The Justification of Safety: What Goes in the Document
The Justification of Safety is the document that says a piece of equipment meets the established safety standards, and only two technical regulations require it, TR CU 010/2011 and TR CU 032/2013. It runs to five sections, it is written by the manufacturer regardless of country, and it must be in the Union's working language.
What is the Justification of Safety for?
Manufacturers of heavy machines, complex equipment and machine tools already know their equipment can be dangerous. To supply, manufacture or use that equipment in the Customs Union, it has to be accompanied by a Justification of Safety, the document confirming that its safety meets the established standards.
It is required for obtaining a conformity document, declaration or certificate, under:
- TR CU 010/2011, On the safety of machinery and equipment
- TR CU 032/2013, On the safety of equipment operating under excessive pressure
Those are the only two. It should be prepared by a specialist who analyses the potential hazards, reviews the equipment documentation, and establishes measures sufficient to prevent them.
What are the five sections of a Justification of Safety?
| Section | What it establishes |
|---|---|
| General description and technical parameters | What the equipment is, where it is used, its size, features and parts |
| General principles of safety organisation | Which requirements the design satisfies |
| Reliability requirements | That it will work correctly across the declared service life |
| Requirements for authorised staff | Who is qualified to operate it |
| Risk analysis | What can go wrong, and how likely it is |
General description and technical parameters
This section is a specification: overall information about the equipment, its branch of use, size, features and component parts. Shelf life and service life belong here too.
General principles of safety organisation
This states how safety is ensured, by meeting the requirements of TR CU 010 and TR CU 032, the manufacturer’s own safety requirements, national safety requirements, and so on. It covers the safety requirements bearing on the design, the standards applied, and the marking label.
Reliability requirements
That the device will operate properly across the service life the manufacturer declares, and how it must be maintained for that to hold.
Requirements for authorised staff
Normally that only properly qualified people may work with the machine, with the specific qualifications listed.
Risk analysis
The section that does the real work. It sets out the risks the equipment can create, vibration, dangerous parts, pressure beyond what the equipment can take, possible damage, mechanisms, and the likelihood of failure in each case.
What should you settle before you start?
One document can serve both regulations. If the equipment falls under TR CU 010 and TR CU 032, the same Justification of Safety applies to both. These two regulations are the only ones where the document is necessary, and it must come from the manufacturer for the conformity documents to be issued.
The manufacturer writes it, in the Union’s working language. That holds regardless of the manufacturer’s country. There is no route by which a document in another language is accepted and translated later.
It covers a product type, not a unit. A manufacturer importing several variants of one product, several types of valve, say, can bring them under one Justification of Safety.
Preparing it is laborious. It needs both a working knowledge of the legislation and practical certification experience, which is why it is one of the documents most often outsourced rather than produced in-house.
Sources
- TR CU 010/2011, On the safety of machinery and equipment, Eurasian Economic Commission
- TR CU 032/2013, On the safety of equipment operating under excessive pressure
- GOST 33855-2016, Safety justification. Recommendations for preparation
Frequently asked questions
Which regulations require a Justification of Safety?
Only two: TR CU 010/2011 on the safety of machinery and equipment, and TR CU 032/2013 on the safety of equipment operating under excessive pressure. No other technical regulation of the Customs Union asks for this document. Where equipment falls under both, one Justification of Safety serves both.
Who prepares it?
The manufacturer, whatever country it is in, and it must be in the Union's working language. It should be written by a specialist who can analyse the potential hazards of the equipment, review its documentation and set out sufficient measures against those hazards, the risk analysis is the section that carries the document.
Can one document cover several products?
Yes, for one type. A manufacturer importing several variants of the same product, different types of valve, for instance, can bring them under a single Justification of Safety. It is written for a product type, so genuinely different equipment needs its own document.
Not sure which of these applies to your product? Send it and we will tell you
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