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Automated Door, Gate and Traffic Barrier FAQs

The Machinery Directive

Many thanks to the DHF for this information.

Automated Door, Gate and Traffic Barrier FAQs

The Machinery Directive

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.

Machinery Directive

1. Does the Machinery Directive apply to all automated doors, gates and traffic barriers?

Yes, without exception, all automated entrance systems are covered by the Machinery Directive.

2. How is the Machinery Directive brought into national law?

The directive is brought into national criminal law by the appropriate national legislation; in the UK it is the Supply of
Machinery (Safety) Regulations 2008 and in the Republic of Ireland it is the European Communities (Machinery)
Regulations 2008.

3. Has the Machinery Directive ever been updated?

The directive and the relevant national legislation has been subject to change since introduction but there have been
no significant changes to the requirements for safety. In 1995, compliance with the 1998/37/EC version became
mandatory; this was withdrawn and superseded by 2006/42/EC in 2009.

4. Who does the Machinery Directive apply to?

The person or company who apply automation to the door, gate or barrier. This can be the manufacturer of the complete
system, the person or company who combines components to form a new system or the person or company who
automates an existing manual door, gate or barrier. There are no responsibilities for owners, managers or operators
under the directive, apart from the fact that, if their system was not compliant with the directive when installed, they
will almost certainly have liabilities under other health and safety legislation.

5. What is the scope of the Machinery Directive?

The Machinery Directive covers a wide range of machinery from simple hand-held tools to complete robotic production
systems in factories. Machinery is defied in the directive as: “An assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or animal effort, consisting of linked parts or components, at least one
of which moves, and which are joined together for a specific application.”

6.  What are the minimum requirements for safety under the Machinery Directive?

There are two parts to this:
i. The Essential Health and Safety Requirements set out in Annex 1 of the directive, and
ii. Recital 14 requires that the “state of the art” is met in achieving EHSR compliance

7. What is the state of the art?

The state of the art is not, as many people, suppose cutting edge or ultimate safety; it is simply the levels of safety
described in various existing product specific standards. Under the directive, a chainsaw must be as safe as a chainsaw
standard; an automated door, gate or traffic barrier must be as safe as a door, gate or barrier standard; and a robotic
production machine must be as safe as a robotic machine standard. The state of the art is focused on the safety of
people and must be achieved as a primary requirement; any hazard that remains is considered to be a residual hazard,
protection of vehicles is a residual matter.

8. Is there any requirement to retrospectively CE mark an existing system?

The answer is no, only where such extensive modifications have taken place that the modification produces a
fundamentally different structure or significantly different functionality. Please note, however, this only covers the
need for new or replacement CE marking; other national health and safety legislation will require that all maintenance,
improvement or modification work results in a safe and compliant system, regardless of its current state or history.

9. Does an installation company need to risk assess installation of a complete system supplied by a 3rd party?

Yes, although compliance is mainly the responsibility of the manufacturer of the system, the installation company must
make an “as installed” risk assessment, taking into account any exposed hazards on the site in question. This assessment
should consider all hazards caused by topography, environment, vehicles and users and apply appropriate primary or
residual hazard controls.
If the installation company suspect they have been supplied with a fundamentally non-compliant system, it should consult
the annex at the end of the appropriate DHF COP for details of how best to proceed.

10. What documentation should be supplied with a new automated gate or barrier system?

− User warnings and safe use instructions
− Detailed maintenance instructions, including: what will need doing; how often; what skills and experience are
necessary
− A Declaration of Conformity with the Machinery Directive 2006/42/EC
− A log book to record maintenance activity
− A CE plate or label on the system bearing: the CE, 2006/42/EC; manufacturer contact details; the year of
manufacture.

11. What documentation should be supplied with a new automated industrial door or domestic garage door?

− User warnings and safe use instructions
− Detailed maintenance instructions including: what will need doing; how often; what skills and experience are
necessary
− A Declaration of Performance with the Construction Products Regulation EU 305/2011
− A Declaration of Conformity with the Machinery Directive 2006/42/EC
− A log book to record maintenance activity
− A CE plate or label on the system bearing: the CE; essential characteristics and performances; the notified body who
did the type testing; EU 305/2011; 2006/42/EC; manufacturer contact details; the year of manufacture.
A more detailed description of the documentary requirements and sample documents can be found in section 4 of the
appropriate DHF COP – see introduction.

 

Unsure if your door is safe?  We regularly run training course about Ellard products, contact us today to find out more and register your interest.

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