To all members of the DHF Automated Gate & Industrial Door Groups

Dear Member

The Machinery Directive and powered gates, doors & barriersYou may have seen an article in the latest issue of Perimeter Systems questioning both the applicability of the Machinery Directive to automated gates and the advice given on this subject by DHF. We are therefore taking this opportunity to write to all our members to clarify the principles underlying our guidance.

A recent meeting with HSE, the main authority responsible for enforcing the Machinery Directive in the UK, has served to confirm the DHF’s position:

1. Powered gates, doors and barriers are clearly “machinery” as defined by the Machinery Directive 2006/42/EC; consequently, they must comply with that Directive. This situation is very unlikely to change in the foreseeable future.

2. The Directive is implemented into UK law by the Supply of Machinery (Safety) Regulations 2008 (SMSR08). SMSR08, like other health and safety legislation, place a significant legal responsibility on any company or person placing machinery, including powered doors, gates, and barriers, on the EEA market, or putting such a system into service for the first time.

3. Compliance with the Directive/Regulations demands achieving the “state of the art” in satisfying the Essential Health and Safety Requirements, within the mandatory framework of the principles of safety integration which require:

firstly, eliminating or reducing risks as far as possible by inherently safe machinery design and construction

secondly, by taking the necessary protective measures in relation to risks that cannot be eliminated

and thirdly, informing users of the residual risks due to any shortcomings of the protective measures adopted.

4. The state of the art is not, as some people assume, “cutting edge safety”, nor meeting the ‘lowest common denominator’, but simply achieving, or in some cases exceeding (see note below), reasonably practicable levels of safety described in current product specific standards.

5. The applicable standards are EN 12453, EN 12604 and EN 12978.6. These standards represent the absolute minimum requirement for safety that must

be achieved following any risk assessment.7. It is not possible to risk assess for a lower level of safety due simply to a low

likelihood of occurrence; the state of the art must be achieved.8. Once the state of the art is achieved, the residual hazards must be assessed; these

are hazards that exist at the state of the art, such as the effects of contact with 400N for 0.75 of a second and 150N for 5 seconds.

9. Residual hazards can be addressed by applying signage, warning lights, ground markings, railings, audible devices, additional photo beams, etc.

Note: In July 2015 the European Commission declared that the current standards were not in fact entirely adequate to provide a presumption of conformity with the Machinery Directive. This means manufacturers choosing to follow these standards cannot simply follow and declare conformity with them as a means of making a safe product but must fully justify their design against the essential requirements in the technical file that must be compiled before the product is placed on the market.

To assist members to achieve legal compliance, while taking account of all the above points, DHF has developed, in consultation with members and other organisations, two guidance documents. DHF TS 011:2018 (gates & barriers) and DHF TS 012:2018 (doors) set out in abridged form the content of the standards and legislation necessary to achieve compliance with the law.  These two documents condense, refine and clarify over 400 pages of legislation and standards into greatly simplified and freely accessible documents.

While HSE does not endorse third party publications, HSE representatives have confirmed that the DHF TS documents provide valuable information in describing the current state of art for these products. Nevertheless, care must always be taken to ensure that all hazards are identified and adequately controlled in line with the Essential Health and Safety Requirements as set out in Annex I of the Machinery Directive 2006/42/EC (and Part 1 of Schedule 2 of SMSR08).

In summary, powered gates, doors and barriers must comply with the Machinery Directive/SMSR08 when supplied or put into service and that situation is very unlikely to change. The standards are intended to help the industry comply with the Machinery Directive/SMSR08 and must be considered as the minimum level of compliance. Importantly, it is appreciated that the standards are detailed and complicated, hence the value of the DHF Technical Specifications which condense and simplify the contents of the standards.

Kind regards

Yours sincerely

Michael Skelding MA (Oxon)DHF Secretary & General Manager