The ABC’s of Machinery

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Essential health and safety requirements

Machines always involve some level of risk. Machine safety assesses the extent to which a machine performs its intended functions while risks have been adequately reduced. Hazards need to be identified and mitigated during the design, construction, use and maintenance of machinery.  Article 8 of the Machine Regulation (EU) 2023/1230 requires that machinery shall meet the essential health and safety requirements set out in Annex III. Identical obligations are stated in Article 5 and Annex I of its predecessor the Machinery Directive 2006/42/EC.

There are more than 1.200 harmonised standards that can be applied for the assessment of machines.
These standards can be of three types, using the international ISO “type A-B-C” structure as the framework.

A-type

A-type standards are basic safety standards. They cover basic concepts, design principles, and general aspects that are applicable to all machinery. Application of A-type standard(s) alone is not sufficient to ensure conformity with the essential health and safety requirements.  A-type standard(s) alone do not give a full presumption of conformity.

Still A-type standards are valuable because they provide an overall framework and guidance for the correct application of the Machinery Regulation (Directive). They address a large range of hazards: mechanical, electrical, thermal, noise, vibration, radiation, ergonomic, chemical and the environment in which the machine is used.
There are only a few A-type standards, the best-known and most widely applied A-type standard is EN ISO 12100.

B-type

B-type standards are generic safety standards. Each deals with one safety aspect or one type of safeguard that can be used across a wide range of machinery. There are two subtypes: B1-type standards focus on particular safety aspects, such as safety distances; while B2-type standards are for safeguards, like two-hand controls.

B-type standards confer a presumption of conformity with the essential health and safety requirements that they cover “when a C-type standard or the manufacturer’s risk assessment shows that a technical solution specified by the B-type standard is adequate for the particular category or model of machinery concerned”. B-type standards that cover particular requirements for safety components confer a presumption of conformity for that essential health and safety requirement.
There are about 100 harmonised B-type standards.

C-type

C-type standards are machine-specific safety standards. They provide detailed safety requirements for a particular machine or a group of machines that have similar intended use and hazards. C-type standards often refer to A-type or B-type standards. When a C-type standard deviates from the requirements of an A or B-type standard, the requirements of the C-type standard take precedence.  Application of the requirements of a C-type standard confers a presumption of conformity with the essential health and safety requirements of the Machinery Regulation (Directive).

Certain C-type standards are organised as a series of several parts applicable to a family of machinery. The general requirements in Part 1 of the standard are applicable to the whole family. Other parts of the standard supplement the generic requirements for specific ‘members’ of the family. Presumption of conformity with the essential health and safety requirements is shown by application of the general Part 1 of the standard together with the relevant specific part of the standard.
There are about 1.000 harmonised C-type standards.

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