Machine Safety: Globalization of safety standards doesn’t equal global compliance
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.?
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