Perimeter barrier certification
IT HAS ARRIVED: THE MACHINERY REGULATION 1230/2023 ..... WILL REPLACE THE MACHINERY DIRECTIVE IN 2027

SHOULD MACHINE REPAIRS BE CE CERTIFIED? UNI EN 14120
When I buy a machine, the machine's Declaration of Conformity also includes protections.
If I then buy a protection from the machine manufacturer as a spare part, that protection will not have the CE as it falls within the certification of the machine.
However, if I buy a protection individually as a safety component, according to the Machinery Directive it must be CE certified.
It is called a “safety component” as it protects a person from getting hurt.
In Annex V of the Machinery Directive there is a list of all safety components.
There is a Technical Standard that indicates how to make protections, providing all the necessary parameters, 14120:2015.

IS EN 14120 MANDATORY FOR FIXED GUARDS? HOW DO I CERTIFY THEM?
There is only one Technical Standard to be respected, EN 14120, but it is not mandatory to respect it.
However, it is mandatory to comply with the Machinery Directive, which was implemented by Legislative Decree 17/2010 and is a mandatory rule.
For example, the RES, Essential Safety Requirement of the Machinery Directive 1.3.7, specifies that I cannot come into contact with moving parts, but not how.
The Technical Standards are just one way of complying with the Machinery Directive, it is therefore possible to self-certify that you comply with it.
If, however, you don't want to take on this responsibility, buy the Standard on the UNI website, where it is written how the protection must be done.
We therefore design based on what is written in the Standard.
If you comply with the Standard you have the Presumption of Conformity, it means that you have done the best in your power.
While if you don't respect it, they can tell you that they didn't respect it because they wanted to save money and you will have to demonstrate that you have carried out an analysis of all the risks.
If, however, you respect the Standard, the analysis has already been done by whoever wrote it and by respecting it you did what was asked of you.

RSPP HSE AND FIXED GUARDS: WHAT DO YOU NEED TO WATCH?
First you need to check whether the protections that the manufacturer has chosen are right for you.
Since the CE is a self-certification, it does not mean that you agree with the Declaration of Conformity signed by the manufacturer.
It could be that you detect obvious risks, in which case you need to report them to the manufacturer.
For example, it is not possible to accept that a worker can put his hand inside moving parts.
The first check to do is therefore to see if the car fits you, and this is not a given.
Then you need to check whether what is written in the manual coincides with the machine delivered.
Because every now and then the Manual is written by an external company, or it is a copy and paste, or often a Manual is made for many machines.
It is not said that the Manual is precise, you have to read it to see if what is written corresponds to the machine.
Finally, periodic checks must be carried out.
As the machine is used, perhaps the interlocks are circumvented, or the Carters are dismantled and not reassembled.
It is necessary to check periodically, if everything is there it shows that you have checked.
Or if something is missing it should be reported and a sanctioning system can be activated. You can send a letter to the worker or reprimand him verbally.
A good RSPP checks periodically.
Verbalizing when the protections are present or not in an injury trial can be useful as it is objective evidence that the protections were present or not that day. Show attention and constant checking of protective devices.
Let's give some examples of what you need to look for and look at when looking at a machine.

CLIMBING ON MACHINERY - FIXED PROTECTIONS AND GUARDS
Guards must not be built with points or handholds where the operator can climb or climb.
Often instead, for a question of speed and practicality, operators climb onto the machinery instead of taking a ladder.
The machine manufacturer should think beforehand that everything that needs to be adjusted must not be at a height, but must be at eye level and outside the perimeter protection.
It may happen that the manufacturer of the machine has designed it to be placed in a pit, but the user does not dig and places it on the ground floor.
In this way all the adjustments are raised to such a height that no one can reach them, and to reach them you often have to climb on traditional protections, which are not designed to support a person's weight.
According to the Technical Standard UNI EN 14122 there are access routes to the machinery designed to support that weight.
The Machinery Directive states that even easily foreseeable wrong behavior must be thought about and imagined.
If I know of a bad behavior that occurs often, I cannot overlook it.

COLOR OF MACHINERY PROTECTIONS
It is good practice to color the protections with a bright colour, yellow for example, to highlight a place where there is a particular danger.
But it is not mandatory to color them in a certain way, it is possible to leave them black, transparent or uniform to the machine.
There is no mandatory rule that obliges you to color them.
However, if colored yellow they are better seen and help to highlight the danger.

CE MARK ON THE PROTECTIONS OF A MACHINE - DOES THE PLATE NEED?
When you sell a car, whoever buys it trusts that it is safe and complies with all the rules.
Whoever sells the machine does not build it entirely, but assembles parts from various suppliers.
Let's say you make the protections and fixed guards that are attached to the machine, such as perimeter guards which are guards that delimit a perimeter beyond that of the machine itself.
The manufacturer of the machine, in order not to take on your responsibilities, asks you to certify what you sell him.
It is a legal obligation, if you sell a safety component it must be CE marked according to the Machinery Directive.
However, if the manufacturer sells a machine already with protections, these are not certified because they are part of the machine.
But if you only sell a component with a protective safety purpose, according to the Machinery Directive it must be CE marked.
This is a very important thing to know, especially when ordering, to prepare the documentation to be given to the customer, such as the CE plate.
If I am a machine manufacturer and I buy perimeter protections from you, I will put your Manual, your CE Plate and your Declaration of Conformity in my Technical File.
If I make the perimeter protections myself I will have my drawings and calculations, which I will put in my Technical File.

FIXED AND MOBILE GUARDS: HOW DO I CHOOSE THEM?
There are two types of protections.
There is the physical one, I physically prevent the operator from reaching the running machine, such as fixed guards and interlocked protections.
Or an intrusion into the danger zone can be detected via light barriers and laser scans in such a way as to prevent the production process from continuing.
A particular case are the Carters with safety interlock, which when removed blocks the entire machine. This prevents the maintenance technician from operating the machinery without restoring the protection.
In this way, without the Carter the operator can access the danger zone of the machinery, but being stationary he is not in any danger.
Let's remember that when a Carter is disassembled it must be immediately recognisable, to leave it disassembled there must therefore be intentionality, or laziness.
So how do I choose when to put a cover, an interlocked door or a laser scan?
I choose it based on the use that the operators make and what they have to do to work.
If the maintenance technician needs to access the machine once a month, a fixed crankcase with 4 bolts is more than fine.
If instead, for example, you have to clean a roller with a solvent and you have to do it every 8 hours, a fixed carter tends not to be reassembled every time, due to laziness.
In this case it is possible to install an interlocked door, so that when it is opened the machine stops.
In reality you should first stop the car and then open the door, but not all of us are so diligent, the interlocked door is used to avoid forgetfulness.
However, if the worker must access the machinery several times during the shift, the Interlocked Door can also be an obstacle.
You can therefore place an Optical Barrier, which however requires certain spaces.
The Optical Barrier also needs Buffer Zones, areas in which it is not possible to touch the machine anyway.
There must be a distance between the operator and the danger, so as to give the machine time to stop, because on some types of machines stopping is not immediate.
A 500 kg reel does not stop instantly, there is a stopping time to verify.
There are also Interlocked Carters, the interlock means that the car will not start again until the Carter has been repositioned, but not all Carters need them.
The Interlocked Fixed Carter is a very little used system, as each interlock costs money and is a possible source of failure.
It is the manufacturer of the machine who must decide whether or not to install it.
It is placed if there are particularly dangerous points where it is known that the operator tends to leave the Carter disassembled and this risk cannot be run.

Hinged shelter? is it fixed or mobile?
We received this question from a court expert who found himself in front of a shelter attached to the car on the right side by a hinge and on the left side fixed with a bolt.

The answer lies in the problem it needs to solve and the result you want to achieve.
As stated in par. 6.3.2 of EN 12100: fixed guard is used if access to the dangerous area is not required in a "normal" situation. That is, it is inevitable to access that area with a high frequency. In that case it is better to use an interlocked mobile guard.
If I put a fixed guard it means that it can/should be removed only a few times, not frequently. Only for cleaning maintenance, etc.
Instead, a mobile shelter - to be functional - should be interlocked when it is opened, and frequently. Otherwise it becomes ineffective.
If I place a fixed guard, for a serious unacceptable risk, I must ensure that it is put back in place before starting.
What happens if they forget it somewhere?
For example, a fixed guard to protect the grinding parts... A grill... if I don't install them... everything works the same.
Thus the operator is more comfortable in case of "clogging", he could not stop the crusher, and intervene with a tool such as a lever.
There are examples of seriously incorrect behavior… easily predictable.
So:
The fixed shelter should be clearly "attached" to the area to be protected, even if removed. A chain? A zipper? So you can see that ..dangling and missing (for example).
Obviously, if removed, it must not remain in position if only supported. It must be fixed.
Otherwise you have to interlock.
Also EN ISO 12100, in par. 6.3.3.2.2 (requirements for fixed guards) includes the hinge as a possibility.

MECHANICAL RISK IN THE MACHINERY DIRECTIVE
There is always a tendency to underestimate the risk that a machine can create, consequently you see many people, for example, disconnecting safety micro switches and carrying them in their pockets.
Many decide to do it their way, because they think they have reasoned better than the car manufacturer.
Those who build machinery must think about the safety of operators and protect them from mechanical risks.
For example, we must ensure that the person using the machine does not get his hand caught in the gears, or that it does not get entangled.
In theory, the worker should not wear bracelets, rings and anything that can get caught, but it is always better to foresee these situations.
The Technical Standards stipulate that projects should be designed according to common sense.
It is also necessary to provide for easily foreseeable misuse.
Mechanical risks can include crushing, entanglement, clipping, cutting, sharp edges, deburred sheet metal, etc.
The risks also include falling, which is more likely to occur at altitude, but can also happen in other circumstances.
Furthermore there are Derivative Risks, which are those resulting from expulsion, for example if while a machine is working, a bottle breaks and explodes, sending pieces of glass flying.
The Machinery Directive lists the RES, essential safety requirements, but not the details on how to comply with them.
The detail is provided by the Technical Standard, but it is not always applicable.
The Machinery Directive states that a risk is avoidable and best resolved if it is done in the design phase.
If you realize that the anti-accident protection you are designing has obvious gaps, from the point of view of the physical protection of the operator, you must take responsibility for it.
Even if after an accident it proves that the operator had been perfectly trained, the accident shows that something went wrong.

CARTER: WHAT IS IT? WHEN IS IT USED? HOW TO USE?
The Carter is a fixed protection, an accident prevention shelter.
In a safety device designed to protect the operator from mechanical risks, the Carter is a means that intervenes between the operator and the danger.
It doesn't matter what material it is made of, but what matters is its function which is to protect the operator.
Being fixed, it must not be able to be dismantled.
There must therefore not be wing nuts that can be easily unscrewed by hand, but they must only be able to be unscrewed using certain tools.
You must have every intention to dismantle a Carter, at your own risk.

WHAT ARE HIGH VISIBILITY PROTECTIONS? – MACHINERY DIRECTIVE
For the same number of machines to be protected, there are customers who want a lot of brightness, therefore a lot of transparency.
In those cases, also based on the product they will be dealing with, glass or polycarbonate, always transparent, will be used for the protections.
What changes between the two?
It depends a lot on functionality, for example glass is more breakable than polycarbonate, but it is easier to clean.
There are discriminating factors that make the customer's choice lean towards one material rather than another.
It is generally the end customer who chooses the material, but it depends on the situation.
If there are elements that can escape from the machine, hitting the polycarbonate, they can damage it but not break it.
In the case of glass, even if they are tempered and have a film, they can break it.
The film allows the glass not to shatter but to collapse when it breaks.
It can be placed on the inside of the protection, making the glass more shatterproof if hit by something, or inside the glass itself.
The High Visibility protections serve to make the process visible, to see the working machine inside, so that the operator can notice any manufacturing defects.
There are customers who prefer to have stainless steel protection, but with a porthole to see the process inside.
The porthole is a 60/70 cm window positioned at eye level, to ensure that the machine can be seen inside.
It can be made of polycarbonate or glass, the choice of materials is up to the customer, but it depends greatly on the sector of use.

DOES A CARTER BECOME OBSOLETE?
A Carter usually does not become obsolete, it can wear out if it is in a highly aggressive environment.
The guards are often made of stainless steel, a material that rarely loses its shelter function over time.
However, it may happen that the shelter is wrong, positioned in an inadequate environment, for example a Carter in a place where dust collects, where instead easily washable systems should be used.
For interlocked guards, however, the quantities of use are marked on each component used to monitor the doors or on the safety switches.
Obviously you don't have to count and take into account every time you open and close the door, but you can get an idea of how long the components will last.
The hinges and interlocked guards have a micro switch, the Manual will say how many openings it has been tested for, for example 60,000.
These are huge numbers, in this case it would have to be opened for 10,000 days, 5 times a day before it gets ruined.
They are more likely to break due to a blow.
Furthermore, the use of the machine may change, so the door may no longer be needed in that position and will have to be moved.
Or in the future the Regulations may change and perhaps a shelter in that particular position will no longer be up to standard, thus becoming unreliable.

MACHINERY PERIMETER PROTECTIONS: WHAT ARE THEY?
Perimeter Protection, in terms of layout and construction choice, is a protection that increases the perimeter of the moving machine.
All protections are external to the machinery, but the Perimeter ones go beyond the perimeter of the machine, creating an internal and protected intervention area.
With them, a buffer, cushioning or maintenance area is created which remains separate from the machinery.
For example, in the food or pharmaceutical sector there are often glass or polycarbonate cages that prevent you from inserting your hand near the moving part, they are Perimeter Protections.
Yellow nets are normally used in machinery with low mechanical or ejection risk, or where forklifts are turning, and prevent a person from entering a certain area.
In the bottling sector, however, there is often a request not to be hit by objects thrown from the machinery, in which case the fixings must withstand the blow as well as the material.

STAIRS FOR ACCESS TO THE MACHINERY: HOW TO CHOOSE?
The customer always tries to put the stairs and accesses in the most unthinkable places, as the spaces in the factory are often very limited.
But they cannot be built and positioned randomly, there are Technical Standards to be respected.
As regards the access stairs to the machinery, there are different reference gradations.
Up to 20° it is a ramp, between 20° and 45° a normal staircase, between 45° and 75° a bunk staircase, while from 85° to 90° a marinara staircase.
All the information on how to choose the access route to the machinery and the characteristics of the various ladders and covers are written in the Technical Standards 14122, which are 4: 14122-1, 14122-2, 14122-3 and 14122-4.
14122-4 specifies how to make a ladder.
It will not have a CE plate as the ladders do not have one, but it must have a plate indicating the weight and correct use.
14122-3 concerns bunk stairs.
In this type of stairs the plate is not necessary.
14122-2 contains the specifications for the walkable flooring, the roof and the parapet, which must be at least 1.10 m high.
In 14122-1 it is indicated how to choose the access route.
These Technical Standards indicate how to construct accesses to the machinery.
With the 4 Standards, all access routes and walkable areas at high altitude are covered.
According to the marine ladder standard, the protective cage for the worker must be positioned from 2.20 m up to 3 m.
It is not necessarily the case that a harness must be used on the marinara, as there is a safety cage in any case.
In some cases, special handrails are provided, those with hooks for carabiners, but these are special cases.
The ladders are an access route to the particular machinery, because you work in a very confined environment.
Ramps and bunk stairs, on the other hand, are easier to use.

PLATFORMS AND WALKABLE FLOORS AT HEIGHT ABOVE THE MACHINES: WHAT SHOULD I LOOK FOR?
The first thing to look at is that the entire walkable perimeter is surrounded by a parapet at least 1.10 m high, a classic railing like those found on balconies.
There must also be a gap between them of at least 500 mm.
Attached to the railing, all around the perimeter of the walkable area, there must be a door sill, i.e. a rise of at least 11 cm.
It helps prevent you from falling or slipping, or to prevent the tools you are using from slipping off the platform.
The third point to check, which is very important, cannot be seen by eye, as it concerns the capacity of the walkable area, i.e. how much weight it can support per square meter.
Normally the calculation is done with 2 operators and a toolbox, and is around 200 kg per square meter.
It is absolutely not permitted to climb over the parapet from the walkable floor and go over the machine.
Sometimes you see the maintenance worker climb over it and walk on the ducts, this is something absolutely not to do as it is very dangerous.
It is one of the easily predictable behaviors, in fact if within the walkable area there is a rise, or something where the operator can put his foot, it is from that point that the 1.10 m of the parapet is calculated.

NEW PROTECTIONS ON OLD MACHINERY: WHO CE CERTIFIES?
When talking about old machines that need new protections, a competent person must go and see the machinery and interview the worker who uses it.
Together with the worker, by interviewing him, we learn the real use of the machine, the good and bad habits, what therefore works well and what should not be done.
Based on these interviews, a risk assessment must be carried out, using Standard 12100, and with the assessment any protections to be applied to the machinery are chosen.
Even if the protections were already present in the old machine and only need to be replaced, you must make sure that they are still suitable and justify your confirmation.
Then we move on to installing the protections, which can be done by the manufacturer or the customer.
It is also necessary to check whether what was chosen in the evaluation is the same as what was actually installed.
Finally, if the construction of the machinery dates back to before 1996, it is necessary to make the Declaration of Compliance with Annex V of the Consolidated Law and as specified in Article 11 of Presidential Decree 459 of 1996.
However, if the machine was built after 1996 it has CE certification, which is not lost.
Improving safety does not change the use of the machinery, but in any case you must demonstrate that you have done something well and justify your choices.

RELIEF OF OLD MACHINE PROTECTION DRAWINGS: WHO DOES THEM?
When you have an old car and need to apply protections to it, it is necessary to first carry out some checks.
It is better to have professionals do them, as the shelters must be tailor-made.
For example, a Carter, if you insert your hand to make an adjustment, must prevent your hand from reaching the other point, therefore it must not be too wide or too narrow.
Furthermore, it is also necessary to note the attachment points, the overall dimensions and the minimum distances from the moving parts, to understand where to position and attach the protections.
All detection activities must be carried out on the site where the machine is present.
These adjustments can also be provided by the customer, but normally it is better that they are made by those who build the protection, because if they are not exact the pieces will not fit.
They must therefore be done by a competent person.
Once the machine has been detected, a layout is extrapolated, from which the construction drawings are defined.
From that moment the planning begins, you choose what type of safety devices to put in, what type of fixings to use, what type of doors, etc.
The type of protection chosen depends on what they have to protect, if High Visibility is important they should be made transparent, if we are talking about a machine that has no ejected pieces you can put a metal mesh.
We work on the drawings, which will then be sent directly to the workshop for construction.
In the meantime, the Technical Office develops the Manual, where each piece is numbered and where there is a diagram to explain the assembly.
Together with the Manual there will be a Check List, to check that all the pieces are present.
There is a Standard where the requirement for the presence of an instruction manual for the machinery is specified.
The protections are safety components and must therefore be CE marked.
Be careful because there are those who don't do it, they are often sold as sheet metal and not as safety components.
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