31st FVI Expert Breakfast

Topic: "The Retrofit Trap" – When does a repair become a "significant change" (and thus a CE nightmare)?

In this session, Markus Scholle (safety expert) clarified when a retrofit is legal and when one becomes a "manufacturer."

• The fear of the CE mark: Many maintenance workers are afraid to modernize old machines because they fear they will have to undergo a new CE process (which is expensive and time-consuming).
• The "Significant Change": Markus explained the rule of thumb: If I create a new hazard (e.g., machine runs faster) or increase the risk, and the existing safety measures are no longer sufficient, then it is a significant change. However, if I only improve safety (e.g., replace old contactors with safe controls), it's usually not a problem.
• Software updates as a risk: New in the Machinery Directive: Even a software update can be a significant change if it alters the functions of the machine (e.g., AI control that drives faster).
• 3D printing of spare parts: Patrick (participant) asked: "Can I 3D print a discontinued plastic part?" Answer: As long as it's not a safety component and doesn't change the function, yes. But be careful with parts that bear loads.
• Documentation saves lives (and jobs): Sascha (participant) reported that he does retrofits with apprentices. Important: Document everything. The BGRCI offers interactive PDFs that guide you through risk assessment. Those who document why they modified something ("safety improvement") are usually on the safe side legally.

Classification: Compliance through data

This episode shows that modifications in the brownfield (existing facilities) are unavoidable. ADAM helps to remain legally compliant.

• ADAM as a "life record file": When I modify a machine, I need to know: What was the original state? What did I change? ADAM records every change (like a logbook). When the BG comes, I can prove: "Here is the protocol, we only changed the control, not the mechanics."
• Linking with regulations: Markus mentioned the BGRCI guidelines. ADAM can store these documents directly on the asset. Before the technician starts the modification, they must complete the "Significant Change" checklist in ADAM. This enforces compliance.
• Light risk assessment: For small changes (e.g., sensor replacement), ADAM can offer a guided process: "Does the speed change? No. Does the force change? No. -> Okay, no CE needed." This gives the maintenance worker confidence.

Conclusion: We must modernize old machines (retrofit) to remain competitive. The fear of bureaucracy must not paralyze us. With the right knowledge and documentation (ADAM), it is feasible.