Comparison of Legal Requirements: The Machinery Directive vs. the Machinery Regulation
1.6.2. Access to operating positions and servicing points
Changes
- Requirement expanded: "production" is replaced by "operation, setting, maintenance and cleaning of the machine or the related product"
- New requirement: "With regard to machines or related products into which persons are to enter for operation, setting, maintenance or cleaning, the machine's access shall be dimensioned and adapted for the use of rescue equipment in such a way that emergency rescue of the persons is possible."
Proposed measures
This is an important change: from “production” to “the entire lifecycle of use”
New focus on rescue, not only access. It is no longer sufficient to enter; it must also be possible to be rescued out.
- Verify that access covers all relevant activities:
- operation
- set-up
- maintenance
- cleaning
- Update the risk assessment so that all of the above activities are included (not production only)
- Identify whether the machine requires persons to enter the machine (fully or partially)
If yes:
- verify that access openings are sufficiently dimensioned for:
- person passage
- rescue equipment (e.g. stretcher, lifting equipment)
- ensure that the design enables rapid and safe evacuation
- check that there are unobstructed access routes (no obstacles to rescue)
- Assess the need for supplementary measures:
- emergency evacuation solutions
- means of communication (alarm)
- rescue instructions
- Update the instructions for use:
- how access is to be carried out safely
- how rescue can be carried out in an emergency
Machinery Directive statutory text
1.6.2. Access to operating positions and servicing points
Machinery must be designed and constructed in such a way as to allow access in safety to all areas where intervention is necessary during operation, adjustment and maintenance of the machinery.
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Machinery Regulation legal text
1.6.2. Access to operating positions and servicing points
Machinery or related products shall be designed and constructed in such a way as to allow access in safety to all areas where intervention is necessary during operation, adjustment, maintenance and cleaning of the machinery or related product.
In the case of machinery or related products into which persons shall enter for operation, adjustment, maintenance or cleaning, the machinery accesses shall be dimensioned and adapted for the use of rescue equipment in such a way that an emergency rescue of the persons is possible.
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