Machinery Safety 101

EN ISO 13849 – 1 Mandatory Implementation Date CONFIRMED!

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? 

Would it be OK to claim pre­sump­tion of con­form­ity using such a har­mon­ized type C stand­ard yet only using EN 954 – 1 for the con­trol circuits?

If your machine is in the scope of a spe­cif­ic har­mon­ized stand­ard, do you have to use it, rather than generics?

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!

5 thoughts on “EN ISO 13849 – 1 Mandatory Implementation Date CONFIRMED!

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