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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

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Page 1: Report on the “NOMAD” project – A survey of …Report on the “NOMAD” project 1 1. Introduction 1.1 Scope of project The NOMAD project was a survey to examine the noise-related

Report on the “NOMAD” project – A survey of instruc tions supplied with machinery with respect to noise and t he

requirements of the Machinery Directive

Prepared by the NOMAD Steering Committee May 2012

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Report on the “NOMAD” project – A survey of instruc tions supplied with machinery with respect to noise and t he

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.

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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

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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 Mac hinery 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);

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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.

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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 type-C standards, Annex IV machines and 2000/14/EC machines. The capabilities of the web-based 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);

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• 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.

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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).

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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 ins tructions 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.

35% 45% 16% 4%% obs.

Not compl iant – NC(i i ) Not compl iant – NC(i ) Compl iant – C(i i ) Compl iant – C(i )

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

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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.

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Cypru

s (n=1

7)

Denm

ark

(n=30

)

German

y (n=40

6)

Spai

n (n=3

55)

Fran

ce (n

=286)

Irela

nd (n

=7)

Nether

lands (

n=100

)

Norway

(n=4

7)

Poland

(n=39

)

Romani

a (n=34

)

Finla

nd (n=12

3)

United K

ingd

om (n

=87)

Not compliant

Compliant

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).

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19%

25%

20%

37%

21%

53%

21%

13%

40%

33%

67%

41%

65%

27%

36%

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50%

64%

45%

33%

33%

11%

41%

69%

56%

20%

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42%

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22%

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69%

50%

41%

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18%

45%

67%

17%

61%

24%

31%

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47%

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7%

CLC/TC 61 F Safety of household and similar electrical appliances - Hand-held motor-

operated electric tools (n=191)

CEN/TC 142 Woodworking machines (n=165)

CEN/TC 144/WG 7 Powered lawn and garden equipment (n=152)

CEN/TC 143 Machine tools (n=131)

CEN/TC 144/WG 4 Portable machines and pedestrian control led machines (n=71)

CEN/TC 153 Machinery intended for use with foodstuffs and feed (n=68)

CEN/TC 144/WG 6 Manually portable forestry equipment (n=67)

CEN/TC 151/WG Construction equipment and building material machines (n=32)

CEN/TC 146 Packaging machines (n=30)

CLC/TC 61 Safety of household and similar electrical appliances (n=27)

CEN/TC 151/WG 3 - Dril l ing equipment (n=27)

CEN/TC 145 Plastics and rubber machines (n=27)

CEN/TC 98 Lifting platforms (n=26)

CEN/TC 232 Compressors (n=26)

CEN/TC 255 Hand-held, non-electric power tools (n=25)

CEN/TC 198 Printing and paper machinery (n=25)

CEN/TC 144/WG 5 Stationary equipment (n=24)

CEN/TC 144/WG 1 Tractors and machinery for agriculture and forestry (n=22)

CEN/TC 183 Waste management (n=22)

CEN/TC 151/WG 1 - Earth-moving machinery (n=18)

CEN/TC 214 Textile machinery and accessories (n=18)

CEN/TC 151/WG 5 - Road construction machines (n=18)

CEN/TC 150 Industrial Trucks (n=17)

CEN/TC 322 Equipments for making and shaping of metals (n=16)

CEN/TC 197 Pumps (n=16)

CEN/TC 144/WG 8 Forestry machinery (n=15)

Not compl ia nt – NC(i i ) Not compl ia nt – NC(i ) Compli a nt – C(i i ) 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 so-called 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.

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73%

81%

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19%

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90%

Annex IV machine (n=265) non-Annex IV machine

(n=1266)

Not compl iant Compl iant

79% 80%

21% 20%

0%

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20%

30%

40%

50%

60%

70%

80%

90%

2000/14/EC machine

(n=458)

non-2000/14/EC machine

(n=1072)

Not compl iant Compl iant

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.

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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 end-user 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.

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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 non-compliant 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

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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 iss ues 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.

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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, EU-OSHA 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, CEN-CENELEC 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, Member-States, 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

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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 Internet-based 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;

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• 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 no ise 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 actua l 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

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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.

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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

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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

P.J.R. Marie Danish Working Environment Authority

Contribution discontinued in May 2011 but Danish data were available

Finland P. Lankinen P. Lankinen Ministry of Social Affairs and Health

Tuija Lukkari

Kari Seppänen

France J. Châtillon, J. Jacques, G. Jeanjean

G. Jeanjean INRS – Nancy & Paris INRS computing department

Claude Maujean Ministry of Labour – DGT

Germany P. Kurtz

G. Brockt

P. Kurtz 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

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Vilnius

Norway - K. Rovik Labour Inspection Authority

Contribution was discontinued in March 2011 but Norwegian data were available

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

I-G Nicolescu

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

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.

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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)

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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

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

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Appendix C

Definitions / explanations of key noise emission qu antities 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-

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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.

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Appendix D

Selected Essential Health and Safety Requirement (E HSRs) from Machinery Directive

2006/42/EC 98/37/EC

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.

The level of noise emission may be assessed with reference to comparative emission data for similar machinery.

1.5.8. Noise

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.

1.7.4.2. Contents of the instructions

Each instruction manual must contain, where applicable, at least the following information:

1.7.4. Instructions

(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:

— 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),

(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:

— 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

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2006/42/EC 98/37/EC — the A-weighted sound power level emitted by the machinery, where the A-weighted 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.

pressure value at workstations, where this exceeds 63 Pa (130 dB in relation to 20 µPa),

— 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.

The manufacturer must indicate the operating conditions of the machinery during measurement and what methods have been used for the measurement.

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 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;

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.

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2006/42/EC 98/37/EC

1.7.4.3. Sales literature

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.

1.7.4. 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 hand-guided 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).

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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)

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Appendix F

Question-set for data gathering

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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?