The arrival of the updated Machinery Directive last year has not, up to now, seemingly brought with it the reams of technical press coverage that the entrance of the original Machinery Directive did when introduced in the UK in 1993. But, according to safety specialist Laidler, this iteration marks the largest change since the directive first appeared. (<a href="http://www.machinery.co.uk/article/31461/Machinery-Directive-ISO13849-1-EN954-1-PUWER.aspx" target="new">See article here)</a>
gives the detail. The new directive, which came into force at the beginning of last year, has implications for machine tool users, suppliers and manufacturers; plus it also has implications for existing machinery and used machinery. It is clear, also, that there are outstanding unanswered issues, as expressed by Europe's machine tool builders' organisation CECIMO.
The major issue is around the replacement of one harmonised standard used in building control systems with a safety function by another. The new standard, ISO13849-1: 2006, is, actually, not new, as the date indicates, but the furore is only just starting to boil up to the public domain as the one it replaces, EN954-1, cannot legally be used as a harmonised standard to demonstrate safety beyond the end of this year. In fact, this is an extension to the original 30 November 2009 end date for its application.
Now, the replacement standard is seen as difficult to understand and, if applied as it should be, will add cost, both to new and existing/used machinery.
Why have we got to this pretty pass? Well, Pilz safety consultant Kevin Ives has written: "I am not the only person that believes the new standard [ISO13849-1] was 'eased' through the approvals process.... With what seemed like undue haste (in comparison with international standards committee history), the new standard was approved and, at the final vote, many countries abstained. Nevertheless, it was approved, despite strong objections, with the UK, USA and Japan voting against it." (See here
Of course, any legal requirement has to be enforced, but, with budgets for the overseeing organisations such as the UK's HSE being slashed, the resource to do so will be diminished. The outcome is, Machinery has been told, likely to be non-compliance, both for new and existing machinery, but it also suggested that the application of the Category 3 EN954-1 approach would still allow safety to be demonstrated, so a prosecution would be unlikely. And that's worth remembering. While harmonised standards are an accepted means of demonstrating safety compliance, it is allowable to use alternative standards, says CECIMO. However, evidence of safety will have to be well documented, if that is the case.
With all the confusion that there appears to be, expect to hear more on this matter as the end-of-year deadline for EN954-1 approaches and then passes.
First published in Machinery, March 2011