FEM has provided detailed comments on a large number of proposals from various entities (mainly Member States) on the revision of the Machinery Directive (MD). These proposals were presented by the European Commission during the last Machinery WG meeting last February.
FEM insisted that the Directive’s current provisions are well-established and have been successfully applied over the years without any safety concerns. In this context, a number of the proposals made do not bring additional safety or other improvements to the current text of the MD. This is notably the case as regards machine learning proposals, specifically in the section on control systems. FEM restated that the MD requirements are sufficient, also for AI enabled machinery, and rejected those views that machinery using AI should be considered as high risk machinery and added to Annex IV. As regards software, FEM members made a counter proposal that software intended to be installed in a hardware assigned and specified by the manufacturer in order to create a safety component to perform a safety function should be listed in Annex V (indicative list of safety components).
FEM also provided critical comments towards proposed changes to the current definitions (for instance on machinery, specific application, partly completed machinery, assembly, installer etc.), as well as towards proposals to amend Annex I on different essential health and safety requirements. As highlighted by FEM, the MD Guidelines provide the necessary clarifications (e.g. regarding the borderline between the MD and Low Voltage Directive).
