An ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis, operating efficiencies and cost savings, as well as all relevant safety standards, such as those from NFPA, ANSI, RIA, IEC, ISO and OSHA. About J.B. Titus.
Machine Safety: Globalization of safety standards doesn’t equal global compliance
October 03, 2012
We’re living in a time when countries around the world are teaming to globalize and harmonize machine safety standards. Both IEC and ISO standards are trending to global standards and slowly being adopted by various countries as requirements for conformance. This begs the question, is compliance becoming global as well?
Compliance is a whole different story as I wrote in a feature article in the June 2012 edition of Control Engineering. In my opinion, compliance and “the law” are somewhat synonymous. In Europe compliance with the listed standards also means compliance with the law since The Machinery Directive is the law and the Machinery Directive lists the standards. These standards are IEC, ISO and other domestic standards such as EN.
In the US compliance with OSHA means compliance with the law (Regulations) since OSHA is the law. However, in the US we also have domestic consensus standards (ANSI, NFPA, NEMA, UL, etc.) and industry needs to be in compliance with these standards. This need is largely driven by due diligence, best practices and liability. And, in some cases, a domestic standard like NFPA 79 is listed by a State like Kentucky and it is then treated as the law. So far there are only a few IEC or ISO international standards that are required within the US as consensus standards. Since they are consensus standards OSHA mostly does not regulate industry’s lawful compliance to IEC or ISO standards because they are not domestic. Always keep in mind that a US OEM could be held liable (but not unlawful) in the US for building a machine compliant to European safety requirements but for US customers to arguably less stringent safety standards. The following graph should help you understand the differences described thus far.
Understanding the model differences should also help you understand the question, “is compliance becoming global?” with the increasing trend for IEC & ISO standards harmonization. One simple example I’ve experienced is when a US company purchases a European machine wherein the machinery OEM certifies the machine to IEC and ISO standards. In this case, doesn’t the US company need to specify the US standards, local standards and OSHA Regulations that the machine will need to be in compliance with for its installed location?
And if not, who is responsible to bring the machine into compliance in the U.S.?
Your comments or suggestion are always welcome so please let us know your thoughts. Submit ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don't see a comments box, then scroll down: Machine Safety: Globalization of safety standards doesn’t equal global compliance.
Contact: www.jbtitus.com for “Solutions for Machine Safety”.
For more than 30 years, J.B. Titus has advised a wide range of clients on machine functional safety solutions, including Johnson + Johnson, Siemens, General Motors, Disney, Rockwell Automation, Bridgestone Firestone, and Samsung Heavy Industries. He holds a Bachelor of Business Administration degree from Oklahoma University in industrial management and an MBA from Case Western Reserve University in marketing and finance. He is a professional member of the American Society of Safety Engineers and is OSHA-certified in machine guarding. Titus is also TUV-certified as a Functional Safety Expert and serves on several American National Standards Institute, National Fire Protection Association, and National Electrical Manufacturers Association national safety and health standards committees. Reach him at jb(at)jbtitus.com and via www.jbtitus.com.
Wednesday, 17-10-12 02:35
Good morning - According the machinery directive and, I think also according the U.S. safety act a risk analysis (RA) must be done. The questionairre for this RA could be annex 1 of the machinery directive or ISO 12100. If the residual risks can not by eliminated by engineering ore guards the end-user must be informed about the residual risk by labels on the machine and safety messages in the user manuals, e.g. according ANSI Z535.6. IEC 82079-1 is defining the structure and the content of user manuals. I could not find U.S. laws which are defining that a RR must be done.