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A lat­er announce­ment from the Euro­pean Com­mis­sion repealed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!