Dear Members


I am writing to ask for your advice on the use Machinery Directive 2006/42/EC 
Exemption for products specifically designed and constructed for military 
purposes.



My question is whether this exemption can be applied to a Military Training 
System specifically designed to train the Military Forces in the use of a 
Weapon System that is designed and constructed for defence purposes. The 
Training System is only used for this sole purpose. That is no other uses. The 
Training System will be installed and used in a restricted/controlled area and 
the instructors, maintainers and operators will be trained in its use.



The Training System includes a mechanism which in the terms of the directive is 
classified as a "lifting accessory". This mechanism along with the complete 
Training System will be subjected to a documented Safety Assessment and Risk 
Assessment before the system is put into service.



The EU Guidelines for the Machinery Directive relating to this exemption are as 
follows:



Article 1 (2)

(g) Machinery specially designed and constructed for military or police 
purposes;



59 Machinery for military or police purposes

The exclusion set out in Article 1 (2) (g) applies to machinery specially 
designed and

constructed for defence purposes or for the purpose of maintaining order. 
Ordinary

machinery used by the armed forces or by the police but which is not specially

designed for defence purposes or for the purpose of maintaining order is 
subject to

the Machinery Directive.

In some countries, certain fire services belong to the military, however 
machinery

designed for use by such fire-fighters is not thereby considered to be designed 
and

constructed for military purposes and is thus subject to the Machinery Directive



Does the second sentence "Ordinary machinery used by the armed forces or by the 
police but which is not specially for defence purposes or for the purpose of 
maintaining order is subject to the Machinery Directive." apply to a Military 
Training System designed specifically to train the armed forces in the use of a 
Weapon System for defence purposes or not?



If a specially designed Military Training System intended for a single use is 
not exempt, would it be considered acceptable for the fore mentioned documented 
Safety Assessment and Risk Assessment to be used as suitable evidence for 
meeting the essential health and safety requirements of the Machinery Directive 
or not?



I would be greatly for the members help. If you would prefer to contact 
directly instead of via the listing my Email work address is 
philip.steven...@uk.thalesgroup.com<mailto:philip.steven...@uk.thalesgroup.com>.or
 my home Emaol address pw...@hotmail.co.uk.






Regards



Philip Stevenson
Senior Specialist Engineer - Electronics, Advanced Weapons, Belfast

Thales

Land & Air Systems
Alanbrooke Road, Belfast, Northern Ireland, BT6 9HB

www.thalesgroup.com/uk<http://www.thalesgroup.com/uk>

Tel: +44 (0)28 90465665
e-mail: 
philip.steven...@uk.thalesgroup.com<mailto:philip.steven...@uk.thalesgroup.com> 
or pw...@hotmail.co.uk



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