22 May 2020, 10:05
On 12th May CECE published its latest position on the revision of the Machinery Directive 2006/42/EC.
The position comments on the different topics currently being discussed in the framework of the revision of the Machinery Directive. Furthermore, it includes a table where CECE’s members react to each of the proposals put forward by Member State’s during the European Commission’s Machinery Working Group meetings.
The list of our main messages on topics such as: new technologies (for example “Artificial Intelligence”), cybersecurity/security requirements, Partly Completed Machinery (PCM), harmonised standards and format and availability of instructions, include:
A machinery does what the designer has programmed the machine to do, by using software, automation and eventually Artificial Intelligence. The type of AI being used and developed today constitutes what is known as narrow AI, whereby a machine can only perform an action assigned from the outset by human – whether a designer, computer specialist or manufacturer.
The Machinery Directive covers safety aspects and should remain as such. Cyberattacks are not considered a foreseeable misuse but a malicious use of the product. Any future cybersecurity/security requirements have to be considered under a separate horizontal legislation and not under the Machinery Directive.
Stakeholders should better understand the reality of the industries in the scope of the Machinery Directive. For example, CECE considers that the concept of Partly Completed Machinery (PCM) is well understood and provides an important role for our industry in setting out fundamental procedures for supply of products that will undergo further interventions before a completed Machinery can be placed on the market or put into service.
The Machinery Directive Guidelines should be adapted whenever necessary. We believe this would solve any potential point of concern quicker without having to wait for a new Machinery Directive.
Some proposals should be discussed in the framework of the development to harmonised standards under the Machinery Directive. Our impression is that some proposals question the available “state of the art” technology or would end up imposing a specific technology to the Machinery Directive. The participation of stakeholders in the standardisation process is the most effective way to address such issues.
Format and availability of instructions should allow for flexibility. Each manufacturer has the responsibility to choose which format of instructions is better for the machines they are placing on the market.
Moreover, we ask the European Commission to carefully analyse the social and economic impacts of any future changes in the Machinery Directive taking into consideration the consequences of the COVID-19 crisis and the economic recovery of the construction equipment sector.