Substantial change of machines

During conversions or modernizations, far-reaching changes are often made to machines and systems in order to adapt them to the current state of the art. For example, they are equipped with new, more powerful drives and/or protective devices or with new control software.

The decision-making steps as to the extent to which a significant change is involved in these cases consist of an analysis of whether

  • hazards are added or risks are increased
  • the existing protective measures of the machine are still sufficient, if necessary
  • the existing protective measures may no longer be sufficient

In the latter case, it must be checked whether the risk can be eliminated or sufficiently reduced with simple protective devices (e.g. “protective plate”, light barrier, etc.).

In the event of a significant change, the machine is treated as a new machine and the provisions of ProdSG and 9. ProdSV (and thus also the Machinery Directive) must be applied in full. In this context, it should be noted in particular that, by allegedly “repairing” or “modernizing” a machine, one becomes its manufacturer in certain cases and, for example, the conformity assessment procedure must be carried out as part of the CE marking.

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