Report on the “NOMAD” project – A survey of instructions

Report on the “NOMAD” project – A survey of instructions
supplied with machinery with respect to noise and the
requirements of the Machinery Directive
Prepared by the NOMAD Steering Committee
May 2012
Report on the “NOMAD” project – A survey of instructions
supplied with machinery with respect to noise and the
requirements of the Machinery Directive
Executive summary
The NOMAD project was a survey to examine the noise-related content of instructions
supplied with machinery offered for purchase in the European Economic Area (EEA). The
project collected more than 1,500 sets of instructions from machines covering 40 broad
machine-families from 800 different manufacturing companies. The information in these
instructions was analysed to determine compliance with the requirements of the Machinery
Directive, and assess the quality of information.
The general state of compliance of machinery instructions with the noise-related
requirements of the Machinery Directive was found to be very poor: 80% of
instructions did not meet legal requirements. The main causes of failure to meet legal
requirements were: some or all required numerical values relating to noise emissions were
missing; and, where values were given they were not traceable to machine operating
conditions or measurement methods, and not credible either against stated
conditions/methods or as warnings of likely risk in real use.
As a consequence, it is considered highly likely that, in making a machinery procurement
decision, employers are prevented from taking noise emissions into account, and are
prevented from understanding what is necessary to manage the risks from noise relating to
equipment that is procured.
Recommendations are made for actions aimed at bringing about a global improvement to the
current situation. The recommendations consist of targeted actions that are achievable on a
large scale, can be carried out within existing frameworks and are expected to have
measureable outcomes. Targeted actions are proposed aimed at raising awareness of the legal
requirements, responsibilities and actions required among the various groups who have parts
to play in the system - machine manufacturers, standards-makers, machine users, and
occupational safety and health professionals. Proposals are also made towards enforcement
campaigns aimed at machine manufacturers, and towards targeted market surveillance
activities.
Recommendations are also made aimed at providing, or improving, tools and resources for
both machinery manufacturers and market surveillance personnel.
i
Contents
1.
Introduction.......................................................................................................................1
2.
Collection of instructions and data extraction ..................................................................2
3.
Analysis of data.................................................................................................................4
4.
Results...............................................................................................................................6
5.
Discussion .......................................................................................................................10
6.
Conclusions and recommendations to Machinery ADCO..............................................12
Appendices......................................................................................................................17
ii
Report on the “NOMAD” project
1.
Introduction
1.1
Scope of project
The NOMAD project was a survey to examine the noise-related content of instructions
supplied with machinery offered for purchase in the European Economic Area (EEA). The
project involved the collection of machinery instructions, extraction and storage of relevant
data from these instructions, and systematic analysis (qualitative and quantitative) of the data
to determine legal compliance and quality of information. The work was supported by the
Administrative Co-operation Group for Market Surveillance under the Machinery Directive
(“Machinery ADCO”) and involved contributions from 14 European Union (EU) and
European Free Trade Association (EFTA) Member States.
The project was overseen by a Steering Committee, with practical contributions being
managed by representatives of individual Member States. Further background information
about the NOMAD project can be found in Appendix A.
1.2
Legal requirements relating to noise in the Machinery
Directive.
The European Machinery Directive (89/392/EEC, 98/37/EC and 2006/42/EC) was introduced
to enable free trade and consistent standards of safety across Member States and European
Free Trade Agreement (EFTA) countries. The Directive contains essential health and safety
requirements (EHSR) relating to a range of health and safety risks arising from the use of
machinery intended for use at work.
In relation to noise, the Machinery Directive (2006/42/EC) places an explicit duty on
machine manufacturers and suppliers to:
•
design and construct products in such a way that the risks resulting from the emission of
airborne noise are reduced to the lowest level taking account of technical progress and the
availability of techniques for reducing noise, particularly at source (EHSR 1.5.8);
with further explicit requirements that the instructions accompanying machinery must
contain:
•
information on noise emissions (numerical values) (EHSR 1.7.4.2u); and
•
instructions on installation and assembly for reducing noise and vibration (EHSR
1.7.4.2j).
The Machinery Directive has other requirements relating to the content of instructions that
apply to all hazards, including noise. The main requirements that can be applied to noise in
relation to instructions are that they must contain:
•
instructions for safe use and necessary training of operators (EHSR 1.7.4.2k);
•
information on residual risks (EHSR 1.7.4.2l); and
•
instructions on protective measures for the user, including appropriate PPE to be provided
(EHSR 1.7.4.2m);
1
Report on the “NOMAD” project
Appendix C contains definitions and explanations of key noise emission terminology used
throughout the report, intended to help those readers unfamiliar with such terminology.
It was the main purpose of this survey to assess the information provided in machinery
instructions (relevant to noise as a hazard) against these legal requirements. The full text of
the EHSRs explicitly or implicitly relating to noise is given in Appendix D.
In its most recent revision (2006/42/EC) the Machinery Directive extended the duty to
provide information on noise emissions; it must now be given in any sales literature
describing the performance characteristics of the machinery, as well as in instructions and
technical documentation (EHSR 1.7.4.3, see Appendix D).
The purpose of providing warnings, risk information and noise emission information is to
allow manufacturers to demonstrate low-noise designs; and to allow purchasers and users of
machinery to make informed choices regarding the safety of a potential purchase and to
understand what measures will be necessary to mitigate the risk in real use.
1.2.1 Numerical values and machines also covered by 2000/14/EC
For certain types of machinery, intended to be used outdoors (e.g. on construction sites and in
parks and gardens) additional requirements on permissible sound power levels and labelling
of sound power levels are contained within Directive 2000/14/EC on noise emission in the
environment by equipment for use outdoors– the so-called “Outdoor Noise Directive”.
The requirement under EHSR 1.7.4.2u of 2006/42/EC relating to numerical values of noise
emissions is in effect modified for those machines that are covered by the Outdoor Noise
Directive as well as by the Machinery Directive (see Appendix E). Whereas under the
Machinery Directive a numerical value for sound power level is required only for “noisier”
machines (i.e. conditional on the magnitude of emission sound pressure level), for machines
which are also covered by 2000/14/EC a numerical value for sound power level must always
be given.
2.
Collection of instructions and data extraction
2.1
Collection of instructions
Collection of instructions took place from November 2009 to January 2011.
Collection of instructions and data extraction was the responsibility of a nominated National
Contact Person (NCP) within each Member State/EFTA Member taking part in the work. At
the discretion of each NCP the work on collection and data extraction could be assigned to
one or more persons acting as National Data Providers (NDP). In some cases the NCP acted
also as a NDP.
A range of methods was used to collect machine instructions. These included: direct approach
to manufacturers/suppliers, gathered from end-users, from web-sites of manufacturers, from
industry-specific internet databases, and from other (secondary) data sources (for example,
access was made to a large number of instructions relating mainly to powered hand-tools that
had been gathered by a university as part of a separate project). Depending on the individual
contributing Member State, instructions were either collected for specific types of machine,
or without any specific machine-type in mind. As a matter of policy, only instructions from
machines first put on the market from 2000 onwards were collected.
2
Report on the “NOMAD” project
It is noted that some contributing Member States resorted to collecting instructions from
manufacturers’ web-sites, having encountered difficulties in collecting instructions from
other sources. Where such web-sites were used it was assumed that the instructions found
were the same as would be provided with the machine.
The total sample of instructions included in the final analysis (i.e. excluding those assessed as
unusable for statistical analysis) was 1,531. This covered 40 broad categories of machine, as
described by the European Committee for Standardization (CEN) Technical Committees
(TCs).
2.2
Data extraction
The Steering Committee developed a question-set (see Appendix F) and accompanying
instructions to allow for a systematic and consistent approach to the identification and
extraction of relevant data from instructions. This was considered necessary as there is no
standard format or layout for instructions, and the NCPs and NDPs were not necessarily
experts in the field of noise.
The team at the French National Research and Safety Institute (INRS) developed an
electronic database and web-based template to facilitate completion of the question-set and
storage of the data extracted. Each completed template relating to a set of instructions was
given a unique reference number, ensuring traceability of the data to an NDP/NCP and to the
original copy of instructions (which were retained by the NCP/NDP). As well as being a
convenient way of completing the question-set, the web-based template assisted data
extraction by providing easy access to information such as lists of common type-B and typeC standards, Annex IV machines and 2000/14/EC machines. The capabilities of the webbased system allowed for the question-set to be presented in the national language of the
various NCPs.
The question-set was aimed mainly at the extraction of factual data, although NDPs/NCPs
were asked to judge the quality with which the information in the instructions that was in
their national language was expressed. NDPs/NCPs could make free-text entries where
necessary, i.e. to capture important information from the instructions that could not be readily
categorised. NCPs, helped by the Steering Committee members, had the task of translating
any free-text entries into English so that everyone in the Steering Committee could
understand and analyse the contents.
When the EC Declaration of Conformity was given alongside the instructions, its content on
noise was considered as an integral part of the instructions and its contents were included in
the extraction of data.
2.3
Issues encountered during data extraction
A range of problems were encountered in the process of identifying and extracting relevant
data from the instructions. Some commonly encountered problems included:
•
having to infer the quantity of a given numerical value when it is poorly described (e.g. is
it power or pressure);
•
inadequate references to multipart safety standards/test codes (e.g. EN 50144);
3
Report on the “NOMAD” project
•
clear typographical errors (for example, for the transposition of digits in a reference to a
standard) that render instructions non-compliant;
•
machines known to be in a category covered by 2000/14/EC, but reference to such not
made in instructions;
•
lack of clear identification of guaranteed and declared sound power level for 2000/14/EC
machines.
3.
Analysis of data
3.1
Analysis methods
Each set of instructions, represented by the data extracted from it to the database, was
assessed individually for its compliance with the requirements of the relevant Directive
(98/37 or 2006/42), and for the quality of the information.
The assessments were based on a synthesis of the data extracted from instructions; to make
the assessments also required knowledge/judgement of the scope of type-B and type-C
standards, and knowledge/experience in acoustics and machinery noise.
To allow synthesis of the data, an assessment grid was developed containing twenty questions
(eleven relating to legal compliance, nine relating to quality), see Appendix G. The
assessment covered factual issues such as presence or absence of required information,
traceability of numerical values to defined measurement methods and operating conditions,
credibility of numerical values in relation to stated operating conditions and likely actual risk
in real use, and quality of information on residual risk and instructions for safe use. Partial
completion of the assessment grid was possible by automated output from the database
system, but some parts of the grid could only be completed by examining the free-text
information.
3.2
Categorisation of instructions
Based on the results of the completed assessment grid, each set of instructions was
categorised according to the following:
C(i)
Compliant – Information correct and very clear
C(ii)
Compliant – Information correct and understandable
NC(i) Not compliant – Some correct information
NC(ii) Not compliant – Information absent or unusable
The final assessment into one of the categories described above was made, in the main, by
members of the Steering Committee, although some assessments were made by NCPs with
sufficient knowledge and experience.
4
Report on the “NOMAD” project
3.3
Noise emission values
3.3.1 Traceability of noise emission values
In assessing traceability of noise emission values, information was sought on the method used
to measure the noise emissions, and the operating conditions under which measurements
were made. For measurement methods, values were considered traceable if the instructions
either:
•
referred to a basic measurement standard,
•
referred to a relevant safety standard (including date and part number where applicable)
which included or referred to a noise test code containing a measurement method, or
•
contained a fully-specified measurement method.
Similarly, for operating conditions, values were considered traceable if the instructions either:
•
referred to a relevant safety standard (including date and part number where applicable)
which included or referred to a noise test code containing operating and mounting
conditions, or
•
contained fully-specified operating and mounting conditions.
High importance was given to the traceability of noise emission values. Instructions were
systematically categorised as “Not Compliant” when the traceability of the measurement
method or the operating conditions were absent or incomplete.
For some machinery families e.g. powered hand-tools, the structure of the safety standards is
complicated. They can comprise a Part 1 providing “general requirements” for the whole
family of machines, with additional parts (e.g. Part 2 – x) covering the hazards particular to
the individual machines within the family. The operating conditions for noise emission tests
are generally included in these additional parts of the safety standard. When instructions
referred only to Part 1 it was considered that traceability was not satisfied (because specific
operating conditions for the particular tool/machine used were generally not included in Part
1 but in the appropriate Part 2 of the safety standard). When instructions referred only to the
relevant Part 2, it was considered that traceability was satisfied (because the use of a Part 2
goes necessarily with the use of the Part 1).
3.3.2 Credibility of noise emission values
It is often considered that the declaration of noise emission values, required under EHSR
1.7.4.2u of 2006/42/EC, completely fulfils the further requirements to provide information
sufficient to warn of risk (1.7.4.2l) and facilitate the use of further protective measures
including personal protective equipment (PPE) (1.7.4.2m). Therefore it was considered
necessary to check whether the declared noise emission values were in fact useful to the end
user, both to warn of actual risk, and to facilitate the purchase of quietest machinery. The
credibility of the noise emission values was assessed with reference to the stated
measurement methods and operating conditions (if any) (Type I credibility), and to the likely
risk during actual use (Type II credibility).
5
Report on the “NOMAD” project
As these checks of credibility rely on a level of knowledge of the contents of noise test codes
and of experience in the use of machines in working environments, there will inevitably be a
subjective element attached to any such assessment. Therefore it was agreed by the Steering
Committee that emission values would only be categorised as ‘not credible’ where, according
to the knowledge, experience and judgement of the assessor, this was clearly the case. It is
important to note that it was not the purpose of this survey to examine whether the noise test
codes contained within or referred to from safety standards produce noise emission values
which are sufficient to warn of risk during intended use, although the assessment of Type II
credibility allowed an impression to be gained on this in some cases.
It should be noted that traceability and credibility are linked in the case of Type I credibility.
If measurement methods and operating conditions have not been stated then it is not possible
to make an assessment of credibility with respect to those methods/conditions.
3.4
Assessment of residual risk information and instructions for
use
The assessment of whether instructions contained the required information on residual risks
and instructions for use relevant to noise, as required by EHSRs 1.7.4.2j, k, m and r (see
Section 1.2) was given careful consideration. Persons carrying out the analysis did not have
experience in every category of machine covered by this survey, or familiarity with every
safety standard. Therefore, instructions tended to be assessed as ‘compliant’ in these aspects
unless ‘common sense’ suggested that such information was lacking.
However, where the assessor was familiar with a safety standard which was known to contain
requirements that specific information or instructions for safe use be included in instructions,
and this information was not found in the specific instructions being assessed, then the
instructions were categorised as “Not compliant”.
4.
Results
4.1
Principal quantitative results
Of the 1,531 sets of instructions assessed in this survey, 1,224 (80%) did not satisfy legal
requirements in relation to the information provided relating to noise. The distribution of
instructions among the four categories is shown in Figure 1 below.
Not complia nt – NC(ii )
% obs.
35%
Not complia nt – NC(i)
Complia nt – C(ii)
45%
Complia nt – C(i)
16%
4%
Figure 1. Categorisation of instructions
From the total sample of instructions, 12% (183) contained no information on noise at all (i.e.
no quantitative information, and no warnings of risk or instructions for safe use). A further
417 contained some information on noise but did not contain the necessary numerical values
of noise emissions, meaning that in total 39% of the sample did not contain the necessary
numerical values. By corollary it is clear that the cause of non-compliance in the majority of
6
Report on the “NOMAD” project
cases is not simply the absence of any information or an incomplete set of numerical values.
It should be noted that where a machine is essentially risk-free with regard to noise (i.e. it
does not produce noise above a defined level) this is required to be stated in the instructions
(EHSR 1.7.4.2u).
A set of instructions that is not in an official Community language of the country in which the
machine it relates to is being offered for sale was, as a matter of policy, categorised as NC(ii)
since this is a matter of strict compliance (EHSR 1.7.4). From the total sample of instructions,
125 (8%) were not in an official Community language. Countries where the percentage of
instructions not in an official language was significant were Netherlands (25% of
instructions, number of instructions, n=25), Norway (23%, 11), Romania (56%, 19),
Denmark (20%, 6), and Cyprus (59%, 10).
Figure 2 shows the categorisation of instructions in relation to the country in which they were
collected.
100%
Not compliant
90%
Compliant
80%
70%
60%
50%
40%
30%
20%
10%
87
)
(n
=
m
Kin
lan
gd
o
d
(n
=1
23
)
(n
=3
4)
Un
i
te
d
F in
n=
d(
Ro
m
an
ia
39
)
)
lan
Po
wa
y(
n=
47
No
r
Ne
th
er
lan
d
s(
n=
10
0)
(n
=7
)
28
6)
Ire
la
nd
(n
=
Fr
an
ce
(n
=3
55
)
Sp
ain
=4
06
)
an
y
(n
30
)
Ge
rm
ar
k(
n=
(n
pr
us
Cy
De
nm
=1
7)
0%
Figure 2. Categorisation of instructions in relation to country of collection
Figure 3 shows the categorisation of instructions in relation to their compliance according to
the general family of machine (CEN/CENELEC Technical Committee responsible for safety
standards for the machine family).
7
Report on the “NOMAD” project
CEN/TC 144/WG 8 Forestry machinery (n=15)
47%
20%
CEN/TC 197 Pumps (n=16)
24%
CEN/TC 151/WG 1 - Earth-moving machinery (n=18)
33%
CEN/TC 183 Waste management (n=22)
44%
16%
4%
4%
CEN/TC 151/WG 3 - Drilling equipment (n=27)
41%
33%
50%
10%
69%
13%
22%
19%
Not compl ia nt – NC(i )
21%
42%
19%
52%
2%
5%
23%
42%
13%
20%
58%
Compli a nt – C(i i)
6%
19%
58%
37%
10%
9%
53%
21%
6%
13%
60%
21%
25%
7%
7%
26%
40%
20%
4%
15%
19%
67%
CEN/TC 153 Machinery intended for use with foodstuffs and feed (n=68)
8%
41%
41%
CEN/TC 143 Machine tools (n=131)
4%
27%
65%
CEN/TC 146 Packaging machines (n=30)
16%
69%
27%
CLC/TC 61 Safety of household and similar electrical appliances (n=27)
8%
40%
36%
CEN/TC 145 Plastics and rubber machines (n=27)
18%
42%
40%
CEN/TC 98 Lifting platforms (n=26)
Not compl ia nt – NC(i i)
9%
18%
50%
CEN/TC 232 Compressors (n=26)
CLC/TC 61 F Safety of household and similar electrical appliances - Hand-held motoroperated electric tools (n=191)
45%
64%
CEN/TC 255 Hand-held, non-electric power tools (n=25)
CEN/TC 142 Woodworking machines (n=165)
50%
45%
CEN/TC 198 Printing and paper machinery (n=25)
11%
67%
CEN/TC 144/WG 5 Stationary equipment (n=24)
CEN/TC 144/WG 7 Powered lawn and garden equipment (n=152)
18%
17%
17%
CEN/TC 144/WG 1 Tractors and machinery for agriculture and forestry (n=22)
CEN/TC 144/WG 4 Portable machines and pedestrian controlled machines (n=71)
18%
61%
11%
33%
CEN/TC 144/WG 6 Manually portable forestry equipment (n=67)
31%
41%
CEN/TC 214 Textile machinery and accessories (n=18)
CEN/TC 151/WG Construction equipment and building material machines (n=32)
13%
69%
CEN/TC 150 Industrial Trucks (n=17)
7%
31%
56%
CEN/TC 322 Equipments for making and shaping of metals (n=16)
CEN/TC 151/WG 5 - Road construction machines (n=18)
27%
19%
4%
Compl ia nt – C(i )
Figure 3. Categorisation of instructions according to general machine family (for n>14 only)
It is possible to compare the compliance of instructions between machines which are socalled Annex IV machines and those that are not, and between machines that are and are not
also covered by Directive 2000/14/EC. Such comparisons are shown in Figure 4.
8
Report on the “NOMAD” project
90%
80%
90%
81%
70%
70%
60%
60%
50%
50%
40%
30%
80%
79%
80%
73%
40%
27%
30%
19%
20%
21%
20%
20%
10%
10%
0%
0%
Annex IV machine (n=265)
Not compliant
non-Annex IV machine
(n=1266)
2000/14/EC machine
(n=458)
Compliant
non-2000/14/EC machine
(n=1072)
Not compliant
Compliant
Figure 4. Compliance of instructions according to machine status
30% of instructions gathered (458 out of the total 1531 instructions) were for machines
covered by Directive 2000/14/EC. These are essentially gardening machines and machines
used on construction sites. For this portion of the data, results are as shown in Table 1.
Table 1. Results for machines covered by Directive 2000/14/EC
Characteristics of instructions/machines
Percentage
Number of instructions from
which percentages are calculated
Machines covered by Directive
2000/14/EC but no value of sound power
level given
20 %
458
Machines covered by Directive
2000/14/EC where no reference made to
Machinery Directive and no emission
sound pressure level given
17 %
458
Further quantitative information on the characteristics of instructions/machines found in this
survey are given in Appendix B.
4.2
Reasons for non-compliance
As noted in 4.1, some non-compliance could be attributed to instructions containing no
information on noise at all (15% of the 1,224 non-compliant instructions). Of the remaining
non-compliant instructions (i.e. those containing some information on noise) 65% contained
all required numerical values of noise emission. This suggests that reasons other than the
absence of numerical values were significant in instructions being assessed as non-compliant.
9
Report on the “NOMAD” project
The use of the assessment grid allowed the reasons for non-compliance of the instructions to
be further analysed. A summary of various reasons for non-compliance (designated as
Reason A, etc.) is presented below:
Reason A. Quantitative data missing
o
45% of non-compliant instructions were missing some quantitative noise emission
information, and 25% provided no emission sound pressure level values (the
compulsory element);
Reason B. Traceability of quantitative values
o
of the non-compliant instructions that contained some quantitative noise emission
values, 75% lacked traceability for these values;
Reason C. Credibility of quantitative values
o
where credibility of quantitative values could be assessed, 64% of non-compliant
instructions did not meet at least one type of credibility, and 38% were not credible
for both types (see Section 3.3.2);
Reason D. Residual risk information
o
where instructions for safe use or residual risk information was assessed, 51% of
non-compliant instructions lacked some aspect of such information;
Reason E. Terminology
o
where terminology was assessed, 32% of non-compliant instructions where
quantitative values were given contained incorrect noise terminology.
Instructions were often found to be not compliant for a combination of reasons. Of the 1,244
non-compliant instructions, 22% show only a single reason for failure of the five Reasons A
to E, with the most common single reason being Reason A – although it should be noted that
where expected quantitative data is missing then its traceability, credibility or associated
terminology (Reasons B, C and E) can not always be assessed. Where non-compliant
instructions showed only one or two reasons for failure, Reasons A and B are the most
significant, being implicated in 40% and 44% of non-compliant instructions respectively.
5.
Discussion
It is clear that the finding that 80% of machinery instructions examined as part of this
survey do not comply with legal requirements in respect of information on noise
represents a significant problem. To put the issue in different terms, it may be supposed
that four out of every five machines being offered for sale in the EU/EFTA area are
improperly carrying a CE mark, and do not provide information that would facilitate an enduser purchasing the safest (lowest noise) machine, or understanding the risks arising from use
of the machine.
The results of the survey suggest that this issue is not particular to machines being offered for
sale in any country or countries (Figure 2), nor to any particular machine class or types
(Figure 3); rather it is a universal problem, with variations only at the level of detail.
10
Report on the “NOMAD” project
Furthermore, the problem is not simply that the required information is not provided; in the
majority of cases at least some quantitative noise data is given, and only 15% of the noncompliant instructions contained no information on noise at all.
There is no evidence that Annex IV machines are more likely to have instructions that
comply with legal requirements with respect to noise (Figure 4). This suggests that the
involvement of Notified Bodies in the compliance procedure has negligible effect on
compliance. Similarly (Figure 4), machines also covered by Directive 2000/14/EC show no
greater likelihood of compliance, suggesting that the requirement for a manufacturer to
consider an additional Directive specifically relating to noise has negligible effect on its
approach to the provision of information on noise in relation to the Machinery Directive.
For machines also covered by Directive 2000/14/EC, the following was found (Table 1):
•
for a rather high percentage of instructions (20%), the manufacturer seems to ignore that
the machine is covered by Directive 2000/14/EC as no value of the sound power level is
given;
•
for a similar percentage (17%), the manufacturer knows that the machine is covered by
Directive 2000/14/EC but does not provide in the instructions the data required by the
Machinery Directive, so giving the impression that he is not aware that the Machinery
Directive applies as well.
It is clear that there is no single significant aspect or type of non-compliance, rather it is the
case that non-compliant instructions exhibit a combination of reasons. A lack of traceability
and lack of credibility of quantitative noise information is implicated in a significant
proportion of failures, with a lack of residual risks/safe use information becoming significant
when considering those instructions showing the worse state of non-compliance, NC(ii).
Having said that the problem is not particular to any machine class or type, there is some
evidence (Figure 3) that some general families of machine (as classified by CEN/CENELEC
Technical Committee responsible for safety standards for the machine family) exhibit more
likelihood of compliance than others: for example, machines covered by CEN/TC 142
(woodworking machines), CEN/TC 214 (textile machinery), CEN/TC 150 (industrial trucks)
and CEN/TC 144/WG8 (forestry machinery). This finding should be treated with caution
however as, whilst CEN/TC 142 machines constitute 11% of the sample, the other three
categories constitute in total only 3% of the sample. Additionally, it is considered that some
machines categorised under CEN/TC 142 should in fact have been categorised under
CLC/TC 61 F.
A large proportion of users/purchasers of machinery are likely to take quantitative noise
emission information at face value; they are unlikely to check the traceability details, and
may not have the knowledge to judge credibility. Therefore it is considered that the
manufacturer has a significant responsibility to ensure that the emission values either can be
taken at face value as a means to compare machines and describe likely risks, or are
accompanied by clear warnings if either of these is not the case (notwithstanding that, if the
declared emissions do not describe likely risks in real use, then further risk information
would be required to be provided to comply with EHSRs 1.1.2b and 1.7.4.2l).
The underlying reasons for the lack of traceability and/or credibility in declared noise
emissions have not been explored as part of this work. However two possible underlying
11
Report on the “NOMAD” project
reasons are: (i) a lack of knowledge among machine suppliers, for example, knowledge of
legal requirements, knowledge of machine safety standards or noise test codes, knowledge of
technical issues around noise or technical know-how in applying or following test codes, and
(ii) a lack of care among machine suppliers, caused by the lack of commercial incentive to
comply (quieter machines or those with better instructions not gaining market share), no fear
of enforcement action and/or reputational harm, or simply that noise and damage to hearing is
not considered a significant risk.
6.
Conclusions and recommendations to Machinery
ADCO
6.1
Conclusions
The general state of compliance of machinery instructions with the noise-related
requirements of the Machinery Directive is very poor. Only 20% of instructions meet legal
requirements with respect to noise information.
As a consequence, it is considered highly likely that, in making a machinery procurement
decision, employers are prevented from taking noise emissions into account, and are
prevented from understanding what is necessary to manage the risks from noise relating to
equipment that is procured.
In the majority of cases, some information on noise is provided (e.g. numerical values of
noise emission); however the numerical values are likely to be not traceable to machine
operating conditions or measurement methods, and not credible either against stated
conditions/methods or as warnings of likely risk in real use.
There is no evidence that the involvement of Notified Bodies in the process of compliance
increases the likelihood of a machine’s instructions being assessed as compliant.
6.2
Recommendations
6.2.1 Recommendations for action to address the issues highlighted by
this exercise
Recommendations made to Machinery ADCO by the NOMAD Steering Committee are based
on the evidence found. They consist of targeted actions that are achievable on a large scale,
can be carried out within existing frameworks and are expected to have measureable
outcomes. In particular, these actions concentrate on moving Category NC(i) in to Category
C(ii).
The principal result of NOMAD is that instructions are globally poor throughout the
extremely wide variety of machinery covered by the Machinery Directive. There is therefore
a need for a global improvement of the current situation. To achieve this, actions are
proposed. They aim at raising awareness of all parties concerned on the current situation.
In order to reach a large-scale improvement of the situation, NOMAD Steering Committee
proposes global actions to be accompanied in parallel by actions targeted to specific
machinery families, specific players, and specific aspects, as set out in Table 2. For each
action proposed, the main players concerned are indicated.
12
Report on the “NOMAD” project
Table 2. Proposed actions
Action
Main players
Wide information, promotion and enforcement campaign
aimed at machine manufacturers. See rationale 1
Machinery ADCO, Member
States, EC
Wide information and promotion campaign aimed at
machine users and the Occupational Safety and Health
(OSH) community. See rationale 2
National OSH
organizations/institutes, EUOSHA Bilbao
Drafting of guidance documents, each specific to a
machinery family, called “How to draft the noise
contents of instruction manuals”. See rationale 3
Member States, national
OSH organizations/institutes,
machinery manufacturers
associations,
CEN/CENELEC machinery
safety TCs, CEN/CENELEC
noise consultants
Setting up of a database for published harmonized noise
test codes. See rationale 4
Machinery ADCO, CENCENELEC Management
Centre (CCMC),
CEN/CENELEC noise
consultants
Actions concerning the standardization system. See
rationale 5
CCMC, National
Standardization Bodies
(NSBs)
Targeted market surveillance campaigns. See rationale 6
Machinery ADCO, MemberStates, EC
Training of market surveillance personnel. See rationale
7
Machinery ADCO, national
labour inspectorates
Clarification of the duties regarding noise emission of
Notified Bodies for Annex IV machines. See rationale 8
Machinery ADCO, Notified
Bodies under 2006/42/EC
Rationale 1
NOMAD highlights very clearly the fact that manufacturers fail to provide the information on
noise required by the law and in so doing impede an effective application of the European
regulation aiming at the prevention of ill health caused by exposure to noise at work (through
the joint use of 2006/42/EC, standards harmonized under 2006/42/EC, and Directive
2003/10/EC on physical agents (noise)). NOMAD clearly highlights the most common
failures met, some of which could easily be corrected by manufacturers. An example is the
traceability of noise emission values: indicating clearly the measurement method and
13
Report on the “NOMAD” project
operating conditions used or simply the harmonized noise test code used does not require any
effort from the manufacturer (assuming that the measurements have in fact been carried out).
Another example is the poor language and incorrect terminology used that highlight a lack of
basic knowledge on noise from manufacturers.
The aim of this information, promotion and enforcement campaign would be to raise the
awareness of manufacturers of the noise aspects of European regulations, their
responsibilities and the resources that are available to support them.
The campaign could be designed (campaign contents, strategy, resources and materials) at a
European level under the aegis of the EC and Machinery ADCO and launched
simultaneously by Member States at national levels.
Rationale 2
This information and promotion campaign would aim at raising awareness among machine
users (purchasers) and OSH experts of the European regulations, their responsibilities and the
resources available to support them. It would promote a “buying quiet” strategy and highlight
the benefits to businesses of purchasing quiet machines.
Rationale 3
NOMAD shows that manufacturers lack the know-how necessary to draft the contents on
noise of instructions in such a way that they fulfil the regulations and make the information
they give useful to the user of the machine. Guidance documents, each specific to a
machinery family, called “How to draft the noise contents of instructions manuals” would be
practical and operational documents to help manufacturers write adequate instructions on
noise. They would in particular provide clear lists of harmonized standards that are
applicable to the machinery family including the time history of each standard. To achieve
this, collaboration with manufacturers associations should be sought. The possibility that
these guidance documents are made normative documents prepared within CEN/CLC TCs
responsible for machinery families should be investigated. This would ensure the effective
participation of manufacturers in the drafting of these documents so ensuring a high level of
acceptance. CEN/CLC noise consultants would assist.
Rationale 4
NOMAD Steering Committee strongly suggests the establishment of a European Internetbased database providing manufacturers with an easy access to the noise test codes (at least
the reference numbers) relevant for their machines, including time history and latest changes.
This should include detailed information about the specific kinds of machines covered by
each standard.
Rationale 5
NOMAD has highlighted the following two facts:
•
where the harmonized standards covering a family of machines have a complex structure
(e.g. hand-held or transportable electric tools, a lengthy series of standards with many
parts specific to sub-families of machines), it is more likely that instructions contain an
inadequate reference to the harmonized standards such that traceability of noise emission
values is impossible to assess;
14
Report on the “NOMAD” project
•
references in instructions to harmonized standards where the date of the standard is
missing, the difficulty in some cases of gaining access to superseded editions of
standards, and the differing dates of national editions of European standards, make market
surveillance very difficult.
Contacts should be made with CEN, CENELEC and NSBs to find ways to improve this
situation.
Rationale 6
Since the entry into force of 2006/42/EC (December 2009), manufacturers have to give the
same information regarding noise in any sales literature describing performance
characteristics as must be given in the instructions (see EHSR 1.7.4.3 of 2006/42/EC).
Targeted market surveillance campaigns could therefore consist of checking the provision of
noise information for a few well chosen machinery sectors through the checking of such
literature (brochures and catalogues presenting performance data of the machine,
manufacturers’ web sites), it being much easier to obtain or access than machine instructions.
Such campaigns could be carried out in parallel with noise emission measurement campaigns
aimed at verifying declared values of noise emission and establishing indicative values of
noise emission for the machine families considered.
Rationale 7
NOMAD highlighted a lack of sufficient knowledge among those carrying out market
surveillance (e.g. labour inspectors) in basic acoustic terminology and on the detail of EHSRs
on noise in 2006/42/EC. In order to carry out efficient market surveillance in this area
specific training appears to be necessary. In this context, a market surveillance check list
providing a short description of the noise-related requirements together with examples of
sufficient, good and bad declarations would be very useful. It must be made clear that
numerical values in decibels used in many European directives can represent different
physical quantities related to noise (for example, noise emissions of equipment, noise levels
at a location, or personal noise exposure levels), and particularly that these quantities cannot
be compared numerically.
Rationale 8
NOMAD shows a trend that instructions for Annex IV machines are slightly more likely to
be compliant than those for non-Annex IV machines. However, instructions on noise should
be significantly better for Annex IV machines given the greater likelihood that a Notified
Body was involved in any conformity assessment process. This is why there is a clear need
for clarifying the duties of Notified Bodies regarding noise and making sure that the
competencies required are present.
6.2.2 Other possible actions for the consideration of Machinery ADCO
Setting up a European Internet-based database of noise emission values
Noise emission data gathered in manuals ranked as C(i) and C(ii) could constitute the starting
point of a European database.
Quality of noise test codes in the context of actual risk representation
NOMAD has highlighted the sensitive and difficult issue of the credibility of noise emission
values found in manuals. Values may be credible with reference to the stated operating
15
Report on the “NOMAD” project
conditions or noise test code, but not credible as representing the actual risk arising from
typical use of the machine. Furthermore it is not always clear that values derived from noise
test codes are capable of indicating the relative risk when there is a difference in actual risk
between machines of the same or similar type. The expectation is that noise test codes have
been drafted in accordance with EN ISO 12001, which states that operating conditions shall
be “reproducible and representative of the noisiest operation in typical usage of the
machine”, however the extent to which operating conditions are validated in this regard, or
represent latest and best knowledge, is not clear. Exploring this issue would include checking
carefully the contents of published harmonized noise test codes and require close contact with
industrial branches. A systematic review in this context of published noise test codes could be
carried out by OSH organizations/institutes in the EU as a NOMAD 2 exercise, starting from
the noisiest and most commonly found machines. It will highlight those noise test codes that
need to be revised.
16
Report on the “NOMAD” project
Appendices
A.
“NOMAD” Project – Facts and figures
B.
Further quantitative results
C.
Definitions / explanations of key quantities and terms
D.
Selected Essential Health and Safety Requirement (EHSRs) from Machinery Directive
E.
Extract from guidelines for the application of 2000/14/EC
F.
Question-set for data gathering
G.
Assessment grid
17
Report on the “NOMAD” project
Appendix A
“NOMAD” Project – Figures and facts
NOMAD is the first joint Member States project under the Machinery Directive aimed at
market surveillance.
NOMAD started in 2008 with 14 Member States. In 2012, 11 were still actively contributing.
Steering Committee members (SC), National Contact Persons (NCP) and other effective
contributors are listed in Table A1. A number of National Data Providers contributed to the
initial gathering and analysis of machine instructions.
Table A1. Contributors to NOMAD project
Country
SC
NCP
Organization
Other effective contributors
Remarks
Cyprus
-
A. Vazouras
Department of Labour
Inspection
Denmark
J.G. Jensen
P.J.R. Marie
Danish Working
Environment Authority
Contribution discontinued in
May 2011 but Danish data
were available
P. Lankinen
Ministry of Social
Affairs and Health
Tuija Lukkari
P.J.R. Marie
Finland
P. Lankinen
Kari Seppänen
France
J. Châtillon, J.
Jacques, G. Jeanjean
G. Jeanjean
Claude Maujean
Germany
P. Kurtz
INRS – Nancy & Paris
INRS computing department
Ministry of Labour –
DGT
P. Kurtz
G. Brockt
BAuA Federal Institute
for Occupational Safety
and Health - Dortmund
W.-T. Peters (LIA NRW)
L. Finkeldei (Ministerium für
Umwelt, Klima und
Energiewirtschaft Baden.
Württemberg)
Ireland
-
J. Colreavy
Health and Safety
Authority - Dublin
Italy
L. Monica
L. Monica
National Institute for
Occupational Safety and
Prevention (ISPESL) Rome
Contribution was
discontinued shortly after the
start of NOMAD. No Italian
data available
Lithuania
-
V. Jusys
State Non Food
Products Inspectorate Ministry of Economy -
No valid data could be
gathered
18
Report on the “NOMAD” project
Vilnius
Norway
-
K. Rovik
Labour Inspection
Authority
Poland
M. Szyszko
M. Szyszko
National Labour
Inspection, District
Labour Inspectorate Szczecin
Romania
-
S. Platon
The National Research
and Development
Institute on
Occupational Safety –
I.N.C.D.P.M.- Bucharest
Spain
B. Juan y Seva
Guevara
J. Leiva Perez
Department of
Machinery Verification
- INSHT (National
Institute of Safety and
Health)
The
Netherlands
D. Korver
D. Korver
Labour Inspectorate –
The Hague
Contribution was
discontinued in March 2011
but Norwegian data were
available
I-G Nicolescu
R. Edam
C. van Hengstum
United
Kingdom
T. Ward
Health and Safety
Executive – Bootle
J. Patel
Health and Safety
Laboratory – Buxton
The database generated by NOMAD contains more than 1,500 sets of instructions from
machines covering 40 broad machine-families from 800 different manufacturing companies.
NOMAD turned out to be a much more difficult and time-consuming operation than initially
thought.
NOMAD ran over 4 years (from 2008 to 2012). It is estimated that the minimum total time
spent by all contributing Member states to NOMAD was 12,000 hours. This includes 4,000
hours that were spent by the INRS, France, team in charge of management, logistics and data
handling and processing. These high figures illustrate the effort and commitment required to
carry out such a survey, which is only a preamble to a market surveillance action.
NOMAD was an elementary investigation of one aspect of the implementation of, and
compliance with, the Machinery Directive. It was not an in-depth scientific study and was
never meant to be one.
19
Report on the “NOMAD” project
Throughout the project, the main participants in NOMAD (Steering Committee members and
National Contact Persons) had a full, open-minded and friendly collaboration. This was
achieved despite the many difficulties that had to be overcome in the course of the project.
NOMAD highlights the complexity of the Machinery Directive concerning risks resulting
from noise emissions. The template developed to capture relevant information from
instructions required more than 60 different fields. This complexity is made even greater for
machines that are also covered by the “Outdoor Noise Directive” 2000/14/EC, in spite of the
correspondence between the two directives described in an EC Position Paper (see Annex E).
NOMAD required the participation of many players from contributing member states, not all
of whom had technical knowledge in acoustics or machinery noise. Those members of the
Steering Committee who were knowledgeable enough in acoustics had to share the data
analysis workload. It must be mentioned that where tasks were required to be done, these
were willingly accepted by members of the Steering Committee.
During the project, unexpected events happened: Italy (the second largest manufacturing
country in the EU) was unable to contribute at all due to the situation at ISPESL (National
Institute for Occupational Safety and Prevention). Personnel changes meant that Denmark
and Norway were unable to continue to support the project, which increased the workload of
the remaining Member States. Among the few data provided by Lithuania, none of them
could be validated by the Steering Committee.
The analysis of the data by those Steering Committee members knowledgeable in acoustics
showed that issues such as the credibility of the noise emission values found in instructions
and the extent to which information for safe use is provided in instructions were critical. In
many cases the information found in instructions was not sufficient to come to any reliable
conclusion. It would have been necessary to discuss with the manufacturer, carry out
measurements for the purpose of verifying declared noise emission values or further research
the contents of the relevant machinery safety standard or noise test code. This would have
taken a lot of time, made NOMAD even longer and was in any case not in the scope of
NOMAD. Deciding on the scope of analysis of the data extracted from instructions was a
subject of debate with in the SC, in particular between the French, German and UK members.
These highlighted a fact: experts from different Member States have sometimes differing
interpretations of the meaning and requirements of the Machinery Directive in relation to
noise emissions, residual risks and instructions for safe use.
Some members of the
NOMAD Steering Committee
and NCPs (l-r: J. Patel, J.
Jacques, M. Szyszko, G.
Jeanjean, J. Châtillon, P.
Lankinen, D. Korver, T. Ward,
G. Brockt, P. Kurtz)
20
Report on the “NOMAD” project
Appendix B
Further quantitative results
Further quantitative information on the characteristics of instructions/machines found in this
survey is shown in Table B1 below. The number of relevant instructions should be noted;
certain characteristics are relevant only for a subset of instructions, dependent on the
information found.
Table B1. Further quantitative results
21
Characteristics of instructions/machines
Percentage
Number of relevant
instructions
No information about noise
12 %
1531
No value of emission sound pressure level
20 %
1530
No value of sound power level where required
26 %
1318
Missing expected information / warnings to the user (other than
numerical values)
38 %
1374
Lack traceability to a measurement method for any numerical value
51 %
1292
Lack traceability to a operating condition for any numerical value
44 %
1292
Refers to 2006/42/EC but no uncertainty given for numerical values
80 %
313
Lack credibility (order of magnitude wrong and/or values not
representative of actual risk) for any numerical values given
50 %
1236
Missing expected information on PPE
32 %
1382
Text about noise is not understandable or meaningless
20 %
1384
Noise terminology is incorrect
28 %
1267
Reference to a wrong Type B standard for emission sound pressure
level measurement method (where a reference is made)
28 %
322
Reference to a wrong Type B standard for sound power level
measurement method (where a reference is made)
13 %
306
Reference to a wrong Type C standard (where a reference is made)
37 %
692
Report on the “NOMAD” project
Appendix C
Definitions / explanations of key noise emission quantities and
terms
Sound power
Sound power is a measure of the total sound energy flow emitted by a source (e.g. a machine)
in the air. It is measured in watts (W) and is normally given as an A-weighted sound power
level, LWA, in decibels ref. 1 pW.
The sound power level is the most important quantity describing the noise emission of a
machine. It is a characteristic of the machine and is independent of the environment in which
the machine is situated. It easily allows the selection of quiet machines and is a key quantity
to carry out a forecast of the resulting sound pressure levels when placing a machine in to an
environment.
Sound pressure
Sound pressure refers to a measurement of air pressure, which is perceived as sound, at a
given location. Sound pressure is measured in pascals (Pa), and normally given as a sound
pressure level, Lp, in decibels ref. 20 µPa.
Emission sound pressure
The emission sound pressure describes the sound directly caused by a machine at a given
position, e.g. its workstation(s). It is generally given as a A-weighted sound pressure level,
LpA.
The emission sound pressure level is measured in such a way as to include only the direct
sound from the machine, and exclude any sound reflections, e.g. from surrounding walls, or
sound from other sound sources around the machine. As such it is a characteristic of the
machine and independent from the environment in which the machine is situated.
Although the quantities cannot be compared numerically, a useful rule of thumb is that for a
given machine the sound power level, in decibels, typically is about 10 dB to 20 dB higher
than the emission sound pressure level.
Values for emission sound pressure level should not be confused with values describing the
noise exposure of workers; the latter take account of all sources of noise to which a worker is
exposed, and the duration of exposures.
Explanation based on an example: a vacuum cleaner will lead to a higher sound pressure
level at the operator’s ears when cleaning the carpet in an empty room compared to the
situation when the same room is filled with curtains and furniture. However, the emitted
sound power is exactly the same in both cases, assuming the same operating condition.
Peak sound pressure level
Peak sound pressure is a measure of the highest value reached by the sound pressure as it
varies with time; it is generally used to characterise the effect of sources of sound that are
impulsive or impactive in nature. Declarations of machinery noise emissions require the C-
22
Report on the “NOMAD” project
weighted peak sound pressure level, LpC,peak, determined at a workstation or other location, to
be given if it exceeds 130 dB.
Decibel (dB)
The decibel (dB) is a logarithmic unit that indicates the ratio of a quantity (e.g. power or
pressure) relative to a specified reference level. The decibel has the advantage of allowing the
convenient representation of very large or small numbers.
Numerical values in decibels are commonly used to describe different physical quantities
related to noise (for example, noise emissions of equipment, noise levels at a location, or
personal noise exposure levels); in general, these quantities cannot be compared numerically.
Noise emission declaration
The noise emission declaration provides the quantitative information on the sound (noise)
generated by a machine. The Machinery Directive requires this information be given in a
machine’s instructions and technical and sales literature.
The declaration includes values of emission sound pressure level, peak sound pressure
level and sound power level, uncertainties associated with these values, and also descriptions
of the measurement methods and machine operating conditions to which the values relate.
Noise test code
A noise test code describes a procedure for the measurement of noise emissions for a specific
machine or machine type. It describes the operating and mounting conditions of the machine
during measurement, and the measurement methods to be used. It also describes the form and
method for declaring the noise emission values. Noise test codes can be incorporated in
machine-specific safety standards, or can be separate standards. Measurement methods can
be fully described, or can be described by reference to a basic noise measurement standard.
A-weighting and C-weighting
The A- and C-weighting filters are frequency-weighting filters. The A-weighting filter is
generally used when assessing the potential for hearing damage, as it is intended to mimic the
response of the human ear to sounds of different frequencies; it reduces the contribution of
the lowest and highest frequencies of sound to the overall measured sound level. However for
impulsive sound the effects are not thought to be so dependent on the frequency-content of
the sound; in these cases it is common to use a C-weighting filter, which essentially gives
equal weight to all frequencies across a defined frequency range.
Type-B standards
Type-B standards are generic safety standards dealing with one safety aspect or one type of
safeguard that can be used across a wide range of machinery:
•
•
type-B1 standards cover particular safety aspects (e.g. safety distances, surface
temperature, noise);
type-B2 standards cover safeguards (e.g. two-hand controls, interlocking devices,
pressure sensitive devices, guards).
Type-C standards
Type-C standards are machine safety standards dealing with detailed safety requirements for
a particular machine or group of machines.
23
Report on the “NOMAD” project
Appendix D
Selected Essential Health and Safety Requirement (EHSRs) from
Machinery Directive
2006/42/EC
98/37/EC
1.5.8. Noise
1.5.8. Noise
Machinery must be designed and
constructed in such a way that risks
resulting from the emission of airborne
noise are reduced to the lowest level,
taking account of technical progress and
the availability of means of reducing noise,
in particular at source.
Machinery must be so designed and
constructed that risks resulting from the
emission of airborne noise are reduced to
the lowest level taking account of technical
progress and the availability of means of
reducing noise, in particular at source.
The level of noise emission may be
assessed with reference to comparative
emission data for similar machinery.
1.7.4.2. Contents of the
instructions
1.7.4. Instructions
Each instruction manual must contain,
where applicable, at least the following
information:
(j) instructions relating to installation and
assembly for reducing noise or vibration.
(e) Where necessary, the instructions must
give the requirements relating to
installation and assembly for reducing
noise or vibration (e.g. use of dampers,
type and mass of foundation block, etc.).
(u) the following information on airborne
noise emissions:
(f) The instructions must give the
following information concerning airborne
noise emissions by the machinery, either
the actual value or a value established on
the basis of measurements made on
identical machinery:
— the A-weighted emission sound
pressure level at workstations, where this
exceeds 70 dB(A); where this level does
not exceed 70 dB(A), this fact must be
indicated,
— the peak C-weighted instantaneous
sound pressure value at workstations,
where this exceeds 63 Pa (130 dB in
relation to 20 µΡa),
— equivalent continuous A-weighted
sound pressure level at workstations,
where this exceeds 70 dB(A); where this
level does not exceed 70 dB(A), this fact
must be indicated,
— peak C-weighted instantaneous sound
24
Report on the “NOMAD” project
2006/42/EC
— the A-weighted sound power level
emitted by the machinery, where the Aweighted emission sound pressure level at
workstations exceeds 80 dB(A).
These values must be either those actually
measured for the machinery in question or
those established on the basis of
measurements taken for technically
comparable machinery which is
representative of the machinery to be
produced.
— sound power level emitted by the
machinery where the equivalent
continuous A-weighted sound pressure
level at workstations exceeds 85 dB(A).
In the case of very large machinery,
instead of the A-weighted sound power
level, the A-weighted emission sound
pressure levels at specified positions
around the machinery may be indicated.
In the case of very large machinery,
instead of the sound power level, the
equivalent continuous sound pressure
levels at specified positions around the
machinery may be indicated.
Where the harmonised standards are not
applied, sound levels must be measured
using the most appropriate method for the
machinery. Whenever sound emission
values are indicated the uncertainties
surrounding these values must be
specified. The operating conditions of the
machinery during measurement and the
measuring methods used must be
described.
Where the harmonised standards are not
applied, sound levels must be measured
using the most appropriate method for the
machinery.
Where the workstation(s) are undefined or
cannot be defined, A-weighted sound
pressure levels must be measured at a
distance of 1 metre from the surface of the
machinery and at a height of 1,6 metres
from the floor or access platform. The
position and value of the maximum sound
pressure must be indicated.
Where the workstation(s) are undefined or
cannot be defined, sound pressure levels
must be measured at a distance of 1 metre
from the surface of the machinery and at a
height of 1,60 metres from the floor or
access platform. The position and value of
the maximum sound pressure must be
indicated.
Where specific Community Directives lay
down other requirements for the
measurement of sound pressure levels or
sound power levels, those Directives must
be applied and the corresponding
provisions of this section shall not apply;
25
98/37/EC
pressure value at workstations, where this
exceeds 63 Pa (130 dB in relation to 20
µPa),
The manufacturer must indicate the
operating conditions of the machinery
during measurement and what methods
have been used for the measurement.
Report on the “NOMAD” project
2006/42/EC
98/37/EC
1.7.4.3. Sales literature
1.7.4. Instructions
Sales literature describing the machinery
must not contradict the instructions as
regards health and safety aspects. Sales
literature describing the performance
characteristics of machinery must contain
the same information on emissions as is
contained in the instructions.
(d) Any literature describing the machinery
must not contradict the instructions as
regards safety aspects. The technical
documentation describing the machinery
must give information regarding the
airborne noise emissions referred to in (f)
and, in the case of hand-held and/or handguided machinery, information regarding
vibration as referred to in 2.2.
Implicit EHSRs in 2006/42/EC
Manufacturers should provide warnings about risks that have not been eliminated and which
the user will need to manage, i.e. residual risks (EHSR 1.1.2b)
In designing machinery, and providing risk information, the manufacturer should take
account of the intended use of the machine and any foreseeable misuse (EHSR 1.1.2c,
1.7.4.1c).
The information that is required to be provided for all hazards, including noise is:
•
warnings about risks that have not been eliminated and which the user will need to
manage, i.e. residual risks (EHSR 1.1.2b).
•
instructions for safe use and necessary training of operators (EHSR 1.7.4.2k);
•
information on residual risks (EHSR 1.7.4.2l);
•
instructions on protective measures for the user, including appropriate PPE to be provided
(EHSR 1.7.4.2m);
•
description of adjustment, maintenance and preventative maintenance requirements
(EHSR 1.7.4.2r).
26
Report on the “NOMAD” project
Appendix E
Extract from guidelines for the application of 2000/14/EC
(http://ec.europa.eu/enterprise/sectors/mechanical/files/noise/pdf/021016ppwg_en.pdf)
27
Report on the “NOMAD” project
28
Report on the “NOMAD” project
29
Report on the “NOMAD” project
Appendix F
Question-set for data gathering
30
Report on the “NOMAD” project
31
Report on the “NOMAD” project
32
Report on the “NOMAD” project
33
Report on the “NOMAD” project
34
Report on the “NOMAD” project
Appendix G
Assessment grid
Question
number
Question
Q1
Does the manual provide information or data about noise?
Q2
Does the manual provide numerical values of emission sound pressure?
Q3
If the value of sound power is required, is it there?
Q4
Does the manual provide any info to the user (warning, instructions for safe use)?
Q5
Are values given traceable to a measurement method?
Q6
Are values given traceable to operating conditions?
Q7
If the manual refers to 2006/42: are uncertainties in numerical values given?
Q8
Are values given credible (order of magnitude)?
Q9
Credibility: do all values provide the user with relevant information about actual risk?
Q10
Are clear and relevant instructions for safe use (e.g. information on measures to reduce noise emission,
maintenance requirements) given?
Q11
Is clear and relevant expected information on hearing protection given?
Q12
Instead of sound power are values of sound pressure at points around the machine given?
Q13
Is text in the user's language understandable and meaningful?
Q14
Is noise terminology correct?
Q15
Are units correct?
Q16
If type-B standards are referred to for emission sound pressure are they the right ones?
Q17
If type-B standards are referred to for sound power are they the right ones?
Q18
If type-C standards are referred to are they the right ones?
Q19
Is the machine under 2000/14?
Q20
If the machine is under 2000/14, does the manual provide the guaranteed AND the measured values of
sound power?
35