2. Staying legal: Machinery Safety and Visibility
Malcolm Kent
CEA Senior Technical Consultant

3. The Law for Manufacturers and Suppliers
Machines supplied into European Union must comply with:
The Machinery Directive
and, if applicable:
The Non-Road Mobile Machinery Engine Emissions Directive
The Low Voltage Directive
The Directive on Noise from Machinery Used Outdoors
The Electro-magnetic Compatibility Directive (radio interference)
The Directive on machines for use in explosive atmospheres
Components might need to comply with:
The Pressure Equipment Directive
The Simple Pressure Vessels Directive

4. The Machinery Directive
Sets out the process for assessing conformity:
Mainly self-assessment by the supplier/manufacturer
Third-party inspection required in some circumstances
Sets out the law with regards technical standards:
Gives a legal standing to European Standards which have been “harmonised”
Lays down a procedure to challenge those standards
Sets out the “Essential Health and Safety Requirements”
Very broad, general requirements (e.g. avoid risks from explosion)
Detailed technical requirements are often in the European Standards

5. The Machinery Directive
Recognises that it might be impossible to completely comply with the EHSRs:
Introduces the concept of the “state of the art”
Requires iterative risk assessment and risk reduction
Risk assessment: hierarchy of measures:
Design risk out
Protective measures (guard against risk)
Warn of residual risk
Requires risk reduction only where a risk exists:
If there is no actual risk there is no need to reduce it
Applies to normal use and “reasonably foreseeable misuse”

6. Visibility The Essential Health and Safety Requirement:
“Visibility from the driving position must be such that the driver can, in complete safety for himself and the exposed persons, operate the machinery and its tools in their foreseeable conditions of use. Where necessary, appropriate devices must be provided to remedy hazards due to inadequate direct vision.”
This is interpreted in the European Standard as:
“Earth-moving machines shall be designed in accordance with ISO 5006:2006 …”

7. ISO 5006 – two basic requirements
Visibility at 12m, on the ground, with specified maximum blind spots.
Visibility of 1.5m high object, 1m from the machine footprint. 300mm max blind spots.
12m

8. ISO 5006 – Status Citizens petition to the European Parliament
ISO 5006 has been officially deemed to be insufficient.
ISO 5006 is being updated but will not be ready for some time.
Manufacturers/suppliers need to refer to the EHSRs of the Directive

9. Visibility – HSE Guidance
The Health and Safety Executive have issued a guidance document:
Don’t panic!
Manufacturers/suppliers should:
1. Review visibility, taking into account:
The existing requirements of ISO 5006:2006;
The recommendations of the proposed amendments as they are developed
The current state of the art
The provision of information on residual risk.
Work towards the implementation of necessary changes
Inform users of residual risks – consider visibility maps

10. Visibility map HSE suggested format for warning of residual risk
Other forms of communicating risk are acceptable

11. The State of the Art The state of the art is never fixed
Direct visibility
3600 vision systems
Mirrors and cameras

12. HSE guidance to owners/operators
Reliance cannot be placed solely on equipment fully meeting EHSRs.
Undertake risk assessments to determine how the machinery should be used safely.
Fit additional visibility aids (e.g. CCTV) to a machine if it is identified that these are needed through the risk assessment process.
“Where earth moving machinery has been properly assessed, the job suitably planned and safe systems of work introduced (pedestrian segregation, etc), then it should be possible to operate the plant safely …”

13. Questions and discussion
Staying legal: Machinery Safety and Visibility
Questions and discussion
CEA
Malcolm Kent
Senior Technical Consultant