Comparison of Legal Requirements: The Machinery Directive vs. the Machinery Regulation
1.3.8.1 Moving transmission parts
Changes
Here is a change (more stringent requirement):
-"should be used" is replaced by "shall be used"
"Interlocking movable guards shall be used when it can be foreseen that access to the parts will be required frequently."
Proposed measures
Previously: it is good practice to use interlocking Now: it is a requirement when access occurs frequently
- Identify all moving transmission parts where access occurs frequently (e.g. maintenance, cleaning, adjustment)
- Verify whether existing guards are:
- fixed guards, or
- interlocked movable guards
- If fixed guards are used where frequent access is required:
- assess whether this leads to guards being removed regularly
- identify the risk of guard bypassing
- Ensure that interlocked movable guards are used where frequent access can be anticipated
- If necessary: replace fixed guards with interlocked movable guards
- Verify that the interlocking meets safety requirements (stops hazardous functions when opened)
- Update the risk assessment so that the choice of guard is justified based on frequency of use
- Update the technical documentation and drawings if modifications are made
Machinery Directive statutory text
1.3.8.1. Moving transmission parts
Guards designed to protect persons against the hazards generated by moving transmission parts must be:
— either fixed guards as referred to in section 1.4.2.1, or
— interlocking movable guards as referred to in section 1.4.2.2.
Interlocking movable guards should be used where frequent access is envisaged.
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Machinery Regulation legal text
1.3.8.1. Moving transmission parts
Guards designed to protect persons against the hazards generated by moving transmission parts shall be:
(a) either fixed guards as referred to in section 1.4.2.1; or
(b) interlocking movable guards as referred to in section 1.4.2.2.
Interlocking movable guards shall be used where frequent access is envisaged.
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