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Machine safety

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Implementing a retrofit with legal certainty

Is a machine still safe after it has been converted, retrofitted or extended? Machine operators must ask themselves this question if they want to use their system for a different purpose or modernize it to bring it up to the latest state of the art.

The strength of Euchner Safety Services is the broad spectrum of engineering. © Euchner

Changes to existing machines are part of everyday life in production operations: companies adapt their production to new products or functions, for example, and modify their machines accordingly. With a retrofit, operators can bring older and technically outdated machines up to the latest state of the art and extend their useful life. In a "digital retrofit", systems and machines are upgraded with modern sensor and communication technology to make them fit for requirements in the Industry 4.0 environment. Modernizing machines and systems offers many advantages, such as compliance with legal requirements.

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Machine operators bear a high level of responsibility for the protection of their employees. In Germany, this is legally regulated in the Industrial Safety Ordinance and the Occupational Health and Safety Act. When it comes to modification and modernization projects for existing machines, there is often uncertainty about the impact on legal requirements. Some operators even avoid making any changes to machines - for fear of losing CE conformity for their machine and having to go through the CE conformity assessment procedure again.

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Important to know: Most conversions and modifications are not "significant changes" that require a new CE marking. As a general rule, if a machine is modified, converted or extended, it must always be assessed as a "substantial change to machinery" using the interpretation paper from the Federal Ministry of Labor and Social Affairs. Operators also have obligations in the case of modifications classified as "non-substantial": They must carry out a risk assessment, check that the entire machine is state of the art, adapt the documentation in a legally compliant manner in accordance with the Ordinance on Industrial Safety and Health and implement suitable safety measures if necessary. Euchner Safety Services offers customized consulting and engineering services for machine manufacturers and operators on all aspects of machine safety. The experienced team can support companies in implementing a conversion or modernization of their machines in a legally compliant manner. The experts prepare documentation, analyze and inspect machines for "significant changes" or "entirety of machines". As a general contractor, they also take on the design, planning and integration of safety solutions, including verification and validation. If necessary, the team implements structural measures and selects and integrates the required components.

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