1. Regulatory framework: what RD 1215/1997 is and requires
Royal Decree 1215/1997 of 18 July transposes into Spanish law Council Directive 89/655/EEC on the minimum safety and health requirements for the use of work equipment by workers. It was substantially amended by Royal Decree 2177/2004, which incorporated Directive 2001/45/EC on work at height.
Its central purpose is clear: to ensure that any work equipment in use — regardless of its manufacture date — meets minimum safety requirements. This makes it the reference standard for every company using mechanical presses of any generation.
The rule distinguishes two types of requirement:
- General minimum requirements (Annex I): applicable to all equipment, including presses predating the mandatory CE marking of machinery.
- Additional minimum requirements (Annex II): for specific equipment, such as work at height, display-screen use or — especially relevant — mobile and load-lifting equipment.
For mechanical presses, Annex I is the main regulatory reference: a safe control system, guarding of danger zones, stopping devices, signage, structural stability, lighting and maintenance are the pillars that structure the whole compliance assessment.
2. Types of mechanical press, parts and main hazards
Before addressing the upgrade, it is essential to understand what type of press you are dealing with. Not all mechanical presses accept the same guarding systems: the clutch type decisively determines which measures are technically possible and which are not.
Fundamental parts
A mechanical press is a machine designed to transmit energy from a prime mover to a punch by mechanical means, in order to work — for example to form or shape — cold metals or materials partly composed of cold metal. Its main components are:
- Die: the assembly formed by the punch (moving part) and the die block (fixed part). It is the machine's main danger zone.
- Slide: the press's main moving element, which performs a reciprocating — usually vertical — motion and to which the punch is fitted.
- Flywheel: stores the motor's kinetic energy to transmit it to the die through a crank-and-connecting-rod mechanism, converting rotary motion into the reciprocating motion of the slide.
- Clutch: the mechanism that transmits motion from the flywheel to the slide. Its type is the decisive factor for the upgrade.
- Brake: the mechanism that, usually by friction, stops and holds the slide when the clutch is disengaged.
Part-revolution presses
In these presses the clutch is generally a friction clutch, operated by a pneumatic system. This allows the slide to be stopped at any point of the down-stroke, disengaging and braking the moving elements simultaneously. They accept most active guarding systems: two-hand controls, light curtains (ESPE/AOPD), guards with premature-opening interlocks, etc.
Full-revolution presses
These are the highest-risk type. They generally have a C-frame and a mechanical or key clutch. Once the production cycle has started, it cannot be stopped before the slide has completed a full cycle and returned to top dead centre. Once engaged, the clutch cannot be disengaged until the cycle is complete.
Main hazards
The most dangerous zone on any mechanical press is the point of operation, that is, the die area. The hazards are essentially mechanical:
- Crushing and shearing — in the die-closing area
- Cutting or severing — by the edge of the punch or the die
- Snagging, drawing-in or trapping — in transmissions, flywheel and clutch mechanisms
- Ejection of material fragments or broken punches
- Electrical, thermal and noise/vibration hazards — to a lesser degree but present
3. Presses before and after 1995: key differences
Two dates are key to classifying any press and determining the regulatory framework that applies to it. The first is 1986, when RD 1495/1986 (the Machine Safety Regulation) came into force, the first general Spanish machine-safety regulation. The second is 1995, when the Machinery Directive fully came into force in Spain along with mandatory CE marking. According to the INSST Technical Guide, equipment that complied with RD 1495/86 or bears CE marking may be presumed to meet Annex I of RD 1215/97, but the employer must carry out the relevant checks in any case.
| Parameter | Before 1986 No regulation | Between 1986 and 1995 RD 1495/86 | After 1995 CE marking |
|---|---|---|---|
| Manufacturing regulation | None at European level. Only national standards (UNE, DIN, BS…) with no harmonisation | RD 1495/86 (Machine Safety Regulation). No Machinery Directive or CE marking | Directive 89/392/EEC or 98/37/EC, later 2006/42/EC. Mandatory CE marking |
| Technical documentation | Manual non-existent or very incomplete. No accessible safety file | Basic technical documentation to RD 1495/86 may exist, but without the format or scope of the CE file | EC Declaration of Conformity, full instruction manual, manufacturer's technical file |
| Duty under RD 1215/97 | Upgrade to Annex I mandatory and complete. The employer bears the whole burden of proof | Mandatory upgrade to Annex I. A prior safety baseline is presumed, but the relevant checks must be carried out | Conformity with Annex I is presumed, but the employer must verify that the real conditions of use do not create additional risks |
| Guards and controls | Typically: full-revolution or key clutch, unguarded pedal, no control redundancy. Relay technology with no functional safety | Variable. Some mechanical guards may exist, but rarely with control systems of a defined safety category | Two-hand controls of safety category ≥ 3 (EN ISO 13849-1); redundant control systems; standardised emergency stop |
| Risk assessment | None. The employer must carry it out in full | Partial or non-existent in today's terms. The employer must complete it | The manufacturer has done its assessment. The employer must supplement it for the real conditions of use |
| Typical upgrade cost | Very high — may require a full redesign of the control and guarding system, or withdrawal from service | High — control-system redesign and retrofit of active safety devices | Moderate — verification, possible guard retrofit or sensor upgrade |
Second-hand presses
The duties of RD 1215/97 apply with equal rigour to equipment bought second-hand. A used press does not inherit any safety verification it may have had at its previous site: the change of location, conditions of use or organisational environment obliges the new employer to carry out its own risk assessment and, if appropriate, undertake the necessary upgrade measures. When a CE-marked second-hand press is acquired, it must also be verified that it has not undergone modifications that invalidate the original Declaration of Conformity.
Importing presses: a different regime by origin
The regime applicable to an imported press depends on its country of origin:
The specific problem of the full-revolution or key clutch
The oldest presses — especially full-revolution or key clutch presses — carry the most serious risk: once the cycle has started, the slide cannot be stopped mid-stroke. This makes it technically impossible to meet certain Annex I requirements without deep engineering interventions (clutch replacement, installation of coupled clutch-brake systems, camshaft overhaul). In extreme cases the upgrade is technically or economically unviable, and the correct conclusion is to withdraw the machine from service.
4. Employer duties
Article 3 of RD 1215/97 states clearly that it is the employer who bears ultimate responsibility for ensuring that work equipment meets the minimum requirements of Annex I, regardless of the machine's age and of who the manufacturer is. The duties are organised around four axes:
4.1 Prior risk assessment
Before putting any equipment into service, the employer must carry out or update the risk assessment in accordance with article 16 LPRL and the Prevention Services Regulation (RD 39/1997). Article 4 of RD 1215/97 further states that this assessment must be reviewed and repeated in the following additional cases:
- When there is any change in the conditions of use, maintenance or environment — including the climatic and organisational conditions of the workplace
- After any modification of the press, its guards or its protective devices
- After an accident or incident that may have compromised the integrity of the equipment or its guards
- After a prolonged period of non-use, since inactivity can cause deterioration of critical safety components not detected by routine maintenance
For presses, the assessment must specifically consider: mechanical hazards in the die area (trapping, crushing, cutting, snagging); hazards from defective or non-redundant control systems; hazards from power failure or accidental reset; ergonomic hazards (repetitive cycles, awkward postures); noise and vibration hazards; and hazards to maintenance staff (lockout/isolation).
4.2 Upgrade to Annex I
When the risk assessment detects deficiencies, the employer must plan and carry out the necessary upgrade measures. The rule sets no general adaptation deadline (the original deadlines have already expired), so the upgrade must be immediate or, at most, the subject of an action plan with a justified deadline documented in the prevention planning, with responsibilities and financial resources assigned.
4.3 A three-level verification and inspection system
Article 3.5 of RD 1215/97 requires the employer to keep equipment in adequate condition. For mechanical presses, the consolidated technical reference — in the INSST Guide as well as the guidance from INRS and HSE — establishes three levels of verification with distinct frequencies and responsible parties:
- Level 1 — per-shift inspection and after tooling change (designated person): the employer must formally appoint, in writing, one or more designated persons to carry out, before the press is used after any setting or die change, the inspection and functional test of all guards and protective devices. In addition, this inspection must be carried out within the first four hours of each shift. The designated person must have sufficient training, competence and authority to halt use of the press if a defect is found. The result of each inspection must be recorded by a signed certificate or tag that must remain physically on or immediately next to the press while it is in force.
- Level 2 — periodic thorough examination (competent person): carried out by a person with technical knowledge and specific experience of mechanical presses — who may be suitably authorised internal staff or an external specialist — with the following frequency: every 12 months where the press has only fixed guards, or every 6 months where it incorporates active guards, interlocking devices, light curtains or two-hand controls. This examination always includes the slide actuation and control components, verification of the stopping time and travel, the state of the clutch and brake linings, and the functional test of all safety devices. The reports of this examination must be kept for at least 2 years and be available to the Labour Inspectorate.
- Level 3 — in-depth verification (during major repairs): taking the opportunities offered by major overhauls or significant repairs, elements not visible in the ordinary periodic examination are inspected whose progressive deterioration could reduce the safety level: axial and radial play of the flywheel, state of bearings and bushings, wear of clutch and brake linings measured against the manufacturer's limit value, state of springs and seals. This verification requires partial disassembly of the machine and must be carried out by highly competent staff — a designated company technician or a specialist provider. Its results must be recorded in the machine's safety log.
4.4 Unique identification of each item of equipment and its guards
The employer must set up an identification system that assigns each press, each independent guard and each protective device a unique code, so that inspection and examination records can be unambiguously associated with the specific element they refer to. A press moved to another location or a guard transferred to another press requires a new verification and a new certificate before being put into service in its new position. A guard or protective device that has been modified or altered must be treated for all purposes as a new one, with the corresponding initial inspection.
4.5 Information and training
Articles 5 and 6 of RD 1215/97 require workers to be informed and trained on the risks, the prevention measures, the correct use of the safety devices and the emergency procedures. This duty extends to: the operators who use the press directly; the maintenance and setting staff; the supervisors and middle managers; and the workers' representatives (prevention delegates). The training must be specific to each type of press and guarding system, documented, and periodically refreshed — especially when the equipment is modified, new technologies are introduced or work procedures change.
5. Practical upgrade following the INSST guide
The National Institute for Safety and Health at Work (INSST) has published a series of reference technical documents for upgrading presses, notably NTP 552 (Mechanical presses: protective devices), NTP 681 and, above all, the Technical Guide for the assessment and prevention of risks relating to the use of work equipment (PDF — INSST), published in fulfilment of the first final provision of RD 1215/1997 itself and required reading for any technician undertaking an upgrade. The recommended methodology follows a structured five-phase process:
Phase 1 — Inventory and classification of the press fleet
The first step is to draw up a thorough inventory recording for each press: make, model, serial number, year of manufacture, tonnage, clutch type (rigid, friction, pneumatic), actuation type (pedal, two-hand control, automation), operating mode (single-stroke, automatic) and the state of the existing guards.
Phase 2 — Risk assessment by zone
Following the machine risk-assessment methodology (EN ISO 12100), each danger zone is analysed: die area, clutch actuation mechanisms, transmissions, part loading and unloading area. For each zone the probability of exposure, the severity of the potential harm and the frequency of exposure are determined.
Phase 3 — Determining protective measures
The INSST guide follows a hierarchy of measures consistent with EN ISO 12100, and must be supplemented with the specific standard UNE-EN 692:2006+A1:2009 (Machine tools. Mechanical presses. Safety), the direct technical reference for this type of equipment:
- Closed (intrinsically safe) dies: their openings and safety distances must satisfy the requirements of EN ISO 13857. Applicable to all press types.
- Fixed perimeter guards: firmly fixed to the machine, to another rigid structure or to the floor. For side and rear transmissions and the clutch-brake mechanism. Applicable to all types.
- Guards with interlocking-and-locking devices: prevent access to the danger zone during any hazardous movement, allowing it only once movement has ceased. Applicable to all press types.
- Control-linked guards with a locking device: only applicable to part-revolution presses.
- Guards with premature-opening interlocks: only applicable to part-revolution presses.
- Light curtains / ESPE (AOPD): optoelectronic devices to EN IEC 61496, installed at the minimum safety distance per EN ISO 13855. Only applicable to part-revolution presses.
- Two-hand controls: safety category per EN ISO 13849-1 (typically PLd / Cat. 3 for medium-high tonnage). Only applicable to part-revolution presses.
- Hold-to-run controls with slow closing speed (≤ 10 mm/s): only applicable to part-revolution presses.
Phase 4 — Implementation and verification
The installation of the protective measures must be carried out by qualified technical staff. After installation, the functional verification of each safety device is mandatory and must be documented. For safety-related control systems (SRP/CS), the verification must include checking the Performance Level (PL) achieved, per EN ISO 13849-2.
"Upgrading a mechanical press is not a one-off act of installing a light curtain. It is an engineering process that requires analysing the complete control and guarding system as a functional whole." INSST technical criterion — RD 1215/97 Technical Guide
Phase 5 — Compiling the upgrade file
The documentation the company must keep includes: the risk-assessment report before and after the upgrade, the technical description of the measures adopted, the drawings or diagrams of the systems installed, the certificates or data sheets of the safety devices, the record of functional verifications and the staff training record.
6. Common problems in real implementation
Upgrading old mechanical presses is one of the most complex technical-prevention processes in industry. Experience accumulated in audits and technical support reveals a recurring pattern of difficulties:
6.1 Mechanical incompatibility of the full-revolution or key clutch
Presses with a full-revolution or key clutch cannot be stopped mid-stroke. This makes it technically impossible to use light curtains or two-hand controls with a controlled stop. The solution requires replacing the clutch mechanism with a friction one with an independent brake, a high-cost intervention that can exceed the machine's residual value.
6.2 Absence of original technical documentation
Old presses often lack any technical documentation. Without electrical or mechanical drawings, reconstructing the functional scheme to design the safe control system requires reverse engineering, with the cost and risk associated with possible interpretation errors.
6.3 Incorrect installation of light curtains
This is the most frequent field error. Many light curtains are installed without correctly calculating the minimum safety distance per EN ISO 13855 (a function of the machine's stopping time and the hand's approach speed). A correctly installed but too-close curtain does not provide the protection it was designed for. The distance must be calculated empirically by measuring the slide's real stopping time.
Another equally frequent error, though less visible, is the wrong choice of type, height or resolution of the light curtain. A curtain with inappropriate muting or blanking resolution can let a hand pass without stopping the cycle. An insufficient protective-field height leaves risk areas exposed above or below the covered zone. And the choice of device type — finger curtain (14 mm resolution), hand curtain (30 mm) or body curtain (40–70 mm) — must be justified in the risk assessment.
Measuring the total response time
Measuring the press's total stopping time — essential to correctly calculate the safety distance — cannot be done reliably with a manual stopwatch or with the manufacturer's catalogue data, which do not account for accumulated mechanical degradation or the real installation conditions. ESNA has the specific measuring equipment to determine the press's total response time (control time + mechanical stopping time of the slide), in accordance with the requirements of EN ISO 13855, ensuring that the calculated safety distance is technically correct and documented.
6.4 Defeating or bypassing safety devices
Production pressure leads in some environments to operators or maintenance staff bypassing safety devices to gain cycle time. This not only removes the protection but may constitute an offence of endangering workers. The technical solution lies in category 3 or 4 control systems (with fault detection) that automatically detect the short-circuit or bypass.
6.5 Unforeseen operating modes
Many presses operate in multiple modes (single-stroke, automatic, setting) that require different levels of protection. The upgrade must cover all modes, including the setting mode — usually the most dangerous, as it requires access with the equipment moving slowly — which must have hold-to-run controls and reduced speed.
6.6 Change management for later modifications
Any modification of an upgraded press — die change, replacement of control components, expansion of the working area — can create new risks that invalidate the original upgrade. RD 1215/97 requires re-assessing the equipment after any significant change; in practice, this requirement is frequently overlooked.
7. 2027 horizon: a further reason to act
The duty to upgrade mechanical presses to RD 1215/1997 has existed for decades and is independent of any European regulatory change. However, there is a contextual element that adds practical urgency to any pending upgrades: Regulation (EU) 2023/1230, adopted on 14 June 2023, will replace the Machinery Directive 2006/42/EC and will apply directly across the EU from 14 January 2027.
This Regulation does not change the duties of RD 1215/97, but it does affect modernisation work on existing presses. Its article 18 defines the concept of substantial modification more precisely: when an intervention creates new or greater risks, the entity carrying it out assumes the manufacturer's responsibilities and must issue a new EC Declaration of Conformity, complete the technical file and meet all the Regulation's essential requirements — including the new requirements on software, artificial intelligence and cybersecurity for connected machinery.
8. Conclusions and roadmap
Upgrading mechanical presses to RD 1215/1997 remains, in 2025, an outstanding debt in many Spanish industrial plants. The original legal deadlines expired decades ago, but the Labour Inspectorate, the benefits surcharge and the civil and criminal liability in the event of an accident mean this process is neither optional nor deferrable.
Recommended roadmap
- Step 1 — Inventory and classification: Identify all the mechanical presses in the fleet, determine whether they are part- or full-revolution, their year of manufacture and documentation status
- Step 2 — Prioritisation by risk: Top priority: full-revolution presses with manual feeding and a high cycle frequency without adequate guards
- Step 3 — Technical assessment per machine: Commission a technician experienced in machine safety (UNE-EN 692, EN ISO 13849-1) to assess each press, starting with the highest-risk ones
- Step 4 — Initial diagnosis with the INSST app: Use the INSST online questionnaire for old presses as a first-diagnosis and prioritisation tool
- Step 5 — Documented action plan: Integrate the measures into the prevention planning with dates, responsibilities and budget
- Step 6 — Execution and verification: Implement the measures and functionally verify each safety device installed, documenting results and measured stopping times
- Step 7 — Training and procedures: Update safe-working procedures and deliver documented specific training to operators and maintenance staff
- Step 8 — Act before January 2027: Pending upgrades involving deep engineering interventions should be started well in advance to avoid being caught by Regulation (EU) 2023/1230