Nick Perkins, DHF Training & Compliance Officer explains what you need to know.
Legally, there is a big difference between a safety device for the protection of people and a device for the protection of vehicles.
Vehicle detectors (eg traditional ground loops and more recent radar devices) are not ‘safety devices’ under the terms of the EU Machinery Directive (MD) or the UK Supply of Machinery (Safety) Regulations (SMSR).
Legally, there is a big difference between a safety device for the protection of people and a device for the protection of vehicles.
Vehicle detectors (eg traditional ground loops and more recent radar devices) are not ‘safety devices’ under the terms of the EU Machinery Directive (MD) or the UK Supply of Machinery (Safety) Regulations (SMSR).
Conversely, safety components for the protection of people, such as safe edges, light grids and laser scanners are ‘safety devices’. The latter group, for the protection of people, are required to be supplied with a Declaration of Conformity under EU MD when CE marked or under UK SMSR when UKCA marked; the minimum level of safety for these devices is defined by EN 12978.
Compliance with EN 12978, as a harmonised standard in the EU and a designated standard in the UK under MD and SMSR respectively, confers a legal presumption of conformity on the device manufacturer.
There are currently vehicle detection sensors with added EN 12453 category D protection coming onto the market. These devices are supplied with a Declaration of Conformity under radio and other electrical directives and regulations, but not machinery, nor are they declared to be in conformity with EN 12978. The reference to EN 12453 category D refers to the device being a non-contact device to supplement force limitation.
EN 12453 refers to protection systems for people as category A & B (hold-to-run) C (force limitation), D (a non-contact supplement for C) or E (non-contact protection that can be used without force limitation). The manufacturers of many of these emerging devices have rated them as vehicle detectors and category D devices under EN 12453. This means that they can be used both in place of a traditional vehicle detection loop and to replace photo beams used to supplement force limitation; they do not, however, provide the primary protection required for people.
Under EN 12453, sensitive safety devices that can provide safety for people (eg safe edges, light grids, and laser scanners) must be compliant with EN 12978, be supplied with a DOC under either EU MD or UK SMSR and be conformity marked CE or UKCA accordingly. The emerging devices described above, however, are mostly not rated under EN 12978 and are not supplied with a DOC under MD, MR, or SMSR. Their intended use is to provide protection for vehicles and to supplement force limitation; consequently, the system must still be force limited and able to pass the force test specified by annex C of EN 12453.
EN 12453, MD, MR and SMSR address the criminal law responsibility to provide safety for people under intended use and foreseeable misuse conditions. The safety of vehicles, on the other hand, is a matter for the civil law (eg negligence), contract law and the potential for insurance claims and is dealt with at the residual risk assessment stage of a compliance assessment.
There are many excellent non-contact devices available that are compliant with EN 12978 and are supplied with a DOC under MD, MR, or SMSR. These can be used to protect people without the need for force limitation, providing they meet the fail-safe requirements of EN 12453 (PL ‘C’ & category 2) as installed and pass the presence detection tests specified by annex D of EN 12453.
Some of these lesser vehicle detection devices are currently being marketed and used as if they were full non-contact devices that negate the need for force limitation, which they are not!
The safety of people is the primary requirement for any powered door, gate, or traffic barrier system and is covered by criminal law relating to the supply of machinery. Devices for the safety of people need to be declared in conformity with EU MD or UK SMSR on a Declaration of Conformity and be compliant with EN 12978.
Devices for the detection of vehicles are not covered by machinery law; they only need to comply with radio and/or electrical directives and regulations and do not need to comply with EN 12978.
Manufacturers, importers, and distributors must ensure that all machinery components they supply are accompanied by an appropriate DOI (drive units and their controls) or DOC (safety devices).
When procuring any machinery device, designers, specifiers, installers, and maintainers should request and assess the relevant legal declaration before using the device in a system.
The DHF code of practice, DHF TS 013-2, explains the above requirements for supply of safety components, partly complete machines (drives and controls) and complete systems. DHF members can download a copy free of charge from the DHF website.
www.dhfonline.org.uk
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There are currently vehicle detection sensors with added EN 12453 category D protection coming onto the market. These devices are supplied with a Declaration of Conformity under radio and other electrical directives and regulations, but not machinery, nor are they declared to be in conformity with EN 12978. The reference to EN 12453 category D refers to the device being a non-contact device to supplement force limitation.
EN 12453 refers to protection systems for people as category A & B (hold-to-run) C (force limitation), D (a non-contact supplement for C) or E (non-contact protection that can be used without force limitation). The manufacturers of many of these emerging devices have rated them as vehicle detectors and category D devices under EN 12453. This means that they can be used both in place of a traditional vehicle detection loop and to replace photo beams used to supplement force limitation; they do not, however, provide the primary protection required for people.
Under EN 12453, sensitive safety devices that can provide safety for people (eg safe edges, light grids, and laser scanners) must be compliant with EN 12978, be supplied with a DOC under either EU MD or UK SMSR and be conformity marked CE or UKCA accordingly. The emerging devices described above, however, are mostly not rated under EN 12978 and are not supplied with a DOC under MD, MR, or SMSR. Their intended use is to provide protection for vehicles and to supplement force limitation; consequently, the system must still be force limited and able to pass the force test specified by annex C of EN 12453.
EN 12453, MD, MR and SMSR address the criminal law responsibility to provide safety for people under intended use and foreseeable misuse conditions. The safety of vehicles, on the other hand, is a matter for the civil law (eg negligence), contract law and the potential for insurance claims and is dealt with at the residual risk assessment stage of a compliance assessment.
There are many excellent non-contact devices available that are compliant with EN 12978 and are supplied with a DOC under MD, MR, or SMSR. These can be used to protect people without the need for force limitation, providing they meet the fail-safe requirements of EN 12453 (PL ‘C’ & category 2) as installed and pass the presence detection tests specified by annex D of EN 12453.
Some of these lesser vehicle detection devices are currently being marketed and used as if they were full non-contact devices that negate the need for force limitation, which they are not!
The safety of people is the primary requirement for any powered door, gate, or traffic barrier system and is covered by criminal law relating to the supply of machinery. Devices for the safety of people need to be declared in conformity with EU MD or UK SMSR on a Declaration of Conformity and be compliant with EN 12978.
Devices for the detection of vehicles are not covered by machinery law; they only need to comply with radio and/or electrical directives and regulations and do not need to comply with EN 12978.
Manufacturers, importers, and distributors must ensure that all machinery components they supply are accompanied by an appropriate DOI (drive units and their controls) or DOC (safety devices).
When procuring any machinery device, designers, specifiers, installers, and maintainers should request and assess the relevant legal declaration before using the device in a system.
The DHF code of practice, DHF TS 013-2, explains the above requirements for supply of safety components, partly complete machines (drives and controls) and complete systems. DHF members can download a copy free of charge from the DHF website.
www.dhfonline.org.uk
Why not Sign-up to Receive these Articles by Email each Day on our newsfeed site
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