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: ISO 13849-1 is mandatory for conformity to the Machinery Directive in Europe but in the USA?
Can this mandatory standard in Europe help U.S. safety efforts? ISO 13849-1 is titled – Safety of Machinery – Safety Related Parts of Control Systems – Part 1: General Principles for Design.
What does a mandatory standard in Europe mean for domestic machine safety compliance here in the United States? ISO 13849-1 is titled – Safety of Machinery – Safety Related Parts of Control Systems – Part 1: General Principles for Design.
A few questions come to mind.
- Will OSHA ever require compliance to ISO 13849-1?
- Will a domestic standard (ANSI, NFPA, NEMA, S2, ASTM, etc.) require compliance to ISO 13849-1?
- Will an international standard ever trump a domestic standard here in the U.S.?
- Will the U.S. adopt the international hierarchy for machine safety compliance?
If anyone has some insight to these (or additional) questions please add your comments at bottom.
As I recall, when safety PLCs came to market (around 2002) U.S. manufacturers could follow the supplier’s manuals for proper application in the machine control system. And, as long as the manuals were followed, very little engineering was required to achieve safety functions. Most of the components were safety rated for Category B, 1, 2, 3, or 4, and to mitigate a Cat 3 hazard every component in that circuit needed to be rated Cat 3. At times control reliable circuits needed to be applied which required multiple components. All of this drove some level of increased safety and a byproduct – reduced unplanned machine downtime. Industry coined this approach to machine safety as “qualitative.”
Now, on stage left is ISO 13849-1. This standard uses a “quantitative” statistical analysis approach to actually engineer the safety-related parts of the control system (SRP/CS). In other words, a probabilistic determination regarding the reliability of components, devices, software, and circuitry of the SRP/CS over time. To be compliant with this standard, users need to become familiar with terms like: PL – performance level, DC – diagnostics coverage, CCF – common cause failure, MTTFd – mean time to fail dangerous, B10d – the number of cycle to which 10% of the components fail to dangerous, and many more. As with the previous paragraph it is assumed that this approach will drive some level of increased safety.
What just happened regarding the above two paragraphs? Did ISO 13849-1 subtly just pull the capability to develop compliant safety circuits from a major portion of U.S. manufacturers? How many manufacturers across the U.S. have the finances or employees capable of performing the quantitative requirements of this standard? How many U.S. machinery manufacturers (OEM) will comply with this standard for fear that OSHA will require compliance prior to a domestic shipment? Throughout my career I haven’t found one OEM who experienced an OSHA inspection where OSHA inspected the machine being manufactured.
In Europe it’s against the law to manufacture an unsafe machine.
So, will compliance to ISO 13849-1 in the U.S. be driven by the threat of liability? Or is there some other driver? How will our small end user manufacturers ever comply? Will these manufacturers consider purchasing a new machine from Europe that’s not compliant to U.S. Categories? What will European machine manufacturers do when a U.S. purchase order specifies U.S. safety standards and Category certified safety components in their SRP/CS?
Has this presented you with any new perspectives? Do you have some specific topic or interest that we could cover in future blog posts? Add your comments or thoughts to the discussion by submitting your ideas, experiences, and challenges in the comments section below.
- The Buzz About ISO 13849-1: The Good, the Bad and the Ugly (and a Possible Alternate Solution) by Mike Carlson.
- Inside Machines: Does adopting ISO 13849-1:2006 change the U.S. model for compliance and enforcement?
- Machine Safety: Domestic U.S. versus international standards
- Machine Safety – incorporating "Functional Safety as part of your machine safety plan – Part 3
Contact: http://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.