Redesign of production lines – significant changes to machines

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If you have modified your system or intend to do so, further measures might be requested. We advise you in case of refitting, modernization, extension, new designs, etc. of production lines for a legally watertight and efficient implementation. We support you in assessing and check for you:

  • Does refitting the production line cause a case of significant modification influencing the machine safety?
  • Is it a case of significant modification?
  • Is an intended change financially feasible (assessing costs and benefits of changes)?
  • Is a new conformity evaluation procedure (CE marking) required?
  • What is the influence of refitting production lines to liability risk, manufacturer responsibility?
  • How much time would be involved in the refit and what resources would be tied into the refit process?

Significant changes due to redesign of production lines

We check for you if the system was subject to a change affecting the safety evaluation and you need to perform a conformity evaluation procedure. Only thorough planning and consideration can protect you from cost traps.

In this, we advise you extensively on all relevant aspects. For example, the standard DIN EN ISO 12100 (Safety of machinery – General principles for design – Risk assessment and risk reduction) related to the Machinery Directive 2006/42/EC requires precautions for maintenance-friendliness during design of a machine. This means that for redesign, refitting and extending a machine, certain factors regarding ease of maintenance must be taken into account in order to facilitate machine upkeep.

The planned redesign of systems or production lines can for example be new, more powerful drives and/or safety devices or a new control software. In such cases, you must also decide and evaluate whether a significant change is given.

If you do a signatificant change to your machine, a new conformity evaluation procedure (CE marking) is required. Relevant for the decision whether a significant change is given are the answers to the following questions:

  • Is there a new hazard / risk increase?
  • Are the present safety-related measures sufficient?
  • Can simple guards restore a safe state?
  • How high is the risk of an injury?
  • How high is the probability of occurrence of an injury?

If you have modified your system or intend to do so: Call us. We will gladly advise you and help you assess if you have made or plan significant changes to your system.

Legal liability in case of redesign of production lines and significant changes to machines

  • In general, the operator is responsible for any machine modification.
  • The operator becomes the manufacturer, having the same obligations of the manufacturer
  • The REFITTER must determine whether a significant change in the sense of the ProdSG is given


When do you need to consider the building site regulation in case of redesigning production lines?

The building site regulation requires that the conditions for effective coordination and enforcement of occupational safety measures are set already in the planning stage of the construction. This shall ensure safety and health protection when performing the construction project.

Machines and production lines are in general not regarded as construction sites in the sense of the building site regulation BaustellV. However, in some cases tasks for upkeep must be integrated acc. to the building site regulation, e.g. upkeep for biogas systems, natural gas filling stations, cement silos. For upkeep, i.e. installation, removal or refitting of machines and production lines, the building site regulation must be taken into account if:

  • the upkeep is done at the same place and time as construction/change of a building system
  • the upkeep is done at the same place and time as demolition of a building system

You are not sure if your upkeep is affected by the building site regulation? Please call us, we will be happy to give you advice.

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