European Machinery Directive

European Union and UK compliance statement.

The Machinery Directive 2006/42/EC scope was clarified, in November 2019, through the European Commission’s “Guide to the application of the Machinery Directive 2006/42/EC Edition 2.2”. In addition to the long-standing risk assessment, there is clarity regarding the responsibility of manufacturers of control units delivering safety functions where independently placed on the market.

EU harmonised, UK designated and other standards are applied to Curtis products, and these are documented in the Curtis product’s EU and UK declarations of conformity documents.

Curtis EU and UK compliant products are offered with assessment to a range of Type-A, Type-B and/or Type-C standards (as described in EN ISO 12100:2010 “Safety of machinery – General principles for design – Risk assessment and risk reduction”) and other standards as required to address the applicable legislation.

OEMs should assess the Curtis component’s declaration of conformity, and information in the Curtis product’s manual against their diverse regulatory requirements. For new OEM designs and OEM design changes where motor controllers with logic are being used, a report can be requested from Curtis regarding that product’s status and compliance data to EN ISO 13849-1:2015 “Safety of machinery – Safety-related parts of control systems – Part 1: General principles for design”; this is for use in accessing the functional safety of safety related parts of the OEM system(s) prior to the OEM’s validation.

In order to understand the new standard it is important to realize that it has two fundamentally different user types: 1.) the designer of safety related sub-systems, and 2.) the designers of safety related systems. In general the sub-system designer (a component manufacturer, such as Curtis Instruments) will need to provide the required data for the system designer to ensure that it is of adequate integrity for the system (the vehicle). This will usually require some testing, analysis, and calculation. The resulting data will be expressed in the format required by the standard as follows:

Performance Level
Mean Time to Dangerous Failure
Diagnostic Coverage
Common Cause Failures

The system designer (the vehicle manufacturer) will then use this data to perform some relatively straightforward calculations to determine the overall Performance Level (PL) of the system.