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Comparison of Legal Requirements: The Machinery Directive vs. the Machinery Regulation

1.1.6 Ergonomics

Changes

  • The requirement is strengthened by replacing "shall be reduced to a minimum" with "shall be eliminated or reduced to a minimum"

  • New requirement: "That demanding working postures or movements and physical exertions exceeding the operator's capacity are avoided."

  • New requirement: "That the human-machine interface is adapted to the operators' foreseeable characteristics, including in the case of a machine or related product with intended fully or partially self-developing behaviour or logic that is designed to operate with varying degrees of autonomy."

  • New requirement: "Where appropriate, that a machine or related product with intended fully or partially self-developing behaviour or logic that is designed to operate with varying degrees of autonomy is adapted to respond appropriately to humans (e.g. through speech or through gestures, facial expressions or body movement) and to inform operators of its planned actions (e.g. what it will do and why) in an understandable manner."

Proposed measures

  • Ensure that ergonomic risks are not merely reduced but eliminated where possible, and that this is documented in the risk assessment

  • Verify that working postures, movements, and force requirements are analyzed and that solutions are in place to prevent the operator's capacity from being exceeded

  • Check that ergonomic analyses cover real use cases (including variation among operators)

  • Ensure that the human-machine interface is adapted to the operator's foreseeable characteristics (e.g. understanding, reaction, behaviour)

  • If the machine has self-developing behaviour or any degree of autonomy:

  • Verify that the interface is designed to be understandable and predictable for the operator

  • Check that the machine can communicate its intended actions in an understandable manner

  • Ensure that the machine can respond appropriately to human presence and behaviour (e.g. via signals, movements or other interaction modes)

  • Verify that these functions are tested and validated from an ergonomics and safety perspective

Machinery Directive statutory text

1.1.6. Ergonomics

Under the intended conditions of use, the discomfort, fatigue and physical and psychological stress faced by the operator must be reduced to the minimum possible, taking into account ergonomic principles such as:

— allowing for the variability of the operator's physical dimensions, strength and stamina,

— providing enough space for movements of the parts of the operator's body,

— avoiding a machine-determined work rate,

— avoiding monitoring that requires lengthy concentration,

— adapting the man/machinery interface to the foreseeable characteristics of the operators.

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Machinery Regulation legal text

1.1.6. Ergonomics

Under the intended conditions of use, the discomfort, fatigue and physical and psychological stress faced by the operator shall be eliminated or reduced to the minimum possible, taking into account at least, the following ergonomic principles:

(a) allowing for the variability of the operator’s physical dimensions, strength and stamina;

(b) avoiding the need for demanding work postures or movements and manual force exertions that exceed the operator’s capacity;

(c) providing enough space for movements of the parts of the operator’s body;

(d) avoiding a machine-determined work rate;

(e) avoiding monitoring that requires lengthy concentration;

(f) adapting the human-machine interface to the foreseeable characteristics of the operators, including with respect to machinery or a related product with intended fully or partially self-evolving behaviour or logic that is designed to operate with varying levels of autonomy;

(g) where relevant, adapting machinery or a related product with intended fully or partially self-evolving behaviour or logic that is designed to operate with varying levels of autonomy to respond to people adequately and appropriately (such as verbally through words and non-verbally through gestures, facial expressions or body movement) and to communicate its planned actions (such as what it is going to do and why) to operators in a comprehensible manner.

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