Operating mobile agricultural machinery safely

Mise en conformité
Réglementation
Sécurité
The use of mobile machinery is one of the leading causes of accidents on farms. In Gironde, over the last 5 years, these machines have caused numerous serious and fatal accidents. The type of machinery involved in these accidents varies: ride-on mowers, standard tractors, vineyard tractors, grape harvesters, etc. Both new and second-hand machines are involved, ranging in age from 3 years to over 20 years. The profile of the users of these machines is also diverse: they are employees as well as farmers, new farmers or farmers close to retirement. Analysis of these accidents shows that compliance with regulations and the way in which mobile agricultural machinery is used are decisive factors in their occurrence. However, the circumstances of the accident sometimes highlight less immediate and less visible causes... linked to work organisation.

What mobile machines?

Small or large, simple or sophisticated, old or new, mobile machinery can be found on every farm.

The most frequently encountered in our department are
  • :
  • tractors and high-clearance tractors,
  • self-propelled machines, also known as MAGA, such as grape harvesters, multi-purpose forwarders, harvesters, etc,
  • all machines powered by self-propelled equipment or tractors, such as trailers, tippers, shredders, rotary harrows, trimmers, balers, sprayers, augers, etc

||And there are so many others...

Compliant machines

To be sold on the European market, a new machine must meet a certain number of design and construction requirements in terms of safety... the main aim of which is to ensure that it can be used without risk to the user's health.

Rules also apply to second-hand machines offered for sale.

And, during its lifetime, it will be necessary to ensure that the machine continues to comply with the construction requirements in force at the time it was manufactured

Acquiring compliant machines

Since the 1990s, the rules governing the marketing of machinery have been based on European legislation. Designed to facilitate free movement between European states, this legislation has harmonised design and construction rules by imposing a high level of safety common to all machines.

Following on from Directive 89/392/EEC of 14 June 1989 and Directive 98/37/EC of 23 July 1998, Directive 2006/42/EC of 17 May 2006, also known as the Machinery Directive, is the reference text in this field.

It has also been fully transposed into French law in Annex 1 of Article R. 4312-1 of the Labour Code. This text is itself part of a wider set of provisions contained in the legislative and regulatory section of the French Labour Code (Part 4, Book 3) which govern work equipment, including machinery

Other Directives supplement or replace the Machinery Directive by laying down specific requirements for certain types of equipment. This is the case, for example, with agricultural and forestry tractors, the marketing of which is governed by European Regulation no. 167/2013 of 5 February 2013. This regulation lays down specific rules on rollover protection structures (roll bars) and on driver restraint systems (seat belts).

The philosophy behind these various Directives remains the same: whatever the country in Europe, a machine offered for sale, sold, imported, hired out, made available or transferred must comply with technical design and construction rules commonly known as the "essential health and safety requirements"

Compliance with technical design and construction rules

Well before the construction phase, the design of the machine must be based on a process of analysis
  • :
  • analysis of the machine's limits, both in terms of normal use and any reasonably foreseeable misuse
  • analysis of the hazards that may arise from the machine and analysis of the associated dangerous situations
  • analysis of the risks to health in terms of severity and probability of occurrence

This analysis is used by the manufacturer to construct a "safe" machine, i.e. a machine capable of performing its functions, being adjusted and maintained without risk to workers' health... throughout its foreseeable life... including during transport, assembly, dismantling, decommissioning and scrapping.

It should be noted that these elements of analysis appear in the technical file compiled by the manufacturer and made available to the French administrative authorities as part of market surveillance.

To guarantee that its machine is 'safe', the manufacturer undertakes to follow the essential health and safety rules defined by the Machinery Directive.

In reality, these rules consist of a set of objectives to be achieved in order to ensure a high level of safety, leaving the manufacturer free to choose the means of achieving them.

There are several types of rule:
  • technical rules common to all machines concerning :
  • -
the principles of safety integration
- choice of materials and products
|- lighting
- machine handling
|- integration of ergonomics
- workstation design
- seating
- control systems
- protection against mechanical risks, in particular loss of stability, breakage in service, falling and ejected objects, moving parts, etc.
- the characteristics of the guards
- protection against other risks, in particular electrical energy, incorrect assembly, extreme temperatures, fire, explosion, noise, - vibrations, radiation, dangerous materials and substances, etc.
- adjustment, maintenance, repair and cleaning operations on the machine and interventions during operation
- information and warning devices
  • .
  • additional technical rules applicable to certain machinery, such as machinery intended for use in the food, cosmetics or pharmaceutical industries, portable machinery, woodworking machinery, etc.
  • additional technical rules applicable to machines subject to particular operating constraints, such as lifting, mobility, working underground, etc.

Compliance procedures

Once the machine or prototype has been manufactured, the manufacturer must follow a conformity certification procedure.

depending on the machine, there are 3 possible procedures
  • :
  • The internal control procedure (Articles R.4313-20 to 22 of the CdT1) or "self-certification".
  • This is
the most commonly used procedure, since it concerns around 80% of machines placed on the market.
The manufacturer ensures that his machine complies with the relevant technical rules of the applicable Directive and draws up, under his own responsibility, a declaration of conformity.
He takes the necessary measures to ensure that the machinery produced will conform to the machine that is the subject of the technical file and to the relevant technical rules
  • .
  • The "EC type-examination" procedure (Articles R4313-23 to 42 of the CdT).
  • This
concerns the machines detailed in article R4313-78 of the French Labour Code.
It is carried out by a notified body. Within the European Union, a notified body is a third party authorised by a Member State to determine whether a product to be placed on the market complies with the essential health and safety requirements defined by the Machinery Directive.
The notified body carries out an examination of the technical file and an examination and test of the machine model, which enables it to draw up an EC type-examination certificate.
the manufacturer then undertakes to produce copies that conform to the model for which the EC type-examination certificate has been issued
  • .
  • Full quality assurance (Articles R4313-43 to 56 of the CdT).
  • It
also concerns the machines listed in article R4313-78 of the CdT.
The notified body assesses and approves the machine manufacturer's quality system and monitors its application. To this end, it ensures that all measures have been taken concerning design, manufacture, final inspection and storage.
Like the EC Type Examination procedure, the notified body does not examine or test the machine. Inspections and tests are defined by the manufacturer in his quality assurance system (techniques used, planning, reports, results and qualifications of the personnel involved).
The manufacturer then undertakes to manufacture these machines in compliance with all the conditions necessary for the quality system approved by the notified body to remain effective

Documents accompanying the machine

whatever the machine concerned and whatever the method of certification, the manufacturer must
  • :
  • affix the CE conformity marking to the machine||
  • draw up an EC declaration of conformity and provide it to the purchaser||
  • compile a technical file attesting to the conformity of the machine
  • provide an instruction manual in French, containing in particular:
  • -
a description of the machine (weight, power, dimensions), information on the machine's noise level, vibration level, etc.
- instructions on, for example, assembly operations, safe practices for using the machine (including the possibility of wearing personal protective equipment), maintenance and adjustments
- warnings on the limits of use, residual risks and their consequences

An often overlooked stage: reception

By the time the machine finally arrives on site, several months may have passed since the order was placed. And production needs may make its use imperative.

Commissioning should always be preceded by an acceptance test, i.e. a phase during which the plant manager, workshop manager or other designated person checks that the machine complies with the applicable regulations (Machinery Directive, other directives, French regulations).

The fact that it is a standard or mass-produced machine does not mean that compliance cannot be checked. Serious and fatal accidents also occur with new mobile machines that may lack one or more points of compliance...bearing in mind what was said earlier about certification procedures and the fact that many machines are self-certified.

If it is a specific machine, designed on request and according to the needs of the company, this commissioning will also be an opportunity to check that the specifications have been respected.

Of course, this is easier said than done?
The operations manager can refer to the Ministry's sheets below (see: Keeping machines in compliance throughout their life).

This acceptance stage enables any anomalies to be detected and reported to the manufacturer. The owner of a new machine has a period of one year from the date of delivery to report any lack of conformity to the seller and, if he considers it necessary, to request that the sale be rescinded (Article L4311-5 CdT). This means that, during this period, the seller is obliged to remedy the non-conformity at its own expense or to take back the machine.

As part of French market surveillance, another system has been in place since the early 2000s: MADEIRA reporting.
MADEIRA reports are sent to the DREETS (or to the MSA's Occupational Risk Prevention Department, which then reports them to the DREETS). This system enables all reports of non-compliant machines in France to be grouped together in a single database. The aim of this notification is, through the intervention of the French government, to obtain from the manufacturer the compliance of all work equipment of the same model as that identified as non-compliant. |

Keeping machines compliant throughout their lifetime

This obligation to maintain compliance applies to all owners of agricultural machinery.
Because in the course of its life, machinery ages and deteriorates as a result of use, external events (aggressive working environment, weather conditions, etc.) or internal factors (poor maintenance, incomplete emergency repairs, intensive work rate, etc.).

This means that the owner must regularly carry out a diagnosis of the condition of the equipment in service and a risk analysis.

|This involves
  • :
  • making an inventory of the equipment and identifying any that are not in compliance
  • defining the measures to be taken (technical modifications and/or organisational measures)
  • |
  • assessing the cost of compliance
  • defining priorities according to risk
  • drawing up a timetable for the compliance work to be carried out.
For
agricultural and forestry machinery brought into service after 1 January 1995, there are practical information sheets that can be used to quickly identify the risks present on the machine, as well as safe operating practices and the obligations incumbent on the company manager.

These
sheets are available free of charge on the website of the Ministry of Agriculture and Food(https://agriculture.gouv.fr/securite-des-machines-agricoles-et-forestieres-fiches-pratiques).

There
are currently around forty of them. They are all structured in the same way, along 3 axes
  • :
  • a components and functions section, presenting the operating principle of the machine and the various components that make it up
  • a design section presenting, in the form of technical specifications, the assessment of existing risks on the machine
  • a use section setting out safe use practices and the obligations of the company or business manager who makes the machine available to his employees.
1ère partie de la fiche remorque semi-portée

Example
of Part 1 of the Semi-mounted trailer sheet

To find out which technical rules apply to your equipment, you can use the diagrams below

Correspondance des textes en fonction de l'année de mise en service des machines mobiles
Correspondence
between the texts according to the year in which the mobile machines were brought into service
Correspondance des textes en fonction de l'année de mise en service des tracteurs
Correspondence
between texts depending on the year the tractors were brought into service

If the equipment is modified

The Technical Guide of 18 November 2014 on operations to modify machines in service, drawn up by the Ministry of Labour and the Ministry of Agriculture, provides guidance on equipment modifications.

Is considered a modification, the replacement, addition or deletion of a component or function, the addition of interchangeable equipment or the modification of the defined application when these operations are carried out on a machine
  • :
  • subject to CE marking and where this operation is not provided for by the manufacturer in the instructions ;
  • not subject to CE marking, and when the purpose of this operation is to renovate the machine in whole or in part, to modify its performance or to change its working conditions.

The assembly of machinery involving at least one machine in service with which a new machine, a partly completed machine or another machine in service can be associated is also considered to be a modification insofar as this assembly is not provided for in the instruction manual(s) or in the absence thereof.

Any owner who modifies a machine made available to his employees or a third party, or who has it modified by a person outside the company (such as an agricultural mechanic), is responsible for compliance with health and safety regulations. In all cases, they must ensure that the modified machine complies with the safety rules applicable to it, and that it is adapted to the working conditions and characteristics in accordance with the provisions of article R. 4321- 2 of the French Labour Code. He must also ensure that its operation and use do not contravene the manufacturer's initial recommendations, where these exist.

In order to fulfil these obligations and provide proof of continued compliance, the owner must draw up a technical file containing a description of the modification and the results of the risk assessment. This file ensures that the modification can be traced.

When a modified machine in service is transferred, it is recommended that this file be submitted in addition to the certificate of conformity.

The owner must inform workers, in an appropriate manner, of the risks to which they are exposed as a result of modifications to the machine. He shall also inform them of the new conditions of use and maintenance and of the instructions or instructions concerning them (articles R. 4323-1 and 2 CdT). |

Second-hand equipment

Secondary-hand equipment is any equipment that has already been used in a European country.

There are no European regulations governing the marketing of second-hand equipment. Consequently, the regulations of the country where the equipment is sold apply.

In France, there are provisions to protect the buyer. In the event of the sale or transfer of second-hand equipment, the seller, whether the owner or the dealer offering the sale, must ensure that the equipment is in conformity. If any defects are found, the seller is obliged to bring the equipment into compliance. In some cases, compliance can be costly and lose its economic relevance. This explains why many farms still have second-hand machines "bought as is", i.e. not in conformity. This means that these machines are potentially dangerous, and the owner may be held fully liable in the event of an accident!

At the time of the transaction, the seller gives the buyer a certificate attesting to this compliance.

The compliance rules applicable to second-hand equipment depend on the date it was first put into circulation and the type of equipment (mobile or not, lifting or not).
schéma de la vente d'un matériel vitivinicole

Trained users

While compliance remains a major factor in machine safety, getting to grips with the machine and using it are also essential and cannot be left to chance.

They help to reduce the number of accidents that occur by giving the user the means to understand the specific features of the machine, its hazards, its limits and the working environment suited to it. They enable an ad hoc response to be made in the event of unforeseen circumstances, malfunctions, anomalies, etc.

In other words, before using a machine in a real working situation, it is important for the user to have received training and been familiar with the machine

The principle: General safety training

As soon as a new machine arrives on the farm or when a machine already on the farm is used by the worker for the 1st time, the latter must receive appropriate practical training.

the aim is to provide knowledge of
  • :
  • the conditions under which the machine is used
  • instructions or guidelines concerning the machine, in particular those contained in the manufacturer's instruction manual
  • how to deal with foreseeable abnormal situations (jamming, breakdown, etc.)
  • conclusions drawn from experience to eliminate certain risks.

Training must be renewed and completed as often as necessary. It provides an opportunity to update knowledge, to add to it if there have been changes (to the machine, to the way the work is carried out, etc.), to identify dangerous working practices, unsuitable work organisation, etc.

It should be noted that when training is given to employees, it must be adapted to take account of their training, qualifications, professional experience and language.

This training is sometimes provided by the vendor when the new machine is delivered to the farm. This is an interesting practice, as it allows you to benefit from a wealth of knowledge and unparalleled feedback. Beware, however, of the content and duration of the training, which can sometimes be insufficient to ensure that the operator has a thorough understanding of the machine and can get to grips with it properly. |

An essential complement: driver training

This training requirement (Article R.4323-55 CdT and Order of 2 December 1998) applies to all drivers of self-propelled mobile agricultural and forestry equipment.

The aim of this training is to give the driver the knowledge and know-how required to drive the equipment safely. It must be updated whenever necessary.

It can be given within the company or by a training organisation

It should be noted that there is no specific approval or accreditation to deliver this training. However, it is strongly recommended that you refer to the knowledge and assessment standards in place for industrial activities. Although outside the scope of agricultural activity, these standards nevertheless concern mobile machines often used on farms (tractors, forklift trucks, rough-terrain handling equipment, etc.). |

Adapted work organisation

The professional knowledge and skills of users are not enough to guarantee the safe use of a machine.
The organisation of the activity will enable the work to be analysed and planned in the best possible conditions

Understanding the working environment

All machine operators must be made aware of the characteristics of the site they are working on, which could present a danger: slope, ditch, narrow headland, power line, tree, etc

It is also important to organise machine/machine or machine/pedestrian co-activity on a plot of land.
As far as possible, machine/pedestrian coactivity should be eliminated. If it cannot be avoided, each person involved must have received clear instructions that must be strictly followed to ensure everyone's safety.

Whatever the type of co-activity, the work areas, the direction of traffic, the rules of priority, the methods of communication, the safety distances (etc.) must be defined and communicated in advance to all the workers concerned. |

Check the equipment

Using equipment that is in good condition increases safety.

On a regular basis, and in any case before a worksite or a work campaign, it is essential to check that the machinery and tools used are in good working order.

any deterioration is a source of danger
  • :
  • either directly, by creating a hazard (damaged hose, broken or missing protective casing, defective cardan shaft protector, missing distance bars) likely to cause an accident, or
  • indirectly, by generating breakdowns that cause delays in planning or production and lead to risk-taking to make up for the time spent on repairs (omission of safety instructions, haste, increased working speeds, use of unsuitable machinery or tools, etc.).).
  • In
addition, for worksites requiring road travel, you must ensure that the tractor's signage, and possibly that of the tool (if the tool hides the tractor's lights), is working properly so that it is visible to other road users.

It should be noted that the decree of 4 May 2006 on the movement of agricultural or forestry vehicles and equipment and their combinations makes it compulsory to use a flashing beacon when moving on public land

Arrange for coupling, uncoupling and storage

Somme accidents occur when the machine is not in use, during coupling and uncoupling. To avoid these risks, equipment must be coupled and uncoupled in easy, simple and functional conditions.

To do this, it must be stored stably on flat, smooth ground, preferably hard ground to avoid denting.

Installing light tools on pallets is a good way of making them easier to move and store. When used in conjunction with handling equipment (pallet trucks, forklift trucks, telescopic handlers, etc.), this reduces the risks involved in coupling and uncoupling tools, such as bumping, crushing, tipping, jamming and strain injuries.

Good storage conditions make for a simplified coupling/uncoupling phase that does not require the help of another person, which can become dangerous.

Finally, the introduction of work procedures and safety instructions (use of remote controls, coupling/uncoupling with the engine off, coupling/uncoupling alone, etc.), and the use of appropriate tools (stanchions, winch, hoist, chocks, etc.) help to prevent the risks associated with this often forgotten phase.

Note that there are automatic or semi-automatic hitching/unhitching systems that make it easier and safer to couple the implement to the tractor

Working on equipment during use

Accidents often occur when work is being carried out on the tool.

To ensure user safety when adjusting or troubleshooting, all work must be carried out with the engine off, the tool on the ground and the moving part at a standstill.

If there is a risk of another person starting the machine, it must be locked out by removing the ignition key. Before intervening, make sure that any residual energy has dissipated (hydraulics, pneumatics, springs under tension, inertia of moving parts).

For some equipment, adjustment requires it to be in operation. In this case, the intervention procedures must be clearly defined before the intervention.

Similarly, any maintenance work carried out on the farm must be carried out after having read the specific instructions for use set out by the manufacturer in the instruction manual.


Contact :
Occupational Risk Prevention Department (P.R.P.) of the MSA Gironde :
05 56 01 97 71 or 05 56 01 97 52
prp.blf@msa33.msa.fr
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