Wednesday, 9 February 2022

20 Years of Automated Gate Standards


EN 12453 was first published in 2000; before this date there were no powered gate standards. Between 2000 and 2010, there was very little discussion of safety or compliance in the UK powered gate industry. However, following the 2010 child deaths in Bridgend and Manchester, much has changed.
 
The UK Health and Safety Executive investigations into these deaths led them to issue a formal objection to the European Commission about the efficacy of the standard. As a result of this, and a later revision of the HSE objection, in 2015, the Commission issued a warning to the industry: they should no longer rely entirely on EN 12453 for legal compliance.

Central to legal compliance in the UK powered gate industry is the Supply of Machinery (Safety) Regulations which bring the EU Machinery Directive into UK criminal law. The Regulations (and the Directive) rely heavily on harmonised standards to describe the minimum level of safety required for compliance. EN 12453 describes this minimum for powered gate safety, by being referenced by EN 13241 which was harmonised with the Machinery Directive in 2003.
 
A common myth in the early years of UK gate safety was that use of standards is optional (which is quite true) but failed to acknowledge the more important fact that attaining an equal or improved level of safety to that described by a harmonised standard is not optional, it is mandatory. This became blindingly obvious as prosecutions relating to the 2010 incidents, and others, played out. UK HSE prosecuted a series of manufacturers, installation companies, and maintenance companies. Central to each prosecution was the responsible company’s failure to reach the level of safety described by EN 12453, some for failing to protect reducing gaps at hinges, others for failing to test the operating force, and several for failing to achieve the structural integrity required by the standard.


During this time, CEN (the European standards body) had begun a revision of EN 12453. In 2017, they published a revised version but much to their consternation, the European Commission, in part on the advice of UK HSE, declined to give it the harmonisation required to confer compliance. As a result, when BSI published BS EN 12453:2017 in the UK, they included a national foreword advising users not to rely on it entirely for legal compliance.
 
Helpfully however, the national foreword did at least explain which areas were deficient and required additional measures. For powered gates, the most important issue was that although the standard explained that all hazards in the movement area of a hinged gate must be protected, where this was being done by force limitation, it only explained how to test the main closing edges. There was no mention of the need to verify safe force in these other critical areas.

It is a fact that since first publication in 2000, EN 12453 has required that any contact with a moving gate must either be completely prevented by hold-to-run, guards or non-contact technology such as light grids or laser scanners, or that operating force and time must be controlled to safe levels which depend on the size of the reducing gap. In reducing gaps over 500mm, the maximum force is 1400N, and in reducing gaps of 500mm or less, the maximum is 400N. In either case, the force must reduce to 150N in 0.75 of a second and reduce further to 25N within five seconds.
 
It has always been the case that should a person be in the path of a moving gate, if it contacts them, it must immediately reverse movement within the prescribed force and time limits. As a supplement to the requirements for limiting force, where a gate auto closes or where un-trained persons might be affected, there must also be low level beams present to reduce the probability of contact with the force limited gate. These ‘supplementary’ beams are an addition to the force limitation, not an alternative; they are not considered to be a stand-alone safety device, they are far too easy to defeat by leaning, reaching, or standing astride the beam. This is an important point; in many death and injury prosecutions, the offending gate was equipped with beams but did not have adequate force limitation.


Very little has changed in terms of safety requirements between 2000 and the current day, only very minor tweaks have been made to the standard. The requirements for control system fail-safe have been upgraded and the need for verification of safe force in areas of a gate that are away from the main edges has been clarified.
 
It is also worth noting that protecting against hinge failure has been a requirement since 2000 (by reference to EN 12604:2000), if a hinge fails, the gate must not fall. In the 2017 revision (by reference to EN 12604:2017), this was relaxed a little to allow a minor movement of 300mm from the vertical. This allows the use of a catch lanyard rather than engineering solutions like reinforced hinge structures or triple hinging. The requirement to protect against hinge failure is not new, there has only been a very minor relaxation of the long-standing 2000 requirement.

CEN have now amended EN 12453:2017 and published it as EN 12453:2017+A1:2021; all indications are that it will eventually achieve harmonisation. When it is published by BSI in the UK as BS EN 12453:2017+A1:2021, it will no longer need to contain the national foreword warning against using it to confer legal compliance, thus ending 10 years of doubt and confusion over automated gate standards in the UK.

During these 20 or so years, very little has changed with EN 12453, the basic concepts for safety and legal compliance have remained constant. Had all systems been manufactured, installed, and maintained in conformity with EN 12453 since 2000, all but one of the 20 or so incidents that have led to death, injury, and prosecution would not have occurred. However, in that time, nearly everything has changed in our industry. There are still pockets of confusion and misinformation, but overall, the message has gradually filtered through. The support from the industry by means of training and educating its people is commendable and things are now much better in the field; systems are being made safe and compliant, most companies in the industry are now getting on board. Only a small minority of criminal outliers remain. Sadly, these will continue to make waves, but across the industry the transformation since 2010 has been dramatic, something our industry should be very proud of.
 
DHF has issued a revised industry code of practice for 2022. Released in January, DHF TS 013:2021 replaces the earlier TS 011 (gates & barriers) and TS 012 (industrial & garage doors) and now covers gates, barriers, industrial doors, and garage doors in a single series of documents. Part 1 is the on-site guide covering safety, part 2 covers legislation for installation, maintenance and repair companies, and part 3 is guidance for owners and managers. The new code encompasses all the changes to EN 12453 and explains how to achieve legal compliance.

Download a copy at: www.dhfonline.org.uk/publications/ (click on gates and barriers).

DHF continues to deliver state-of-the-art fully accredited training on all aspects of safety and legal compliance in classrooms or online: www.dhfonline.org.uk/training/
 
Nick Perkins, DHF Training and Compliance Officer

https://www.dhfonline.org.uk





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