How to design guards that comply with the Machinery Directive

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Paul Laidler, Business Director for Machinery Safety at TUV SUD Product Service, a global product testing and certification organisation, offers the following suggestions to help with the design of machine guarding

How to design guards that comply with the Machinery DirectiveAlthough guards play a vital role in ensuring that machines are safe, they are often treated surprisingly casually and continue to be the cause of many severe injuries that could have been prevented.

To try and tackle this problem, the updated Machinery Safety Directive (2006/42/EC) came into force in December 2009. This must now be observed by anyone supplying a machine in the European Union. However, many machine designers seem confused by the changes and are still not taking them into account. So what are the core elements that need consideration for guarding design and how should they be tackled?

Physical guarding

Guarding receives specific attention in the Essential Health and Safety Requirements (EHSRs) of the Directive. EHSRs cover safety features that manufacturers must build into their machines before they can carry the CE mark that shows it conforms to EU requirements.

Section of these EHSRs requires that all fixed guards must be removable only with the aid of tools. While a similar requirement was contained in the previous Machinery Directive, the fixing systems must now remain attached to the guards when the guards are removed. This means that ordinary machine screws and bolts can no longer be used as a means of attaching guards unless provision is made for the screws or bolts to be held captive when the guard is removed.

Section 1.4.1 now also requires that guards must protect against the ejection of falling materials and objects. For example, if a grinding wheel explodes, can the guarding contain that explosion and protect the people in the vicinity?

Section also states that guards should be incapable of remaining in position when their fixings have been removed. This could be challenging for designers and means that some careful thinking will be required. For example, designers need to ensure that hinged guards open automatically when they are released and that guards on the top of machines are not retained in position by gravity when their fixings have been removed.

Fool-proofing Interlocks

Interlocks prevent a user from making unsafe actions. When it comes to guarding one of the most relevant standards is BS EN 1088, which covers interlocking devices.

Section 5.7 of BS EN 1088 states that - "If the specification of the safety interlocking device is such that it is possible to defeat the safety function solely by a reasonably foreseeable action at the interlocking device itself and if the device itself is to be relied upon to prevent defeat, it should provide measures to minimise the possibility of defeat."

Exactly what constitutes 'a reasonably foreseeable action' is the operator not using machinery correctly, or choosing to take short cuts. If a manufacturer can prove they took all reasonable steps to ensure that an interlocking device could not be defeated, then it becomes a 'deliberate misuse' by the operator, rather than the fault of the company that supplied the machine.

The standard also states that 'defeat in a reasonably foreseeable manner' includes the removal of actuators and switches with the intention of disabling an interlocking device. For designers, this represents a problem, as how can they possibly fix these so that they cannot be removed with normal tools?

While solutions such as welding or gluing may seem to be the only methods to fool-proof any tampering, BS EN 1088 does not recommend this. It suggests that companies recognise the reasons why operators attempt to defeat interlocks, and that these are addressed in the machine design. The real question here is whether the machine design can be modified so that the guard no longer inhibits productivity, which, in turn, means that the operator will not be tempted to defeat the interlock.


TUV SUD Product Service is hosting a free webinar on 27 September 2013 at 14:00 BST, Practical Approach to Guarding for The Machinery Directive.

This webinar will help attendees to gain practical knowledge of how to apply relevant EN guarding standards to ensure machinery complies with the requirements of the Machinery Directive and the Provision and Use of Work Equipment Regulations (PUWER).

Follow the links to register for the machine guarding webinar or to find out about other webinars hosted by TUV SUD Product Service

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