Warning on visibility
Warning on visibility

Warning on visibility causes uncertainty among machinery manufacturers and operators

VDMA position paper provides assistance
Frankfurt, 9 November 2015 – Ever since the EU Commission issued a warning relating to the standard in which the provisions covering visibility requirements for earth-moving machinery are set out, there has been widespread uncertainty among manufacturers and operators alike. A position paper is intended to help clarify the situation.
Ever since the warning issued by the EU Commission in relation to the requirements set out in European standard EN 474-1 on visibility for earth-moving machinery came into effect on 28 January this year, there has been uncertainty as to when an earth-moving machine meets statutory requirements and what measures are required for safe operation and, consequently, operation in compliance with applicable regulations.
For manufacturers the warning means that for any earth-moving machinery placed on the market after this date it can no longer be assumed that in meeting the requirements set out in EN 474-1 they will have complied with statutory requirements concerning visibility. The so-called presumption of conformity does not apply. This could give rise to considerable problems, especially in case of legal proceedings. Since the presumption no longer applies, the manufacturer may under certain circumstances have to prove that the precautions he has taken within the framework of the risk assessment were sufficient, in other words that he is not at fault. Similar considerations apply to machinery operators. Where an accident occurs as the result of an inadequate risk assessment, this can have significant consequences. The standard committee is currently working on the revision of EN 474-1. Completion and the concomitant lifting of the warning are not to be expected before late 2016, the respective committee (CEN/TC 151) has stated.
Five points suggested for the risk assessment
To provide manufacturers and operators with help in the intervening period, the VDMA Construction Equipment and Building Material Machinery Association has now issued a position paper. Among other things this provides detailed explanations of the statutory obligations with which the manufacturer must comply with regard to the documentation involved and, as a consequence, the drawing up of the declaration of conformity. The responsible EU committee has suggested the following five points, which the VDMA recommends should be taken into account in the risk assessment as of now:

  • direct visibility must have priority,
  • near field visibility must be improved by lowering the test specimen from 1.5 m to 1.0 m,
  • visibility aids such as camera monitor systems or mirrors must be mounted in the forward direction
  • visibility aids must not be impaired due to movable machinery parts, e.g. excavator arm,
  • mirror-to-mirror systems are not permitted.

VDMA issues warning against putative panaceas
If certain machines do not comply with these criteria, the VDMA position paper suggests that measures should be selected which are state of the art and comply with the protection objectives “as much as possible”. An explicit warning is given against putative panaceas. The camera monitor systems available on the market cannot be considered safety systems, only comfort or assistance systems. They cannot replace construction site organisation and communication. Also viewed critically are the visibility maps currently being discussed. These are intended to show the driver which areas the driver cannot see at all or can only see with difficulty. It has not yet been proved that these lead to better safety. The position paper also sets out other arguments against their effectiveness.
Operators and employers are advised to check their risk assessments meticulously for each machine application and to update them where necessary. During the current transitional period there should be an “emphasis on organisational and personal protective measures”. This can include increased use of additional human guides and the adjustment of construction site organisation. The VDMA position paper also suggests referring to the rules of the Employers’ Liability Insurance Association for the Construction Industry concerning earth-moving machinery (BGR 500, Clause 2.12) and the document published by the Federal Institute for Occupational Safety and Health entitled “Bekanntmachung zur Betriebssicherheit 2111” (Information on occupational safety 2111). Operators can also contact the machinery manufacturers to obtain further information.
The position paper is available for downloading in German and in English at the following link http://bub.vdma.org/article/-/articleview/10279543
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