New standards required for commercial vehicle superstructures in the form of machinery

To ensure that the safety and health of workers is taken into account during the design of new commercial vehicle superstructures in the form of machinery, the German Social Accident Insurance Institution for the transport industry (BG Verkehr) is seeking to initiate development of standards for dump trucks, silo trucks and car transporters. Experts from manufacturing and operating companies are sought for this work.

As a German Social Accident Insurance Institution, the BG Verkehr is particularly concerned with the safety and health of drivers during the use of commercial vehicles. An important aspect here is the safety of access and entry points and working areas on vehicle superstructures. According to accident statistics from the BG Verkehr and other accident insurance institutions, falls, including falls from a height, during the use of access points and the performance of work on vehicles or vehicle superstructures are among the most common occupational accidents. These accidents often cause serious injury, in some cases with long periods of absence from work, and may even be fatal. As long ago as November 2022, the BG Verkehr held an industry conference on the subject of the underestimated hazards of falls from vehicles and access points to working areas on vehicles, and effective measures for reducing these hazards to a minimum.

Gaps in rules and regulations

Safety requirements for vehicle superstructures are described in the DGUV accident prevention regulation concerning vehicles (DGUV Regulation 70), which is currently being revised. However, its scope excludes superstructures in the form of machinery mounted on the base vehicle, such as tipping systems for dumpers and silo trucks or moving load areas for car transporters, as these must comply with the requirements of the Machinery Directive 2006/42/EC and, as of 20 January 2027, the Machinery Regulation (EU) 2023/1230. Accident prevention regulations (DGUV regulations) are addressed primarily at member companies of the German Social Accident Institutions, and not directly at the vehicle manufacturers. Nevertheless, many manufacturers of vehicle superstructures in the form of machinery refer to the requirements of DGUV Regulation 70 concerning working areas on vehicles and access, entry and exit points as a basis for the design of their products, since the Machinery Directive describes only general objectives of protection.

Existing harmonised product standards for the safe design of vehicle superstructures in the form of machinery are as yet limited in number and address refuse collection vehicles or concrete mixer trucks, for example. A French national standard (NF R17-109) for dump trucks was introduced in August 2020. This could serve as the basis for a European standard; work on its transposition has not yet begun at European level, however. No standards exist at this time for the superstructures of silo trucks and car transporters.

For vehicle superstructures falling within the scope of the EC Machinery Directive, reference can also be made to the EN ISO 14122 series of standards, Safety of machinery – Permanent means of access to machinery. However, the design requirements set out in these standards are geared primarily towards stationary machines. They often cannot be applied to the specific conditions for vehicles and their superstructures deriving from the provisions of road traffic legislation, such as dimensions and weight. A gap in the regulations therefore exists for dump trucks, silo trucks and car transporters. Specific requirements in product standards (ideally harmonised) would be extremely useful for manufacturers and operators alike.

Requirements for manufacturers and operators

The safety and health requirements currently in place for vehicle superstructures in the form of machinery are set out in Annex I of the Machinery Directive. Manufacturers’ obligations include assessing the risk during the intended use and reasonably foreseeable misuse of the product and taking appropriate technical protective measures.

Operators must observe national regulations during use of the product. In Germany, these include the German Occupational Safety and Health Act (ArbSchG) and the German Ordinance on industrial safety and health (BetrSichV). They are therefore required to conduct a risk assessment in which they determine and evaluate the working conditions to be taken into account in the design of work equipment and machinery and during its selection and use. Machinery in this context also includes vehicle superstructures in the form of machinery. Adherence by manufacturers to the harmonised safety requirements set out in standards is highly advantageous for operators.

Towards international standards

In the light of this situation, the BG Verkehr wishes to promote two work items for standards development that contain specific provisions for access and entry points and working areas and protection against falls from a height on vehicle superstructures in the form of machinery:

• Extension of the EN ISO 14122 series of Type B standards (generic safety standards) by a new part describing essential requirements for access to superstructures in the form of machinery mounted on mobile/non-stationary machinery
• European (ideally harmonised) Type C standards (product safety standards) for dump trucks, silo trucks and car transporters

A request for development of the new part of the EN ISO 14122 series of standards for mobile/non-stationary machinery has now been submitted to ISO/TC 199, Safety of machinery. As soon as this request has been approved, the essential requirements are to be developed in ISO/TC 199 in an international working group.

The envisaged product standards for dump trucks, silo trucks and car transporters are intended to support manufacturers in complying with the statutory product safety requirements and to provide guidance to operators during purchase of these vehicles. To this end, the BG Verkehr is seeking to introduce a work item in CEN/TC 301, Road vehicles, in cooperation with the DIN Standards Committee Road Vehicles and Mobility.