I am working a project to adapt our equipment for the new Machinery Directive (2006/42/EC). Because of the revisions related to guards, I find myself facing a fundamental question for which I can find no direct address in the various guides available either for the new or the old directive.
The basic question is "Does section 1.4 apply to any guard, or only guards provided to protect against risks arising from moving parts?" I see in 1.3.8 very specific instructions on how fixed guards etc... should be used as relates to moving parts, and criteria for such guards is given in sections of 1.4. I do not see anywhere else in the Annex an instruction saying guards should be provided to protect against risks arising from other hazard types such as electrical hazards, or thermal hazards, or toxic material hazards. Nonetheless, section 1.4 sits there on its own...unqualified. So it could be understood as applying to any guard per the rather broad definition in 1.1.1(f). " ‘guard’ means a part of the machinery used specifically to provide protection by means of a physical barrier;" The practical import of this is, for example, if I have a panel covering the entrance of a hazardous voltage electrical assembly, is it a "fixed guard" that must have attached fixing systems (captive hardware) Regards, Lauren Crane Product Regulatory Analyst Corporate Product EHS Lead Applied Materials Inc. Austin, TX 512 272-6540 [#922 26540] - external use - Save paper and trees! Please consider the environment before printing this e-mail.
