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.
Machinery Directive In 4 Days Drops EN 954 and EN ISO 13849-1 Is Fully In Force: What’s Your Impact?
December 27, 2011
In Europe on Jan. 1, 2012 the qualitative process (EN 954) of machine safety hazard identification (B, 1, 2, 3, and 4) and mitigation disappears and the quantitative process (EN ISO 13849-1) is fully in force with its compliance requirements of Performance Level (a, b, c, d, and e). The Category system is officially put to rest and hence forth all safety circuit (electrical, hydraulic, or pneumatic) must follow these new prescriptive requirements. But, here in the United States how does this change affect your business?
Bloggers have had a field day for the past two years posting numerous blogs on the second and final postponement of de-activating EN 954 via the Machinery Directive. Multiple articles have been written by industry experts. Automation suppliers have developed; posters, presentations, forums, books, web based training, and videos. This blog site has had no shortage of provocative attention to this subject either. European industry can no longer avoid the transition for machine safety compliance.
Original Equipment Manufacturers (OEM’s) and integrators engineer safety circuits every day as a normal course of their business. So, to build a machine or safety control system compliant to the Machinery Directive and EN ISO 13849-1 should be a manageable transition. Particularly since the first step of legal compliance in Europe is directed at the OEM and integrator firm. In the United States OSHA is the law and the first step of legal compliance is directed at the end user.
As a core business practice, do end users in the US engineer safety circuits every day?
In my opinion, the answer to this question is emphatically – NO! So, how will this influence emerging from Europe affect your business in the U.S.? The answer to this question varies dramatically because……..it depends.
First, a little history as I understand it. EN stands for European Norm and U.S. standards have historically not referenced EN standards normatively. IEC and ISO standards are international in scope and the US has representatives participating on these standards committees. IEC and ISO standards are working their way into domestic standards and EN ISO 13849-1 is finding its way into our U.S. standards. Therefore, the qualitative process from EN 954 (extracted, modified, and adopted) in US standards has started to be updated and modified to the quantitative requirements of EN ISO 13849-1. One of the issues U.S. standards writers are grappling with is how to require US end users (large and small) to comply with these safety circuit design requirements.
So, “it depends” really boils down to timing in my opinion. I believe many U.S. standards will have addressed the compliance requirements of EN ISO 13849-1 within three to five years based on their regular update cycles. Today and during this time frame you might address these requirements differently based on whether your business is domestically focused versus internationally focused. Or, whether your standards have completed their update cycle recently? My suggestion is to always check for the latest issue of your standards. Several tools are available from automation suppliers (listed below) and they’ll help you in your transition to the new requirements.
Your comments or suggestion are always welcome so please let us know your thoughts. Submit your 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: Machinery Directive In 4 Days Drops EN 954 and EN ISO 13849-1 Is Fully In Force – What’s Your Impact?
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.