The new EU Machinery Regulation (EU) 2023/1230 introduces significant changes to the safety requirements for mobile machinery. The changes relate in particular to seats, the risk of contact with contact lines and the safety of autonomous machines. In addition, the regulation takes into account digital risks such as self-development and protection against data damage for the first time. These requirements are intended to address both physical and digital safety issues.
According to section 3.2.2 of Annex III to the Regulation, if mobile machinery is at risk of overturning (in particular if it is equipped with ROPS), it must be equipped with a restraint system (e.g. a seat belt) to keep people in their seats or inside the protective structure. In addition, if the restraint system is not in use, the machine must not move and a visual and audible signal must be given to the driver.
Before the official regulations were finalised, the French authorities considered in 2024 what the new requirements might mean in practice. It is also possible to use a door instead of a seat belt, as in some forklift trucks. The machine should only move when the driver is in the seat (as indicated by a weight sensor) and the restraint system is in use (seat belt fastened or door closed). Movement is understood to mean the forward or backward movement of the machine, as well as its control during movement; the movement of moving parts (e.g. booms) is not included.
The new requirements are taken into account in the standards currently being developed for forestry machinery (EN ISO 11850), rock drilling equipment (EN ISO 18758) and foundation drilling and construction equipment (EN ISO 20770-1).
According to section 3.5.4, mobile machinery must be designed in such a way as to eliminate the risk arising from contact with live overhead power lines. If the risk cannot be completely eliminated, the danger of electric shock must be prevented.
This requirement applies to machinery operating outdoors. The first step is to consider reducing the height of the machinery (to eliminate contact with overhead lines). If this is not possible, the risk must be reduced by other means. The proposed technical solutions, which are more or less feasible, include, among other things, insulation of equipment parts, remote or autonomous control, collision prevention devices, cameras to improve visibility, positioning systems and electric field sensors. Operating instructions should also include information on residual risks of electric shock and fire, machine dimensions, correct use of protective devices and emergency actions after contact with overhead lines.
The future safety standard for forestry machinery does not currently address the risk of contact with overhead power lines. With regard to rock drilling equipment, an attempt is being made to meet this requirement by referring to the electrical safety standards for machines IEC 60204-1 and IEC 60204-11, as well as to general visibility requirements. With regard to drilling and foundation construction equipment, a separate section is devoted to this requirement, including the requirement to insulate the cab, work platform and controls from electrical current, instructing the operator by means of a sign to remain in the cab, and providing additional information in the operating instructions on permissible voltage ranges and means of protection.
The Machinery Regulation contains a number of new requirements for autonomous mobile machinery. Autonomous operation means ensuring all essential safety functions of mobile machinery while it is moving and in the working area without constant interaction with the operator. The requirements are divided into different sections and relate, among other things, to monitoring functions, control systems, start-up or movement, movement functions, control circuit failure, movement to the charging station and operating instructions.
With regard to control systems, the manufacturer must take into account the risks arising in the event of a malfunction when autonomous mode is activated. For example, the blades of a robotic lawn mower must stop if the robot falls. The requirement for a movement function means that the device must either move in a closed space or be equipped with a system for detecting people, animals and obstacles. If there is a risk of contact, the device must stop and its moving parts must not pose a hazard.
In the current standards for mobile machinery, the requirements for autonomy are largely not implemented. This means that a manufacturer can design an autonomous machine, but the requirements of the Machinery Directive must be met in a different way than by referring to a harmonised product standard. In this case, the ISO 17757 autonomy standard may be useful.
