Machine safety is not one set of rules but three layers that apply at the same time. The product rules say what a machine has to meet before it is placed on the market. The design standards say how that level is calculated and evidenced. The user rules say what you have to do with the machine afterwards — check it, maintain it, take it out of service. Questions get hard when they are asked in the wrong layer: a machine can be correctly CE marked and still be used wrongly, and it can be maintained impeccably without ever having had a technical file. In the design layer the starting point is risk assessment to EN ISO 12100, which Verkio describes step by step.
The three layers, and where each belongs
The product requirements
The new Machinery Regulation: who becomes the manufacturer, when a rebuild is a substantial modification, and what the technical file has to contain.
Safe control systems
Performance Level, category and verification — how reliance on a safety function is calculated instead of being a matter of opinion.
Lifting
Lifting appliances and accessories: CE marking, equipment made in-house, lift planning, inspection and discard criteria.
The questions that tell you which layer you are in
- Is the machine about to be placed on the market or put into service for the first time? Then it is the product rules, and the manufacturer role may be yours.
- Have you changed something in the machine? Then the substantial modification assessment decides whether you just became the manufacturer of a new machine.
- Is the question about how much a protective function can be relied on? Then it is the design standards and a calculation, not a view.
- Is it about how the equipment is used, checked and discarded? Then it is the user rules, and they apply to a flawlessly CE marked machine as much as to any other.
The CE mark says something about the machine, not about the work
A CE mark is the manufacturer's declaration that the machine meets the product requirements when it leaves them. It says nothing about how it is rigged, who operates it, or whether the guard has been bypassed since the spring. Both sides need their own answer.
Questions about machine safety
- We have a systematic work environment management system. Is that enough?
- For the user side it is the foundation, but it does not answer the product question. No routine for safety walkarounds turns a machine you rebuilt into a machine with a technical file and a declaration of conformity. They are two obligations, and they rest on different evidence.
- Who here needs which course?
- Anyone who designs or reviews safety functions needs the control systems part. Anyone who rigs, inspects or buys lifting equipment needs the lifting part. Anyone who owns a rebuild project needs the Machinery Regulation. The roles often overlap in a smaller organisation, and then it is the same person who needs several.
- Does this only apply to new machinery?
- No. The product rules bite on what you place on the market or modify substantially, but the user rules and the requirements on lifting accessories apply to equipment you have had for thirty years just as much as to what arrived last week.
Training in machine safety
Online courses at your own pace, plus an instructor-led half day on the regulation. Licences are bought as a number and handed out to design, maintenance and purchasing in the portal.
See the courses