DTR for Machinery in Poland: What It Contains and Who Is Responsible for It

The binder with the machine’s technical and operating documentation is usually “somewhere”. The problem starts on the day of an inspection – or, worse, after an accident, when you have to prove that the machine was used in line with the manufacturer’s instructions. That is when it turns out the documentation is missing, is only in German, or relates to a different version of the equipment.

The most common reaction is: “the supplier never gave it to us”. In Poland, that sentence has no defensive value. Below we explain what the documentation should contain, who is responsible for it once the machine has been delivered, and what to do if it is missing.

What is DTR and what does it contain?

DTR (dokumentacja techniczno-ruchowa, technical and operating documentation) is the term commonly used in Poland for the set of documents supplied with a machine. EU legislation uses different wording – Directive 2006/42/EC and the Polish Regulation of the Minister of Economy of 21 October 2008 that implements it refer to instructions and a technical file. So “DTR” is a shop-floor term rather than a legal one, which can cause misunderstandings during inspections.

In practice, DTR usually includes:

• operating and maintenance instructions, including the machine’s intended use and any prohibited uses;
• the EC/EU declaration of conformity and information on the CE marking;
• technical data and electrical, pneumatic and hydraulic diagrams;
• a list of spare parts and consumables;
• an inspection schedule, the warranty card and the maintenance log.

Can DTR be in a foreign language only?

No. The instructions must be available in Polish – either as the original instructions or as a translation of the original. Documentation only in a foreign language does not meet the requirements, even if the operator “manages somehow” and the machine has been running for years without incident.

This is one of the non-compliances that a labour inspector from the National Labour Inspectorate (PIP) spots fastest: all it takes is walking up to the machine and opening the binder. No process knowledge or measurements are needed.

Who is responsible for DTR: the manufacturer or the employer?

The manufacturer or importer places the machine on the market with the CE marking, a declaration of conformity and instructions in the language of the country of use. That is where their role ends.

From delivery onwards, the burden shifts to the employer. Under Article 215 of the Polish Labour Code, the employer must ensure that machinery is safe, and under Article 237⁴ § 2 it must issue instructions for its operation. The Regulation of the Minister of Economy of 30 October 2002 on minimum requirements obliges employers to provide workers with written information and instructions on the use of machinery, and the general OSH regulations require these instructions to be permanently available at the workstation. This is part of the wider set of health and safety responsibilities of managers in Poland.

That is why “the supplier didn’t give us the DTR” is not a line of defence. Missing documentation must be obtained from the supplier or recreated – the duty to ensure safe operation rests with the employer either way.

DTR vs OSH workstation instructions – not the same thing

DTR describes the machine as the manufacturer sees it. OSH workstation instructions describe how a specific worker should operate it in your plant: with your settings, your materials and your work organisation.

Workstation instructions are based on the DTR and on the occupational risk assessment, but they do not replace it – and vice versa. Inspectors expect both documents, and confusing them is one of the most common mistakes in companies without their own OSH service.

Checklist: reviewing DTR in your plant in six steps

1. List your machines: name, serial number, year of manufacture, location, CE status.
2. Assign to each item the documents you actually have – not the ones you should have.
3. Check the language of the instructions and whether the documentation version matches the machine’s serial number.
4. Record modifications, retrofitted guards and control changes – and check whether the documentation covers them.
5. Verify availability: is a copy of the instructions at the machine, and is the original kept safe?
6. Compare the inspection dates in the DTR with the actual entries in the maintenance log.

During such a review, it is worth checking the elements that most often drift away from the documentation – for example emergency stops and guards added after years of operation.

Old machines and machines without documentation

Machines put into service before Poland joined the EU often have neither CE marking nor complete DTR. This does not mean they have to be scrapped – they are subject to the minimum requirements of the 2002 regulation.

If the documentation has been lost, the standard route is:

• asking the manufacturer for a duplicate;
• and if that is not possible – having the documentation recreated by an expert or an engineering firm, based on inspection, measurements and an assessment of compliance with the minimum requirements.

The result is a technical study with operating instructions that replaces the lost DTR. This is a standard part of machinery safety projects – especially in plants with second-hand machinery.

Modifying a machine can make you its manufacturer

Adding a feeder, replacing a controller, joining two machines into a line – changes like these can turn the employer into the manufacturer of a new machine, with the obligation to carry out a conformity assessment, prepare the documentation and affix the CE marking.

In this scenario, a company bears the full responsibility of a manufacturer, usually without realising it. That is why any significant modification should be assessed before it is made, not after the fact.

If the modification concerns a machine working in an explosion hazard zone, the stakes are even higher: the change may undermine the explosion protection assumptions made by the manufacturer.

From 20 January 2027, the rules change

Directive 2006/42/EC will then be replaced by Regulation (EU) 2023/1230, which:

• explicitly defines a “substantial modification” of a machine;
• adds requirements for cybersecurity and for machinery using artificial intelligence;
• allows instructions in digital form – provided they remain available for 10 years and the user can request a paper version.

Machines lawfully placed on the market before that date remain legal – there is no obligation to recertify them.

Machines in explosion hazard zones – DTR is not enough

If a machine operates where flammable gases, vapours or dusts may be present, the technical and operating documentation alone does not close the matter. The inspector will also ask for the documents required by explosion protection regulations:

• the Explosion Risk Assessment (OZW) – mandatory wherever flammable substances or combustible dusts are used;
• the Explosion Protection Document (DZPW) – prepared on the basis of the OZW;
• confirmation that electrical installations in Ex zones meet the requirements of EN 60079-14.

Equipment intended for Ex zones also has its own marking and its own manufacturer’s technical documentation, separate from the regular DTR. An ATEX audit of machines and installations covers conformity assessment, technical documentation and CE + Ex marking, so both sets of documents can be checked in a single visit.

What you risk without DTR

Missing instructions in Polish, no access to them at the workstation, or operating the machine contrary to the manufacturer’s recommendations are offences against employee rights. A labour inspector can issue a fine of up to PLN 5,000, and in court proceedings the fine can reach PLN 60,000. The inspector can also order the machine to be taken out of use – which is often more painful than the fine itself, as it stops production overnight.

The most serious consequences, however, come after an accident. Without DTR, it is practically impossible to show that the machine was used correctly and maintained in line with the manufacturer’s recommendations. This translates directly into the employer’s liability and the injured person’s claims.

Not sure what state your machine documentation is in?

EHS Consulting audits machines and their documentation, assesses compliance with the minimum requirements, prepares workstation instructions and occupational risk assessments, and advises on modifications and LOTO procedures. Your machinery can be reviewed on its own or as part of a wider OSH audit. Get in touch – we will start with a review of your machinery.

Legal basis: Articles 215 and 237⁴ of the Polish Labour Code; Regulation of the Minister of Economy of 30 October 2002 (Journal of Laws No. 191, item 1596); Regulation of the Minister of Economy of 21 October 2008; Directive 2006/42/EC; Regulation (EU) 2023/1230. Legal status: September 2026.