This morning the European Commission confirmed the statement made by Marie Poidevin of CEN last week by publishing s revised list of standards (2009/C 321/09) including EN 954–1:1996, EN ISO 13849–1:2006 and EN ISO 13849–1:2008, noting “The date of cessation of presumption of conformity of the superseded standard, initially fixed on 28.12.2009, has been postponed for two years.”
Machine builders who have been putting off implementation of this standard in their designs have now gained another two years to educate themselves and to update their design processes to include the additional analysis required.
Coming on the mandatory implementation date of the latest revision of the Machinery Directive, which now explicitly requires risk assessment to be completed as part of the design process, and new rules that will bring in products that were incorrectly being marked exclusively under the Low Voltage Directive, the next two years will be busy ones for those companies who have not been paying much attention to the changes in this important directive.
Companies who are well prepared and were ready for the original date are ahead of the market and should take this opportunity to take some gains over theor competitors by advertising their ability to produce compliant machinery.
Today’s edition of the OJ also brought in a couple of standards previously notified under the old Machinery Directive, but there are many others that remain to be notified. Most of these are pending updates to bring them into conformity with the revised Essential Requirements, while some may be replaced by new ISO adoptions of their content with new material added.
On the EMC-PSTC email forum, a couple of questions were posed that will likely be on the minds of many readers. For those who don’t know, Type C standards are “product family” standards that cover a specific type of machinery, like lifts, or power presses. :
What if a Type C standard references only EN ISO 13849–1?
I’d like to address these questions in this post, so here goes…
If you are declaring conformity to a Type C standard, and that standard calls out EN ISO 13849–1 for control reliability, then in my opinion you should be using that standard UNLESS there is some overriding reason that prevents you from using it. “We didn’t feel like it” or “It’s too hard” don’t count. If you’re in a position where you must continue to use EN 954–1, then rationale must be written for the technical file that clearly describes the reasons preventing the implementation of the new standard, and furthermore, what has been done to provide an equivalent level of safety and reliability as would be gained by using the new standard.
If your machine is in the scope of a specific harmonized standard, then it should be declared using that standard and not the generics. This is discussed in the guidance documents for the directive. The generic standards are there to be used for products that are not within the scope of existing harmonized standards, and for the guidance of Technical Committees writing Type C standards. The Type C standard will give the user a specific list of common hazards found on the type of machinery covered by the standard, and will provide specific control measures that are expected to be used to control the risks associated with those hazards. If there are hazards that are not covered by the standard, then generic standards may be used to deal with the risks related to that unique hazard.
Need more information? Feel free to contact me offline to discuss your application!
+DougNix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. (http://www.complianceinsight.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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