The Brexit Vote and CE Marking: What’s it going to mean for Canadian Exporters?

Shocked and Amazed by Brexit

UK and EU Flags against a blue sky during the Brexit VoteThis morning I am shocked and amazed to learn that one of the founders of the European Union has chosen to leave that Union. Joining the EEC in 1973, the UK and other European countries moved toward the formation of the EU, first as an economic treaty, and eventually as a political union. Today, the separation begins.

What now?

Starting today, the UK will need to determine how best to get its house in order before triggering Article 50 of the Lisbon Treaty. This is expected to take at least a couple of years. In that time, there is a possibility that Scotland may hold another exit referendum from the UK, and may then choose to apply to join the EU. This may also happen in Ireland, further diminishing the size of the UK. We will have to wait and see what these countries will choose to do in coming months.

What effect does this have on Canadian and US Exporters?

If you export to the EU and you have European branch offices in the UK and other European countries, the exit of the UK from the EU will have little effect, other than on the question of language. Unless Scotland or Ireland choose to leave the UK and join the EU, AND they choose to include English as one of their official languages, it’s possible that English may no longer be an official language of the European Union. This could mean that instructions, manuals, operator screens, hazard warnings and other text-based information on your products that are provided primarily in English may no longer be permitted.

If you are using the services of a company that provides services to “compile the technical file” for your product, and that company is located in the UK, you will have to find another company to provide these services. This would also be true for companies using services of company acting as Authorized Representatives. Again, I recommend taking a deep breath and waiting to see what Scotland and Ireland will do.

If a change in Authorized Representative, or person “authorised to compile” is required, this will also impact the information on the nameplates on your products since the Authorized Representative’s or person-authorised-to-compile’s name and contact coordinates must be on the nameplate along with the manufacturer’s information. This same change will also be required on the product Declaration of Conformity or Incorporation.

What now?

Young Woman Meditating on the grassTake a deep breath. Wait.

We need to give the UK and the EU some time to determine how they are going to organise their divorce. This is a world changing decision, and the changes will not be done without due care and attention. In the mean time, we must watch and wait. Here at Compliance inSight Consulting and the Machinery Safety 101 blog, we will be watching and talking to our colleagues in Europe, and we will keep you up to date as we know more.

Now, with me… breathe deeply…

New Directions in Plastics Machinery

Canada’s Participation in ISO TC 270

SCC Standards Council of Canada LogoIn February of 2016, Canada formed the SCC Mirror Committee (SMC) to ISO TC 270, Rubber and Plastics Machinery. This international technical committee is currently developing ISO 20430, the first international plastic injection moulding machine standard. Until the publication of ISO 20430, two standards have been fighting for dominance: EN 201, Plastics and rubber machines — Injection moulding machines — Safety requirements, and ANSI B151.1, American National Standard for Plastics Machinery – Horizontal Injection Moulding Machines – Safety Requirements for manufacture, Care and Use.

Canada has a strong plastic and rubber industry, with key equipment manufacturers like Athena Automation, Husky Injection Molding Systems, Mold Masters and GN Plastics among others producing world class machinery for the industry. The industry is represented nationally by the Canadian Plastics Industry Association. Despite this, Canada has never had its own standard for this type of machinery.

Involvement in ISO TC 270 allows Canada’s plastics industry to have a voice in developing the international standards for the machinery they design and build, and which ever more commonly, they buy and use.

The committee needs your help to know which way Canadian industry wants us to focus our efforts as the work on ISO 20430 wraps up in coming months. We have a short survey, just three questions long, where you can rank five possible topics we can focus on. We will be submitting our committee vote in early August on the topic, so you have a month or so to answer the questionnaire. Let us know your preferences.

Why now?

ISO LogoUntil the publication of ISO 20430, two standards have been fighting for dominance: EN 201 in Europe, and ANSI B151.1 in North America. Until the relatively recent formation of ISO TC 270 in 2012, there were NO international standards for this type of machinery. While there have been some efforts to harmonise the European and ANSI standards, there are still some significant gaps between these standards. In addition, ANSI’s B151 committee has a number of additional standards for auxiliary equipment for items like robots designed to unload molds, that are not directly addressed in EN standards.

Canada was given a chance to participate through our ongoing friendship with ANSI and the USA, so between 2012 and 2015, Canadian delegates attended ISO TC 270 working group meetings informally, and put Canada’s perspective forward through the US ANSI TAG committee, but in 2016 it became clear that we needed to form our own committee. If you are involved in the industry and you are a member of one of these general groups and would like to get involved with standards development, please go to our recruiting page and join us!

Committee Membership Matrix

Matrix Category Min Max Current
Total  15  25  6
Producer Interest (PI) 3 5 3
User Interest, Management (UM) 3 5 1
User Interest, Labour (UL) 3 5 0
Regulatory Authority (RA) 3 5 1
General Interest (GI) 3 5 1

As you can see from the table, we need members in every group except the producers to meet our intended balance.

Definitions of the Categories

Producer Interest (PI) — Machine builders, Auxiliary Equipment Manufacturers, Consultants, and Engineering Companies providing for-profit services related to plastics and rubber machinery.

User Interest, Labour (UL) — Canadian labour unions, labour organizations, and individual workers located at Canadian workplaces.

User Interest, Management (UM) — Trade associations, companies, contractors, and organizations representing companies engaged in work performed in Canada.

Regulatory Authorities (RA) — OHS provincial and federal regulatory bodies (labour and electrical).

General Interest (GI) — Safety associations, research organizations, institutions, and non-commercial consultants who have expertise in the subject area.

We need your help!

CAC ISO TC 270 needs your help!

Can you volunteer some time? Sign up!

Can you help direct us? Answer our questionnaire!

Need more information? Contact Doug Nix!

Workplace Risk Assessment – CSA Z1002: Love it, Hate it, Tweak it

CSA Z1002 CoverThe CSA Z1002 TC Needs to Know: Love it, Hate it, Tweak it?

We need to know: Do you Love CSA Z1002? Hate CSA Z1002? Does it need some tweaking? We have a survey so you can let us know!

The First of Its Kind

In 2012, CSA published the first OHS Risk Assessment Standard of its kind: CSA Z1002, Occupational health and safety — Hazard identification and elimination and risk assessment and control. This standard has been in use in Canadian workplaces for four years now, and the Technical Committee is considering the need for updates and improvements to this important standard.

Key to the Z1000 Family

Z1002 is a key member of the Z1000 OHS Management System family of standards because it provides a central tool used in all of the other standards: Risk Assessment. Because it holds this central role, it’s important that it work smoothly and effectively, providing the kind of information that all of the other standards need to do their parts in reducing workplace risk.

The origins of Z1002 come from the machinery safety world where risk assessment is well developed, but the methods presented were broadened to allow their use in many other areas. Were they broadened enough? Could they be improved? These are important questions!

Influencing Other Standards

Shop Floor Hazard Identification
Shop Floor Inspection

The Significance of Z1002 in the Z1000 family has given it additional influence in other CSA OHS standards, including CSA Z432 Safeguarding of Machinery, CSA W117.2 Safety in Welding, Cutting, and Allied Processes, and even in CSA Z614 Children’s Playspaces and Equipment! This kind of influence puts even greater pressure on the standard, and the Technical Committee, to provide the kind of solid, reliable guidance needed.

The Second Edition

In order for the Technical Committee to move on to revising the standard and producing a Second Edition, we need input from the user community. We have heard a bit from some users, but we really want to hear from YOU. CSA has created a very brief survey that you can take to let the TC know how you are using the standard, if it’s doing the job for you, and what you think needs trashing, polishing, or tweaking. We REALLY want to hear from you, so please, take a few minutes and answer the survey! You’ll feel all warm and fuzzy because you did, and we’ll get some good ideas about what to do with the future edition of Z1002! Sound like a good deal? I thought so!

Got questions about this? You can always contact me: dnix@complianceinsight.ca.