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Machinery Directive

Machinery Directive

Paul Taylor, head of industrial products (UK) at TÜV SÜD Product Service asks if the Machinery Directive is future fit?

All machines supplied in the European Economic Area must comply with the Machinery Directive 2006/42/EC, which defines a machine as: an assembly fitted with, or intended to be fitted with, a drive system other than directly applied manual or animal effort, consisting of linked parts or components, at least one of which moves, and which are joined together for a specific application; machinery referred to above that is missing only the components to connect it on site or to sources of energy and motion; lifting apparatus whose only power source is directly applied manual effort; an assembly of machines and/or partly completed machinery which, in order to achieve the same end, are arranged and controlled to function as an integral whole; or as interchangeable equipment which is assembled with machinery or a tractor in order to change its function.

The results of the European Commission’s open public consultation on the evaluation of the performance of the Machinery Directive highlights some interesting views. I also have some potential concerns for how effective the Directive will be in helping businesses achieve their Industry 4.0 goals.

The public consultation assessed whether the Directive has achieved its objectives and if it remains relevant to industry. The evaluation process gained feedback from a range of stakeholders. This included notified bodies, industry associations, workers, consultancies and a standardisation body. Some of the feedback covered whether the Directive was fit for purpose in supporting new technological developments, such as Industry 4.0 and the Internet of Things. This was all assessed against the extent to which the Directive contributed to the five areas of relevance, effectiveness, coherence, efficiency, and EU added value.

Part of this research also considered innovation. When asked “To what extend does the current Directive sufficiently allow for innovation?” 44% of respondents felt that to a small or moderate extent the Directive had been able to deal with new innovations and technologies since its introduction. Some 56% were slightly more positive and declared that this had been achieved to a larger extent, or entirely. Similarly, when asked whether the Directive was likely to be able to deal with new innovations and technologies over the next 10 years, 52% came out on the side of a ‘small’ or ‘moderate extent’, while 49% answered that the Directive would support this to a large extent, or entirely.

However, when asked how likely the Directive would be able to deal with changes to the business environment over the next 10 years, respondents seemed less positive, with 55% citing ‘to a moderate extent’, ‘to a small extent’ and ‘not at all’. Only 45% agreed that it would be able to deal with such changes to a large extent or entirely. The results of this consultation would suggest that while half of industry is upbeat about how the Machinery Directive will be able to support innovation, there is another half which is not quite so convinced.

Industry 4.0 will be a major paradigm shift for industry, where manufacturing will face massive disruption as developments move towards fully connected, self-organising intelligent factories. One of these disruptions will be finding the answer to a new machinery safety approach, which will of course require the Machinery Directive to be more relevant, effective and efficient than ever before.

Currently, the majority machines on the factory floor are unconnected, which means that machinery safety can be comfortably assessed in a static environment. However, Industry 4.0 principles introduce highly flexible, automated ‘plug and produce’ manufacturing, where machinery and production lines can be quickly reconfigured. Industry 4.0 principles therefore sees highly adaptive machinery and production lines, which can be quickly reconfigured at a press of a button. Of course, as machine configurations change, so do the risk variables.

In the currently understood, and relatively unconnected industrial world, if a machine has a substantial change made, a full CE marking and assessment process must be completed before it can be returned to service. Industry 4.0 will see a shift from static risk assessment to one of dynamic risk, which means that the Machinery Directive’s static risk assesment approach will not meet future requirements.

In the new world of Industry 4.0, machines will autonomously self-optimise. While ongoing digital transformation will drive innovation across a wide range of industries, machinery safety experts will face significant challenges as we move towards fully connected, self-organising intelligent factories.

A dynamically reconfigurable Industry 4.0 system therefore requires a new and integrated approach to machine safety assessment, for example, a new, modular method of certification that delivers integrated support for machinery end users as they progress towards Industry 4.0. The key benefit of modular certification is the major cost and time savings it contributes to the operation of adaptive self-configuring Industry 4.0 production systems. Our experts are therefore developing a modular certification scheme for smart factory components, addressing issues such as interface standards, interoperability, functional safety and IT security.

Directives, including the Machinery Directive, have not yet addressed the needs of an industry 4.0 environment, but we will see a move from a human-led static risk assessment approach to a machine-led dynamic risk assessment approach, with an ever increasing reliance on multiple layers of functional safety.

As Industry 4.0 becomes ever more agile and automated, so the approach to machinery safety must reflect and support that. For many, Industry 4.0 therefore remains a concept and goal, rather than a reality, raising more questions about machinery safety than can currently be answered.

The connected world of Industry 4.0’s smart factories adds a new and significant dimension of complexity in terms of machinery safety challenges. The Standards bodies will therefore face significant challenges as we move towards fully connected, self-organising intelligent factories.

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