European Economic and Social Committee is against a full revision of the Machinery Directive

On 10^th June, the European Economic and Social Committee (EESC) adopted in plenary an Information Report on the Revision of the Machinery Directive. 

In its report, the EESC considers the Machinery Directive as an important and successful instrument for European industry and its basic approach must be left unchanged.

Many of the EESC’s conclusions are in line with CECE’s position, including:

• Essential Health and Safery Requirments in Annex I: The EESC considers that changes in this section of the Machinery Directive would have a deep negative impact on the work of developing needed harmonised standards and must be avoided;
• Cybersecurity: the EESC recommends that the issue of cybersecurity be dealt with in a separate horizontal item of legislation;
• Technological developments and Artificial Intelligence (AI): the Directive's health and safety requirement duties on the manufacturer deal adequately with developing technologies such as self-learning algorithms and robotics that are designed to work within safe boundaries and predetermined operational envelopes, as they can go through the Risk Analysis & Risk Reduction (RA&RR) process before being placed on the market;
• Role of Standardisation: recognizes and supports the well-functioning approach of setting objectives to be achieved in the text – leaving standardisation to adapt and flesh out the details of how they can be achieved.

Moreover, the report also includes comments relating to:

• Partly Completed Machinery (PCM): the EESC recommends that the revision of the Machinery Directive should require that all the relevant EHSRs and risk reduction measures be applied to any PCM placed on the market, as detailed in the technical file, with the exception of those that can only be applied as part of the process of combining the PCM to produce a machine under the scope of the Directive;
• “State of the Art”: the EESC recommends introducing a definition of the term "state of the art" to avoid confusion and abuse;
• Format of instructions: the EESC recommends requiring that the paper format of the essential operator guide (quick start guide) containing more detailed and comprehensive information also be provided in digital format, but with the safeguard of providing a hard copy of the instructions to any end user requesting it;
• Ergonomic risks: EESC requests an improvement of the text of the Machinery Directive by stressing the importance of ergonomic risks;

Full opinion of the EESC available on their website and CECE’s position available on CECE website.