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

1.3.7. Risks related to moving parts

Changes

The requirements level is expanded with requirements related to human-machine interaction.

- New requirement: "Prevention of the risk of contact leading to hazardous situations and the psychological stress that may be caused by interaction with machinery shall be adapted to"

- New requirement: "a) coexistence between human and machine in a shared space without direct cooperation"

- New requirement: "b) interaction between human and machine."

Proposed measures

- Identify whether the machine involves:
- coexistence between human and machine (shared space)
- direct interaction between human and machine

- Update the risk assessment to include:
- risks arising from the presence of a person in the machine operating area
- risks during interaction (e.g. collaboration, manual intervention, control)

- Ensure that measures to prevent contact are adapted to the intended use:
- separation (guards, distance)
- monitoring (e.g. sensors, scanners)
- speed and force limiting

- Assess and manage psychological factors that may affect safety:
- unpredictable movements
- non-intuitive behavior
- lack of feedback to the operator

- Ensure that the machine's behavior is predictable to the operator:
- clear motion patterns
- signaling before movement
- visual or audible indicators

- During interaction:
- verify that the machine responds in a safe and expected manner in the presence of a person
- ensure that risk reduction does not rely solely on the operator's behavior

- Update the instructions for use with:
- description of how the human and machine are to coexist/interact safely
- any limitations in use

Machinery Directive statutory text

1.3.7. Risks related to moving parts

The moving parts of machinery must be designed and constructed in such a way as to prevent risks of contact which could lead to accidents or must, where risks persist, be fitted with guards or protective devices.

All necessary steps must be taken to prevent accidental blockage of moving parts involved in the work. In cases where, despite the precautions taken, a blockage is likely to occur, the necessary specific protective devices and tools must, when appropriate, be provided to enable the equipment to be safely unblocked.

The instructions and, where possible, a sign on the machinery shall identify these specific protective devices and how they are to be used.

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Machinery Regulation legal text

1.3.7. Risks related to moving parts

The moving parts of the machinery or related product shall be designed and constructed in such a way as to prevent risks of contact which could lead to accidents or shall, where risks persist, be fitted with guards or protective devices.

All necessary steps shall be taken to prevent accidental blockage of moving parts. In cases where, despite the precautions taken, a blockage is likely to occur, the necessary specific protective devices and tools shall, when appropriate, be provided to enable the equipment to be safely unblocked.

The instructions for use and, where possible, a sign on the machinery or related product shall identify these specific protective devices and how they are to be used.

The prevention of risks of contact leading to hazardous situations and the psychological stress that may be caused by the interaction with the machinery shall be adapted to:

(a) human-machine coexistence in a shared space without direct collaboration;

(b) human-machine interaction.

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