FRONT DOOR POLICY (FDP)

Many companies are regularly tasked with the purchase of machines or products for which safety is a key element. Our practical experience shows that the purchaser often relies on the information provided by the manufacturer stating that the product to be delivered is safe and that it complies with all of the safety requirements laid out in the European Directives. If we consider, for example, machines, we see that at the time of the purchase, the manufacturer promises that the machine will be delivered with the “CE” marking. However, experience has taught us that in many cases this is not true. Perhaps because the manufacturer itself is no longer entirely up-to-date with regard to the regulations in force or that not doing so allows the manufacturer to offer the machine at a greater discount. In fact, we see over and over again that many foreign manufacturers know virtually nothing about which safety regulations apply in Europe. The purchasing company is often so trustworthy that they do not even verify whether the supplier has fulfilled its obligations in the area of safety. Or, sometimes, even the purchasing company has insufficient knowledge of the applicable regulations. The result? An unsafe machine which is simply allowed to enter the company through the front door.

The Occupational Health and Safety Legislation (ARBO) states that the employer is required to provide safe working equipment to its employees.[1] This is emphasized again in the Work Equipment Directive 2009/104/EG (included in the Dutch legislation as Chapter 7 of the Dutch Working Conditions Decree). Therefore an unsafe machine or a machine that does not comply with the safety requirements yet which is still operational is automatically the responsibility of the employer. The manufacturer is responsible for the delivery of a safe machine, but the employer is responsible for the use of an unsafe machine. In addition to the obligations of the employer, the fact that the employer also has rights is often forgotten. On the basis of the European Product Directives (for machines, primarily Machinery Directive 2006/42/EG), the employer has the right to demand a safe product from the supplier. This demand is met by means of an EC Declaration of Conformity.[2].

So, in order for the employer to comply in a simple manner with his obligations, the employer must ensure that only safe machines and products enter the company. From our standpoint, this is the least expensive and simplest manner. We call this employing a Front Door Policy. As ESV Technisch Adviesbureau BV, our goal is to promote the use of this Front Door Policy. In the context of this Front Door Policy, we have developed a simple instrument which we want to make available to companies, free-of-charge. Our Purchasing and Inspection Checklist is a simple instrument that supports the making of good agreements during the purchasing phase and that supports the performance of an incoming inspection when a machine is delivered. You can request this Checklist using the link below.

In the event of any inadequacies, you can notify the supplier with the specifics. If you think that this is a step too far for you or that you lack sufficient knowledge in-house to use this Checklist responsibly, then we can guide you in the application of a Front Door Policy. If you do not wish to employ a Front Door Policy, we can also perform a CE Check Audit for you when your machine is delivered. We will then check approximately 10 aspects of the machine, and on the basis of our findings draw a conclusion about the safety of the machine. This CE Check Audit can be completed in few hours. Based on this quick check, we can then ascertain whether a safe machine has been delivered or whether a more in-depth inspection is necessary.

As part of implementing the Front Door Policy, we recommend stating in the purchasing terms and conditions that a safety technical acceptance procedure will be part of your purchasing and acceptance criteria. This then results in the final payment being directly dependent on the results of the safety technical acceptance procedure.

Jozef Visarionovitsj Stalin had a beautiful saying which indicates precisely what we are trying to make clear with our Front Door Policy. He said, ’’TRUST IS GOOD, BUT VERIFICATION IS BETTER”. [1] Work equipment can be a machine, a device, an installation and/or a tool.  Since we at ESV Technisch Adviesbureau BV are primarily focussed on machine safety, our Front Door Policy is mainly focussed on making good purchases of safe machines. [2]  The EC Declaration of Conformity is a mandatory document which must be provided upon the delivery of a product which has been made in accordance with a Product Directive.

ESV Technisch Adviesbureau
  • Mercuriusweg 30 - 3771 NC - Barneveld
  • +31 (0)342-424251
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