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The EOT equipment used in industrial operations are frequently modified by users, for many reasons. These adjustments may affect the safety of machines as designed by the original manufacturer. In this context, the European Union-approved, "Guide to application of the Machinery Directive 2006/42/EG" includes, in section 72, the following explanation: "The Machinery Directive also applies to machinery based on used machinery that has been transformed or rebuilt so substantially that it can be considered as new machinery."

Dealing with modifications that focus on improved performances of the existing machines leads by default to a careful analysis of the machine itself.
Although Machinery Directive 2006/42/EC applies to new machinery placed on the EU market, whenever our intervention to existing machinery implies a substantial modification, we consider it to be new machinery. As a result, this "new" machinery must be placed on the market according to the Machinery Directive.
What does this mean?
The manufacturer shall proceed with the CE marking procedure of the machinery, as it is a brand-new machinery. A technical file shall be prepared and a new EC Declaration of Conformity shall be issued.
Furthermore, the manufacturer shall investigate the history of the machinery, because it will be a new machine assembled with second-hand components as well as new parts and technology, which are the reason for the new placing on the market. The existing parts may have been in use for a known period of time, causing potential wear and damage. For this reason, an accurate analysis shall be carried out.
It is highly recommended to proceed with this investigation before starting to design and implement the modifications: the results of the survey may indicate poor conditions of the machinery or other issues that may discourage the investment plan.
In such cases, Danieli applies a full engineering approach to the problem, including:

• Residual life survey. The machinery is completely investigated by a specialized engineering firm. Weldings and structures are checked carefully; installed components, such as motors, limit switches, electrical equipment, are closely verified.
• Residual life estimation. It is important to know how long the machine may be working after it is made available to the market. An estimation is done using calculation models. A fundamental input is provided by the owner of the machinery who is the only person who knows its past duty.
• Corrective actions. After the survey has been concluded, a list of improvements that need to be done in order to comply with current standards is prepared: e.g., the installation of new guardrails, the replacement of electric cables or other devices, or even welding repairs.

Together with the mandatory and standard documents required by the Machine Directive, the technical file must be compiled with additional documents attesting to the specific initial and final status of the machine.

What are the criteria that define whether a modification is substantial or not?
There are crucial aspects that Danieli engineers analyse carefully, applying by default some of the following investigations:
Does the intervention to the equipment exceed the preventive and the corrective maintenance?
Does the intervention modify the operating modes originally foreseen by the manufacturer when the machinery was initially placed on the market (e.g., the new crane becomes an automatic equipment)?
Does the intervention introduce any new risks to be considered?

There are many questions to be answered. The Danieli team is able to carry out the solution, adopting the right technical approach to the business case investment.