Machinery Directive: Orgalim Contribution to the Guide of Interpretation to the Machinery Directive
Published: 26 September 2019
Policies & Issues: Internal Market - Product Safety Legislation
The current Machinery Directive 2006/42/EC, Annex I, section 1.7.4. does not specify whether the instructions should be made available in paper or electronic format. However, the Guide of Interpretation to the Machinery Directive (edition July 2017) states that the economic operator has the possibility to provide them in electronic file, but without giving further clarification.
In this paper, Orgalim would like to suggest some clarifications to the explanations provided in the guide of interpretation, give practical examples on the different formats in which the instructions can be provided and justify the benefits of each of the alternative means of providing instructions. Finally, we would like to submit a new text to be taken on board in the next revision of the guide.
In line with the opinion expressed by other stakeholders at the last meeting of the Machinery Working Group, Orgalim believes that economic operators need a flexible approach on this issue as a one size fits all solution does not work and the possibility to deliver instructions in digital formats besides the paper form offers many opportunities in terms of usability for all parties involved.
When placing machines on the market, the information and in particular the instructions provided by the economic operator on the safe use of machines can take various forms. Indeed, in most cases, the machinery is delivered to an end customer or an employer who puts the machine into service and uses it themselves or alternatively, makes the machine available to their employees to perform their work.
One important point is that flexibility should be offered to the economic operator to decide together with the next person in the value chain, which form of the instructions would suit their needs best. This flexibility should be extended along the whole value chain.
To read the position in full, please download the document above.
Manager - Technical Regulation
Junior Adviser - Internal Market