In recent social media posts, some people and organisations have been implying that force testing of doors and gates is not legally necessary, nor particularly beneficial. This article seeks to clarify the situation; it should be read in conjunction with the previous article regarding the significance of standards in relation to the law.
EN 12453 for industrial & garage doors, vehicle gates, and traffic barriers, sets the minimum requirement for safety. Twenty criminal prosecutions in the past 15 years have shown this to be true without any doubt. Whilst a company is not usually compelled to use the standard, it is necessary to achieve an equal or better level of safety.
What the UK regulator says about force testing
In a 2018 HSE website article on the revision of EN 12453 and EN 12604, the HSE clarify the relationship with the law: “These new standards are a major step forward in helping to define the 'state of the art' for all products in scope, especially for the safety related parts of the control system on which these products depend for safety. They maintain the previous requirements for basic strength, stability and testing, including where force limitation is the primary means of delivering safety”. The same article also stresses the need for force testing where appropriate: “Where force limitation is the primary means of safety, impact and crushing forces should be as low as possible (the standards give maximum levels), and verified by testing post installation.”
Note that this article was written in 2018 before the current (EN 12453:2017+A1:2021) amendment was published; the 2017 revision referenced in the article included a legal compliance warning in the UK BS version, whilst the now current 2021 amendment is published without the warning. As the 2021 amended version is now listed by the European Commission as a harmonised standard under the EU Machinery Directive, it now quite clearly defines the current state-of-the-art for compliance.
Similarly, in another HSE website article, the importance of force testing during installation and maintenance is stressed: “where force limitation is the primary means of safety some form of objective force testing will be required to ensure the final product as delivered is within safe limits, and to subsequently check the product remains safe.”
What we learn from past prosecutions
The legal significance of force testing was also very firmly underlined following the HSE prosecutions of two companies following the death of Carolina Golabeck in Bridgend, where the gate had supplementary beams but defective force limitation. A subsequent HSE presentation on the case to industry points out that the two companies concerned had not tested the closing forces and that one had actually claimed to have used a “hand test” to verify safety. Whilst there were many more things wrong with the gate, it was closing force that caused the fatality. As low level beams do not satisfy the requirements for non-contact presence detection used without force limitation, even if had beams on both sides it would still have been non compliant and not safe enough for legal compliance; low level beams do not prevent a person leaning, reaching or falling into the crush zone. The threshold for using non-contact presence detection is that all hazards are protected such that contact with hazardous movement is prevented, not just made less likely.
What the standard requires
Force testing verifies safe force, which can be arrived at inherently or by application of safe edges. Given that DHF has measured in excess of 1000N (enough to kill a child) against a safe edge on numerous gate systems, unless safe edges are force tested, it cannot be known if they are suitably specified, safe, or compliant. Successful use of a safe edge requires that the stopping distance (over travel) of the system, does not exceed the over travel provided within the safe edge structure (the distance it can be crushed before it becomes solid).
In the section on force testing, the standard states: “The following clauses describe the tests necessary at the closing edges, but where other hazards of doors [and gates] are being protected by limitation of forces, the values specified in Annex A shall be verified at that hazard." Hence, it is not sufficient to simply test at the main edge and then claim the system to be safe and compliant, all hazardous areas that could contact a person must be verified to be within the limits of safe force.
It is worth clarifying at this point that force limitation is not the only way to provide safety and compliance in the swept area of a moving door or gate under EN 12453. Whilst non-contact presence detection devices are a mandatory supplement to force limitation on automatic systems, if non-contact presence detection is to be used without verified force limitation (eg in the swept arc and around the hinges of a hinged gate or at the supports and in the runback area of a sliding gate), it must protect the entire swept area and height of the hazardous movement zone, the single low level beams used to supplement force limitation are not sufficient. Where non-contact presence detection is relied upon, testing the effectiveness of the devices is necessary using the appropriate EN 12453 test pieces.
The need for holistic testing verification
Of course, force testing only verifies safe force, plenty more inspection and testing is a necessary to demonstrate overall safety and compliance:
To think that force testing alone will demonstrate overall safety, or that force test results are an indication of overall safety and compliance of a system, is a plainly ridiculous concept.
The overall legal requirement
To summarise, the law requires:
Residual risk assessment
Once compliance with EN 12453 is achieved or bettered, it represents the legal minimum safety for all systems, regardless of location and use. The residual risks must then be identified, risk assessed, and controlled appropriately, such that all persons and vehicles that might be affected will be adequately protected. The standard does not consider vehicle safety, the criminal law is only concerned with the safety of people, vehicle risks must be assessed at the residual stage. The residual stage is a genuine risk assessment: degree of harm x frequency of operation x likelihood of occurrence x nature of site x nature of users. At differing sites, the same design fully compliant gate will need widely differing residual hazard controls in the form of: even lower force, non-contact devices, signage, ground markings, audible or visual warnings, traffic control and calming, pedestrian controls, user instructions, and training. On differing sites, the need for residual risk controls can be anywhere from none to all of the above.
Record keeping
The responsible company must keep a documentary record to demonstrate compliance and safety, this will include all inspections and test results; inspections. Test results are not necessarily a client document, few would understand or be able to accurately apply or interpret them in relation to the specifics of a particular system. Legally, the client must receive a Declaration of Conformity for new systems, and it would be appropriate to issue a certificate of compliance for existing systems that have been made safe.
Conclusions
Whilst it is tempting to offer easily digestible snapshot guidance on what are actually quite technically and legally complex issues, doing so very often ends up oversimplifying the issue and can lead to a proliferation of false and potentially dangerous narratives.
The DHF COP, TS 013 part 1 contains the facts and is a free download to anyone who needs it. It has been written by people who sit on all the relevant European and British standards committees and contains only the facts as described by the appropriate standards, or on occasion items of additional guidance where it is deemed helpful by DHF. DHF training is comprehensive and holistic, it does not cut corners. It will not make you a good or approved installer; only many years of experience, product training, and qualification via the door, gate and barrier NVQ can prove that, but our training will equip you with the rules as they are, without shortcuts.
DHF does not create any new or additional requirements in TS 013, it simply explains the rules as they are.
10th October 2023
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