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    PLANT VISIBILITY THROWN INTO CONFUSION BY EU

    Standard does not reflect state of the art on visibility aids

    Action by the European Commission means that compliance with EN 474-1:2006 +A4:2013 Earth Moving Machinery – Safety – General Requirements in respect of visibility will no longer automatically assure compliance with the Essential Health and Safety Requirements (EHSRs) of the Machinery Directive 2006/42/EC, particularly EHSR 3.2.1. Driving Position, concerning visibility from the operator position.

    The European Commission has withdrawn the presumption of conformity in respect of visibility because it believes that:

    • There have been an unacceptable number of accidents related to visibility;
    • EN 474-1:2006 +A4:2013 and ISO 5006:2006 do not fully meet the EHSRs; and
    • ISO 5006:2006 does not fully reflect the state of the art; i.e.it does not fully reflect the possibilities offered by modern visibility aids and systems.
    Action required by HSE

    HSE Advice is that:

    Manufacturers and importers of Earth Moving Machinery within the scope of EN 474-1 should review the conformity assessment of their product ranges in respect of visibility from the operator’s position to ensure continued compliance.

    Where necessary they should then implement improvements to affected products. The review of the conformity assessment can be undertaken directly with the Machinery Directive 2006/42/EC, in particular EHSRs 3.2.1. Operator’s Position, 1.1.2 (b) Principles of Safety Integration, and 1.7.4.2 (l) Contents of Instructions, and fully consider the state of the art. Manufacturers may wish to work towards the recommendations proposed in the amended standards, as they are developed, as part of their conformity assessment.

    The review should take into account:

    • The existing requirements of ISO 5006:2006;
    • The recommendations of the proposed amendments as they are developed
    • The current state of the art
    • The provision of information on residual risk. A visibility map is considered a suitable approach. (see Appendix 1).

    HSE recognises that the design of many current models of Earth Moving Machinery are driven by the requirements of ISO 5006, and that it may not be possible to respond to a step change in requirements immediately. Where this is the case, manufacturers should work towards the implementation of necessary changes to the design and user instructions using a risk assessment approach.

    This is likely to address machines with significant maskings, (blind spots) for example, when reversing. Where design improvements cannot be made in the short term, then manufacturers should revise their instructions to inform users of residual risk.

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