Driving environmental performance
Machinery Directive 2006/42
Machinery On Slopes
How can manufacturers try and
protect the customer?
Richard Comely
Product Manager
Ransomes Jacobsen Ltd
Company Confidential
Company Confidential
1
Driving environmental performance
Machinery Directive 2006/42
Summary
• How do manufacturers protect their customer
by law?
• How can we do better than the law demands?
2
Driving environmental performance
Machinery Directive 2006/42
Why CE Mark Machines?
• Aims to protect consumers by requiring all
products entering or manufactured in the EU to
comply with this and numerous other directives
• Additionally the machinery directive is intended
to give all manufacturers in the European Union a
Level playing field in which to produce & sell
• Four Freedoms
– Freedom of Access
– Freedom of Goods
– Freedom of Money
– Freedom of Service
If You Don’t
Comply
3
Driving environmental performance
Machinery directive 2006/42
Non-Compliance is:
• Failure to Provide a Technical File (48hrs!)
• Failure to Provide Operating Instructions
• Failure to Provide Declaration of Conformity
• Incorrect Application of CE Mark
• Non-Application of CE Mark
Are They Serious?
4
Driving environmental performance
Machinery directive 2006/42
The Penalties:
• On summary conviction (Non- compliance of
2006/42/EC)a fine of up to £5000 Fine or 3
months in prison.
• VOSA intervention on Conviction £5000 Fine
&/or 6 months in prison.
• On conviction on indictment of Health &
Safety issue an unlimited fine &/or 2 years in
prison.
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Driving environmental performance
Machinery directive 2006/42
Six Steps to Compliance
1. Assess the safety of the machine
2. Compile a Technical File
3. Provide a Declaration of Conformity for
Machine – (No accessories or interchangeable equipment, with
full fuel tanks or batteries)
4. Provide a Declaration of Conformity for
Safety Accessories (ROPs, FOPs, TOPs)
5. Provide a Certificate of Incorporation for
interchangeable equipment (Decks, Cylinders, Snow
Ploughs, Partly completed machinery etc.)
6. Affix the CE Mark
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Driving environmental performance
Machinery directive 2006/42
Step 1: Safety Assessment
• 2006/42/EC
• Annex I
• Section 1: General
Principles
• Section 3: Mobility of
Machinery
• BS EN ISO 141211:2007 – Safety of
Machinery – Risk
Assessment Part 1 Principals
The manufacturer
must carry out a risk
assessment on the
machinery in order
to determine the
health & safety
requirements which
apply to m/c and to
ensure they have
been met
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Driving environmental performance
Machinery Directive 2006/42
What does CE stand for?
Check
Everything!
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Driving environmental performance
Machinery directive 2006/42
When completing a Risk Assessment you also need to
consider how user‘s can misuse the machine!!!
Is this Reasonably
Foreseeable Misuse?
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Driving environmental performance
Machinery directive 2006/42
Essential Health & Safety
Requirements
Noise (1.5.8)
Vibration (1.5.9
Machinery
maintenance
(1.6.1)
Risk of trip
Slip or fall
(1.5.15)
Operator Position
(1.1.7 & 1.1.8)
Driving positions
(section 3.2.1),
Seating (section 3.2.2),
Access to operators
Position & Service Points
(1.6.2)
Lighting (1.1.4)
Handling of Parts (1.1.5)
Control Devices (1.2.2)
Starting/moving (section 3.3.2),
Extreme Temperatures (1.5.5)
Operator Intervention (1.6.4
Information (1.7)
Emission of hazardous
Materials & substances
(1.5.13)
If your work involves any of the items listed you could affect CE
compliance
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Driving environmental performance
Machinery directive 2006/42
Step 2: Technical File
• This is a major
component of a
machine’s development
history
• Include everything Test
data, calculations, risk
assessment, supplier
signoff’s etc
• The manufacturer or
importer will generally
have to produce the
Technical File in 48 hours
from the time of the
original request
• Include the data showing
failures and how these
were over come! Very
important………
• In the UK only the HSE
can ask for this file
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Driving environmental performance
Machinery directive 2006/42
Contents of a Technical File
1. Risk Assessments
6. Manuals
2. Essential Health &
Safety
Requirements
7. Series Manufacture
3. Standards
4. Certificates &
Specifications
5. Drawings
8. Other
Documentation
9. Declarations and
Inclusions
This information does not have
to be in a central file but you must
be able to collate it in 48hrs
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Driving environmental performance
Machinery directive 2006/42
• Type A standards (fundamental safety standards)
giving basic concepts, principles for design, and general
aspects that can be applied to all machinery.
• Type B standards (group safety standards) dealing
with one safety aspect or one type of safety related
device that can be used across a wide range of
machinery:
– type B1 standards on particular safety aspects (e.g.
safety distances, surface temperature, noise),
– type B2 standards on safety related devices(e.g.
two-hand controls, interlocking devices, pressure
sensitive devices, guards).
• Type C standards (machine safety standards) giving
detailed safety requirements for a particular machine or
group of machines.
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Driving environmental performance
Machinery directive 2006/42
6.) Minimum Marking Requirements
− the business name and full
address of the manufacturer
and, where applicable, the
authorised representative,
− designation of the machinery,
− the CE Marking
− designation of series or type,
− serial number, if any,
− the year of construction, that is
the year in which the
manufacturing process is
completed.
It is prohibited to pre-date or
post-date the machinery when
affixing the CE marking.
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Driving environmental performance
Machinery directive 2006/42
Instructions
• Instructions must be supplied in the
language of the country of intended use
• There are 26 different languages
• The average translation costs £15,000 per
language
• The average change to a manual cost
£1500+
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Driving environmental performance
Machinery directive 2006/42
What do we test?
• Noise
– Bystander (measured in a hemisphere)
– Operator ear
• Vibration
– Whole body (WBV)
– Hand Arm (HAV)
• Stability
– Machine static on a tilting table
– Worst case scenario
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Driving environmental performance
Machinery directive 2006/42
How do we test stability?
Do not use on slopes greater than 15º
• Q1: My operators manual has the paragraph
above, does this mean that the machine will
tip over if it is tilted more than 15º?
– No, EN 836 (1997) is the European safety standard
for powered lawnmowers, which includes a stability
test. The slope angle quoted is half of the machine
limit of stability angle.
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Driving environmental performance
Machinery directive 2006/42
How do we test stability?
• Q2: How do you test the machine limit of
stability angle?
– Ransomes products are tested statically on a tilt
table. A 1mm thick steel strip is placed under the
wheels likely to lift, when it is possible to pull out
the steel strip from under one of the tyres (with a
10N force) the limit if stability has been reached.
Highway 2130 (LPG)
Commander 3520
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Driving environmental performance
Machinery directive 2006/42
How can we do better?
Swing-Out Centre
mower
TST™ (Tilt Stabilisation
Technology)
22
°
18
°
15
°
The only
mainstream
commercial
cylinder mower
on the market
with swing-out
accessibility of
the centre cutting
unit
The only mower on the market with active
stabilisation technology.
At 15deg the operator is warned of the slope
angle
At 18deg the hydraulic lift, locks maintaining a
lower C of G
At 22deg the mowers disengage to stop
mowing
Driving environmental performance
Machinery directive 2006/42
Protecting the Operator
Angle of machine (real
time)
Mower float locked
(18°)
Mower disengages
(22°)
01/03/
2011
Driving environmental performance
Machinery directive 2006/42
Protecting the Machine
Warns when service
required
Lists part numbers
required for next
service
• Fault warnings (last 50 faults logged including excess slope if
TST fitted)
• Fault diagnosis (technician aid)
01/03/
2011
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