ALLMI guide to EN12999 A3 @ Nov 2009

Introduction

As has been the case on the introduction of previous amendments to EN12999, a number of members have understandably raised the question of how this affects machines which they may hold in stock as at 27 December 2009; the date upon which the A3 amendment is placed on the official European Journal.
This is particularly an issue under the current climate and the Technical Standards Committee has discussed the matter at length; making reference to both the Machinery Directive and a number of other standards in terms of precedents and product definitions.
In relation to the issue of machines held in stock as at 27 December 2009, the Technical Standards Committee has taken the following interpretation/view:-
1. That the date on which a machine is placed into the market for the first time is when the requirements of EN12999 A3 should be met. “Placing into the market” means the date at which the Manufacturer has completed the assembly of the machine and it is therefore available for sale.
2. That according to the wording of the Machinery Directive, a Loader Crane becomes a machine at this point; irrespective of the fact that it has not been mounted to its power source.
3. That an importer/installer is not changing or modifying the features which determine its compliance with the Essential Health & Safety Requirements of the directive in the course of its subsequent installation.
4. That subsequently, any “machine” built prior to 27/12/09 falls under the auspices of the previous version of EN12999 A2 and should not be required to conform to the requirements of A3 even if it is installed after that date.
5. That if any machine with a 2009 plate is installed for the first time after 27/12/09, the Declaration of Conformity needs to state it conforms to EN12999 A2; and not EN12999 A3.
6. That Customers should be made aware at point of sale whether they are buying an A2 or A3 compliant machine and what the differences are. This should be documented as you are providing them with the means to fulfil their own obligations under PUWER; as the owner of the equipment is ultimately responsible for providing the correct equipment for their employees to use.
7. That due to the above, there is no clear way of implementing or achieving any cut-off date in relation to the date by which any (yet to be installed) loader with a 2009 plate should be brought into line with the requirements of EN12999 A3.
8. That as a consequence of the above, the only criteria which can be applied is that anyone subsequently examining the loader crane will take the year of manufacture from the loader serial number plate bearing the CE mark and base his examination on the A2 variant.

Stabiliser interlocks

The main concern for most members is over the forthcoming requirement for what are commonly called “stabilizer interlocks”. As per the guidance issued on 25 August, the requirement is as follows:-
• On loader cranes with a rated capacity of 1,000 kg or above, or a maximum net lifting moment of greater than 40,000 Nm or above, the stability of the vehicle shall be included in the safety function of the Rated Capacity Limiter.
• Basically, deployment of each stabilizer is monitored by the RCL system and the system should either lock out or reduce the capacity in areas where stabilizers have not been fully deployed. This requirement will not apply to Timber Handling Cranes.
It would be inappropriate for ALLMI to advocate the type or use of any particular system to achieve the above. As stated, the RCL needs to know the respective positions of the stabilizers and either lock out or reduce the capacity accordingly in the event of partial or non-deployment. Therefore, it should be assumed that Manufacturers will produce various systems capable of achieving this – some of which will be more technically sophisticated (user friendly?) than others.
One inevitable outcome of the above is that occasions may arise where the loader can only work at a reduced capacity. This means that the issue of calibration & testing of loaders in these areas requires attention.
In relation to the Calibrating of Loaders in any reduced capacity areas, the Technical Standards Committee has already published Guidance Note 015.

Ground pressure / Noise testing / Audible & visual warning

Ground pressure

Manufacturers are limited to ensuring that the foot diameter is such that it the resultant maximum ground pressure is no more than 4MPa and they are responsible for providing the means to ensure that i.e. foot-pads if necessary.
This figure will usually be calculated by the manufacturer on the assumption that both (or all) stabilisers are extended fully outwards and lowered in accordance with their instructions.

Noise Testing

Another requirement under the A3 amendment is the testing of noise. Under the Machinery Directive, it is accepted that the Manufacturer is unable to state the noise levels of the machine as it has not yet been mated with its Power source. The responsibility for this therefore lies with the installer.
ALLMI is in the process of compiling some comparative emission data for similar loader crane installations to ease this process and it is hoped that over a relatively short period of time, there will be sufficient data available to produce a standard matrix for members to use; thus negating the need in many cases to physically conduct such testing on each installation.
After ongoing consultation with noise-testing consultants regarding the current situation in events where this is not covered by the matrix, the correct practice would be to carry out the sound-power level test. This is a complex exercise requiring specialised equipment and very specific test criteria. The cost of such testing is highly prohibitive as it equates to approximately the same price as an average 10 t/m crane installation.
It is therefore ALLMI’s aim to produce the comparative emission data as soon as possible in order to address this issue. In the meantime, a template for carrying out an abbreviated basic test for sound pressure levels is attached as Appendix C. Members should be aware that this does not fully meet the requirements laid out in EN ISO 11201:1995; but as an interim measure, we hope to assemble the data needed to confirm further testing level required. All members are therefore requested to submit copies to ALLMI of noise tests carried out to expedite this process.

Audible & visual warning

The new standard contains a stated requirement for both audible and visual warning in the cab for either Boom Height Warning (or Boom Not Stowed) and for the “manual stabiliser not locked” warning system.
In relation to Boom Height Warning, ALLMI members have advocated the fitment of both as a failsafe for many years and most members have done so; but please note that for all A3 machines, it becomes mandatory on any or all of these devices.
In relation to the “manual stabiliser not locked” warning system (introduced originally in the A2 amendment) – please note that this should also now be audible as well as visible from the transport driving position. This applies only to manual stabilisers.

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