EN 954 – 1 /​ ISO 13849 – 1:2006 Mandatory Implementation Date Change

The EC Machinery Working Group announces the exten­sion of the man­dat­ory imple­ment­a­tion date for EN ISO 13849 – 1:2008.

Regular read­ers will be aware of the con­tro­versy that has sur­roun­ded the man­dat­ory imple­ment­a­tion of EN ISO 13849 – 1:2006, ori­gin­ally sched­uled for 28-​Dec-​09. The EC Machinery Working Group met this week to review the opin­ions of European machinery experts. Following the meet­ing, it was announced that the man­dat­ory imple­ment­a­tion date will be exten­ded by some time, how­ever no date was giv­en.

Some spec­u­la­tion exists about the length of the exten­sion, with some sources say­ing that it could be as little as 12 months to as long as five years. Until the EC revises the dates and pub­lishes them in the Official Journal we won’t have the ‘final word’, how­ever we are hop­ing that an announce­ment will be made to cla­ri­fy the decision and the date.

If you are a machine build­er who has already imple­men­ted EN ISO 13849 – 1:2006 and the val­id­a­tion stand­ard EN ISO 13849 – 2:2006, you are ahead of the game. Your efforts have not been wasted, as your sys­tems already con­form to the require­ments that will even­tu­ally be man­dat­ory for all machine build­ers. For those machine build­ers who have yet to imple­ment these stand­ards, you’ve gained a bit of a reprieve, but you will still be required to imple­ment these stand­ards even­tu­ally. If you have yet to begin imple­ment­a­tion, now is the time.

I will post the new man­dat­ory imple­ment­a­tion dates as soon as this inform­a­tion is avail­able.

More flip-​flopping on EN 954 – 1?

In recent posts I’ve been dis­cuss­ing the changes in the use of EN 954 – 1, Safety of Machinery – Safety Related Parts of Control Systems. Part 1: General Principles for Design. The EU ori­gin­ally announced that this stand­ard was to be with­drawn on 31-​Dec-​09, being replaced by EN ISO 13849 – 1. As you may know, there are sig­ni­fic­ant dif­fer­ences in these two stand­ards.

A later announce­ment from the European Commission repealed

In recent posts I’ve been dis­cuss­ing the changes in the use of EN 954 – 1, Safety of Machinery – Safety Related Parts of Control Systems. Part 1: General Principles for Design. The EU ori­gin­ally announced that this stand­ard was to be with­drawn on 31-​Dec-​09, being replaced by EN ISO 13849 – 1. As you may know, there are sig­ni­fic­ant dif­fer­ences in these two stand­ards.

A later announce­ment from the European Commission repealed the with­draw­al of EN 954 – 1, extend­ing its use until 31-​Dec-​12. This announce­ment was itself with­drawn.

So where do we stand today? Currently, EN 954 – 1 will be with­drawn on 31-​Dec-​09 and will be replaced by EN ISO 13849 – 1, UNLESS this decision is again reversed by the EC in con­sulta­tion with the EC Machinery Working Group. A meet­ing is planned for 7/​8-​Dec-​09 to dis­cuss this situ­ation and to resolve the con­fu­sion.

As a machine build­er, there is only one prudent course of action – imple­ment EN ISO 13849 – 1 in your designs. If the decision remains as it cur­rently stands, then your products will con­form to the require­ments on 31-​Dec-​09 and you will be able to con­tin­ue to ship product to the EU. If the decision is reversed by the EC and EN 954 – 1 remains in use until 2012, then you are three years ahead of the require­ment and should be using that to full advant­age in your mar­ket­ing and sales efforts.

My friend Jon Severn has a post related to this on his blog at MachineBuilding​.net.

EU changes direction on EN ISO 13849 – 1

Update on EN ISO 13849 – 1 man­dat­ory imple­ment­a­tion date.

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 29th 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 (3rd Sept) by a CEN employ­ee. However, the EU Commission nev­er con­firmed the report, and on September 24th 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 3rd 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 – 8th 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!