the nr-12 norm explained and simplified - machinery safety inbrazil

sice is aleading certification service agency in shanghai china, andsice-brazil is a branch of sice, locates in sao paulo. sice-brazilis accredited by crea to perform nrs inspetion and art regstration.nr12 certification is a part of sice-brazil industrialservice.

foreword

with 210 million people, brazil is a country with an enormousconsumer market, and has large industrial complexes for themanufacturing of consumer goods, as well as being a strong exporterof food and raw materials.

brazil seeks to make industrial processes more efficient so thatcosts can be lowered, and the prices of products become morecompetitive, as well as a demand for safer machinery and es are increasingly engaged in reducing the number and theseverity of work accidents, as well as meeting safety re inspections, both from government inspectors, customer auditsand independent certifications.

both countries have standards that guide the reduction of risks inmachinery and e, which promote principles and methodologiesfor the elimination of hazards and for a sufficient reduction ofrisks. however, it is important to align the technicaldocumentation of the machine, both in terms of translation intoportuguese, and for the specifics of local regulations.

regulatoryoverview

the main standard in brazil for issues related to the safety ofmachinery and e is the regulatory standard no. 12 –machinery and work e safety, known as nr-12. this normativehas re for a machine to be imported, marketed,manufactured, transported, installed and operated in brazil.

nr-12:origins and purpose

in brazil, the work relationships are regulated by theconsolidation of work laws (clt), which contains complementaryobligations such as the regulatory standards, under the chapter ofsafety and medicine at work.

the regulatory standards, identified by the acronym nr (normaregulamentadora), in portuguese, consist in obligations, rights andduties that must be observed by employers and workers. theirpurpose is to ensure the safety and health standard in the workenvironment, avoiding accidents and illnesses related to labour.commissions and groups formed by workers, employers and governmentrepresentatives produce and revise the regulatory standards,according to recommendations from the international labourorganization (ilo), in an equal tripartite system.

the first version of the regulatory standard nº12 machinery andwork e safety (nr-12) was published in 1978 and its purposewas to regulate specific articles from the consolidation of worklaws - clt.

between 1978 and 2010, the nr-12 suffered specific changes, drivenby regional initiatives. in 2010 a tripartite group of work, withgovernment representatives, employers and workers, approved asignificant revision, considering suggestions received fromsociety. in this new edition of the norm, a consolidation oftechnical references was carried out, including fundamentalprinciples, protection measures and the establishment of severalminimum re to prevent labour related accidents andillnesses. it also foresaw the employment of new and old machineryand e, and aspects to be observed in the manufacturing,importation, commercialization and exhibition.

the 2010 revision was the major significant advancement to alignlocal demands related to machinery and e safety withinternational standards. in the subsequent years, the norm sufferedother changes that facilitated the exchange of technology avoidingtechnical barriers, as well as some that updated the standard tofacilitate the understanding and application.

the 2010 update was broadly aligned with the machinery directive2006/42/ec of the european parliament and of the council of 17 may2006, granting an acceptance advantage to machines that alreadybear the ce marking.

markettrend for machines compliant with nr-12

in brazil, the engineering teams that prepare the specificationsfor machinery and e for the manufacturing processesincreasingly include the full compliance with nr-12 in thetechnical specifications. nr-12 is the most important regulatorystandard related to machine safety in brazil, an item that must bemet by the supplier through evidences in form of reports anddeclarations of the manufacturer or importer.

in the area of process engineering e, compliancere of industrial plant components are fre re audits.

in the automotive industry, manufacturers fre receiveexternal audits, both for iso certification and labour inspectors,in which nr-12 items are fre verified. it is also common forcompanies audited by labour inspectors to enter into an agreementto carry out adaptations of the machines in their productionprocess within a schedule to fully comply with the nr-12, but alsosimultaneously seek greater process automation.

another topic of recent discussions in brazil is the need forinvestment in sanitation, which is an example of sector that isrelated to welding technology and also requires machines thatcomply with the nr-12.

internationalregulations

the safety of machines and e must be considered from theconceptual design stage of the machine until its operation in theindustrial plant. the correct identification of hazards and theeffective reduction of risks is not a simple task, it is necessaryto follow a methodology that guarantees results and that isapplicable in several stages, such as in the design, manufacturing,commercialization, use and disposal phases.

safetyin machinery and international standardization

the use of established methodologies, guided by internationalstandards and their national counterparts, makes the process ofeliminating hazards and reducing risks in machinery and emuch more efficient.

the use by manufacturers of local standards aligned withinternational standards that harmonize technical specifications isextremely important to reduce commercial barriers betweencountries. as an example of a source of standards with applicationin several countries, we can mention the standards of theinternational organization for standardization-iso, which is anindependent, non-governmental international organization with amembership of 165 national standards bodies.

maininternational applicable standard for risk assessment

in the case of machinery and e, the iso standard thatguides risk reduction from the design stage is iso 12100:2010safety of machinery -- general principles for design -- riskassessment and risk reduction.

the scope of this iso standard states: “specifies basicterminology, principles and a methodology for achieving safety inthe design of machinery. it specifies principles of risk assessmentand risk mitigation to help designers in achieving this objective.these principles are based on knowledge and experience of thedesign, use, incidents, accidents, and risks associated withmachinery. procedures are described to identify hazards, estimateand evaluate risks during relevant phases of the machine’s lifecycle, and for the elimination of hazards or sufficient riskreduction.”

this standard aims to help designers, manufacturers and anyinterested persons to interpret the essential safety reof machines.

machinesafety related technical standards

some other standards can be used on more specific topics within themachinery risk reduction process. in the table below are examplesof technical standards based on international standards related tosafety in machinery and e. these standards are applied inthe various stages of the life cycle of a machine, such asconstruction, validation, and operation.

marketadvantages for machines in compliance with safetyregulations

from the point of view of the machine manufacturer's business valueproposition, offering machines with a safety certification can be acompetitive advantage by standing out from the competition,eliminating market barriers, or even meeting a demand fromcustomers who have practices that actively promote the reduction ofaccidents or who want to reduce the risks of interdiction and finesin cases of local inspection during the life cycle of themachine.

the behaviour of customers in brazil generally follows one of thefollowing alternatives:

· import or purchase machines with all the necessary documentationto comply with the nr-12.

· carry out the import of machines, with all the physical partsconstructed in compliance with international standards, but thedocumentation and evaluation part of the compliance to the nr-12are done in site, generally the translation related needs, andoften using engineers from their own staff or hiring specializedcompanies in engineering documentation to ensure compliance.attention to the negotiation of that aspect before acceptance ofthe purchase order.

initialchecklist for nr-12 compliance

the applicable regulatory standard in brazil is the nr-12 –machinery and work e safety, and it is noted that many ofthe items in the standard are in line with the main internationalstandards related to safety of machines.

an example is that the nr-12 indicates that in its execution thefollowing must be considered: “the characteristics of machines ande, of the process, risk assessment and the state ofue” which are topics covered by the iso 12100 standard.despite the alignment between nr-12 and iso standards, some itemsof nr-12 must be observed independently, such as those related tomachine manuals and the link of a legally professional inthe country to be technically responsible for the installed safetysystems for the machine.

below please find our concise initial checklist for nr-12compliance

supplier'sdeclaration of conformity (not mandatory for supplier, highlyrecommended)

a specific certificate is not mandatory or literally foreseen inthe nr-12 for the manufacturer of the machine to issue,nevertheless a declaration of conformity, listing all theregulations applied to the machine construction, is highlyrecommended, as the importer and the user of the e may nothave sufficient technical capacity to judge on acceptance whetherthe machine was constructed in accordance with the applicablestandards. the moment the buyer accepts the machine and startsusing it, he becomes responsible for the machine and is subject toinspection notices and fines. therefore, the lack of a certificateis a major risk factor for the buyer and user of the machine.

imported machines manufactured in accordance with iso 12100 relatedto risk assessment and risk reduction and following the guidelinesof the iso 13849 for the safety-related parts of control systems,are considered compliant with most of the safety re ofthe nr-12, and has a better chance to achieve a complete complianceenabling an engineering registered in brazil to issue a technicalterm of responsibility (art) for the machine. specific types ofmachines, that has a specific applicable harmonized european type“c” standard are also close to full compliance to the nr-12.

operatinginstructions (mandatory for importer and operation)

consists of a set of operating instructions (manuals) in theofficial language of the country translated to portuguese.

the machinery and e shall have instructions manualsprovided by the manufacturer or the importer with safetyinformation concerning all stages of use.

the manuals shall:

· be written in brazilian portuguese, with legible type and sizecharacters;

· be objective, clear, unambiguous and easy to understand;

· have highlighted signs or warnings regarding safety; and

· be available to all users in the workplace.

the manuals of the machinery and e manufactured or importedshall follow the applied national or international standards. (theiso 12100 standard brings many of the guidelines for theelaboration of manuals).

operationalsafety procedures (mandatory for importer and operation)

a set of work and safety operational procedures based on the riskassessment of the machine – as required by iso 12100. safetyprocedures with detailed and standardized description of each task,based on the risk analysis, are expected here.

safety-relatedparts of control systems and risk assessment report (mandatory forimporter and operation)

this re defines the required safetycategory as per iso 13849-1 for the machine or thee. the engineer in brazil, who issues the technical term ofresponsibility (art) for the machine, usually translates, orgenerates the risk assessment report confirming the required safetycategory for the machine to category its application for inspectorsand auditors. if the machine is not manufactured in accordance theiso 13849, the engineer should not issue the technical term ofresponsibility, as the e is likely not be compliant to thenr-12.

the safety systems must be selected and implemented in order tofollow the following re:

a) have a safety category according to the risk assessmentregarding official technical standards;

b) be under the technical responsibility of a legally professional; (it means that an engineer registered in thebrazilian regional council of engineering (crea) must issue atechnical term of responsibility (anotação de responsabilidadetécnica – art) to certify it.).

c) have technical compliance with the control system to which theyare integrated;

d) installation that cannot be neutralized or bypassed;

e) remain under automatic surveillance, i.e. monitoring, ifindicated by the risk assessment and according to the re category, except for exclusively mechanical safety devices;and

f) stopping dangerous movements and all the other risks whenfailures or abnormal working conditions occur.

visiblemachine information (mandatory for importer andoperation)

the machinery and the e produced as from the effective dateof this standard shall have indelible information in a visibleplace, containing at least:

a) official company name, national registry of legal entities(cnpj), and address of the manufacturer or the importer;

b) information on type, model and capacity;

c) identification or serial number and year of manufacture;

d) registration number of the manufacturer or the importer in thecrea (it means that the importer or the manufacturer must beregistered in the brazilian regional council of engineering (crea)and

e) weight of the machinery.

the manufacturer is highly likely to have such a sign on themachine with most of the information, however a new sign with allof the items above, in portuguese, must be generated and applied tothe e locally.

hazardand risk signaling (mandatory for importer andoperation)

the inscriptions shall clearly indicate the risk and the part ofthe machinery or e to which they relate and shall not beused only the inscription of “danger”. these must be in brazilianportuguese.

conclusion

the reduction of risks in machinery and e is one of theobjectives of companies, both manufacturers and companies thatdepend on machinery and e in their manufacturing processes.understanding the alignment between international and localstandards can facilitate the trade of machinery and ebetween countries, yet local peculiarities must be observed toavoid problems during the delivery of a new machine or even as adifferential to make a sale.

the brazilian industry has great potential for ac machinesthat meet the principles of risk reduction and several industrialareas are already standing out for adopting practices thatguarantee machines in compliance with the law when purchased.

there is a great possibility of gains in the cooperation betweenswiss and brazilian companies in favour of safer machines that meetthe efficiency and challenges of the brazilianindustry.