What type of certification is required for an automatic door employed as access point to a danger area or for closing off a loading area of a machine subjected to the Directive?
Access points to maintenance areas or more simply the guards running on rollers near the material loading/unloading bays are always more commonly managed by automatic doors integrated in the guard fencing system. The type of certification such doors need to be marketed is open to debate and deserves an in-depth analysis.


Provided that the main machine must be built and certified according to the Machinery Directive 42/2006, in order to identify the certification procedures to follow,  we need to understand how the accessory “automatic door” can be defined among the ones listed in the directive by excluding before hand the items: “machines”, “interchangeable equipment (eg. Toolings), “lifting accessories”, “chains, ropes and webbing ” and “Removable mechanical  trasmission devices”. At this point, only two categories are left to define the object of this paper:
c)«safety component»
• which serves to fulfil a safety function ,
• which is independently placed on the market
• the failure and/or malfunction of which endangers the safety of persons ,
• which is not necessary in order for the machinery to function, or for which
normal components may be substituted in order for the machinery to function.
Annex V of the directive contains a list of safety components: 

1. Guards for removable mechanical transmission devices.
2. Protective devices designed to detect the presence of persons.
3.  Power-operated interlocking movable guards designed to be used as safeguards
    in machinery referred to in items 9, 10 and 11 of Annex IV.
4. Logic units to ensure safety functions.
5. Valves with additional means for failure detection intended for the control of
    dangerous movements on machinery.
6. Extraction systems for machinery emissions.
7. Guards and protective devices designed to protect persons against moving parts
involved in the process on the machinery.
8. Monitoring devices for loading and movement control in lifting machinery.
9. Restraint systems to keep persons on their seats.
10. Emergency stop devices.
11. Discharging systems to prevent the build-up of potentially dangerous electrostatic
12. Energy limiters and relief devices referred to in sections 1.5.7, 3.4.7 and of
Annex I.
13. Systems and devices to reduce the emission of noise and vibrations.
14. Roll-over protective structures (ROPS).
15. Falling-object protective structures (FOPS).
16. Two-hand control devices.
17. Components for machinery designed for lifting and/or lowering persons between
different landings
g) « almost machinery»
'partly completed machinery’ means an assembly which is almost machinery but
which cannot in itself perform a specific application. A drive system is partly
completed machinery. Partly completed machinery is only intended to be
incorporated into or assembled with other machinery or other partly completed
machinery or equipment, thereby forming machinery to which this Directive
The definition of “almost machinery” is the one commonly applied except in those cases where the description at item 3 of annex V fits the purpose i.e. applications for which automatic movable guards (doors) serve on machines type 9,10 and 11 as described in annex IV:
Categories of machinery to which one of the procedures referred to in Article 12(3)
and (4) must be applied
9. Presses, including press-brakes, for the cold working of metals, with manual
loading and/or unloading, whose movable working parts may have a travel
exceeding 6 mm and a speed exceeding 30 mm/s.
10. Injection or compression plastics-moulding machinery with manual loading or
11. Injection or compression rubber-moulding machinery with manual loading or
For these particular categories of machinery you will need to follow the complete EC certification procedure for safety component, referring to type C and type B standards (EN ISO 12100, 14120, 13849, 14199, 13855, 13850) as well as to the Directive, of course. You will also need to guarantee full compliance during the executive phase to attain conformity status and therefore apply CE marking. Finally the end-product will be supplied with the following documents written in a EC language and the language of the country of destination of the guard:
• EC Certification conformant to the machinery directive and pertinent harmonized    
• assembly instructions
• technical booklet
• CE  marking label
• use and maintenance manuals
For all other applications, the definition to be applied is “almost-machinery” which allows to substitute the CE marking with the not least demanding declaration of incorporation, hence shifting certification responsibility to the broader field of main machinery to which the system will be incorporated.
However, conformity to type C and type B standards above mentioned must still be verified  with the possibility to shift machinery risk analysis safety requirements to elements before or after the door (guard).
Requested documents for “almost-machinery” in an EC language:
• declaration of incorporation
• assembly instructions
• relevant technical documentation 
• Use and maintenance manuals


We have outlined two possible conformity declarations which, despite being very similar in terms of standards requirements, follow very different documentation procedures in terms of contents and “manufacturer's” responsibility.
Pertaining this issue, we need to mention the current offer on the market which favours the employment of high-speed doors EC certified according to the EN 13241-1:Industrial, commercial and garage doors and gates” which have nothing to do with the machinery directive and risk prevention.
 EN 13241-1 standard does not belong to the machinery directive harmonized standards, infact, it belongs to the directive “Construction Products” which requires the manufacturer to carry out a number of tests in order to determine performance levels regarding water tightness, release of dangerous substances, resistance to wind load, thermal resistance, air permeability, geometry of glazing, mechanical resistance and stability, operating forces and durability with no single reference to protection from danger.
Access produces and certifies   Machinery Directive 42/2006  automatic movable guards with functional characteristics responding to the needs of the machines to which they are connected: 
• Drive type (e.g. electric, pneumatic)
• Transmission type (e.g. chain, rope, webbing)
• Door type (e.g. single, double, sliding horizontally or veritically)
• Opening and closing speed according to machine cycle time
• Actual dimensions of stroke 
Then adding the typical safety requirements analysis applied to an access point in order to reduce risks
•  Machine risk analysis and specifically RES analysis
•  Guard design criteria 
• Safety distance from danger for upper and lower limbs 
• Structural characteristics for push resistance ( according to ISO 14120)
•  Anti-spill characteristics for dangerous substances 
• Electromagnetic compatibility
• Performance level required for control circuits
• Pressure sensitive devices
• Selection criteria for interblocking devices associated to the guards
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