The new legislation defining the general criteria of safety and prevention in the field of fire and evacuation in the workplace is close to its enactment and entered into force.

The Ministerial Decree of 10 March 1998 has therefore reached the final acts and is awaiting its abrogation and replacement by the new legislative provision.

MTM Consulting can follow your company in managing this specific issue and the transition to the new fire risk assessment model.

The Ministerial Decree of 10 March 1998 "General criteria for fire safety and emergency management in the workplace" is a staple in the management of these important aspects for the past 20 years.

The approval of the new text by the Scientific and Technical Committee for Fire Prevention, a committee established during the reorganization of the provisions relating to the functions and tasks of the National Fire Brigade, is now a recent text, which can now take the path of approval. at the other deputy seats of the state.

The assessment of fire risk is the tool of the employer to certify that the measures implemented to protect the safety of workers and other people present in the workplace are consistent with the level of risk present, measures that they concern both the technical and constructive equipment of the workplace, the risk prevention system and the information and training provided to their workers and teams.

According to the indications of Legislative Decree 81/2008 in the risk assessment document, the employer must quantify the fire risk for each room and certify the measures taken to:

-reduce the likelihood of a fire;

-guarantee suitable evacuation routes and emergency exits;

-implement the measures for rapid fire signaling in order to guarantee the activation of the intervention procedures by means of suitable alarm systems;

-ensure the presence of measures and equipment for the extinction of a fire, which must be maintained in full efficiency;

-provide workers with adequate information and training on fire risks.

The new text then provides a classification of work environments in four groups, based on their presence in Annex I of the D.P.R. August 1, 2011 No. 151 "Regulation simplifying the rules governing the procedures relating to the prevention of fires" and the presence of specific safety standards that indicate the minimum fire-fighting measures to be applied.

Based on this classification, it then provides specific mandatory technical and procedural provisions by type of workplace.

The contents of the draft are instead substantially similar to those of the D.M. 10 March 1998 for aspects of fire risk assessment, identification of prevention, control and maintenance measures (in which the obligation to register controls) was added, and emergency planning.

The draft decree confirms the current training system for firefighters and emergency management, introducing the periodicity of the (five-year) update and the programs for updating.

From what emerges from the work remains the right not to write down the emergency plan in cases of workplaces where they are occupied up to 9 workers, workplaces open to the public with overcrowding up to 49 people, regardless of the number of workers, although absolutely recommended.

In the risk assessment required by the Machinery Directive 2006/42/EC, the analysis of the safety and reliability of control systems of the machine is primary as different hazardous conditions could arise from a wrong design of the control system or from a level of system reliability not congruent to the risks present on the machine. In this regard, the Machinery Directive 2006/42/EC defines specific design criteria for the control systems and collects them within the related essential safety requirements.

MTM Consulting s.r.l. is able to follow the manufacturers of machines in the drafting of the technical file and, in particular, the risk assessment, providing the most appropriate indications for the design of the control system of the machine so that it is safe and reliable according to the risks actually present on the machine. This study is carried out with the aid and methodologies provided by the reference technical standard: UNI EN ISO 13849-1: 2016. 

Safety and reliability of control systems

The Machinery Directive 2006/42/CE contains, in Annex I, the essential health and safety requirements that the machine must meet before being put on the market and / or put into service by the manufacturer. The risk assessment required by the Machinery Directive must be functional to demonstrate the fulfillment of all the safety requirements applicable to the machine. In fact, the design choices made by the manufacturer must be the direct result of the risk assessment so that the operators, who will have to deal with the machine at all life stages, are exposed only to those residual risks that emerged from the assessment itself.

The risk assessment must also cover the design choices related to the equipment (electric, pneumatic and / or hydraulic) of the machine's control system, in particular as regards those parts of the safety-related parts of control systems. 

In particular, the essential health and safety requirement 1.2.1 of Annex I - "Safety and reliability of control systems" - defines the requirements that the machine's control system must meet in order to avoid the occurrence of hazardous situations related to a wrong design or to a potential failure of the same system. For example, some evaluations that need to be made:

•The control systems must not be influenced externally by the work environment in which the machine operates: if the machine is designed for outdoor use, the control systems must be designed in compliance with this environment.

•The control systems must withstand the foreseeable stresses: for example, continuous operation on a control device (a button, for example) must not cause it to break quickly, with potential additional hazards for the operator.

•If the management and control system of the machine is damaged or faulty, there must never be any situations of hazard for the operator: the operating logic of the machine must remain separate from the safety logic, always ensuring that this last is able to monitor the correct operation of the first. In fact, the machine must not have unexpected start-ups, no stops when required (in particular if emergency), changes to the process parameters that lead to unexpected hazardous situations, unexpected behavior, etc.

•Predictable human errors, related to human-machine interaction, must not lead to the creation of hazardous situations: for example, the operator intervention on a management software must not entail hazardous conditions for the operator except by voluntary intervention by the operator himself so that he is effectively aware of what he is about to enable. 

The requirements set out in point 1.2.1 of Annex I apply to all parts of the control system which, in the event of a breakdown, may involve hazards due to unsolicited or unforeseen machine behavior. The parts of the control system most involved are the parts of the control system linked to the safety functions (start, stop, emergency stop, etc.). Failure of these safety features would result in a failure of the corresponding safety function and, consequently, a potentially dangerous situation for the operator.

UNI EN ISO 13849-1: 2016 standard

All the components of the control system are subject to faults and / or breakages, therefore it is unthinkable to imagine designing a control system that will never fail. It is reasonable, however, to select the safety-related parts of the control system so as to create a control system that is sufficiently safe and reliable compared to the result that emerged from the risk assessment. The design choices (both as components adopted and as architecture) of the safety-related parts of the control system must be such as to guarantee a level of reliability (Perfomance Level) appropriate to the result of the risk assessment and therefore to the level of risk actually present on the machine. 

The UNI EN ISO 13849-1: 2016 standard presents the probabilistic approach now enunciated. 

The contents of the standard can be enclosed in these four sequential steps:

•Exclusion or reduction of the probability of failures by adopting reliable components and proven safety principles.

•Use of standardized components with verification of the safety functions by the control system at regular intervals.

•Redundancy of the elements of the control system so as not to lose the safety function in case of failure or breakdown.

•Automatic control for continuous detection of faults and failures.

These concepts are normally applied in combination with each other.

The risk assessment carried out according to the methodology established by the standard thus allows to identify a level of reliability of the control system that is adequate to the risks present on the machine and to choose the correct components to create a control system with the required level of reliability.

The safety distance between an opening in a shelter and a dangerous point, or between a light curtain and a hazardous point, is often a matter of debate between manufacturers and user customers, as these aspects affect the machine's dimensions or may limit the operability by operators.

The practical implications related to the safety distance are therefore very important aspects, both in the case of the construction of new machines and in the case of evaluation and adaptation of old machines.

MTM Consulting can follow your company in managing this specific issue, through the use of assessment methods and solutions appropriate to your reality and regulatory requirements.

The UNI EN ISO 13857: 2008 standard "Safety of machinery - Safety distances to prevent the achievement of dangerous areas with the lower and upper limbs" is the basis of reference for the sizing of the safety distance in many application cases, including in particular we can remember:

-the meshes of a protection network;

-the openings of channels or slides used for loading/unloading of machined pieces;

-openings to allow sampling;

-the height from the ground of the perimeter guards.

For the dimensioning of these distances the standard provides a series of elevations that express the minimum safety distance to be respected between the beginning of the opening and the nearest dangerous point reachable, according to the dimensions of the opening (width and height) and of its shape.

The UNI EN ISO 13855: 2010 standard "Positioning of protective means according to the approach speed of parts of the human body" is instead suitable for calculating the distance that the barrier of photocells must have from the nearest internal hazardous point reachable. In fact, in case of positioning too close to the machine it could incur a non-effectiveness of the barrier, which once crossed would still allow the reaching of the moving parts before they are actually stopped. In the opposite case, however, an excessive distance increases the necessary space around the access point for its protection from intrusions, and therefore arrests, unwanted, and makes it more difficult to operate on the machine in case of frequent operations near the danger zone.

The minimum safety distance is defined by a formula that considers:

-the speed of crossing the barrier, depending on whether it is an arm or a whole body;

-the resolution of the barrier, or the distance between the single emitting beams;

-the speed of response of the barrier, a typical data provided by the manufacturer of the photocell barrier;

-the stopping speed of the dangerous member once the stop command has been given.

Sizing these safety distances according to the harmonized standards of the Machinery Directive, both for new and existing machines, provides presumption of conformity about these points and evades any doubt in the event of disputes, whether they come from a customer or an inspection body.

The continuous and prolonged use of the machine by the operator, in the latter, leads to a certain confidence linked to the use of the machine with a consequent lowering of the level of attention and greater probability of incurring harmful consequences.

MTM Consulting s.r.l. is able to follow the employers in the drafting of the risk assessment document also with respect to the methods of interfacing the operators with the machines. The activity is also carried out towards the machine manufacturers in order to highlight the potential risks associated with incorrect, and therefore unforeseen, use of the machines themselves.

The prolonged use of a machine in time leads the operator to a high level of knowledge of the machine but leads to a reduction in the perception of the actual risks and dangerousness of the machine. In fact, the monotony, repetitiveness and also the experience negatively affect the perception of the risk that the operator has with consequent increase in harmful events. This lower risk perception, compared to the real one (mainly linked to the statistics of accidents on similar machines), and therefore the confidence in using the machine exposes the operator to higher risks compared to those to which an operator working for the first time on the same machines would be exposed.

In fact, over time, the operator tends to lose the necessary attention and to take the proper precautions related to the use of the equipment and exposes himself, unconsciously, to the dangers of the machine increasing the probability of a dangerous event. Ultimately, the operator tends to perform, unconsciously, an incorrect use of the machine as it differs from what was originally intended by the manufacturer.

Interventions by the employer

The monotony linked to the intervention that the operator must implement on the machine is the first aspect on which the employer must intervene. The monotony, in fact, gives rise to a sort of confidence between the operator and the machine used, the consequence of which is the underestimation of the dangers present on the machine with the consequence of being exposed more to harmful events.

The first solution that can be adopted by the employer is the rotation of the tasks: the periodic shift of the personnel between the different work stations of a production line or between the different machines of a department, is able to reduce the confidence effect with the different machines and/or workstations in line, determining a general improvement in the operator's level of attention during the planned activities.

Another aspect on which the employer must concentrate is the continuous training of the personnel. In replacement (or in addition) to the rotation of the tasks the employer have to guarantee, also thanks to his own prevention and protection service, a continuous training to his own operative personnel (according to article 73 of Legislative Decree 81/2008 and subsequent amendments). The continuous training must be aimed, among other things, also to keep high the level of attention of the personnel towards the risks present and related to the use of the machines, awakening those attentions in the operator that the monotony and repetitiveness have necessarily mitigated.

The same cited art. 73 expressly requires that personnel receive adequate training in relation to safety with regard to the conditions of use of the equipment and foreseeable abnormal situations. The training must therefore be aimed at highlighting the correct methods of use of the equipment and the abnormal conditions that could also derive from an unconsciously incorrect use of the machine to which the confidence in the use of the machine can potentially lead.

Compared to this mode of unconsciously incorrect use, even the machine manufacturer, already in the design phase, can adopt specific measures.

Solutions that the machine manufacturer can adopt

The manufacturer of a machine, before placing it on the market, is required to carry out a specific risk assessment aimed at demonstrating the compliance of the machine with the safety requirements of the Machinery Directive 2006/42 / EC. Specifically, the risk assessment must analyze the safety of the machine not only with respect to the intended use but also with respect to the reasonably foreseeable incorrect use, as defined: a "use of the machine in a manner different from that indicated in the instructions for use, but which may derive from easily predictable human behavior". As we indicated above, predictable human behavior is also an unconsciously misused use caused by historically predictable factors, such as monotony, repetitiveness, etc.

During the design of the machine, these factors must also be considered by the manufacturer of the machine itself, starting from the methods of use adopted in the past on similar machines, rather than statistics on accidents. The UNI EN ISO 12100: 2010 standard - "General principles of design - Risk assessment and risk reduction", provides some indications of the types of incorrect use or human behavior that can be easily foreseen to be taken into consideration during the evaluation and subsequent reduction of risks up to the machine design stage.

Ultimately, if during the risk assessment the machine manufacturer should detect situations of risk related to prolonged use of the machine and, therefore, to a lowering of the operator's attention level, already in the planning stage, specific measures necessary to reduce these risks must be adopted, highlighting, as always foreseen in the risk assessment process, the residual risk present in the instructions for use. Among other things, these aspects fall within the principles of ergonomics which must comply with the specific requirements of the essential requirement 1.1.6 of Annex I of the Machinery Directive 2006/42 / EC.

The next step it is up to the user who is required to adopt the procedures for use and interfacing with the machine defined by the manufacturer and included in the instructions for use and transmit them to the staff in charge of using the machine during the above mentioned mandatory training and training activities.

INAIL has made available in 2017 a software application for the assessment of biological risk in healthcare environments. The activities carried out in the health services (hospitals, clinics, dental offices, assistance services) are among those that may pose a risk of exposure to biological agents for all employees employed therein. But even in the productive, engineering and manufacturing sectors in general, we are exposed to this risk, even if the exposure does not concern all the workers but certainly some work in the company must also be evaluated in this sense.

MTM Consulting can follow your company in managing this specific theme, through the use of evaluation methods recognized by ARPA and INAIL, creating specific work procedures and inspection for your company.

Biological risk means the probability that an individual will come into contact with a pathogenic organism, become infected and contract an illness. The risk is potentially always present in all living and working environments and the Consolidated Law Decree 81/2008 dedicates an entire title to it, Title X.

The INAIL recalls how except in a few exceptions related to some activities, the risk from biological agents is often underestimated in many workplaces. Raw materials or substances used, biological fluids, organic dust, animals, insects, plant substances, poor hygiene or bad management of aeraulic plants can indeed be sources of potentially dangerous biological contamination. The biological risk for non-employees is often environmental and then, transversal; therefore, there is no work environment in which this risk can be ignored.

The starting point is therefore fundamental, for those companies that do not manipulate biological agents, is in fact the initial analysis of the possible exposure scenarios, indicating all the activities during which it is possible to incur contact with a biological agent.

ARPA and INAIL Liguria have developed a calculation algorithm that, through qualitative assessments, leads to a score associated with a risk value, similar to what is already widely used by classical methodologies for the risk assessment of exposure to chemical agents. The risk is calculated as a product of probability damage.

In particular is added the theme of the management of air conditioning systems, which can become, in case of poor or inadequate maintenance, the source of the spread of potentially pathogenic microorganisms that find ideal conditions for their development. With regard to the plant maintenance methodologies and the necessary timeframes to prevent these problems, a specific UNI EN 15780: 2011 standard was adopted by UNI: "Ventilation of buildings - Ducts - Cleaning of ventilation systems".

The assessment of business risks must therefore propose:

-an analysis of the possible environments and scenarios related to this type of risk;

-operational activities that can be carried out in relation to these scenarios and corporate environments;

-tasks shown as they can perform these activities or come into contact with them;

-a risk value evaluated with the quantitative / qualitative method;

-measures to be implemented, for example targeted cleaning / maintenance interventions or detailed surveys, to monitor the presence of dangerous sources;

-training and information dedicated to employees exposed.

The Personal Protective Equipment, subject of the new Regulation (EU) 2016/425 which replaces the Directive 89/686/EEC, must be made available to the workers, by the employer, when the risks cannot be avoided or sufficiently reduced through technical measures of prevention, through collective protection means or with measures, methods or procedures of reorganization of work.

MTM Consulting s.r.l. is able to follow the employers in the drafting of the risk assessment document and therefore in the research and adoption of PPE suitable to reduce those residual risks emerging from the same risk assessment. The choice of PPE must always meet the criteria of necessity and suitability also in light of the new Regulation (EU) 2016/425.

Legislative Decree no. 81/2008 and s.m.i. analyzes the obligations and responsibilities of the employer and of the workers with regard to the selection and use of personal protective equipment in Title III. The definition of PPE, reported in art. 74, is the following "any equipment intended to be worn and held by the worker in order to protect him against one or more risks likely to threaten his safety or health at work, as well as any complement or accessory intended for that purpose".

Reading the definition emerges a clear concept: the PPE is designed and manufactured to be worn or held by a single person to protect it from one or more risks to its health or safety.

The primary obligation of the employer (Article 17) is to carry out an assessment of all the possible risks present in the company; this assessment must be formalized in the risk assessment document (Article 28). This document should highlight all the possible risks present in the company and the consequent prevention and protection measures necessary to reduce these risks. However, where the risk assessed in a specific activity can not be adequately reduced through technical prevention measures, through collective protection measures or from measures, methods and procedures for the reorganization of work, it is necessary to use specific PPE (Article 75 of the D.Lgs. 81/2008 and s.m.i.).

The employer has the obligation (Article 18) to provide workers with the necessary and appropriate personal protective equipment, after hearing the person responsible for the prevention and protection service and the competent doctor, if any.

Let's see in detail what are the requirements that must comply with the PPE in order to ensure effective protection against the operator:

•They must be CE marked according to Regulation (EU) 2016/425.

•They must be adequate for the risk to prevent, without in itself entailing an additional risk for the operator.

•They must be adapted to the conditions existing in the workplace.

•They must take into account the ergonomic or health needs of the operator.

•They must be able to be adapted to the user according to his needs.

In choosing the PPE to be provided to their workers, the employer is therefore obliged to follow the following points:

•The choice is related to the result of the risk assessment carried out in the company: the PPE are to be used where the risks cannot be avoided by other means.

•The choice depends on the type of risk and the characteristics of the device itself, which can be found on the documentation attached to the device, in order to ensure that it is effective and, at the same time, does not cause additional risks to the operator.

•The choice must be updated whenever there is a significant change in the elements of the previously performed risk assessment.

The new Regulation (EU) 2016/425 on PPE

On 21 April 2018 the new Regulation (EU) 2016/425 on personal protective equipment enters into force and repealing Directive 89/686/EEC. The general objectives of this regulatory update in the legal form of "Regulation" and not more than "Directive" are, essentially, to better protect the health and safety of PPE users avoiding inconsistencies in product coverage and evaluation procedures of the conformity that were present in the various national transpositions, to define specific obligations and responsibilities for all the subjects involved (therefore, manufacturers, agents, importers and distributors) and to simplify the European regulatory framework on PPE.

The scope of the Regulation is indicated in art. 3:

a) "devices designed and manufactured to be worn or held by a person to protect themselves against one or more risks to their health or safety;

b) interchangeable components of the devices referred to in point a), essential for their protective function;

c) connection systems for the devices referred to in point a) which are not held or worn by a person, which are designed to connect such devices to an external device or to a secure anchor point, which are not designed to be connected in fixed way and that do not require fixing before use ".

The Regulation establishes the responsibilities for the various economic operators which intervene in the PPE supply and distribution chain on the territory of the EU. For this reason they must take measures to ensure that only PPE compliant with the Regulation is made available on the market according to their obligations as indicated in the arts. from 8 to 11 of the Regulations. Specifically, the Manufacturer is required to draw up the technical documentation referred to in attached III of the Regulations and to carry out the conformity assessment procedure pursuant to art. 19; procedure that changes according to the risk category to which the PPE belongs as indicated in attached I. The conformity assessment procedure is an obligation that concerns only the manufacturer.

Specific obligations are also defined for the figure of the importer which puts on the EU market protective devices from third countries. The first obligation, in particular, shows the need to import only PPE compliant with the Regulation. In fact, the importer is required to verify the effective conformity of the product before placing it in the territories of the Union. Likewise, the importer is required to verify that the Manufacturer has carried out the conformity assessment procedure appropriate to the category of protection of the PPE and that he has prepared the technical documentation. An importer who considers or has reason to believe that an PPE does not comply with the essential health and safety requirements applicable in the attached II, do not place it on the market until it has been brought into conformity.

The Regulation applies from April 21, 2018 with some exceptions:

•Articles 20 to 36 and Article 44 apply already from 21 October 2016;

•Article 45, paragraph 1, apply from 21 March 2018.

Important to underline the transitional provisions highlighted in art. 47: Member States shall not impede the making available on the market of products contemplated by Directive 89/686/EEC which comply with this Directive and placed on the market before 21 April 2019. In addition, EC certification certificates and approvals issued by notified bodies, pursuant to Directive 89/686/EEC, they remain valid until 21st April 2023, unless they expire before that date.

Initial testing, verification of safety equipment and any tampering, scheduled maintenance and interventions within / beyond the extraordinary maintenance are events that if underestimated or not traced may lead to penalties or assumptions of responsibility not considered.

MTM Consulting can follow your company in defining the procedural solution and the correct and sufficient records to protect your workers and respect with current legislation.

Article. 70 of the Consolidated Law requires that machines placed on the market in Italy after 21/09/1996 (date of entry into force of the Machinery Directive 98/37 / EC) must be CE marked.

Already this simple and apparently obvious obligation presupposes the presence of a register in the company that reports the various dates of manufacture and installation of individual machinery and equipment.

Article. 70 of the Consolidated Law also requires that, even in the case of a marked machine, the employer certifies the presence or absence of at least the obvious non-conformities of the machine that can be easily identified.

This obligation is absolved through the drafting of a test report that at least includes: visual inspection, consistency with the intended use by the manufacturer, technical aspects related to production and tooling, tests related to individual safety devices (emergency buttons, light curtains, interlocked doors, fixed protections, etc.), photographic material that certifies the state of the machine before use, verification of the documental completeness and information provided by the manufacturer.

Regarding, however, the machines placed on the Italian market before 9/21/1996, the obligation to verify the conformity of the machine to the technical indications reported in Attached V - Legislative Decree n. 81/2008 it is the responsibility of the employer of work. Even more so then a formal certification of the related conditions of the machine itself, with the drafting of a dedicated assessment of the related risks, becomes fundamental.

With regard specifically to the maintenance of the machines, Article 71 of the decree is very clear: the maintenance on the machines must be periodic and must be such as to ensure, over time, safe use maintaining a level of safety similar to that the car originally had.

Also in this case the recording of maintenance work carried out on a machine becomes essential and mandatory, to reconstruct its history and certify whether or not extraordinary maintenance has been exceeded, allowing intervention and for example already directing its suppliers in the event of changes to a new one marking of the machine.

Article. 71 of the Consolidated Law requires and reminds that the equipment must be "subjected to the measures for updating the minimum safety requirements" as set out in Article 18, generic regarding the obligations of the Employer: "update the prevention measures [... ] in relation to the level of evolution of the technique of prevention and protection ". This obligation means that even though the Employer has in his house, for example, a machine that is not very recent but CE marked, the Machinery Directive has existed since 1996, or even less recently, must verify the presence on the market of more efficient and effective safety devices and provide for their replacement. . The improvement of the safety performances alone does not involve a new CE marking of the machinery.

Machine use and maintenance is an important aspect in the risk assessment process and the Employer must support his attention in the fundamental steps concerning the life of a machine through the use of systematic records. In fact, maintenance allows to keep the machine in efficiency, guaranteeing continuity in production and, over time, an adequate level of safety for the operator, attesting the conformity over time of the equipment used.

The defeating of an interlock device associated with a guard is a matter of particular importance as according to the Machinery Directive the manufacturer must make it impossible to use reasonably foreseeable use and therefore also prevent the normal or foreseeable tampering of the safety devices by using solutions and solutions that are part of the good current protection technology.

The EN ISO 14119:2013 "Safety of machinery. Interlocking devices associated with guards. Principles for Design and Selection "provides indications to limit possible reasonably foreseeable tampering of said interlock devices.

MTM Consulting can track your company in defining the correct and sufficient solution in designing safety devices that comply with current regulations and guarantee the full functionality of the machine.

The neutralization of an interlock device can be seen as a reasonably foreseeable misuse and therefore as a lack of a manufacturer, since the 2006/42/EC Machinery Directive also requires that these types of incorrect uses be applied in the application of the principle of security integration.

The considerations regarding the ease of tampering with a device also involve employers as they are required to take the necessary measures to minimize the risks associated with the use of work equipment and to prevent the same equipment from being used used for operations and under conditions for which they are not suitable. This obligation becomes fundamental when you have pre-CE machineries or, in any case, dated, as it becomes essential that a timely and appropriate evaluation and analysis of the risk car be determined with the aim of determining whether the safety devices are still efficient and current; Legislative Decree 81/2008 obliges the Employer to take into account the evolution of the state of the art of protection systems and maintain its machines up to date.

EN ISO 14119: 2013 emphasizes that minimizing the interference between the interlock device and machine operation is the best incentive for failure to fail. This means that before focusing on how to build an unattable interlocking device it is much more important to design the correct effect that the opening of that interlock has on the machine and therefore its operation, this is what it pleases and causes a defeating.

The design guidelines of EN ISO 14119: 2013 help manufacturers make safety devices that make the level of protection offered by the machine solely elusive through a slight tampering of such devices, tampering that must therefore go beyond the reasonably foreseeable misuse.

However, the indications contained in the standard include the incorporation into the design of a true machine security management path and the relative operability of the machine during its various stages of life (use, equipment, product change, start-up, maintenance, etc.) , then go to the latest technical guidance aimed at the correct choice, installation and protection of the device.

These indications are therefore useful not only to the manufacturer but also to the employer, who is therefore able to use efficient machinery at every stage of life and where only voluntary acting, which in itself may be disincentivated, can lead to real evasion of the safety device and therefore also to the possible accident or injury.

Safety distances management is a subject common to almost all industrial machinery in order to ensure the effective protection of the worker who works on them, of course by the manufacturer who makes a new machine but also by the employer work that makes available old or new machines to their employees, having to evaluate their suitability over time.

MTM Consulting can track your business in defining the right and sufficient solution to protect your employees and comply with current legislation.

The UNI EN ISO 13857: 2008 "Safety of machinery - Safety distances to prevent the reaching of dangerous areas with lower and upper limbs" presents the precise measures concerning the safety distances to be applied according to certain geometric parameters, and it must be, in our view, widely known to those who handle the safety of a machine, providing unambiguous reference measures.

The safety distance is an aspect that must be respected in the sizing of many types of openings or fixings, fixed or mobile or perimeter, including in particular we can remember:

the meshes of a protective net;

openings in a fixed or movable guard;

- the openings of channels or slides used to unload processed pieces;

- the openings or slits used to load or puncture raw materials inside hoppers, tables or grip systems, or to allow - the entry or exit of conveyor belts;

- the openings for sampling;

- the height from the ground of the perimeter protections;

- free space between two protective structures;

- the size of any slot or aperture that would allow a dangerous moving organ to reach from the outside.

To this end, UNI EN ISO 13857: 2008 provides a series of non-readable brochures that serve as a guideline for positioning the shelters and dimensioning the protective nets in order to ensure the safety distance.

The first prospectus relates to the size of small openings on the machine's sheaves, and provides the minimum safety distance to be met between the start of the opening and the nearest dangerous point reachable. This distance is provided according to the opening size (width and height). For example, a very wide slot opening and height of 2 cm, the minimum distance from the first dangerous point reachable must be 12 cm. If the height of the aforementioned opening reaches 3 cm, the distance from the dangerous organ suddenly reaches 85 cm, considering the possible passage of the arm.

A second interesting example is the floor-to-ceiling height that must comply with the perimeter protectors, which provides the minimum safety distance between the top of the perimeter guard and the nearest dangerous reachable point. This minimum safety distance is provided on the basis of the ground clearance of the perimeter guard and the height of the reachable hazard point, discriminating between high risk and low risk (ie possible more or less serious injury) regarding the hazardous point.

The UNI EN ISO 13857: 2008 standard, in addition to the above-described outlines, also provides other measures, for example, at the safety distances of dangerous parts placed above the operator's head or indications in case of openings which, besides their size, difficult access with obstacles or labyrinths of various types, in order to allow reduced distances in the air between opening and dangerous area.

The security distances provided by the standard may seem at first glance very cautious and almost unrealistic. However, two fundamental aspects must be considered.

The first is that the norm also considers people with anthropometric dimensions that are not necessarily common, or very small, thus guaranteeing their safety. We also talk about geometric measures and therefore difficult to challenge, or we know that the rule is voluntary and the manufacturer can decide different solutions, but they must be justified; justifications based on avoiding a rise in costs, increased landmarks or better productivity can not be used in this case.

Introduction

The aim of this article is to address the problem of potentially explosive areas being created at the stationary and traction batteries, namely the UPS and UPS battery packs and the pallet trucks.

Although most companies do not have operations that need to handle flammable liquids / gases or electrostatic or explosive dust, the typical case of battery charging is a widespread situation; even this activity can create a potentially explosive atmosphere.

During the article, we analyze the generic problem of zoning, then illustrating a methodology for evaluating battery charging areas, based on specific standards in this area.

Legislative obligations

ATEX zoning has always been a delicate business problem, which is overlooked on many aspects of safety at work and involves most of the activities and employers. ATEX zoning is in fact an issue that affects all employers and businesses, regardless of their work activity. In fact, Legislative Decree 81/2008 requires, in the specific Title dedicated to this issue, that each company must compile a "Explosion Protection Document".

The possible formation of a potentially explosive area comes from various and partly widespread industrial activities:

   -   charging of traction batteries;

   -   charging stationary batteries;

   -   use, handling, distribution or storage of flammable substances (gases or liquids);

   -   use of machinery and work equipment that manipulate or produce flammable substances or explosive or electrostatic powders (paper dusts, wood powders, powders of polymeric origin, cereals and flours, etc.);

   -   thermal power plants;

   -   purification plants.

In the specific "Title XI Explosive Atmospheric Protection", Legislative Decree 81/2008 requires the Employer to avoid the formation of such areas, eliminating the risk if there is a possibility, or to assess the actual formation of Explosive atmospheres through the preparation of a specific "Explosion Protection Document", Article 294 of Legislative Decree 81/2008, which must contain effective zoning of these areas, in case the deletion of the source of Possible danger is not possible for productive purposes.

Zoning

This Explosion Protection Document should be the starting point for assessing, on the basis of zoning, application and presence in the company of many procedural and technical aspects:

-the adequacy of the electrical and mechanical equipment installed within the identified areas; equipment must be labeled according to the specific ATEX Directive 2014/34/EU by the respective manufacturers, depending on the type of area identified and the substance it gives;

   -   the need to integrate staff training;

   -   the need for working procedures in identified areas, with access control and usable equipment;

   -   the need to introduce certain specifications for materials and new equipment to be installed;

   -   the need to establish proper procedures for the storage and handling of materials, substances or wastes;

   -   the need to specifically manage the activity of suppliers and contractors in the company.

Zoning in general is based on specific CEI EN standards of the CEI EN 60079-10-1 (CEI 31-87) and CEI EN 61241-2 (CEI 31-88), and through the relevant CEI 31-35 interpretative guides and CEI 31-56 according to the following steps:

   1. Identify the sources or possible sources of emission and the chemical / physical characteristics of the substances emitted.

   2. Assign the degree of output for each source:

      -   Continuous degree;

      -   First degree (periodic or occasional issue);

      -   Second degree (unexpected emission, breaks off).

   3. Assess the flow rate.

   4. Assess the type of Zone, that is, the probability of an explosive atmosphere, based on the degree of emission and ventilation.

   5. Calculate and graph graphically the extension of the Zone, based on:

      -   emission rate;

      -   ventilation (artificial, natural, degree and availability, with or without physical impediments, number of air intakes, etc.).

Charging the batteries

The batteries commonly used in the company are lead or nickel cadmium and are distinguished, as already anticipated, in:

   -   traction batteries, ie batteries that equip forklift trucks, pallet trucks, cleaning machines, etc.

   -   stationary batteries, ie batteries that equip UPS (integrated or not), auxiliary services of power and telephone, rescuers, etc.

Batteries are usually recharged in dedicated areas, or in areas located inside production areas.

As is known, during the charging phase, the lead-acid battery emits several gases, including hydrogen, or a particularly volatile gas with high explosion characteristics, gas that is specifically emitted following water electrolysis.

Depending on how the gas is emitted into the atmosphere, the batteries are classified in:

   -   open batteries, ie batteries that allow free gas outlets, as they are free of cover, or have a cover through which the gas can freely leak;

   -   Batteries controlled by valves (closed or sealed), ie batteries closed with a hermetic cover, but equipped with a valve to vent any overpressure.

For zoning, as an alternative to Generic Gas Gases series 60079-10 CEI EN, it is possible to refer to CEI EN 50272-2 (CEI 21-39) standards on stationary batteries and CEI EN 50272-3 (CEI 21 -42) on traction batteries. These two rules analyze the problem by focusing in particular on proper ventilation to ensure the areas where charging points are located to limit the extension of the area, which should otherwise be considered to be the same as that of the entire local area and beyond if there are ducts or openings that put it in communication with other premises.

CEI EN 50272-2 and CEI EN 50272-3

Hydrogen has a high level of explosiveness, as a 4% concentration in the air (Lower Explodibility Limit) is sufficient to generate an explosion in the presence of an effective trigger. EN standards therefore propose to keep hydrogen concentration significantly below 4%, by ensuring proper ventilation. The EN standards thus provide simplified formulas to calculate the required ventilation air flow rate in a battery recharge room and the minimum ventilation opening surface that ensures such air flow with a good safety factor.

In the immediate vicinity of a charged battery, even in the presence of the calculated minimum ventilation, there is always a foreseeable existence of a dangerous zone which, for its characteristics, should be classified as Zone 1: "area where the formation of an explosive atmosphere, consisting of a mixture of air and flammable substances in the form of gas, vapors or fog, is likely to occur occasionally during normal activities. " This area extends for a distance of 0.5 meters from the source of the traction battery gas, or from the battery valves itself. As for parking batteries, the distance varies depending on the battery characteristics, depending on the voltage and the rated capacity of the battery.

Conclusions

Standards CEI EN 50272-2 and CEI EN 50272-3 identify the necessary measures in battery charging locations to prevent the explosion hazard due to the emission of hydrogen, particularly dangerous gas, not only for the above-mentioned Lower Explodibility Limit but also because it is very light, with the tendency to stride in narrow spaces and focus on the high areas of the premises.

The standards then analyze the specific ATEX problem of charging areas:

   -   prescribe that battery cells have a minimum (natural or forced) ventilation to keep the hydrogen concentration far below 4%;

   -   indicate how to calculate the required ventilation and the minimum aperture width to ensure it naturally, without the use of fans or extractors;

   -   specify that even in the presence of proper ventilation, near a battery there is a potentially explosive zone;

   -   provide simplified formulas to calculate the extension.

In order to prevent explosions in battery cells, therefore, it is sufficient:

   -   Provide rooms for the minimum ventilation openings provided by CEI EN 50272-2 and CEI EN 50272-3 or adequate localized ventilation;

   -   check the absence in the potentially explosive area near the ignition battery (electrical systems, electrical and mechanical equipment) or install in the area of Ex II 2G electrical and mechanical components marked CE marked in accordance with the Atex 2014/34/EU Directive.

The risk of exposure to biological agents is potentially always present in all living and working environments and Testo Unico D.Lgs. 81/2008 devotes you an entire title, Title X Exposure to biological agents.

ARPA and INAIL Liguria have developed a calculation algorithm that, through qualitative evaluations, leads to a score associated with a risk value similar to that already widely used by classical methods for assessing the risk of exposure to chemicals.

MTM Consulting can also follow your company in managing this specific subject, through the use of recognized recognition methods, creating specific work and inspection procedures for your business realities.

Although the risk of exposure to biological agents is a matter of working in an environment where biological agents are manipulated, such as a research lab or a healthcare facility, it is present in almost all companies. Some types of business situations may expose their workers to the risk of contact with biological agents. This is the case for those who, for example, perform sanitizing, purge sewage systems, access to remote areas of the company, and with unmanageable minimum hygiene levels, waste treatment and storage, management of company purifiers, system interventions Aeroulic, first aid workers, etc.

The method proposed by ARPA and INAIL calculates a risk related to a disease related to the type of disease that can be contracted in case of exposure and to a probability. The likelihood of contracting a biological infection is influenced by many factors that are summarized in the method in six major factors:

• The amount of potentially infected material manipulated;
• The frequency of manipulation of potentially infected substances;
• The presence of collective protection devices present;
• The presence of good working practices and hygiene standards;
• The presence and use of DPI workers eligible for biological risk;
• The presence of adequate training and information of workers.

The result of the evaluation, which must be shared with the Competent Doctor, leads to a level of risk that determines how the company's management of its individual tasks is in line with the risks involved.

Such assessment must be formalized in a specific document.

Workload handling activities also include, as explicitly stated by Testo Unico D.Lgs. 81/2008, the actions of pulling and pushing of loads, ie actions involving the horizontal shift of loads through the use of pallet trucks Manuals, carts or baskets, all manually driven or pulled, without the use of engines or other devices.

Ergonomic studies of international character show that this type of movement has a significant influence on the pathologies associated with the spine-lumbar spine

MTM Consulting can also follow your company to handle this specific assessment by using a digital dynamometer and graphic representation of the data, as required by the standard ISO 11228-2.

Often, these manual load handling activities by pull and push actions are poorly evaluated by the Employer if compared to manual load lifting activities. The motivation may lie in the fact that for this type of activity there has never been a net transportable weight limit, unlike manually lifting, since the factors to consider to assess the related risk are many and not primarily the only weight to be manipulated ; It is therefore very difficult to clearly set a threshold of attention, unless applying a specific methodology.

Legislative Decree 81/2008 proposes for the assessment of towing actions and the use of the International Standard ISO 11228-2: 2007 - Ergonomics - Manual Handling - Part 2: Pushing and Pulling, which basically resumes Already known method for evaluating such actions by Snook and Ciriello.

This standard proposes to obtain the maximum applied force recommended by some matrices, where the input data are:

• sex of the person handling the movement;
• frequency of push / pull action (from once every eight hours to once every ten minutes);
• maximum distance traveled, in meters;
• height of the hands of the hands during the shot or push action.

The maximum recommended force must be compared with the force actually sustained during the action, thus obtaining a hazard index, called the Movement Index. In order to detect the really supported force, it is necessary to measure on the site, thus simulating the actual traction or thrust activity, this force by means of a dynamometer, gaining the force data and representing it in the form of a graph, from which extrapolating the initial starting force (peak ) And retaining force.

The results obtained must be submitted to the Competent Doctor in order to assess the suitability of the individual staff, the need to activate the specific health surveillance, the need to mechanize the activity if it is too risky for the staff.

On September 15, 2015, the International Standardization Organization (ISO) revised the ISO 9001 Standard.

The Norm that governs the implementation, implementation and maintenance of a Quality Management System is virtually unchanged since 2000, although the latest version is in 2008, but now with the new version 2015 substantial changes have been introduced that concern a little ' The whole system of the system implemented in the company.

MTM Consulting can track your company in managing the transition plan to the new ISO 9001 Standard, incorporating changes in your management system already implemented and certified.

The new novelty introduced by the new ISO 9001 concerns the need to assess quality-related risks as a starting point for system implementation, a risk considered as uncertainty associated with achieving goals that can be summed up as capacity To provide regular customers with products / services that meet the requirements and increase customer satisfaction. It is therefore required in the business processes to search for those related risks, evaluating and prioritizing them, and then trying to control and monitor them accordingly.

The new ISO therefore wants a contextualized management system, down to the risks of individual organization and not generic. In doing so, it also leaves greater freedom in the formulation of formal documentation to support the system, ie more freedom on how to set up business management, but great relevance to the risks involved and the goals to be achieved.

Here are briefly the other novelties that follow from the draft standard, published in September 2013.

- Different high-level structure, now applicable to all management system standards (9001, 14001, 18001).

- Use of the term "goods and services" instead of the term "product".

- Introduction of the context and stakeholder expectations analysis.

- Emphasis on the process approach.

- Eliminate preventative actions.

- Use of the term "documented information" instead of "documents" and "registrations".

- More details on the control of external supplies of goods and services.

- Missing the mandatory figure of the Management Representative.

IAF and ISO have defined a transition period of 3 years from the publication of the new edition of the standard, that is, the period when all the 2008 version certificates of the standard will be brought to the new version. Therefore, for companies that have been certi fi ed to certify ex novo or meet the three-year renewal of existing certification, it is necessary for the companies that have been certified or renewed to comply with the ISO 9001: 2015 guidelines. Certified companies, who have only planned surveillance visits since September 2015, may decide to maintain a certified quality management system in accordance with the 2008 scheme, creating a transition plan where points, steps, timelines are identified And responsibility to get aligned completely with the new edition of the norm. All this is valid until September 2018 where each certified system will only have to comply with ISO 9001: 2015.

The year 2016 marked the entry into force of many new editions of existing directives, including the most important and known are the Low Voltage Directive, Electromagnetic Compatibility Directive, the ATEX and PED. These include the Directive that applies to a larger number of devices, equipment and components is certainly the Low Voltage Directive.

MTM Consulting can follow your company to assess what changes for your company and your product with the entry into force of the new Directive and related harmonized standards, helping you make the Technical File.

Directive 2014/35/EU, commonly called Low Voltage, came into force in April 2016; it has been implemented in Italy by Legislative Decree no. 19 May 2016, n. 86, which translates this into Italian by entering the sanctions Directive.

The Directive applies to all equipment, components or parts of components that have made efforts within the following voltage limits: 50 to 100 volts alternating current, from 75 to 1500 Volts DC.

It therefore covers both defined and complete objects, or ready to use, but also in parts broken or incomplete, or even just some of them, like the power cables: to all that is marketed to be fed, or lead inside electrical current to voltage above falls within the scope of the Low voltage Directive and therefore must comply with its requirements, be marked EC and be accompanied by a Declaration of Conformity.

The manufacturer must comply with the safety requirements of the Directive. The harmonized standards for this Directive are in this case particularly useful because detailing issues such as identification of the wiring, the requirements of power cables, construction of switches and differential temperature of the live parts requirements, test methods for fire resistance, requirements of insulating materials, etc., thus providing a presumption of conformity with precise technical indications, not mentioned in the directive given its scope so exterminated.

The manufacturer then supplies its single product has CE marking and declaration of conformity. It demonstrates the conformity of his product build, and maintain active a Technical File and a manufacturing process control system, as with any other product Directives, and assumes responsibility for compliance with safety requirements by drafting and signing a Declaration of CE conformity, to be delivered to the customer with the product itself.

The new edition of the UNI EN ISO 13850: 2015 specifies the principles of the design of the emergency stop regardless of the type of energy used (electric, pneumatic or hydraulic) and, as such, represents the current state of the art applicable. This standard introduces a number of changes from the previous edition and introduces some important aspects of the design in relation to the emergency stop function for sets of machines.

MTM Consulting LTD It is able to follow the manufacturers of machines in the drafting of the technical file and, in particular, of the risk assessment, ensuring a continuous and effective regulatory update in order to identify the best technical solutions and representative of the prior art that they can reduce the risk of the use of the machine.

Recently it has been published the new edition of the UNI EN ISO 13850: 2015 relating to the emergency stop function design principles. This rule, since last May 31, 2016 replaces the previous edition of 2008 and give a presumption of conformity with the essential safety requirement 1.2.4.3 of the Machinery Directive 2006/42/EC.

The requirement 1.2.4.3 of Annex I of the Legislative Decree no. 17/2010, Italian transposition of Directive 2006/42 / EC says "the machine must be fitted with one or more emergency stop devices to enable it to avoid situations of danger which might arise in the imminence or be averted."

The only machines to be excluded from this requirement are:

• "Machines in which an emergency stop device would not lessen the risk, because it does not reduce the time to get the normal shutdown or because it does not allow to take specific measures that the risk requires;
• seals portable machines and / or hand-guided".

These concepts are also contained in the UNI EN ISO 13850: 2015: where there should be an emergency stop on the machine is necessary to refer to the contents of the technical standard analyzed here, so you have the presumption of conformity with the obligations set from the requirement.

The emergency stop function must be available and operational irrespective of the mode of operation of the machine (for example, the machine in operation, or turned on but not working) and must be implemented by a single human action (pressure of an emergency button, crossing of a security barrier, shot by a safety rope, etc.).

In designing the emergency stop function is necessary to consider all the potential dangers that could be generated consequently to an emergency stop of the machine: for example, you may need to assess the danger of entrapment in the case of machines where the operator stations on them (think of the equipment dedicated to the people) lifting; it is also important to evaluate the stopping time of moving parts and, therefore, assess whether to implement a stop category 0 (uncontrolled stop: is released immediately power to the motors and the moving parts are stopped by inertia) or a stop of Category 1 (stop controlled: they send braking engines and then you go off the power). In any case, the emergency stop condition must always be maintained by engagement of the emergency stop device until its release. Unlocking of the latter can be achieved only by an appropriate operator's manual operation (for example, by turning the dial as shown on the button or by pressing the reset button of a safety rope) and must not restart the machinery but only permit restarting function. Ultimately, the unlocking of the emergency stop device must always be the result of a specific voluntary action from the operator.

In the case of sets of machines (plant) design of the emergency stop function it must be assumed that you may not need a single emergency stop of the entire set; for some configurations may be necessary to provide more emergency stops, each relating to a specific set area. In this regard, the issues to consider are as follows:

• whole layout and thus a chance to see the affected area from emergency from the control point;
• production process: in some cases an emergency shutdown of the whole set could result in costly machine stops, hence the need to foresee emergency stop "partial";
• the expected exposure to the dangers: the emergency stop of the entire set could result in additional risks to the operator (for example, switching off the intake system of a treatment tank may present a risk due to the fumes and / or vapors that are generated from the tub for the operator which may be taken in that area).

The UNI EN ISO 13850: 2015 gives the basic requirements for emergency stops localized to parts of a complete system:

• each emergency stop localized to a certain area of ​​an entire system must be clearly identified: within the instructions for use, by means of labels affixed at the actuators on the machine, etc.
• The emergency stop function of the plant area should not cause additional hazard in the remaining areas of the system or increase the risks to the already dangerous situation.
• The emergency stop function of the plant area must not cause the emergency shutdown of other plant areas.

Directive 2009/125/EC "establishing a framework for the setting of specific ecodesign requirements for energy related products" aims to identify equipment with high sales volumes and higher margins for improvement of its environmental performance, with the aim of setting minimum technical and quality parameters that the manufacturer has to respect for placing equipment into service in the European market.

MTM Consulting can help your company to verify the applicability of that directive to your product and to incorporate into the production process all the changes related to eco equipment, in order to respect new obligations regarding the environment and energy.

Directive 2009/125/EC appears as a product Directive and therefore any manufacturer of products falling within its scope must ensure that he has placed on the market products compliant with such directions, by affixing the CE marking on the product and adding to the product Declaration the compliance with this Directive and demonstrating this compliance by the production of a specific technical file.

It is also a Framework Directive therefore requires the general lines which are then supplemented by EU regulations, one for each type of product included in the Directive. Since the entry into force of the Directive have in fact been issued, and will be issued in time, various implementing regulations that incorporate the detailed implementing measures. So only the adoption of parameters set out in the Regulations gives the right to the CE mark; as for the other product Directives, products that do not have them they can not be placed on the European market.

Within each Regulations it indicates the date from which those technical provisions should be put in place, providing the minimum standards required. Usually the Regulation also contains a development aimed at improving the environmental efficiency of these minimum parameters, indicating an entry into force in the following years gradually for more and more restrictive parameters.

These parameters may include:

• measurable technical performance, as the maximum current permissible under certain conditions or noise;
• technical design solutions, such as the number of polymers used for wrappers or packaging, or the methods of separation of individual materials placed on equipment;
• targeted information to the customer, to be able to better manage, from the environmental point of view, the apparatus in all stage of its life cycle, from installation, use, maintenance, to its disassembly.

From December 2008 to date they were issued regulations for the marking of the following equipment for professional use, as well as others dedicated to equipment exclusively for domestic application:

• fluorescent lamps, high intensity discharge;
• circulators gland;
• motor fans;
• air conditioners;
• centrifugal pumps for water;
• directional lamps, lamps with light emitting diodes;
• equipment for the room heating and the mixed heating apparatus;
• electric engines;
• small, medium and large power transformers;
• ventilation unit;
• professional refrigerated cabinets, of the culling, the condensing unit and process chillers;
• solid fuel boilers (wood biomass and coal).

 [mtm consulting s.r.l.]

There are now around 180 working days until EN 954-1 ceases to provide a presumption of conformity to the Machinery Directive. Although it may seem like a long time until 31 December (269 days), we should assume that there are only five working days in the week, with two days off at Christmas, a week's annual leave over the summer, plus a handful of bank holidays.

If you have no 'real' work to do, then 180 days is plenty of time to get up to speed with EN ISO 13849-1 and/or EN 62061. But most machine builders and system integrators will have sufficient work to keep them busy for most of that time.

It is now more than a year since the new Machinery Directive (2006/42/EC) came into force, but the situation is still fairly fluid in some respects. The EC Machinery Working Group meets regularly to discuss matters relating to the Directive and corresponding standards; the last meeting took place on 21/22 December. According to the Stakeholder Report published in the UK by BIS (the Department for Business, Innovation & Skills), a number of issues were discussed, which demonstrates that the Machinery Directive is not as 'black and white' as might be expected.

For example, EN 12635 (Industrial, commercial and garage doors and gates - Installation and use) is currently harmonised to the Machinery Directive, but the UK has raised a formal objection against this standard, as it would appear that there is scope for improvement. Other topics under discussion ranged from variable reach trucks, tail lifts and loader cranes, to stave splitters, dynamometers and 'grey' imports of machinery.

If you would like more information, copies of the current and previous Stakeholder Reports are available in PDF format from the BIS website.

ISO 12001:2010 'Safety of machinery. General principles for design. Risk assessment and risk reduction' will combine the old ISO 12100 (parts 1 and 2) and ISO 14121. This should simplify the process of designing machinery to fulfil the requirements of relevant standards, and we are told that there are no changes to the actual requirements. However, machine builders need to ensure that their documentation cites the standards that are current when machinery is placed on the market.