Extension of the Risk Assessment - Implications for Retrofit Projects

Industrial Safety

The extension of the risk assessment leads to challenges in retrofit projects. In order to meet the safety requirements of the Machinery Directive and the Ordinance on Industrial Safety and Health, operators must expand their risk assessment to include technical aspects.

  • Industrial Safety

Extension of risk assessment

Effects for Retrofit Projects

Fortunately, safety is becoming increasingly important in the industry. However, the many different origins of the safety requirements give rise to uncertainties when implementing these requirements. This is mostly due to the fact that the legislator leaves a very large part of the responsibility to the operators. Traditional retrofit projects suddenly find themselves in a state of limbo between manufacturer and operator obligations. In addition to the technical modernizations, a decision must now be made as to whether a system has been significantly modified and is therefore considered a new machine or whether fundamental approvals such as a new operating permit are required.

The good news first: in a retrofit, anything that increases safety can be implemented without major formal marketing processes. After all, the aim should always be to provide safe work equipment. However, good documentation is essential in order to be able to understand the reasoning behind the measures afterwards.

 

Manufacturer and operator obligations

There is still the problem of the conflict between manufacturer and operator obligations. In principle, plant operators must comply with the operator obligations. At the heart of this is the requirement that machinery being worked on must comply with the state of the art. This must be assessed, documented and updated in a risk assessment. If this risk assessment determines that a hazard can no longer be reduced by organizational or personal measures, it must be reduced technically. It is necessary to plan and implement the technical measures in accordance with the state of the art.

Hazard assessment and risk assessment

At this point at the latest, operators should expand their risk assessment to include the technical aspects of the manufacturer's obligations. For a retrofit, it is therefore necessary to expand the risk assessment to include the technical safety aspects of the risk assessment from the Machinery Directive. The advantage here is the use of standards harmonized under the Machinery Directive. By using these standards, it can be assumed that the state of the art is implemented. These standards exist not only for individual machines, but also for safety functions. Anyone who now thinks that these requirements from the Ordinance on Industrial Safety and Health and the Machinery Directive should not be mixed up should be told that the Ordinance on Industrial Safety and Health even explicitly refers to the Machinery Directive as the state of the art.

Do you need support with your risk assessment? Please feel free to contact us! We look forward to hearing from you!

 


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