4S prepares a written, documented hazard analysis for you, as required by Austria’s Employee Protection Act (ArbeitnehmerInnenschutzgesetz, ASchG) for any machine operator (employer) who modifies a piece of equipment or combines it with another.
Under Section 35(2) ASchG (Austria):
“The use of equipment, or of its conditions of use, that has been modified to a greater extent than intended by the manufacturer or supplier, is only permitted if a hazard analysis has been carried out and the necessary measures have been taken.”
For the combined use of several pieces of equipment, Section 35(4) ASchG additionally applies:
“A combined use of equipment not intended by the manufacturers or suppliers is only permitted if 1. the compatibility of the equipment is ensured, 2. a hazard analysis has been carried out, and 3. the use is limited to the scope defined in the hazard analysis, with any additional restrictions and measures resulting from the hazard analysis implemented where necessary.”
When you become a manufacturer yourself
A modification does not always stay within the scope of a hazard analysis under the ASchG. If the machine’s output is increased or its function extended, the modification may make you the manufacturer of the machine yourself – in that case, instead of a hazard analysis, a full CE conformity assessment procedure under Machinery Directive 2006/42/EC or the Machinery Regulation (EU) 2023/1230 is required, including a risk assessment.
Process
- You send me the documents on the planned or already completed modification – initial condition, modified or combined equipment, technical data.
- Clarification of whether the case remains a hazard analysis under the ASchG or whether the modification makes you a manufacturer.
- You receive the written hazard analysis with the necessary measures – or, where applicable, the classification as a CE conformity assessment procedure.
Who this is for
For any Austrian machine operator or integrator who modifies a piece of equipment, changes its conditions of use, or combines several pieces of equipment that were not intended for this joint use.
Not sure whether your modification makes you the manufacturer of a machine, meaning you need a CE conformity assessment procedure instead of a hazard analysis? Contact 4S – I will help you clarify this in line with the law.
Are you delivering machinery into German-speaking markets (Germany, Austria, Switzerland)? 4S can also act as your German-speaking point of contact on site and support the entire project from a safety-engineering perspective. Technical documents are prepared directly in German or English; a Spanish or Swedish version is translated on request.