Filtration systems intended to be integrated into machinery cabins in order to protect operators or other persons against hazardous materials and substances, including plant protection products, and filters for such filtration systems.

Essential health and safety requirements (EHSRs) Annex III

This Annex correlates with the old Directive’s Annex I. Much of the text is unaltered but the following significant changes are noted.

Part A, Definitions, was included as 1.1.1 in the old Directive’s Annex I. The same nine terms are defined, with the definitions being all but identical to those in the old Directive. Note that, as with the old Directive, these definitions are similar to but not identical to those in, for example, IEC 62061:2021 (Safety f machinery. Functional safety of safety-related systems), ISO 12100:2010 (Safety of machinery. General principles for design. Risk assessment and risk reduction) and ISO 14120:2015 (Safety of machinery. Guards. General requirements for the design and construction of fixed and movable guards).

Part B, General principles, is very similar to the General principles laid down at the start of the old Directive’s Annex I. However, a new paragraph makes it clear that the risk assessment and risk reduction shall include hazards that arise throughout the lifecycle of the machinery or related product. It also makes a direct reference to self evolving behaviour or logic for machinery or related products with varying levels of autonomy.

Ergonomics (Clause 1.1.6) gives consideration to how operators interact with machinery or related products that have either fully or partially self-evolving behavior.

Autonomous mobile machinery (Clause 3.6.3.3) gains extra requirements, which are included in annex III and the supplementary essential health and safety requirements to offset risks due to the mobility of machinery or related products.

Protection against corruption (Clause 1.1.9) introduces cyber security requirements related to OT (Operational Technology) and has been added to cover the increase in industrial networks for safety systems, and also the generation of data to support the growth of connected enterprise solutions. It covers both hardware and software requirements.

Machinery needs to ensure that the connection of another device – either locally or remotely – doesn’t lead to a hazardous situation. In addition, any hardware component that transmits signals or data and has access to software that is critical for the machinery’s compliance to relevant health and safety requirements, needs to be protected against both accidental or intentional corruption, and will collect evidence of both legitimate or illegitimate interventions.

Finally, for protection against corruption, software and data that are critical for the compliance of the machinery or related products with the relevant health and safety requirements, shall be identified as such and shall be adequately protected against accidental or intentional corruption. The machinery or related product shall identify the software installed on it that is necessary for it to operate safely; and shall be able to provide that information at all times in an easily accessible form. The machinery or related product shall collect evidence of a legitimate or illegitimate intervention in the software or a modification of the software installed on the machinery or related product or its configuration.

Machinery Safety: Safety and reliability of control systems (Clause 1.2.1)

Control systems shall be designed and constructed in such a way as to prevent hazardous situations from occurring. They also should withstand where appropriate to the circumstances and risks, the intended operating stresses and intended and unintended external influences, including reasonably foreseeable malicious attempts from third parties leading to a hazardous situation.

It’s here that the link between safety and cybersecurity is evident. There is also the need for a tracing log containing the data generated in relation to an intervention, and of the versions of the safety software uploaded after the machinery or related product has been placed on the market or put into service. This needs to be enabled for five years after such an upload.

The requirement here is exclusively to demonstrate the conformity of the machinery or the related product with this EHSRs should a reasonable request from a competent national authority be made.

For OEMs developing control systems or logic with fully or partially self-evolving behaviour, that are designed to operate with varying levels of autonomy, additional requirements have been added into the EHSRs in Annex III.

They shall not cause the machinery or related product to perform actions beyond their defined task and movement space.

Recording of data on the safety related decision-making process for software-based safety systems ensuring safety functions must be enabled and retained for one year after the machinery or related product is place on to the market or put into service. At all times it must be possible to correct the machinery or related product in order to maintain its inherent safety.

Substantial modifications – explanation of Article 3 (16)

After being placed on the market or put into service, should machinery be modified, by physical or digital means (meaning hardware or software), in a way that is not foreseen by the manufacturer, and which affects the safety of such products by creating a new hazard or increasing an existing risk, the modification should be considered as substantial when significant new protective measures are required.

The person that carries out the substantial modification should be required to perform a new conformity assessment before placing the modified product on the market or putting it into service. This conformity assessment can be restricted to the part of the production line that has been modified, and so does not have to be completed for the whole assembly.

Compliance Route

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There is more emphasis in the regulation for third-party certification. However, self-certification is still possible as long as the machinery is in Annex I Part B and is built preferably using harmonized standards or a common specification. If the machinery is not in Annex I, the preferred route is to follow harmonized standards. The compliance route for this type of equipment is in Annex VI module A. For all other equipment, third-party certification through a notified body is required.

Annex VI, Internal production control (Module A) 

This annex correlates with Annex VIII of the old Directive, which is entitled ‘Assessment of conformity with internal checks on the manufacture of machinery’. It is largely unaltered but the following changes are to be noted.

The first three paragraphs have been redrafted but the content is essentially the same.

Paragraph 4, CE marking and EU declaration of conformity, is new. This states two requirements relating to: affixing the CE marking to the machinery or related product; and drawing up a declaration of conformity, keeping it for 10 years and making a copy available to the relevant authorities upon request.

Paragraph 5, Authorised representative, is new. This states that the manufacturer’s obligations under paragraph 4 can be fulfilled by an authorised representative provided those responsibilities have been specified in the mandate. Note that in the old Directive, paragraphs 1 and 2 simply refer to ‘the manufacturer or his authorised representative’.

Annex VII, EU type-examination (Module B)

This annex correlates with Annex IX of the old Directive, which is entitled ‘EU type examination’. It has been redrafted and expanded for clarity. In addition, the following changes are to be noted.

Subparagraph 7.2 is more specific about the manufacturer’s responsibility for notifying the notified body of modifications to the machinery or related product, or to the technical documentation, or to the state of the art, that may affect the conformity. Such modifications shall require approval in the form of an addition to the original EU type-examination certificate. Jumping ahead, subparagraph 7.6 presents a simplified review procedure to be applied when a manufacturer notifies a notified body about such a modification or change to the state of the art.

Subparagraph 7.4 introduces specific deadlines for renewing EU type-examination certificates. The manufacturer is now required to apply 12 months prior to expiry of the existing certificate at the earliest, and six months prior to expiry at the latest.

Subparagraph 7.5 includes the following statement: ‘The notified body shall ensure that the review procedure is finalised before the expiry date of the EU type examination certificate.

PART A Categories of machinery or related products to which a procedure referred to in Article 25(2) shall be applied:

1. Removable mechanical transmission devices including their guards.

2. Guards for removable mechanical transmission devices.

3. Vehicle servicing lifts.

4. Portable cartridge-operated fixing and other impact machinery.

5. Safety components with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions.

6. Machinery that has embedded systems with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions that have not been placed independently on the market, in respect only of those systems.

PART B Categories of machinery or related products to which one of the procedures referred to in Article 25(3) shall be applied:

1. Circular saws (single- or multi-blade) for working with wood and material with similar physical characteristics, or for working with meat and material with similar physical characteristics, of the following types:

1.1. sawing machinery with fixed blade(s) during cutting, having a fixed bed or support with manual feed of the workpiece or with a demountable power feed;

1.2. sawing machinery with fixed blade(s) during cutting, having a manually operated reciprocating saw-bench or carriage;

1.3. sawing machinery with fixed blade(s) during cutting, having a built-in mechanical feed device for the workpieces, with manual loading and/or unloading;

1.4. sawing machinery with movable blade(s) during cutting, having mechanical movement of the blade, with manual loading and/or unloading.

2. Hand-fed surface planing machinery for woodworking.

3, Thicknesses for one-side dressing having a built-in mechanical feed device, with manual loading and/or unloading for woodworking.

4. Bandsaws with manual loading and/or unloading for working with wood and material with similar physical characteristics, or for working with meat and material with similar physical characteristics, of the following types:

4.1. sawing machinery with fixed blade(s) during cutting, having a fixed or reciprocating-movement bed or support for the workpiece;

4.2. sawing machinery with blade(s) assembled on a carriage with reciprocating motion.

5. Combined machinery of the types referred to in points 1 to 4 and in point for working with wood and material with similar physical characteristics.

6. Hand-fed tenoning machinery with several tool holders for woodworking.

7, Hand-fed vertical spindle molding machinery for working with wood and material with similar physical characteristics.

8. Portable chainsaws for woodworking.

9. Presses, including press-brakes, for the cold working of metals, with manual loading and/or unloading, whose movable working parts may have a travel exceeding 6 mm and a speed exceeding 30 mm/s.

10. Injection or compression plastics-molding machinery with manual loading or unloading.

11. Injection or compression rubber-molding machinery with manual loading or unloading.

12. Machinery for underground working of the following types:

12.1. locomotives and brake-vans;

12.2. hydraulic-powered roof supports.

13. Manually loaded trucks for the collection of household refuse incorporating a compression mechanism.

14. Devices for the lifting of persons or of persons and goods involving a hazard of falling from a vertical height of more than 3 m.

15. Protective devices designed to detect the presence of persons.

16. Power-operated interlocking movable guards designed to be used as safeguards in machinery referred to in points 9, 10 and 11 of this Part.

17. Logic units to ensure safety functions.

18. Roll-over protective structures (ROPS).

19. Falling-object protective structures (FOPS).

Annex IV, Technical documentation

This annex in the Regulation correlates with Annex VII in the old Directive. As with the old Directive, the annex is divided into Part A for machinery and related products and Part B for partly completed machinery. A subtle change is that the old Directive refers to a ‘technical file’ for machinery and ‘technical documentation’ for partly completed machinery, whereas the Regulation now refers to ‘technical documentation’ for both.

Part A, Technical documentation for machinery and related products The Regulation’s Part A preamble no longer explains that the technical file must demonstrate that the machinery complies with the Directive. Instead, the preamble states that the technical documentation shall specify the means used by the manufacturer to ensure conformity with the EHSRs. Also, the preamble no longer requires the technical documentation to be compiled in one or more of the official Community languages. However, various articles in Chapter II (Obligations of economic operators) state that information and documentation shall be provided in a language that can be easily understood by the competent national authority requesting it.

As in the old Directive, Part A then goes on to list what the technical documentation shall include.

Whereas the old Directive requires the file to contain a ‘general description’ of the machinery, the Regulation requires a ‘complete description’. The precise meaning of ‘complete’ is unclear, yet the change implies the description should provide more than the ‘general’ description requires under the old Directive. In addition, the technical documentation now requires a complete description of the intended use of the machinery or related product, which is not required under the old Directive.

The new Regulation also seems to require more technical detail. The old Directive requires the file to contain an overall drawing, drawings of the control circuits and pertinent descriptions and explanations, plus full details drawings, calculations, test results, certificates, etc to check conformity with the EHSRs. In contrast, the new Regulation requires design and manufacturing drawings and schemes for the machinery or related products, components, sub-assemblies and circuits, plus descriptions and explanations necessary for understanding these, as well as the calculations, test results, inspections and examinations to verify conformity with the EHSRs.

Regarding standards and common specifications adopted by the Commission, the Regulation requires references to these to be included and, where only parts of these have been applied, the parts applied need to be stated. Where standards or specifications have only been partially applied or not applied at all, the technical documentation needs to describe what other technical specifications have been applied in order to meet each applicable EHSR.

Note that the old Directive requires the technical file to list the standards and specifications used and indicate which EHSRs are addressed by the standards and specifications. However, this correlation between standards and EHSRs is not required in the Regulation.

Another new requirement (h) in Part A is for a description of the means used by the manufacturer during production to ensure conformity of the machinery or related product with the design specifications.

Note that the old Directive’s Part A requires detailed plans and specific information about sub-assemblies used for the manufacture of machinery but only if such knowledge is essential for verifying conformity with the EHSRs. This is not included in the Regulation’s Part A but similar text is included in the preamble to the Regulation in paragraph (34): ‘Detailed plans of subassemblies used for the manufacture of the product within the scope of this Regulation should only be required as part of the technical documentation where knowledge of such plans is essential for assessing conformity with the essential health and safety requirements set out in this Regulation.’

There is a new requirement (m) for the technical documentation to include source code or programming logic of safety-related software to demonstrate conformity (but only further to a reasoned request from a competent national authority).

There is a new requirement (n) as follows: ‘for sensor-fed, remotely-driven, or autonomous machinery or related products, if the safety related operations are controlled by sensor data, a description, where appropriate, of the general characteristics, capabilities and limitations of the system, data, development, testing and validation processes used’.

The old Directive’s Part A includes a statement to the effect that the technical file must be made available to competent authorities for at least ten years. Although this requirement has been removed from Annex IV in the Regulation, the same requirement is included in Chapter II (Obligations of economic operators), Article 10(3). However, instead of the time starting from ‘the date of manufacture of the machinery or, in the case of series manufacture, the last unit produced’, Article 10(3) states ‘at least 10 years after the machinery or the related product has been placed on the market or put into service’.

The old Directive’s Part A makes it clear that the technical file does not have to be located in the Community, nor does it have to be available in material form. These points are not stated unambiguously in the Regulation, though in numerous places it is stated that the technical documentation must be available for inspection by competent national authorities. In Chapter II (Obligations of economic operators), various articles state that information and documentation shall be provided in paper or digital format.

The old Directive’s Part A states that a failure to present the technical file on request by a competent national authority may constitute sufficient grounds for doubting the machinery’s conformity with the EHSRs. An equivalent statement is not included in the Regulation but Article 46 (Formal non-compliance), paragraph 1(e) requires Member States to require the relevant economic operator to end the non-compliance when the technical documentation is either not available or incomplete for machinery or related products. Paragraph 2(b) requires the same in relation to partly completed machinery.

Part B, Technical documentation for partly completed machinery

Part B contains similar changes to Part A. However, there are some minor differences.

Part A, indent (b)(ii) requires the documentation for machinery and related products to include the following with respect to the risk assessment: ‘the description of the protective measures implemented to meet each applicable essential health and safety requirement and, when appropriate, the indication of the residual risks associated with the machinery or related product’, while the corresponding indent in Part B requires ‘the description of the protective measures implemented to eliminate identified hazards or to reduce risks and, where appropriate, the indication of the residual risks’. Interestingly, this text in the Regulation is identical to that in the old Directive.

Part A indent (j) requires the documentation to include the declaration of incorporation for partly completed machinery that has been incorporated. However, Part B does not contain the same requirement, yet it is conceivable that a partly completed machine could incorporate another partly completed machine.

Similarly, Part B does not contain the indent (k) of Part A, which requires the documentation to include copies of declarations of conformity of machinery or related products, as well as any products covered by other harmonised legislation, that have been incorporated – yet it is conceivable that partly completed machinery could incorporate, in particular, products covered by other harmonised legislation.

Strictly speaking, the documentation would have to ‘catch up’ when the documentation is prepared for the final machinery or end product, but preparing the final documentation would be easier if all of the appropriate declarations of incorporation and conformity were included in the documentation prepared for the partly completed machinery.

EU declaration of conformity and EU declaration of incorporation

This annex in the Regulation correlates with Annex II in the old Directive. As with the old Directive, the annex is divided into Part A (EU declaration of conformity of machinery and related products) and Part B (EU declaration of incorporation of partly completed machinery). Footnotes makes it clear that it is optional to number the declarations.

Generally speaking, under the Regulation, the declaration of conformity and declaration of incorporation shall contain essentially the same information as was required under the old Directive, but the presentation will have to be amended in order to comply.– 40 Both Parts no longer contain a requirement for the declaration to be drawn up under the same conditions as the instructions, nor is there a requirement for it to be typewritten or handwritten in capital letters. However, the preamble to the Regulation references Decision No 768/2008/EC of the European Parliament and of the Council (common framework for marketing of products), which requires the declaration to be translated into the language or languages required by the Member State in which market the product is placed or made available.

Part A, EU declaration of conformity of machinery and related products No…

Although it is not stated in the annex, paragraph (52) of the Regulation’s preamble permits a single declaration to be drawn up in cases where multiple EU legal acts apply. In contrast, paragraph 4 in the old Directive’s Parts A and B make provision for this.

In Part A, paragraph 3 is new, relating to lifting machinery intended to be installed in a building or structure and that cannot be assembled in the manufacturer’s premises. The address of the building or structure shall be stated in the declaration of conformity.

In Part A, paragraph 4 is new, requiring the following statement to be included in the declaration of conformity: ‘This declaration of conformity is issued under the sole responsibility of the manufacturer.’ In the old Directive,

Part A paragraph 3 requires the following to be included in the declaration of conformity: ‘description and identification of the machinery, including generic denomination, function, model, type, serial number and commercial name’. In the Regulation, this has been replaced by two paragraphs, 1 and 5, as follows: ‘1. The machinery or related product (product, type, model, batch or serial number) or substantially modified machinery or related product’ and ‘5. Object of the declaration (identification of the machinery or related product allowing traceability; where necessary for the identification of the machinery or related product, a colour image of sufficient clarity may be included).’

Part A, paragraph 6 covers part of the old Directive’s Part A, paragraph 4, by stating ‘The object of the declaration referred to in point 5 is in conformity with the following Union harmonisation legislation.’– 41

Part A, paragraph 7 combines the contents of the old Directive’s Part A paragraphs 7 and 8, as well as going further by requiring details to be provided about partially applied standards and specifications. The new paragraph 7 requires the following to be included in the declaration of conformity: ‘References to the harmonised standards referred to in Article 20(1) or common specifications adopted by the Commission in accordance with Article 20(3) that were applied, including the date of the publication of the reference to harmonised standards in the Official Journal of the European Union or of the common specification, or references to the other technical specifications, including their date, in relation to which conformity is declared. In the event of partial application of harmonised standards or common specifications, the EU declaration of conformity shall specify the parts which were applied.’ Note that it is insufficient to state the date of publication of harmonised standards, rather the declaration of conformity must also state the date of the publication of the reference to harmonised standards in the Official Journal.

Part A, paragraph 8 is more specific about the details required in relation to notified bodies and type-examinations. Paragraph 8 requires the following to be included in the declaration of conformity where applicable: ‘the notified body … (name, number) … performed the EU type-examination (Module B) and issued the EU type-examination certificate … (reference to that certificate), followed by conformity to type based on internal production control (module C) or the conformity based on unit verification (module G) or full quality assurance (module H).’

Part B, EU declaration of incorporation of partly completed machinery No…

Part B contains similar changes to Part A. However, there are some minor differences.

Part B, paragraph 6 refers to harmonised standards and common specifications adopted by the Commission. Note that whereas Part A paragraph 7 requires the declaration of conformity to state the date of the publication of the reference to harmonised standards in the OJ, Part B paragraph 6 only requires the declaration of incorporation to state the date of the standard or common specification.

Finally, Annex V no longer includes the ‘Custody’ paragraph that was contained in the old Directive’s Annex II, requiring the manufacturer or authorised representative to keep the original declaration of conformity or incorporation for at least 10 years from the last date of manufacture. Note, however, that the same requirement is now laid down in Chapter II (Obligations of economic operators) in various articles relating to different classes of economic operator, as well as both the declaration of conformity for machinery and related products, and the declaration of incorporation for partly completed machinery

Machinery Safety: Engineering Controls Beyond the Guard

Depending on the requirements and machinery risk assessment, there are other engineering control measures which can be implemented to protect machine operators. These fall broadly into presence-sensing and access-control categories –

Interlocking devices:

An interlocking device is typically a type of switch, integrated into a safety circuit of the control system, which acts to stop or prevent the hazardous operations of a machine until certain conditions are met (e.g. access door fully closed). There are several types of interlocking device available (see ISO 14119). This includes contact (mechanical cam/hinge, tongue-operated) and non-contact (magnetic, inductive etc) types.

For practical application the interface with the overall machine control system and possible failure modes have to be taken into account. Multiple interlocks (redundancy), actuated in different ways (diversity) are sometimes required.

In the real world, interlocks are also sometimes (deliberately) bypassed by machine operators, due to their perceived nuisance to operation/efficiency.

Light curtains: Where regular access is required, a solution often used is a light curtain. This is an electronic presence sensing device (ESPD), consisting of an emitter positioned on one side of an (access) opening which emit beams across to a receiver on other side. When a beam is broken, the hazardous operations of a machine will be prevented/stopped.

There are many factors which have to be taken into account for practical application of a light curtain. This includes the possible direction and angle of approach, the distance between the operator and the hazardous machinery, device resolution (density of beams), performance (e.g. reaction time) of the device etc (see ISO 13855).

Safety Mats: Safety or sensing mats are generally simpler in design but more limited in application than light curtains. The mat is essentially a pressure-operated switch that can be used to prevent hazardous operations. They can be used to keep an operator in one working zone (if they step off, the machine stops or is prevented from starting) or can be placed around the hazardous operation so that an operator walking on the mat triggers a shutdown. 

Two-handed controls:

Two-handed control of a machine is very useful if there is only one operator. It keeps the operator in the designated operational zone, a safe distance from any hazardous operations. When the operator releases one of the two controls, the hazardous operation of the machine is prevented/stopped. There are several different types (functional designs) of two-handed controls (see ISO 13851).

Our Machinery Safety Experts conduct comprehensive machine inspections, produce compliance reports aligned with applicable regulatory requirements, and prepare technical files evidencing conformity with relevant UK and EU legislation.