Safety Justification

A safety justification is a document containing a risk assessment, information on minimum safety measures, and technical documentation. This document is essential because it accompanies the machine throughout its life cycle.

In addition, the safety justification is a document that has to be updated following the risk assessment and ensures the safety of employees by protecting them from possible accidents and health damage.

Valid requirements for the preparation of the safety justification can be found in the following technical regulations: TR CU 010/2010 On the safety of machinery and equipment and TR CU 032/2013 On the safety of pressure equipment.

It is the GOST 33855-2016 standard that defines the content of the security justification, which recognizes the two forms of this document: complete and abbreviated. The second requires no proof and is declarative, while the full form involves examinations and tests.

Security justification: what is the purpose?

As you will no doubt have realized, the safety justification is one of the most important documents to enable the application for an EAC certificate or EAC declaration from the ESA. This is stipulated in the technical regulations TR CU 010/2010 On the safety of machinery and equipment and TR CU 032/2013 On the safety of pressure vessels.

How do you prepare a security justification?

The safety justification document must be produced when the equipment is designed and may be issued for different types of models or series. In addition, its purpose is to verify the current condition of the machine.

The original copy of the safety justification will be kept in the design office and also made available to the manufacturer. Technical Regulation TR CU 010/2010 on machinery safety states that the declaration and all related documents, including the safety assessment, must be kept for 10 years after the expiry of the declaration.

Security justification: the structure

The safety justification is produced with the help of the manufacturer’s technical documents which are provided for in the Machinery Directive 2006/42/EG. The safety justification is characterized by an introduction and 11 paragraphs divided as follows:

  1. paragraph: main parameters and equipment features
  2. paragraph: general safety concept for machinery construction
  3. paragraph: requirements for machine reliability
  4. paragraph: personnel requirements
  5. paragraph: risk assessment
  6. paragraph: safety requirements for the commissioning of machinery
  7. paragraph: requirements for safety management during operation of machinery
  8. paragraph: requirements for quality management during machine operation
  9. paragraph: environmental protection management requirements for the commissioning, operation, and disposal of machinery
  10. paragraph: requirements for information gathering and safety analysis during commissioning, operation, and disposal of machinery
  11. paragraph: safety requirements for the disposal of machinery

Security justification: the necessary documents

After understanding what structural elements make up a safety justification, it is important to identify the documents required to obtain it. In particular, you will need an operating manual prepared in accordance with GOST R 2.610-2006 in Russian, the certificate for the components, complete detail drawings with calculations and valid test results to verify the conformity of the equipment, the commissioning plan, instructions for repair, operation, and maintenance, general requirements for personnel: duties, rights, and responsibilities, safety measures, information on quality management, methods of disposal, use, storage or recycling of hazardous substances.

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Giovanni Devoti
Technical office, Esam S.p.a.