The Food Machinery Company (FMC)

The Food Machinery Company is a UK-based supplier of industrial food processing and packaging machinery, supporting sectors including meat processing, cooking, bakery, hygiene, washing and packaging. Based in Rochester - Kent. The company provides machinery supply, bespoke engineering, installation, commissioning and after-sales support for food manufacturers across the UK and Ireland.

Automatic Slicing Machine

FMC routinely manages machinery compliance activities in house. Given the level of risk and complexity of adapting this specialist Japanese slicing machine for the UK market, they engaged Neuguard to provide independent support throughout the CE/UKCA conformity process.


Neuguard’s scope included:


  • Design Risk Assessment (DRA)
  • Safety Requirements Specification (SRS)
  • Safety Related Controls Verification (SISTEMA Calculations)
  • Safety Related Controls Validation
  • Noise Testing
  • EN 60204-1 Verification Testing
  • O&M Manual Drafting
  • EHSR Assessment
  • CE Declaration
  • Engineering Drawings Review
  • Technical File Compilation


The project provided FMC with a structured route to demonstrate that the final modified machine met the applicable UK machinery safety requirements.

The Machine


The Food Machinery Company imported a high-speed boneless meat slicing machine from Japan for installation into UK food production facilities. The machine consisted of a short infeed conveyor, an internal slicing section containing circular cutting blades, and a long outfeed conveyor. Working alongside FMC, Neuguard assessed the imported machine against UK machinery safety requirements and supported the design modifications necessary for its intended use within UK food production facilities. While helping the team at FMC better understand the standards applied to such a machine.


The machine was identified as falling under the scope of the type-c designated machinery safety standard EN 16743 - Food processing machinery. Automatic industrial slicing machines. Safety and hygiene requirements


The Project


The project was treated as more than a documentation exercise. The Design Risk Assessment identified the machine as an assembly of machinery, with FMC modifying the machine before placing it on the UK market and issuing the final Declaration of Conformity once conformity had been confirmed.


The Risk Assessment


The design risk assessment reviewed the imported slicing machine across its full lifecycle, including transport, installation, normal operation, cleaning, maintenance and dismantling. The assessment identified key hazards including access to moving blades, drawing-in and entanglement risks, electrical hazards, maintenance access, guarding integrity and foreseeable misuse.


Controls were then specified using the hierarchy of risk reduction, including fixed and movable guarding, active guard-locking interlocks, zero-speed monitoring, emergency stop integration, aperture guarding, tamper-resistant fixings, residual risk information and user training requirements. The assessment provided the basis for FMC’s design modifications and the supporting CE/UKCA technical file.


Guard Modifications

The machine was fitted with active guard-locking interlocks on movable guards that allowed access into the slicing danger zone. These were specified so that access could not be gained while the machine was in automatic operation. The safety-related control system was required to detect that the machine had reached zero speed before allowing the interlocks to disengage, and once any movable guard was open, the safety circuit was required to prevent unexpected restart until all guards were closed, locked and reset.


The infeed and outfeed apertures were also reviewed and modified to ensure compliance with the dimensions provided in EN 16743, Table 2. Where required, tunnel guards were installed with a tunnel length in compliance with EN ISO 13857 to inhibit reach through into the process area (danger zone).


Additional conveyor guarding was specified to control drawing-in and entanglement hazards. Accessible gaps between fixed and moving parts of the conveyor system were required to be continuous and no greater than 5 mm in accordance with EN 619, including hazards accessible from underneath the conveyor system. 

Safety-Related Control System


FMC also introduced a safety-related control strategy for the machine. The Safety Requirement Specification defined the safety devices required for the safe operation of the machine, including three emergency stop devices, six active guard-locking interlocks with closed-position monitoring, two motor zero-speed monitoring devices, and safety logic. The machine could only start when the safety system was healthy, all emergency stops were reset, no safety fault alarms were active, and all movable guard interlocks were engaged.


Emergency Stop Circuit


The emergency stop strategy was updated so that the emergency stop function covered the entire machine, including the infeed and outfeed conveyors. The SRS also identified that an additional emergency stop device was required at the infeed conveyor to comply with EN ISO 13850, and that a reset push-button needed to be added and integrated into the safety-related control system.


Maintenance Procedures


The blade-sharpening function was specifically risk-assessed because the machine requires a semi-automatic sharpening sequence after every eight hours of use. The safety concept required the sharpening procedure to be contained within the safeguarded area and prevented from starting unless the safety-related control system confirmed that all movable guards were closed and locked. 

'We didn't just update the OEM instruction manual from Japan. We re-wrote it'

The electrical installation and hygienic / environmental suitability were also considered. The machine was intended for use in a food processing environment which may be wet due to CIP processes, and that ingress protection into the electrical parts of the machine would be provided so that the machine was suitable for use in food production environments.

Finally, the user information was re-written by our trained technical author to reflect the modified machine and its residual risks and to ensure the content requirements complied with Essential Health & Safety Requirement 1.7.4.2 of the Supply of Machinery (Safety) Regulations.


The O&M manual covered the operation and maintenance of the Automatic Slicing Machine as imported and modified by FMC for the UK market, including safety information, lockout, cleaning, adjusting, blade grinding, transporting, installing, interlocking devices, emergency stop locations and much more. 

Special Focus: Fault Masking

One of the more technical aspects of the project was the assessment of fault masking within the interlocked guard circuit.


The machine used multiple movable guards to control access into the hazardous slicing area which was required for regular cleaning. Because several interlocking devices were associated with one safeguarded area, the design had to consider whether faults in a serially connected guard circuit could be masked by the operation of other guards.


The DRA process therefore considered ISO/TR 24119, which deals with the evaluation of fault masking in serial connections of interlocking devices associated with guards with potential-free contacts.


This was important because the safety function relied on the control system being able to determine whether all guards were closed and locked before permitting hazardous machine motion. A masked fault could theoretically reduce the diagnostic effectiveness of the interlocking circuit, particularly where multiple guards are opened and closed during cleaning or maintenance. For that reason, Neuguard did not treat the interlocks as isolated components only; the guard system was assessed as a complete safety function within the wider machine control architecture.


The risk assessment considered the foreseeable tasks that would require guard access, including cleaning, maintenance and blade-related interventions. The control measure was not simply “fit interlocks”. The DRA required active guard-locking interlocks, closed-position monitoring, prevention of restart while guards were open, zero-speed confirmation before unlocking, and integration in accordance with EN ISO 14119. The required safety function was assessed to achieve the required performance level in accordance with EN 16743 and EN ISO 13849-1.


The SRS then translated that risk assessment into functional control requirements. It required the safety-related control system to be healthy before automatic operation or blade sharpening could begin, specified the interlocked guard locking and unlocking sequence, required zero-speed confirmation before guard release, and identified safety fault alarms including “Movable Guard NOT Closed”, “0-Speed Undetected” and “Safety Device Feedback Fault”.


This fault masking work was then formalised into the interlocked guard technical report. The purpose of that report was to demonstrate that the guard interlocking arrangement had been considered beyond basic device selection, including how faults could be detected, how guard access would be controlled, how hazardous motion would be prevented, and how the safety function would be validated before CE/UKCA marking.


In practical terms, this meant the project followed a traceable route from risk assessment, to safety requirements, to control design, to SISTEMA calculation, to validation, and finally into the technical file. That level of traceability is particularly important when imported machinery is modified for the UK market, because the party placing the modified machine on the market must be able to demonstrate that the final machine, not just the original imported equipment, satisfies the applicable safety requirements.