Machine Safety: what is the value of ISO 13849-1 for U.S. domestic compliance?
ISO 13849 clearly states that it is a standard for designers. If these designers work for U.S. original equipment manufacturers (OEMs), does the OEM have an enforceable legal requirement for compliance? Under the European Machinery Directive (MD), common opinion is no, but there may be exceptions. Blinders off everyone, there are so many tails on this dog!
Those involved include OEMs, engineering firms, large, medium and small manufacturers (end-users), domestic only and international companies… just to mention a few. But, who has compliance responsibility? The legal answer to this question is often associated with OSHA regulations, which require employers to provide safe working conditions for every employee. That said, and in contrast to the MD, OSHA does not typically inspect or approve a machine’s safety before its sold and commissioned for production. OSHA most likely assesses the safety of a machine following an incident and tells the owner what needs corrected, assesses fines and establishes a required time frame for all identified corrective measures. Because of OSHA, I believe that a simple “copy paste” of ISO 13849 into the U.S. system for domestic compliance is difficult at best.
This position is illuminated as I follow various forum groups on this subject. LinkedIn has a great forum group on this topic called “IEC 62061 and ISO 13849 machinery functional safety.” A related discussion thread was started by Heinz Knachstedt, Mgr. of Safety Products at C&E Sales Inc. What impresses me is that many of the great contributors go into discussions about the European MD, things designers should do and shouldn’t do, statistical reports and lots more great stuff. At the end of discussion the question still remains: what is the “practical” value from ISO 13849-1 for U.S. domestic compliance? I would like to see some effort by forum responders to answer the questions in view of our U.S. enforcement model.
Many of my colleagues describe OEM compliance responsibility in the U.S. as “best practices” and/or “liability,” but not the “law." Let’s follow the flow! After an OEM manufacturer’s a machine (compliant with ISO 13849-1) it is sold, installed and commissioned at a manufacturer’s end-user facility in the U.S. Excepting union agreements, insurance requirements, purchase order terms and conditions, policy issues, and the like, there is generally no requirement to prove compliance in our model of enforcement.
Next is a rule I have become fond of: 80/20. In the broad brush around 20% of all types of U.S. companies in industry have designers. Conversely, 80% of all types of U.S. companies in industry will not have designers. If I were a betting man I’d bet that in most cases the safety circuit of a machine built to ISO 13849-1 after it’s sold and commissioned would never have that circuit re-calculated for verification to design compliance. The reason why: there’s no one in place with the skill set! Of course the first exception would be in the event of an unfortunate incident and resulting liability.
So, are we by default in a mode to discover what pieces and parts of ISO 13849-1 that we can “copy paste” into our domestic standards, best practices, and company based requirements? If the answer is yes, than I believe we dilute the full value of ISO 13849-1 as a standalone machine safety standard. On the other hand, I believe a lot of the requirements built into ISO 13849-1 are truly enhancements for machine safety. Perhaps the “practical value” is to adopt those requirements that work within our model and simultaneously enhance machine safety for reduced injuries.
Will a U.S. MD replace OSHA? Not in my life time!
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 increasing role of functional safety in complex machine design by Mark Nehrkorn, a Control Engineering article.
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