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The Machinery Directive Existing System Repair and Maintenance

Existing System Repair and Maintenance

With thanks for the DHF

Automated Door, Gate and Traffic Barrier FAQs

 

These FAQs are intended as a quick reference to the main points of automated entrance legal compliance and safety.
They cover automated doors, gates & traffic barriers primarily intended for vehicle use, but which might also be
accessible to people; they also include shutters over commercial entrance doors, eg shop front shutters.
These FAQs do not cover automatic doors that are intended solely for pedestrian access. The Automatic Door Suppliers’
Association (ADSA) can provide guidance on automatic pedestrian door safety.
Use of these FAQs should be backed up by consulting the appropriate DHF COP as appropriate; DHF TS 011:2018 Code of
practice for automated gates & barriers AND DHF TS 012:2018 for industrial doors & domestic garage doors.
DHF codes of practice are available for download in the technical specification section of the publications area of the
DHF website at www.dhfonline.org.uk.

The Machinery Directive Existing System Repair and Maintenance

Existing System Repair and Maintenance

20. Do systems at workplaces need to be brought up to current standards?

Invariably, this question turns out to be: did the system comply with the standards in force at the time of installation?
Given that the standards for vehicle doors, gates and traffic barriers have not changed significantly since 2000 and,
before that, there were no standards for these systems, it would be reasonable to judge an existing system against these
standards. Although there is no requirement for manufacturers to upgrade existing systems in line with changes to
standards, workplace legislation requires that owners and managers of workplaces keep up with current levels of safety;
eg the levels of safety allowed in the 1960s would not be tolerable in a modern workplace.
The following criminal legislation is applicable to workplace owners and managers:
− UK = Workplace (Health Safety and Welfare) Regulations
− Republic of Ireland = Safety, Health and Welfare (General Applications) Regulations
These require that “reasonable and practicable” steps are taken to provide safety. Legal precedent has proven that
current standards represent “reasonable and practicable” measures in this regard.

21. Do systems at rented property need to be brought up to the current standards?

As with FAQ 20 above, this question usually turns out to be: did the system comply with the standards in force at the
time of installation?
Given that the standards for vehicle doors, gates and traffic barriers have not changed significantly since 2000 and,
before this, there were no standards for these systems, it would be reasonable to judge an existing system against these
standards. Although there is no requirement on manufacturers to upgrade existing systems in line with changes to
standards, general health and safety legislation requires that owners and managers keep up with current levels of safety;
eg the levels of safety allowed in the 1960s would not be tolerable in a modern rented property.
The following criminal legislation is applicable to rented property owners and managers:
− UK = Section 3 of Health and Safety at Work Act 1974 (Article 5 1978 Order in NI)
− Republic of Ireland = Safety, Health and Welfare at Work Act 2005 and the Housing (Standards for Rented Houses)
Regulations 2008.
These require that “reasonable and practicable” steps are taken to provide safety. Legal precedent has proven that
current standards represent “reasonable and practicable” measures in this regard.

22. I am a domestic householder, does my system need to be brought up to the current standards?

Again, as with FAQs 20 & 21, this question usually turns out to be: did the system comply with the standards in force at
the time of installation?
Although there is no health and safety legislation directly applicable to domestic householders, it would still be wise to
ensure systems are safe, as there could still be civil action for negligence in the event of an incident. However, anyone
working on a domestic system is bound by health and safety legislation and, hence, cannot leave a system in service
with safety critical defects following repair, maintenance or modification. See also FAQ 23 below.

23. Are maintenance companies allowed to leave an unsafe system in service following repair, maintenance or modification work?

Essentially, no; to do so would leave them in breach of national health and safety legislation:
− UK = Section 3 of Health and Safety at Work Act 1974 (Article 5 of the 1978 Order in NI)
− Republic of Ireland = Safety, Health and Welfare at Work Act 2005
If the work the client has requested or agreed to would result in there being safety critical defects present, maintenance
companies cannot legally leave the system in service. The client is of course at liberty to make their own decision once
they are in possession of the facts; it is after all their system and their liability that is at stake.
If a DHF member company find themselves in this situation, they will explain the safety defects to the client, provide a
solution proposal, leave the system safe, show the client how this has been done and issue them with an unsafe system
notice. More detail on this can be found in section 5 of the relevant DHF COP – see introduction. This is not an attempt
to dictate or influence policy on a system owner/operator, it is simply a measure to protect the maintainer’s duties
under criminal law and ensure that all stakeholders in the process are informed and able to make reasoned and informed
decisions.

24. What hazards need to be addressed?

A. Structural failure must be prevented
B. Vertically moving doors must be prevented from falling back in the event of a fault
C. Sharp edges and hooking hazards must be prevented
D. Electrical safety must be maintained
E. Hazards caused by moving parts must be controlled:
− Crushing: where horizontally reducing gaps get to 500mm or less or any vertically reducing gap between the
ground and 2.5m
− Impact: where a person can be hit or pushed when not in a crushing zone
− Shear: where passing elements create a guillotine effect
− Draw-in: where body parts can be pulled into the gaps between moving elements
All reachable hazards must be either eliminated, prevented or controlled in line with the state of the art. Where the
state of the art has been achieved, a residual hazard may still exist; these can be controlled further by the use of signs,
markings, lights, audible warnings and railings etc based on a local risk assessment. All hazards must be controlled to
the state of the art before they can be treated as residual; it is not possible to simply rely on signage and markings etc
if the state of the art is not achieved – see FAQ 7.

 

Existing System Repair and Maintenance – contact us for all your door, gate and barrier needs.

 

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