§174 The Three-Step Method
Section 1.1.2 (b) outlines the approach that must be applied when determining the actions to be taken to manage the risks that have been identified and assessed through the risk assessment described in General Principle 1. This hierarchy of actions explained below is one of the key requirements of the directive. The three successive steps are ordered in priority and are often referred to as the three-step method:
Step 1 = first priority – Inherent safe construction measures
Step 2 = second priority – Technical protective measures
Step 3 = third priority – Information to users
This order of priority must be followed when choosing measures to manage a specific risk in order to meet the corresponding essential health and safety requirements (EHSR). Therefore, the manufacturer must exhaust all possibilities for inherently safe design measures before applying protective measures. Similarly, they must exhaust all possibilities for protective measures before relying on warnings and instructions for operators. The application of the three-step method must also take into account technological development – see §161: comments on General Principle 3.
Step 1 = first priority
The highest priority is given to inherent safe construction measures as they are more effective than protective measures or warnings. Some examples of such measures are:
Elimination of the source of risk entirely, e.g. by replacing flammable hydraulic fluid with a non-flammable type, or by removing the risk of falls by placing maintenance points easily accessible at ground level instead of at height – see §178: comments on section 1.1.3.
Design of control systems and actuators so that safe function is ensured – see §184–185: comments on section 1.2, and §297–298: comments on section 3.3.
Ensuring the machine's inherent stability through its shape and weight distribution – see §206: comments on section 1.3.1.
Ensuring that accessible parts of the machine do not have sharp edges or rough surfaces – see §209: comments on section 1.3.4.
Sufficient distance between moving and fixed parts to avoid pinching risks – see §212: comments on section 1.3.7.
Positioning the operator so that they have a clear view around risk areas.
Avoiding surfaces with extreme temperatures that are accessible – see §226: comments on section 1.5.5.
Reduction of noise, vibrations, radiation, or hazardous substances at the source – see §229 (noise), §231 (vibration), §232 (radiation), §235 (hazardous substances).
Reduction of speed and power of moving parts or the machine’s motion where possible.
Placement of dangerous parts in inaccessible areas – see §212.
Placement of adjustment and maintenance points outside risk areas – see §239: comments on section 1.6.1 in Annex I.
Step 2 = second priority
If it is not possible to eliminate risks or sufficiently reduce them through inherent safe design measures, priority is given to technical protective measures to prevent people from being exposed to the risks. Examples include:
Protection: fixed safeguards, interlocking movable protections with locking where necessary, or adjustable safeguards that limit access – see §218–220.
Protective devices – see §221.
Isolation of live parts – see §222.
Enclosure of noise sources – see §229.
Damping of vibrations – see §231.
Enclosure or evacuation of hazardous substances – see §235.
Equipment to compensate for lack of direct visibility – see §294.
Protective structures against tipping, rolling, or falling objects – see §315–316.
Stabilization devices – see §335: comments on section 4.1.2.1.
Step 3 = third priority
Finally, for the remaining risks that cannot be sufficiently reduced by inherent safe construction measures or technical protective measures, information must be provided to exposed individuals in the form of warnings, signs, and information on the machine, as well as to users through instructions so that necessary precautions can be taken. Examples include:
Information or warnings on the machine in the form of symbols or pictograms – see §245.
Audible or visual signals – see §248.
Indication of weight on the machine or parts that require lifting equipment during the lifecycle – see §253.
Warnings against use by certain persons, e.g., minors below a certain age – see §263.
Information on safe assembly and installation – see §264.
Specification of the need to provide users with necessary information and training – see §266.
Information on supplementary protective measures in the workplace – see §267.
Specification of the need to provide suitable personal protective equipment to operators and ensure that it is used – see §267.
Providing warnings and instructions is considered an integral part of the machine's design and manufacturing. However, the fact that this is the third step in the order of priority according to section 1.1.2 (b) means that warnings and instructions must not replace inherent safe design measures or technical safeguards when such are possible, taking into account the technical development.
