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.

04/07/2014


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.

Related articles:

The increasing role of functional safety in complex machine design by Mark Nehrkorn, a Control Engineering article.

Machine Safety: Can end user companies comply with ISO 13849-1: 2006 without design engineering resources?

Inside Machines: Does adopting ISO 13849-1:2006 change the U.S. model for compliance and enforcement?

Contact: http://www.jbtitus.com for “Solutions for Machine Safety”.



Engineers' Choice Awards
The Engineers' Choice Awards highlight some of the best new control, instrumentation and automation products as chosen by Control Engineering subscribers.
System Integrator Giants
The System Integrator Giants program lists the top 100 system integrators among companies listed in CFE Media's Global System Integrator Database.
System Integrator of the Year
Each year, a panel of Control Engineering and Plant Engineering editors and industry expert judges select the System Integrator of the Year Award winners in three categories.
Design of Safe and Reliable Hydraulic Systems for Subsea Applications
This eGuide explains how the operation of hydraulic systems for subsea applications requires the user to consider additional aspects because of the unique conditions that apply to the setting
How to Maximize Factory Automation Efficiency with Low Cost Machine Vision
This eGuide illustrates solutions, applications and benefits of machine vision systems.
Wireless Reliability in Harsh Environments
Learn how to increase device reliability in harsh environments and decrease unplanned system downtime.
October 2018
HMI hardware evolution, Data acquisition strategies, Matching motors and drives, Machine vision advice
September 2018
Optimize controls via cloud software, ladder logic simulation, industrial wireless best practices
August 2018
Augmented reality and virtual reality education, autotuning PID control, cybersecurity advice, educating engineers
Edge Computing
This article collection contains several articles on how today's technologies heap benefits onto an edge-computing architecture such as faster computing, better networking, more memory, smarter analytics, cloud-based intelligence, and lower costs.
Data Center Design
Data centers, data closets, edge and cloud computing, co-location facilities, and similar topics are among the fastest-changing in the industry.
IIoT: Machines, Equipment, & Asset Management
Articles in this digital report highlight technologies that enable Industrial Internet of Things, IIoT-related products and strategies.
SIDB

Find and connect with the most suitable service provider for your unique application. Start searching the Global System Integrator Database Now!

October 2018
2018 Product of the Year; Subsurface data methodologies; Digital twins; Well lifecycle data
August 2018
SCADA standardization, capital expenditures, data-driven drilling and execution
June 2018
Machine learning, produced water benefits, progressive cavity pumps
John O. Ayuk, PE, CFSE, PMP, CAP
Automation Engineer; Wood Group
Doug Baker
System Integrator; Cross Integrated Systems Group
Jose S. Vasquez, Jr.
Jose S. Vasquez, Jr.
Fire & Life Safety Engineer; Technip USA Inc.
Data Centers: Impacts of Climate and Cooling Technology
This course focuses on climate analysis, appropriateness of cooling system selection, and combining cooling systems.
Safety First: Arc Flash 101
This course will help identify and reveal electrical hazards and identify the solutions to implementing and maintaining a safe work environment.
Critical Power: Hospital Electrical Systems
This course explains how maintaining power and communication systems through emergency power-generation systems is critical.
Engineers' Choice Awards
The Engineers' Choice Awards highlight some of the best new control, instrumentation and automation products as chosen by Control Engineering subscribers.
System Integrator Giants
The System Integrator Giants program lists the top 100 system integrators among companies listed in CFE Media's Global System Integrator Database.
System Integrator of the Year
Each year, a panel of Control Engineering and Plant Engineering editors and industry expert judges select the System Integrator of the Year Award winners in three categories.
Design of Safe and Reliable Hydraulic Systems for Subsea Applications
This eGuide explains how the operation of hydraulic systems for subsea applications requires the user to consider additional aspects because of the unique conditions that apply to the setting
How to Maximize Factory Automation Efficiency with Low Cost Machine Vision
This eGuide illustrates solutions, applications and benefits of machine vision systems.
Wireless Reliability in Harsh Environments
Learn how to increase device reliability in harsh environments and decrease unplanned system downtime.
October 2018
HMI hardware evolution, Data acquisition strategies, Matching motors and drives, Machine vision advice
September 2018
Optimize controls via cloud software, ladder logic simulation, industrial wireless best practices
August 2018
Augmented reality and virtual reality education, autotuning PID control, cybersecurity advice, educating engineers
Edge Computing
This article collection contains several articles on how today's technologies heap benefits onto an edge-computing architecture such as faster computing, better networking, more memory, smarter analytics, cloud-based intelligence, and lower costs.
Data Center Design
Data centers, data closets, edge and cloud computing, co-location facilities, and similar topics are among the fastest-changing in the industry.
IIoT: Machines, Equipment, & Asset Management
Articles in this digital report highlight technologies that enable Industrial Internet of Things, IIoT-related products and strategies.
SIDB

Find and connect with the most suitable service provider for your unique application. Start searching the Global System Integrator Database Now!

October 2018
2018 Product of the Year; Subsurface data methodologies; Digital twins; Well lifecycle data
August 2018
SCADA standardization, capital expenditures, data-driven drilling and execution
June 2018
Machine learning, produced water benefits, progressive cavity pumps
John O. Ayuk, PE, CFSE, PMP, CAP
Automation Engineer; Wood Group
Doug Baker
System Integrator; Cross Integrated Systems Group
Jose S. Vasquez, Jr.
Jose S. Vasquez, Jr.
Fire & Life Safety Engineer; Technip USA Inc.
Data Centers: Impacts of Climate and Cooling Technology
This course focuses on climate analysis, appropriateness of cooling system selection, and combining cooling systems.
Safety First: Arc Flash 101
This course will help identify and reveal electrical hazards and identify the solutions to implementing and maintaining a safe work environment.
Critical Power: Hospital Electrical Systems
This course explains how maintaining power and communication systems through emergency power-generation systems is critical.
Engineers' Choice Awards
The Engineers' Choice Awards highlight some of the best new control, instrumentation and automation products as chosen by Control Engineering subscribers.
System Integrator Giants
The System Integrator Giants program lists the top 100 system integrators among companies listed in CFE Media's Global System Integrator Database.
System Integrator of the Year
Each year, a panel of Control Engineering and Plant Engineering editors and industry expert judges select the System Integrator of the Year Award winners in three categories.
Design of Safe and Reliable Hydraulic Systems for Subsea Applications
This eGuide explains how the operation of hydraulic systems for subsea applications requires the user to consider additional aspects because of the unique conditions that apply to the setting
How to Maximize Factory Automation Efficiency with Low Cost Machine Vision
This eGuide illustrates solutions, applications and benefits of machine vision systems.
Wireless Reliability in Harsh Environments
Learn how to increase device reliability in harsh environments and decrease unplanned system downtime.
October 2018
HMI hardware evolution, Data acquisition strategies, Matching motors and drives, Machine vision advice
September 2018
Optimize controls via cloud software, ladder logic simulation, industrial wireless best practices
August 2018
Augmented reality and virtual reality education, autotuning PID control, cybersecurity advice, educating engineers
Edge Computing
This article collection contains several articles on how today's technologies heap benefits onto an edge-computing architecture such as faster computing, better networking, more memory, smarter analytics, cloud-based intelligence, and lower costs.
Data Center Design
Data centers, data closets, edge and cloud computing, co-location facilities, and similar topics are among the fastest-changing in the industry.
IIoT: Machines, Equipment, & Asset Management
Articles in this digital report highlight technologies that enable Industrial Internet of Things, IIoT-related products and strategies.
SIDB

Find and connect with the most suitable service provider for your unique application. Start searching the Global System Integrator Database Now!

October 2018
2018 Product of the Year; Subsurface data methodologies; Digital twins; Well lifecycle data
August 2018
SCADA standardization, capital expenditures, data-driven drilling and execution
June 2018
Machine learning, produced water benefits, progressive cavity pumps
John O. Ayuk, PE, CFSE, PMP, CAP
Automation Engineer; Wood Group
Doug Baker
System Integrator; Cross Integrated Systems Group
Jose S. Vasquez, Jr.
Jose S. Vasquez, Jr.
Fire & Life Safety Engineer; Technip USA Inc.
Data Centers: Impacts of Climate and Cooling Technology
This course focuses on climate analysis, appropriateness of cooling system selection, and combining cooling systems.
Safety First: Arc Flash 101
This course will help identify and reveal electrical hazards and identify the solutions to implementing and maintaining a safe work environment.
Critical Power: Hospital Electrical Systems
This course explains how maintaining power and communication systems through emergency power-generation systems is critical.
click me