Safety PLC 2027 – program change, version evidence and restart test | Word/PDF/Excel

Are you going to change a safety PLC program or update the control system's safety logic? Document the difference between the old and new versions, perform a traceable risk triage, plan and conduct controlled safety tests, and make an explicit decision before the plant can be restarted. This specialist package is designed for machine manufacturers, integrators, and machine safety officers in Sweden.

Quick facts: 15 files (7 DOCX, 7 corresponding searchable PDFs, and 1 XLSX with 9 tabs), Swedish legal/technical working documentation, a Swedish guide, and a separate English user guide. The PDF versions are static and not digitally fillable. Price: SEK 79 upon publication.

When is the product useful?

Example: a change in logic for a protective door, emergency stop, safety I/O, or version change in a PLC/safety PLC system. The package is also useful when a passed FAT test must be followed by SAT, when the firmware and the program's previous baseline need to be documented, or when a rollback requires new verification.

What is included – and what is not?

Excel: nine tabs and a traceable chain of control

The tabs are Overview, Changes, Functions, Risk Triage, Testing, Versions, Actions, Decisions, and Read Me. Excel includes controlled status selections and calculations that count, for example, open risk ratings, failed tests, open actions, and items marked “Do Not Release.” The formulas have been tested with synthetic test cases, and the customer file is delivered without test data. Excel counts issues – it does not assess machine safety or approve any release.

Seven-step workflow

1. Record the machine, the program version before the change, and the current firmware.
2. Specify the changed safety behavior, dependencies, and risk analysis.
3. Assess whether the change falls under the Machinery Regulation's definition of a substantial change.
4. Establish safety functions and actual test criteria through a qualified expert.
5. Perform verification in an approved, safe test environment; document failed results without overwriting previous evidence.
6. Test requirements for version and intervention traceability, archiving, and the technical file.
7. Make a separate technical decision and then an actual operational/restart decision according to the organization's safety process.

Legal basis and dates

The Machinery Regulation (EU) 2023/1230, consolidated version shall generally apply from 20 January 2027 (Article 54). Certain provisions apply earlier. Article 52 contains transitional provisions, meaning that an existing machine does not automatically require a new CE assessment just because someone updates a program.

Article 3.16 defines a substantial change through several cumulative conditions: including a subsequent physical or digital change that was not planned by the manufacturer, a new hazard or increased risk, and specific protection requirements under points a or b. It is incorrect to call every program change substantial. Article 18 may entail manufacturer liability when a substantial change actually exists. Annex III, sections 1.1.9 and 1.2.1 cover, among other things, safety-critical software, control systems, and the recording of changes/updated program versions. Annex IV applies to technical documentation.

A specific provision in Annex III, section 1.2.1 f, concerns an intervention log and uploaded versions of safety software for five years after upload for the specified control purpose. This is not a general rule that personal data or secret source code must be archived for five years in an Excel file. Check applicability, confidentiality, data protection, and secure storage separately.

See also Swedish Work Environment Authority's information on the new Machinery Regulation. Potentially relevant standards, such as ISO 12100, ISO 13849-1, and IEC 62061, require separate competent application; the template package contains no PL/SIL calculation.

Difference from other machine templates

This package focuses on specific program versions, safety function tests, and release/rollback evidence. For a more comprehensive legal assessment of whether a change is substantial, Substantial Machine Change 2027 is also available. For general EU product documentation, see EU Machinery Regulation 2027 – Risk Assessment and Technical File, and for more general acceptance testing, FAT/SAT Test Protocol. The products serve different purposes.

Frequently asked questions

Does a program change automatically make the machine a new CE product?

No. Make a concrete legal and technical assessment according to the applicable regulation and the machine's history. Article 3.16 requires more than the software being changed.

Can we release the machine if Excel shows zero failed tests?

No. Zero may mean that no test was recorded. The responsible party must ensure an applicable risk assessment, complete verifications, and separate operational approval.

Does it include a ready-made PLC program or a PL/SIL calculation?

No. The product contains administrative templates and verification documentation, not programmable safety logic, established machine parameters, or certification.

Are the PDF files digitally fillable?

No. The PDFs are searchable and printable reference versions. Use DOCX and XLSX for editing.

Are the working templates available in English?

No. The five working templates and Excel are in Swedish. An English guide is included to assist with the Swedish documents.

Can we put all PLC source code in Excel?

This is not recommended. Instead, record secure internal version IDs, hash values, and approved archive references. Limit access to protected documentation and source code.

Version, delivery, and review level

Version 1.0 – November 12, 2026. The legal sources have been checked with AI assistance against the consolidated EU regulation and the Swedish Work Environment Authority's information. No independent external legal review, technical functional testing on a real plant, CE assessment, or regulatory certification has been performed. Finalize and review the documents with someone who has expertise in the current machine and function. The digital customer ZIP file should be linked to the download function only when the product is ready for publication. The package is not automatically delivered to buyers at this stage because the product draft is not published.