4S assesses for you whether a planned or already completed modification of your machine requires a hazard analysis under the ASchG – or whether it makes you the manufacturer of the machine yourself, thereby triggering a complete CE conformity assessment procedure under the Machinery Directive 2006/42/EC or, from 20 January 2027, the Machinery Regulation (EU) 2023/1230.
When a modification makes you the manufacturer
If the modification increases the machine’s performance, extends its function, and thereby creates new hazards or increases existing ones, the party carrying out the modification may become the manufacturer of the machine. In this case – regardless of the machine’s age – a complete CE conformity assessment procedure is required, including a risk assessment, instructions for use, and a declaration of conformity. If the modification stays within the original manufacturer’s intended purpose and limits, a hazard analysis under Section 35 of Austria’s Employee Protection Act (ArbeitnehmerInnenschutzgesetz, ASchG) is generally sufficient.
Process
- You send me the documents for the planned or already completed modification – the machine’s original condition, planned or implemented changes, and technical data.
- Assessment of whether the modification stays within the machine’s original intended purpose and performance limits, or makes you the manufacturer.
- You receive the written conversion assessment with a clear classification – hazard analysis under the ASchG or a CE conformity assessment procedure – including the respective next steps.
- On request, 4S takes over the further services (hazard analysis, risk assessment, documentation, validation) directly afterwards.
Who this is for
For machine operators, control cabinet builders and integrators who want to modify, extend, or combine an existing machine with another, and who need legal certainty about the resulting obligations.
Also useful
For existing machinery in ongoing operation, as well as for inspection obligations independent of any modification, see also Hazard Analysis under the ASchG and the Workshop on Operation and Modification of Machinery.
For a broader overview of the topic, see our machinery safety workshops.
Not sure whether your planned or already completed modification makes you the manufacturer of a machine? Contact 4S – I will help you classify your modification with legal certainty.