Indo-German collaboration on Machine Safety in India – by Mr. Rajesh Nath, Managing Director VDMA (German Engineering Federation, India)

Regulatory framework in India is supported by three governmental pillars:

The first pillar is the Ministry of Labour & Employment (MoL&E). It is responsible for the health, safety, and welfare of workers.

The second pillar of the regulatory framework is the Bureau of Indian Standards (BIS) which formulates Indian Standards for machinery safety through its technical committees.

The third pillar is the Ministry of Heavy Industries & Public Enterprises (MHI&PE) which introduced the National Capital Goods Policy in 2016 outlining minimum acceptable safety, environmental impact standards, and performance requirements for machinery.

Machinery safety, in the traditional Indian context, is addressed from an occupational safety standpoint. More recently, there has been a shift in viewing machinery safety as an integral part of product safety. The current challenges faced by the industry can be categorized into four areas:

• Central and state level regulations
• Standardization in machinery safety
• Compliance
• Awareness and capacity building

A survey conducted indicated that European manufacturers are most concerned with the lack of a robust machinery safety regulation in India.

The Indian Factories Act, 1948, allows each state to formulate its own rules, which results in differing interstate provisions. As industry operates across various states, compliance is difficult and expensive. Because of varying state regulations, and uncertainty about which acts apply for machinery, it is difficult for the industry to identify which criteria are applicable and how to apply standards. This affects their adoption. A comprehensive roadmap, including the classification of standards, and an awareness raising campaign for users, would improve this situation.

New manufacturing technologies such as Industry 4.0 and the use of Internet of Things (IoT) could play a role in enhancing machinery safety –perhaps using new ways of tracking processes and machine performance. The present regulations do not adequately reflect the technological advancements made in manufacturing processes. The awareness about the value addition brought by safety features and its impact on reducing downtime and enhancing productivity at large is limited. A comprehensive awareness raising campaign paired with capacity building is needed.

The need of the hour: Creating awareness about machinery safety, promoting and building a culture of safety through adoption of international good practices. The first step would be to work together with regulators to sensitize industry management on the long-term detrimental effects of unsafe machines and precautions that can be taken to mitigate these effects.

The second step would be to develop training programs for workers at operational level as part of a life cycle approach, which incorporates safety at every stage of the implementation of a process or product, also taking into consideration future manufacturing technologies such as Industry 4.0.

Systematic training programs in industrial institutes would ensure that the working population of tomorrow is aware of their responsibilities to meet required safety precautions, and along with this contribute to a safe work environment.

The EU addresses machine safety through comprehensive directives and regulations that set standards for manufacturers to follow. These directives outline requirements for design, manufacturing, and risk assessment of machinery to ensure compliance with safety standards. Additionally, the EU provides guidelines for conformity assessment procedures to enforce compliance and enhance machine safety across member states.

In June 2023 the Machinery Regulation (EU) 2023/1230 was introduced. The new regulation replaces the Machinery Directive (Directive 2006/42/EC) and has entered into force throughout all EU Member States. From January 2027 its application becomes mandatory, and the new requirements must be applied by all economic operators.

The regulation – as did the 2006 directive – defines the mandatory essential health and safety requirements that machinery products must fulfil to be placed on the European market, as well as the procedures for assessing their conformity, while the technical details are mainly provided through European harmonized standards elaborated by European standards organizations.

The requirements of the Regulation are aimed at machinery manufacturers and other economic operators such as importers. The CE marking indicates that the machinery product meets the health and safety requirements in place and can be traded without restriction in the internal market.

To conclude I would like to state that the German Engineering Federation (VDMA) and the Global Project Quality Infrastructure (GPQI) of the German Federal Ministry for Economic Affairs and Climate Action (BMWK) have been facilitating Indo-German cooperation on machinery safety for the last 7-8 years. As part of these efforts, the European Union (EU) Machinery Directive and its implementation experience have been shared with Indian authorities where many industry experts have contributed immensely.

We hope that India adopts the European Guidelines for Machine Safety so that safety of worker and productivity enhancement takes place so that Manufacturing can contribute 25% to the GDP of the country as India moves towards becoming a 5 Trillion USD economy by 2027-28. So let us be part of this growth story of India.