Revision of Standards for Powered Doors, Gates and Barriers

Health and Safety Executive - Safety alert

Introduction:

• British/European standards BS EN 12453:2017 concerning the safety requirements and tests for powered doors, gates and barriers primarily for vehicular use, and BS EN 12604:2017 concerning mechanical requirements and tests for the safety of both powered and non-powered versions of these products, have now been published. They are available for purchase online from BSI.
• They replace and supersede in full the 2000/01 versions of these standards which dealt with the same products and issues; these two new standards cover what was previously dealt with in four standards (BS EN 12453, BS EN 12445, BS EN 12604 and BS EN 12605).
• These new standards are a major step forward in helping to define the 'state of the art' for all products in scope, especially for the safety related parts of the control system on which these products depend for safety. They maintain the previous requirements for basic strength, stability and testing, including where force limitation is the primary means of delivering safety. The requirement on force limitation is not to exceed the existing force limits (basically 400 N for crushing and 1400 N for impact).
• HSE's view, however, is that there are aspects of the standards where they do not as yet fully meet the objectives of the Essential Health and Safety Requirements (EHSRs) of the European Machinery Directive 2006/42/EC. This means that compliance alone with the standards will not be enough to meet the requirements of the Supply of Machinery (Safety) Regulations 2008 (SMR08) for either new products placed on the market, or when first put into service (eg in situ manufacture, and powering existing gates).

Background:

• Following two child fatalities which involved powered gates in 2010, HSE carried out a detailed examination of the suite of British/European standards then available to support the design and construction of powered doors, gates, barriers etc (see the related previous Safety Bulletins). HSE concluded that collectively the standards failed in a number of areas to adequately support the EHSRs of the Machinery Directive.
• The Directive, which has been implemented into UK law for well over 20 years by SMR08, applies to all machinery, which includes powered doors, gates and barriers, when newly placed on the market, or when first put into service (eg when made in situ, or existing manual gates are 'motorised').
• The UK launched its Formal Objection to the standards in December 2010, as permitted by Article 10 of the Machinery Directive.
• The European Commission considered the objection and agreed with the UK that the key standards did not entirely satisfy the EHSRs of the Machinery Directive. Its decision was confirmed and published by two Decisions which were made publicly available in 2015. Additionally, warnings were placed against the entries for EN 12635 and EN 13241-1 in the list of standards harmonised under the Machinery Directive in the official Journal of the European Union, in effect removing the 'presumption of conformity' that they previously gave.
• Removing this presumption of conformity does not prevent manufacturers and installers of these products complying with the Directive/UK Regulations. Rather it means that manufacturers/installers who choose to use these standards can no longer simply rely on complying with the standards to meet all of the requirements of the Directive/UK Regulations.
• Regulation 7(1) of SMR08 requires all machinery such as powered doors, gates and barriers to be safe. It is the duty of the person responsible for the design, construction and placing on the market/putting into service of the machinery to ensure this. Others then have the ongoing responsibility to keep the product safe through its lifetime of use, which includes ensuring non-employed persons are not endangered by the equipment (see below for link to FAQs).

Action required:

• The new standards are not "harmonised". This means that manufacturers (and installers, who often 'put into service' a new machine made in situ), must continue to show through a detailed technical file for each product how it has been designed and constructed to meet the safety objectives of the legislation. This must be undertaken before the CE marking is applied and the product is made available to the end user, together with comprehensive User/Maintenance Instructions, and a Declaration of Conformity, which must be made out in the name of the person responsible for the product's conformity.
• While these new revised standards can help define the 'state of the art' which must be reached, in all cases a thorough assessment of risk must be undertaken which fully considers the unique environment of use, the presence of and use by any vulnerable person, and all hazards arising from use, and foreseeable misuse, such as riding on the door or gate.
• Design measures (to avoid risk, eg from hinge areas, collapse/falling over) and protective measures (guarding, fencing, safety edges, presence detection, etc) must be implemented during construction, taking into account the presence of any vulnerable populations such as children and those with reduced mobility or other disabilities, and any foreseeable misuse that may arise (such as playing on or near such equipment, or anyone rushing through gaps). You cannot rely on warnings alone to manage significant risks, although they may have their place in some circumstances.
• Where force limitation is the primary means of safety, impact and crushing forces should be as low as possible (the standards give maximum levels), and verified by testing post installation.
• Where the technology permits, the check of the safety function should take place before each movement. This is very important where vulnerable populations are at risk, as even one failure could result in serious or fatal injury from crush/entrapment.
• Effective measures should be taken to detect any failure in the means of suspension of vertically moving doors, preferably stopping further use (unintended movement beyond 300 mm should be prevented), so that action can be taken before any catastrophic failure.
• The existing harmonised standard BS EN 12978:2003+A1:2009 on safety devices for power operated doors and gates gives specific requirements to support the safe design of these products (Note: a revision of this standard is expected in 2019).
• Although these standards are not intended for retrospective application, many existing powered doors, gates and barriers may not be as safe as they should be (some did not meet the previous standards or requirements for safety when originally supplied), so they can be used to support the re-assessment and any necessary upgrades to make existing products safer for continued use.
• All readers are advised to consider the other available information and the existing Safety Bulletins published by HSE on these products (see below for links).

Relevant legal documents:

• The Supply of Machinery (Safety) Regulations 2008 (SMR08), which implement Directive 2006/42/EC on Machinery (Note: these replaced the previous 1992 UK regulations, which implemented earlier versions of the Machinery Directive, and have required the same standards of health and safety for all new machinery since January 1995).
• The Workplace (Health, Safety and Welfare) Regulations 1992, especially Regulations 5 (maintain workplace equipment and systems) and 18 (on safety of doors, etc)
• The Health and Safety at Work etc Act 1974, especially Section 3 the duty towards the safety on non-employed persons (eg the public and visitors) arising out of the way an undertaking is conducted (also applies to landlords and managing agents).

References:

• Machinery Directive 2006/42/EC
  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006L0042
• which is supported by the 'Guide to the application of the Machinery Directive 2006/42/EC' http://ec.europa.eu/docsroom/documents/24722
• BS EN 12453:2017 Industrial, commercial and garage doors and gates – Safety in use of power operated doors - Requirements and test methods, available from:  https://shop.bsigroup.com/
• BS EN 12604:2017 Industrial, commercial and garage doors and gates - Mechanical aspects - Requirements and test methods, available from: https://shop.bsigroup.com/
• BS EN 12978:2003+A1:2009 Industrial, commercial and garage doors and gates — Safety devices for power operated doors and gates — Requirements and test methods, available from: https://shop.bsigroup.com/
• Commission implementing Decision (EU) 2015/1301 of 20 July 2015 on the publication with a restriction in the Official Journal of the European Union of the reference of standard EN 13241-1:2003+A1:2011 on industrial, commercial and garage doors and gates under Directive 2006/42/EC of the European Parliament and of the Council
• Commission implementing Decision (EU) 2015/1194 of 20 July 2015 on the publication with a restriction in the Official Journal of the European Union of the reference of standard EN 12635:2002+A1:2008 on industrial, commercial and garage doors and gates under Directive 2006/42/EC of the European Parliament and of the Council

General note:

Please pass this information to others who may have this type of product or equipment on their premises; or those who advise on/assess (including consultants); those who specify (including architects and their clients), design, make, supply, install, maintain, service this type of equipment; or those who have any responsibility (eg landlord/managing agent) for this type of equipment.