A safety justification is a document that contains the risk assessment, information on the minimum required safety measures from the design and operating documents, and technical documentation. The document accompanies the machine in all phases of its life cycle. The safety justification must be constantly updated and extended with the results of the risk assessment during operation and after repairs. The safety justification is intended to ensure the safety of employees and protect them from accidents and damage of their health or the environment.

The important requirements for the preparation of a safety justification are contained in the Technical Regulations TR CU 010/2010 On safety of machinery and equipment and TR CU 032/2013 On safety of pressure equipment.

The content and structure of the safety justification is provided by GOST-R standard 54122-2010 "Safety of machinery and equipment. Requirements for the safety consideration" and GOST 33855-2016 "Safety justification. Recommendations for preparation". The GOST-R standard 54122-2010 was developed according to the Machinery Directive 2006/42/EC and Annex VII of the "Technical documentation for machines".

The GOST-R norm 54122-2010 knows two forms of safety justification - full and shortened. The shortened form is declarative and requires no proof. It is used to prove the conformity of the machine with the technical regulations. The full form requires tests and evidence. It contains all measurement and test results and a written safety concept.

Purpose of a safety justification

The safety justification is an important part of the documentation required for EAC Certificate or EAC Declaration of the Eurasian Economic Union in accordance with the Technical Regulations TR CU 010/2010 On safety of machinery and equipment and TR CU 032/2013 On safety of pressure equipment.

Issue of a safety justification

A safety justification shall be issued during the project planning phase. A safety consideration can be issued for multiple models, types or series. The safety justification must reflect the actual condition of the machine or equipment, therefore the additions are required after commissioning, modernization or repair.

The original of the safety justification remains with the planning office or manufacturer and a copy is made for the operator or the manufacturer. The technical regulation TR CU 010/2010 On safety of machinery and equipment sets, that the declaration and all related documents, including the safety justification, must be kept 10 years after the expiration of the EAC Declaration.

Content of a safety justification

A safety justification shall be issued on the basis of technical documentation from the manufacturer, which is listed in the Machinery Directive 2006/42/EC in Annex VII "Technical documentation for machinery".

The safety justification consists of an introduction and 11 sections

Section 1 Basic parameters and properties of the machine
Section 2 General safety concept for the construction of the machine
Section 3 Requirements for the reliability of the machine
Section 4 Requirements for personnel
Section 5 Risk assessment
Section 6 Safety requirements while commissioning the machine
Section 7 Requirements for safety management during operation of the machine
Section 8 Quality management requirements for the operation of the machine
Section 9 Requirements for environmental management during commissioning, operation of the machine and disposal of the machine
Section 10 Requirements for information gathering and analysis on safety during commissioning, operation and disposal of the machine
Section 11 Safety requirements for disposal of the machine

In order to create a safety justification we require the following documents:

  • instruction manual made according to GOST R standard 2.610-2006 in Russian
  • certificates on components
  • technical passport
  • full detail drawings with calculations, test results necessarily to verify compliance of the machine with the essential safety requirements
  • plan of commissioning
  • instructions for repair, operation and maintenance
  • general requirements for the staff: its duties, rights and responsibilities
  • security measures in the event of an accident and assistance for the injured
  • information about quality management
  • methods for disposal, recovery, storage or further processing of hazardous substances, if they are present in the machine or equipment

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Our experienced experts develop high-quality technical documentation for the conformity assessment: EAC Certificate, EAC Declaration, state registration, fire safety certification, etc. If necessary, we can translate your documents into Russian.

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Costs for the preparation of the safety justification

The cost for preparation of the safety justification depends on various factors. We always find an individual concept and offer a variety of payment options to meet the needs of our customers.

If you have any questions regarding the creation of the safety justification, please contact us, we will gladly consult you about the offer. 

In our video, we explain what an EAC Certification is and how and where to certify or declare your products for the introduction on the EAEU market.

The EAC Certification and the EAC Declaration are complex procedures that attest your products the conformity with the technical regulations of the EAEU and require a lot of know-how. Schmidt & Schmidt will support you with the certification of your products for the EAEU market.


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