What does adding wireless remote control to an existing machine mean under 2006/42/EC?
The essential health and safety requirements of Machinery Directive 2006/42/EC are a legal obligation. Adding a remote control system to an existing machine afterwards may count as a substantial modification with respect to that machine's risk assessment and technical file. Making that assessment, and updating the documentation if required, is the responsibility of the party operating or modifying the machine.
A retrofit kit on its own is a component; what creates liability is the machine as installed, as a whole.
The logic of the directive works like this: the essential health and safety requirements (EHSRs) are binding. Harmonized standards such as EN ISO 13849 are the building blocks used to demonstrate that those requirements have been met. In other words, applying a standard is not the goal — it is a method of verifying that the requirements are satisfied.
What is expected in practice:
- Update the machine's risk assessment after the modification; new remote control brings new scenarios (operator away from the machine, changed line of sight).
- Renew operator training and the work instructions to match the new working method.
- Record the modification in the technical file and maintenance records.
- For machines subject to periodic inspection, such as lifting equipment, notify the authorized inspection body of the modification.
AXI Teknoloji declares CE conformity for the HCT400 and HCT402. That is a declaration concerning the kit itself; the conformity of the machine as it exists after the kit is fitted falls within the assessment of the operator or the party making the modification.
Full coverage of this topic: Connect Plus and Minus, Run: Installation That Does Not Depend on Technical Staff