Machinery Safety 101

In a post on 15-​​Sep I reported that the European Union had decided to delay the manda­tory imple­men­ta­tion date of  EN ISO 13849–1 for an addi­tional three years. This report was based on infor­ma­tion obtained from an inter­nal source at the European Commission and has since been reversed by that same source.

Mr. Glyn Garside pro­vided the fol­low­ing update to this impor­tant story:

It has been widely reported, but never con­firmed, that the EU com­mis­sion had accepted the CEN pro­posal to extend the date of ces­sa­tion of pre­sump­tion of con­for­mity of EN 954–1:1996 until the end of 2012. THESE REPORTS HAVE NOW BEEN AUTHORITATIVELY DENIED.

(By the way, this dis­cus­sion of dates of ces­sa­tion of pre­sump­tion of con­for­mity only affects the European stan­dards, EN 954–1 and EN ISO 13849–1. International stan­dard ISO 13849–1 is obvi­ously con­trolled by ISO and not by CEN or the EU. The cur­rent edi­tion of ISO 13849–1 is 2006, essen­tially iden­ti­cal to EN ISO 13849–1 : 2008.)

At this point the pos­si­bil­ity of an exten­sion of the tran­si­tion from EN 954–1 to EN ISO 13849–1 remains con­tro­ver­sial, con­fused and IMHO uncer­tain. (There’s been approx 3 years tran­si­tion period already.) If I were still a man­u­fac­turer, I would not want to wait until Dec 29^th to find out if I could still ship my prod­uct using EN 954–1!

The reports of an exten­sion were based on an email sent ear­lier this month (3^rd Sept) by a CEN employee. However, the EU Commission never con­firmed the report, and on September 24^th the same CEN employee, Marie Poidevin, has writ­ten,
—————–
> “We have been informed today by the European Commission […] that con­trary to what was expressed in
> my pre­vi­ous mes­sage sent on the 3^rd of September, EN 954–1 will not give pre­sump­tion of con­for­mity
>  to the new MD 2006/​42/​EC until fur­ther notice.
> “Indeed, due to dis­cus­sions fol­low­ing the announce­ment made below, the EC wishes to gather experts’
> views and, there­fore, this issue will be dis­cussed at the next Machinery Working group to be held on
> the 7-​​8^th December.“
—————–

A related email from Ian Fraser (“EC Policy Director for the Machinery Directive”), dated 2009-​​09-​​18 states,
—————–
“Following the dis­cus­sion at the meet­ing of the Machinery Working Group held on 7 and 8
July 2009, we have received a num­ber of ques­tions con­cern­ing the tran­si­tion from stan­dard
EN 954–1 to stan­dard EN ISO 13849–1 on safety–related parts of con­trol sys­tems.
At the meet­ing of the Machinery Working Group, there was gen­eral agree­ment on two
aspects:
1. Manufacturers who apply stan­dard EN ISO 13849–1 ben­e­fit from a pre­sump­tion of
con­for­mity, even if the har­monised C-​​type stan­dard relat­ing to the machin­ery con­cerned still
refers to the cat­e­gories of EN 954–1;
2. Harmonised C-​​type stan­dards that refer to the cat­e­gories of EN 954–1 con­tinue to con­fer a
pre­sump­tion of con­for­mity until they are amended to refer to stan­dard EN ISO 13849–1.
These con­clu­sions will be recorded in the min­utes of the meeting.

During the dis­cus­sion, sev­eral par­tic­i­pants indi­cated that more time was needed for the
indus­try, and in par­tic­u­lar for SMEs, to adapt to the new stan­dard. As Chairman of the
meet­ing, I asked whether it might not be prefer­able to post­pone the date of ces­sa­tion of
pre­sump­tion of con­for­mity for EN 954–1.
In response to this sug­ges­tion, on 30 July 2009, Mr. Steiger wrote to the Commission, on
behalf of the CEN Machinery Sector, to request that the date of ces­sa­tion of pre­sump­tion of
con­for­mity for EN 954–1 be excep­tion­ally post­poned until 31 December 2012 […].
The Commission will reply to this request from CEN. However, given the com­plex­ity of the
issues involved, the Commission intends to con­sult experts and to seek the opin­ion of the
Machinery Working Group to be held on 7 and 8 December 2009, before reach­ing a final
deci­sion.
Kind regards,
Ian FRASER“
—————

Thanks again to Glyn Garside and the EMC-​​PSTC List Server!

+DougNix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. (http://​www​.com​pli​an​cein​sight​.ca) in Kitchener, Ontario, and is Lead Author and Managing Editor of the Machinery Safety 101 blog.

Doug’s work includes teach­ing machin­ery risk assess­ment tech­niques pri­vately and through Conestoga College Institute of Technology and Advanced Learning in Kitchener, Ontario, as well as pro­vid­ing tech­ni­cal ser­vices and train­ing pro­grams to clients related to risk assess­ment, indus­trial machin­ery safety, safety-​​related con­trol sys­tem inte­gra­tion and reli­a­bil­ity, laser safety and reg­u­la­tory conformity.

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