When I buy a machine, the Declaration of Conformity for the machine also includes guards. If I then buy a guard from the machine manufacturer as a spare part, that guard will not have the CE mark since it falls under the machine certification. However, if I buy a guard individually as a safety component, according to the Machinery Directive, it must be CE certified. It is called a "safety component" because it protects a person from injury. Annex V of the Machinery Directive lists all safety components. There is a Technical Standard (14120:2015) that specifies how to make guards, providing all the necessary parameters.

There is only one Technical Standard to comply with, EN 14120, but it is not mandatory. However, compliance with the Machinery Directive is mandatory, which was implemented by Legislative Decree 17/2010 and is a binding standard. 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. Technical Standards are only a way to comply with the Machinery Directive; it is therefore possible to self-certify compliance. If, however, you don't want to take on this responsibility, purchase the Standard from the UNI website, which specifies how the protection must be implemented. The design is then based on what is written in the Standard. If you comply with the Standard, you have the Presumption of Conformity, meaning you have done the best you can. However, if you don't comply, they can accuse you of not complying in an attempt to save money, and you will have to demonstrate that you have performed a complete risk assessment. If, on the other hand, you comply with the Standard, the analysis has already been done by whoever wrote it and by complying with it you have done what was required of you.

Per prima cosa è necessario controllare se le protezioni che il costruttore ha scelto vanno bene per te.

CE MARKING ON MACHINE SAFETY DEVICES – IS A PLATE REQUIRED? When selling a machine, the buyer trusts it to be safe and compliant with all regulations. The seller doesn't build the entire machine, but assembles parts from various suppliers. Let's say you make the fixed guards and shields that attach to the machine, such as perimeter guards that delimit a perimeter beyond that of the machine itself. The machine manufacturer, to avoid liability, asks you to certify what you sell. This is a legal requirement; if you sell a safety component, it must be CE marked according to the Machinery Directive. If the manufacturer sells a machine already equipped with guards, these are not certified because they are part of the machine as a whole. However, if you sell only a component with a protective safety function, according to the Machinery Directive, it must be CE marked. This is very important to know, especially when ordering, to prepare the documentation to give to the customer, such as the CE plate. If I'm a machine builder and I buy perimeter guards from you, I'll include your Manual, CE Plate, and Declaration of Conformity in my Technical File. If I build the perimeter guards myself, I'll have my own drawings and calculations, which I'll include in my Technical File. FIXED AND MOVABLE GUARDS: HOW DO I CHOOSE? There are two types of guards. There's physical guarding, which physically prevents the operator from reaching the machine while it's running, such as fixed guards and interlocked guards. Or it's possible to detect an intrusion into the danger zone using optical barriers and laser scans, thus preventing the production process from continuing. A special case is guards with a safety interlock, which, when removed, shuts down the entire machine. This prevents the maintenance technician from operating the machine without restoring the guard. Thus, without the guard, the operator can access the machine's danger zone, but since the machine is stationary, he or she is not in any danger. Remember that a cover must be immediately recognizable when disassembled, so leaving it disassembled must be intentional, or lazy. So how do I choose when to install a cover, an interlocking door, or a laser scanner? I choose based on the operators' use and what they need to do to work. If the maintenance worker needs to access the machine once a month, a fixed cover with four bolts is more than adequate. If, for example, he needs to clean a roller with solvent every eight hours, a fixed cover tends not to be reassembled each time, out of laziness. In this case, it is possible to install an interlocking door, so that when it is opened, the machine stops. In reality, the machine should be stopped first and then the door opened, but not all of us are so diligent; the interlocking door is useful to prevent forgetfulness. If, on the other hand, the worker needs to access the machine multiple times during the shift, even the interlocking door can be an obstacle. An optical barrier can be installed, but it requires certain spaces. The optical barrier also requires buffer zones, areas where the machine cannot be touched. There must be a certain distance between the operator and the hazard, allowing the machine time to stop, as some machines do not stop immediately. A 500 kg reel doesn't stop instantly; there's a stopping time that must be verified. Interlocked guards are also available; the interlock prevents the machine from restarting until the guard has been repositioned, but not all guards require them. The fixed interlocked guard is a very rarely used system, as each interlock costs money and is a potential source of failure. It's the machine manufacturer's responsibility to decide whether or not to install one. It's installed when there are particularly dangerous points where the operator is known to tend to leave the guard off, and this risk cannot be taken. Hinged guard? Is it fixed or movable? We received this question from a court expert who encountered a guard attached to the machine on the right side with a hinge and on the left side with a bolt. The answer lies in the problem it is designed to solve and the desired result. As stated in paragraph 6.3.2 of EN 12100: a fixed guard is used if access to the danger zone is not required in "normal" situations. That is, frequent access to that area is unavoidable. In that case, it is better to use an interlocking movable guard. If I install a fixed guard, it means it can/should be removed only a few times, not frequently. Only for maintenance, cleaning, etc. A movable guard, however, to be functional, should be interlocked when opened, and frequently. Otherwise, it becomes ineffective. If I install a fixed guard for a serious, unacceptable risk, I must ensure it is replaced before starting. What happens if someone forgets it somewhere? For example, a fixed guard to protect the grinding parts... A grate... if I don't install them... everything works the same. This way, the operator is more comfortable in the event of a "blockage," he might not stop the crusher, and might intervene with a tool like a lever. There are examples of seriously incorrect behavior... easily predictable. Therefore: The fixed guard should be "attached" clearly to the area to be protected, even if removed. A chain? A hinge? This way it can be seen that... it's dangling and missing (for example). Obviously, if removed, it must not remain in place if only placed on top. It must be fixed. Otherwise, it must be interlocked. Even EN ISO 12100, in paragraph 6.3.3.2.2 (requirements for fixed guards), includes the hinge as an option. GUARD: WHAT IS IT? WHEN IS IT USED? HOW IS IT USED? The guard is a fixed protection, a safety guard. In a safety device designed to protect the operator from mechanical hazards, the guard is a device that interposes itself between the operator and the hazard. The material it is made of doesn't matter, but its function, which is to protect the operator, does. Being fixed, it must not be disassembled. Therefore, there must be no wing nuts that can be easily unscrewed by hand; they must be unscrewable only with the use of specific tools. You must be fully intentional about disassembling a guard, at your own risk. WHAT ARE HIGH VISIBILITY GUARDS? – MACHINERY DIRECTIVE. For the same type of machinery to be protected, some customers require high levels of brightness, and therefore transparency. In those cases, depending on the product being handled, glass or transparent polycarbonate will be used for the guards. What's the difference between the two? It depends largely on the function; for example, glass is more fragile than polycarbonate, but it's easier to clean. There are some factors that influence a customer's choice of one material over another. Typically, the end customer chooses the material, but it depends on the situation. If there are any objects that can come out of the machine and hit the polycarbonate, they can damage it but not break it. In the case of glass, even tempered glass with film can break it. The film prevents the glass from shattering but rather sags when it breaks. It can be placed on the inside of the guard, making the glass more shatterproof if struck by something, or inside the glass itself. High-visibility guards are used to make the process visible, allowing the operator to see inside the machine in operation and spot any manufacturing defects. Some customers prefer stainless steel guards, but with a viewing window to observe the process inside. The viewing window is a 60/70 cm window positioned at eye level, allowing the operator to see inside the machine. It can be made of polycarbonate or glass; the choice of material is up to the customer, but it depends greatly on the industry. DOES A HOUSING BECOME OBSOLETE? A housing doesn't usually become obsolete; it can wear out if placed in a highly aggressive environment. The guards are often made of stainless steel, a material that rarely loses its protective function over time. However, it may be that the guard is incorrectly positioned in an unsuitable environment, for example, a housing in a place where dust collects, where easily washable systems should be used. For interlocking guards, however, the usage rate is marked on each component used to monitor the doors or on the safety switches. Obviously, you don't have to count and keep track of every time the door is opened and closed, but it can give you an idea of how long the components will last. Hinges and interlocking guards have a microswitch; the manual will state how many openings it has been tested for, for example, 60,000. These are huge numbers; in this case, before it wears out, it would need to be opened for 10,000 days, five times a day. They're more likely to break from a single impact. Furthermore, the machine's use may change, so the door may no longer be needed in that position and will need to be moved. Or regulations may change in the future, and a guard in that specific location may no longer be compliant, thus becoming unreliable. MACHINERY PERIMETER PROTECTION: WHAT ARE THEY? Perimeter protection, in terms of layout and construction, is a protection that increases the perimeter of the moving machine. All protections are external to the machinery, but perimeter protections extend beyond the machine's perimeter, creating an internal, protected intervention zone. They create a buffer, shock-absorbing, or maintenance zone that remains separate from the machinery. For example, in the food or pharmaceutical industries, glass or polycarbonate cages are often used to prevent people from reaching near the moving part; these are perimeter protections. Yellow nets are commonly used on machinery with low mechanical or ejection risk, or where forklifts are turning, to prevent people from entering a specific area. In the bottling industry, however, there is often a requirement to avoid being hit by objects thrown from machinery; in this case, the fastenings must be as strong as the material. MACHINERY ACCESS LADDERS: HOW TO CHOOSE? Clients always try to place ladders and access points in the most unlikely places, as space in the plant is often very limited. However, they cannot be built and positioned haphazardly; there are technical standards that must be followed. Machinery access ladders have different reference levels. Up to 20° is a ramp, between 20° and 45° is a standard ladder, between 45° and 75° is a stepladder, and between 85° and 90° is a ladder. All the information on how to choose the access route to the machinery and the characteristics of the various ladders and covers are contained in Technical Standards 14122, of which there are four: 14122-1, 14122-2, 14122-3, and 14122-4. Standard 14122-4 specifies how to build a ladder. It will not have a CE plate as ladders do not have one, but it must have a plate indicating the weight and proper use. Standard 14122-3 concerns step ladders. These types of ladders do not require a plate. Standard 14122-2 contains specifications for the walkable flooring, the cover, and the parapet, which must be at least 1.10 m high. 14122-1 indicates how to choose the access route. These Technical Standards indicate how to construct access routes to the machinery. The 4 Standards cover all access routes and walkable areas at height. According to the Standard on ladders, the worker's safety cage must be positioned between 2.20 m and 3 m. A harness isn't necessarily required on ladders, as there is a safety cage in place. In some cases, special handrails are provided, such as those with hooks for snap hooks, but these are special cases. Ladders are a special type of access route to machinery, as they require work in a very confined space. Ramps and stepladders, on the other hand, are easier to use. PLATFORMS AND WALKABLE FLOORS AT HEIGHT ABOVE MACHINERY: WHAT SHOULD I LOOK FOR? The first thing to check is that the entire walkable perimeter is surrounded by a parapet at least 1.10 m high, a traditional railing like those found on balconies. Furthermore, there must be a clearance of at least 500 mm between them. Attached to the railing, all around the perimeter of the walkable area, there must be a heel guard, a raised area of at least 11 cm. This prevents falls or slips, or prevents tools from sliding off the platform. The third point to check, which is very important, is not visible to the naked eye, as it concerns the load capacity of the walkable area, or how much weight it can support per square meter. This calculation is typically done with two workers and a toolbox, and is approximately 200 kg per square meter. Climbing over the guardrail from the walkable floor and standing on top of the machine is absolutely prohibited. Sometimes you'll see the maintenance worker climbing over it and walking on the gutter; this is absolutely not an option as it is extremely dangerous. This is easily predictable behavior. In fact, if there is a raised surface or something within the walkable area where the operator can step, the 1.10 m of the guardrail is calculated from that point. NEW PROTECTIONS ON OLD MACHINERY: WHO CERTIFIES CE? When dealing with old machinery that requires new protections, a competent person must inspect the machinery and interview the worker who uses it. Through interviews with the worker, the operator learns how the machine is actually used, its good and bad habits, and what works well and what shouldn't. Based on these interviews, a risk assessment is performed, using Standard 12100, and based on this assessment, any protections to be applied to the machinery are chosen. Even if the protections were already present on the old machine and simply need to be replaced, it is necessary to ensure they are still suitable and justify their approval. The installation of the protections then takes place, which can be performed by the manufacturer or the customer. Furthermore, it is necessary to verify that the selection made in the assessment is identical to what was actually installed. Finally, if the machinery was built before 1996, a Declaration of Conformity must be submitted in accordance with Annex V of the Consolidated Law and as specified in Article 11 of Presidential Decree 459 of 1996. If the machinery was built after 1996, it has CE certification, which is not lost. Improving safety features does not alter the use of the machinery, but in any case, it is necessary to demonstrate that you have done something well and justify your choices. SURVEYS AND DRAWINGS OF PROTECTIONS FOR OLD MACHINES: WHO MAKES THEM? When you have an old machine and need to apply protections, you must first perform some surveys. It is best to have them done by professionals, as the guards must be custom-made. For example, if you insert your hand into a guard to make an adjustment, it must prevent your hand from reaching the other point; therefore, it must not be too loose or too tight. Furthermore, it's necessary to measure the attachment points, overall dimensions, and minimum distances from moving parts to determine where to position and attach the guards. All surveying must be done on-site where the machine is located. These adjustments can also be provided by the customer, but it's usually best for the guard manufacturer to do so, as if they're not accurate, the parts won't fit. Therefore, they must be performed by a competent person. Once the machine is surveyed, a layout is extracted, from which the construction drawings are drawn. From that point, the design process begins, deciding what type of safety devices to install, what type of fastenings to use, what type of doors, etc. The type of guard chosen depends on what they need to protect. If high visibility is important, they should be transparent; if the machine doesn't have ejection parts, a metal mesh can be used. The drawings are worked on, and then sent directly to the workshop for construction. Meanwhile, the Technical Office develops the Manual, where each part is numbered and contains a diagram explaining the assembly. Along with the manual, there will be a checklist to ensure all parts are present. There is a standard that specifically requires an instruction manual for the machinery. Guards are safety components and must therefore be CE marked. Be careful, as some do not do so; they are often sold as sheet metal and not as safety components.