Interview with Roman Frontczak, director of research and development at Wood-Mizer Industries in Kolo.'On 29th December 2009 the new Machinery Directive 2006/46/EC came into force, replacing Directive 98/37/EC. The new Directive imposes additional obligations on manufacturers in terms of safety and health in designing and production of marketed machines'
reports Janusz Bekas of Gazeta Przemys?u Drzewnego (GPD), the leading Polish timber industry journal. He interviewed Roman Frontczak recently….GPD: Does this presage the end of machines which do not meet European law requirements?Roman Frontczak:
Not at all. Even so, any machine marketed in the European Union must meet minimum safety requirements and comply with the relevant directives and harmonised standards, if any. The manufacturer must conduct his own verification that the machine meets such requirements. In certain cases a machine must be submitted to an EU authorised laboratory for tests.GPD: Wood industry machinery represents a special group, doesn't it?RF
: Yes, most of them belong to a group of machines listed in Annex 4 of the Machinery Directive. This requires manufacturers to carry out the whole machine certification process with an authorised body prior to commencing sale of the machine within the European Union market.GPD: How is this achieved? RF:
The Directive describes the necessary, formal procedures, while the most common approach used by Wood-Mizer in Kolo is the EC type examination. This involves an authorised body undertaking the process of assessing the compliance of a machine with listed directives and standards. Subsequently, a report with comments and recommendations is prepared. When the recommendations are complete, a certificate is received. Thus equipped, we issue an EC Declaration of Conformity and slap a CE label onto the machine.
Actually, the Wood-Mizer company has maintained such a certification process for CE label marking of machinery since the mid-1990s, when we began offering our products on the market of the then European Union. At the same time the machine had to meet certain criteria for a safety mark B in the Polish market. In 2004, the CE became the official safety symbol throughout the enlarged European Union and our prescience was rewarded.GPD: What has changed since then?RF
: In 2006 a new Machinery Directive was enacted and came into force on 29 December 2009. All manufacturers are required to offer machines in accordance with the new Machinery Directive. This involves carrying out the process of re-certification of all
machines which are subject to this requirement. We were much advanced in this process and work with two certification units from Germany. It was a major organizational effort, since every model of a machine needed to be available for tests. The machine is checked according to a protocol based on the requirements of directives and harmonised standards. Inspection covers among others things, the operational function of the machine, safety circuits and ergonomics.GPD: Is it always possible to meet the imposed conditions and take into account current state of the art?RF:
Inspectors are experienced people. They know what will be acceptable but also what must be changed. Some solutions can be considered as meeting regulatory requirements or a method must be indicated which will accomplish the same thing in a different way. In fact, it is not just a strict check and report, but rather a discussion about what is acceptable within the current stage of technology and what needs to be modified to comply with the Directive.GPD: Is every manufactured machine subject to approval?RF:
It is the machine type
that is certified. We presented the machine in the form of the most advanced model in the entire product line. All machines should have the same design solutions, while any differences are accounted for as equipment options and the power of the drives used.GPD: Is a certificate 'forever'?RF:
Certificates are finite but good for five years. After that they need renewing. In the event of alterations to machinery, the certification body must be informed of the extent of changes. Each case is judged on the information received and the notified body decides whether it accepts the changes or whether it requires re-certification. The certification body maintains the data about the machine and an entire history of cooperation. The Directive describes in detail how long such documentation is to be kept both by the manufacturer and by them. The manufacturer must keep it for ten years from production of the last model of the machine.GPD: The new directive requires manufacturers to take further action on a thorough risk analysis of all safety circuits and machine safety functions, which must be carried out in an appropriate manner and properly calculated at the appropriate time. Right?RF:
Yes. Risk analysis is an integral part of the design process. It was required by previous regulations
when a manufacturer carries out his own compliance evaluation. The new Directive introduces risk analysis as a basic tool for ensuring machine safety. The manufacturer must carry out a detailed risk analysis of safety components, determine their class, assess the degree of risk and select safety measures in line with that degree of risk. The certification body then requires a written manufacturer's declaration that the procedure has been carried out.GPD: And what about the small manufacturers of machines?RF:
There are a number of consulting firms which are responding to the needs of small firms by preparing documentation for the certification. However, the size and facilities of a company do indeed matter. Many small outfits with just a few people find it difficult to keep abreast of changes. For them, preparing documentation in the right and proper way is a challenge. Furthermore, the cost of the procedures can present a problem.GPD: So, is risk analysis of safety items a financial burden for manufacturers?RF:
The cost cannot be underestimated. It is not the price of the procedures alone but also those on-costs of attaching safety devices, additional electronics to monitor machines' functions and safety guards. There is also the cost of organisation and implementation and of extra security measures on machines.
Any manufacturer wishing to offer its machines throughout the European Union has to bear this additional cost. It obviously affects the price of machines, which means it benefits manufacturers making large series of machines who in turn benefit from the economies of scale. Small, regional players who build machines for local sawmills could suffer. Theoretically, they could disappear from the market or continue manufacturing in the 'grey market'.
All Wood-Mizer's lines of machines have been subjected to certification. Nevertheless, having been granted certificates we have found it necessary to monitor the technical changes and renew the certificates periodically. Consequently, our costs are no inconsiderable, especially when we have to complete a new certification within one year. Normally the process is spread over several years. We began the process of re-certification in accordance with the new directive in June and by December 29th 2009 we were well prepared.GPD: Who is responsible for machines imported from outside the European Union?RF:
Under the new directive the primary organisation which imports a machine into the European Union becomes, under the law, the 'manufacturer' of that machine. This is a significant change which, in my opinion, will result in sealing the market and improving the safety of machinery.GPD: The new Machinery Directive imposes considerable obligations regarding proper conduct during construction of new machines and the commencement of production. Correct?RF:
The formal requirements of the directive, particularly the amended content of the conformity declaration with name, address, role and signature of the person authorised to prepare the documentation, also appear essential to me.
These people can always be called upon to submit appropriate explanations.GPD: What is the situation related to the new Machinery Directive as regards the owners and operators of sawmill machinery?RF:
Machines purchased before 29 December 2009 had to meet the requirements of the directive in force at that time. The situation is different for products purchased since where the new rules are applied.
Now, in the event of an inspection, if a machine is incompatible with the new directive, then the Labour Inspectorate may prohibit the use of the machine until it undergoes CE certification and its manufacturer affixes the CE label.