KAN Report 23
|Consideration of non-electrical hazards in standardization in support of the Low Voltage Directive, 01/2000
H. Enderlein/W. Gläser/S. Weißflog (4 MB)
Bookmarks in the pdf file link directly to the individual chapters. In the list of bookmarks, all sections available in English and French are highlighted in colour.
Background to this report
The Commission for Occupational Health and Safety and Standardization (KAN) was founded in 1994 to assert German interests in OH&S matters, especially with regard to European standardization. KAN is composed of delegates of employers’ and employees’ representative bodies, the state (Federal and Regional governments), the Hauptverband der gewerblichen Berufsgenossenschaften (HVBG, Federation of the Statutory Accident Insurance Institutions of the Industrial Sector) and the German Standards Institute (DIN). One of KAN’s tasks is to focus public interest in the field of occupational health and safety and to exert influence on current and future standardization projects by delivering opinion on specific subjects.
KAN commissions studies and expert reports in order to analyse issues relevant to occupational health and safety in standardization and to reveal deficiencies or erroneous developments in standardization activity.
The present study was based upon the following task:
In its Mandate M/015 of May 1993, the EU Commission stipulates that harmonized standards in support of the "Low Voltage Directive" (73/23/EEC) which refer to machinery must also consider the relevant non-electrical hazards as if the basic health and safety requirements of the "Machinery Directive" (89/392/EEC) applied to these machines.
At the same time the EU Commission's Mandate M/015 entrusted CEN and CENELEC with the task of preparing a standardization programme for standards published within the framework of the Low Voltage Directive and relating to the machinery sector. The purpose of the standardization programme was to establish which European documents were in need of revision. CEN and CENELEC responded to this request in a joint letter dated 14 January 1994. Mandates M/079 of December 1994 and M/083 of February 1995 entrusted CEN and CENELEC with the task of revising the documents concerned.
Aim of the project study
The aim of KAN project study 23 is to analyse the consideration of relevant non-electrical hazards in standardization in support of the "Low Voltage Directive" which is called for in Mandate M/015.
1. Compilation of a table listing all standards, draft standards and standardization projects in support of the Low Voltage Directive which contain provisions governing machines, together with the basis for their classification
2. Identification in the table of those documents requiring revision as a result of Mandates M/079 and M/083, those which have already been revised, and those the revision of which is in progress, where applicable with a brief explanation of the progress of revision
3. Production of a detailed open-answer questionnaire which must contain the following points:
- Consideration of the list of hazards according to Annex I of the Machinery Directive
Has a list of hazards according to Annex I of the Machinery Directive (cf. prEN 1050) been worked through?
Which clauses deal with which hazards?
- Reference to relevant type A or type B standards in accordance with the Machinery Directive
- Information on the drawing up of "information for use"
In what form are the requirements concerning the use of machines specified?
Does the respective standard specify that such requirements be included in instruction handbooks?
Is this issue dealt with in a special section on "information for use" as described in clause 5 of EN 292-2?
- State of the art for emissions of noise, vibration, hazardous substances and non-ionizing radiation:
How was/is the state of the art treated? (with explanation in each case) by
1.) Specification of design measures
2.) Specification of measuring methods (are representative, practice-oriented operating conditions established?)
3.) Indication of emission parameters
4.) Use of personal protective equipment or other protective measures
5.) Notes in the information for use
- Co-operation with other standards bodies:
Did or does co-operation take place with other standards bodies in relation to special issues? (if yes, indication of the issue/standards body)
- Assessment of the standard by the CEN consultant:
Has the CEN consultant already reviewed the document? (result of the review and comments where applicable)
4. Survey of members of the German reflecting committees, especially German occupational health and safety experts who are concerned with implementation of Mandates M/079 and M/083
5. Evaluation of the survey, and production from it of a detailed project report intended as a basis for discussion for the working group accompanying the project
6. Analysis and assessment of the results of the survey with regard to the implementation status of Mandates M/079 and M/083 (with indication where applicable of existing deficiencies, both in general terms and with reference to specific examples from selected standards/draft standards)
KAN wishes to thank the authors for carrying out the project and presenting the report, and also the experts involved for their critical support and their assistance in evaluation of the work.
The following summary of the study and its recommendations were approved by KAN on 9.06.99.
The standards organizations CEN and CENELEC were commissioned by the EU Commission in its Mandates M/015 and M/083 to consider the relevant non-electrical hazards in standards supporting the Low Voltage Directive (73/23/EEC) which relate to machinery as if the essential health and safety requirements of the Machinery Directive (89/392/EEC) applied directly to the machines in question.
The present study provides a comprehensive overview of the current state of progress of the electrotechnical standards to be revised in accordance with the above Mandates. The results have been obtained by the commissioned party’s own analyses and by consultation with experts.
The standards in the series EN 50144: "Safety of hand-held electric motor operated tools", EN 60335: "Safety of household and similar electrical appliances" and EN 61029: "Safety of transportable motor-operated electric tools" listed in the annex of Mandate M/083 were subjected to particular review in this study. In the process, the standards reviewed were found to be in need of revision, in some areas considerable, with regard to certain essential hazards.
Progress of work
By the end of October 1998, 40 of the 63 standards listed in the annex of Mandate M/083 had been reviewed and where applicable revised. 18 standards were still undergoing revision at this time. No review is planned of the five standards in the EN 60730 series listed in the annex of the Mandate, "Automatic electrical controls for household and similar use". Standard EN 50087 (bulk-milk coolers) is currently the subject of review to establish whether revision is required.
CENELEC/TC 61 estimates that only 5 of the 30 standards in the EN 60335 series which are listed in the annex of Mandate M/083 required or require adaptation to the essential health and safety requirements of the Machinery Directive.
Some of the standards to be analysed, which had already been published prior to the appearance of the draft Mandate M/083 in September 1994, were declared reviewed/revised retrospectively by CENELEC. These include in particular the standards EN 50144-1:1995, EN 60335-1:1995 and EN 61029-1:1995, which have been valid since 5 July 1994.
Identification of non-electrical hazards
The identification of non-electrical hazards was performed by the standards bodies on the basis of previous experience and procedures (DKE K 511 and K 514). ISO/IEC guides were also employed for this purpose. No indication is made of a risk assessment in accordance with a state-of-the-art procedure (e.g. EN 1050, ISO/IEC Guide 51) having been carried out in the course of review/revision of the standards listed in the Mandate. No list has been compiled of the significant hazards in the affected standards (in accordance with the provisions of EN 414).
Satisfactory consideration is not given in the mandated standards in the EN 60335 series to hazards arising from noise and vibration emissions.
The procedures for the measurement of noise specified in the EN 50144 and EN 61029 series of standards (in this case in consideration of prEN 61029-1:1998) do not satisfactorily reflect representative use of the machines, with regard either to the measurement or to some extent to the state of operation to be selected. The states of operation specified in Parts 2 of the EN 61029 series of standards reflect "worst case" conditions. The states of operation selected for vibration measurement on comparable electrical (CENELEC) and non-electrical (CEN) tools should be brought into line where possible. The standards/draft standards fail to state indicative values for noise and vibration emissions. No provisions are made with respect to the reduction of noise and vibration emissions.
Measured values obtained by means of the measuring procedures specified in the standards can currently be employed only for the purpose of comparing machines of similar type (i.e. as an aid to purchase). They do not represent a suitable mechanism by which conclusions can be drawn regarding occupational health and safety (e.g. assessment level, vibration severity).
An additional procedure for dust measurement in accordance with EN 1093-8:1998 should be applied as an alternative in the standards analysed in the EN 50144 and EN 61029 series of standards, in particular for machines producing low dust volumes. The standards analysed governing equipment for commercial kitchens in the EN 60335 series of standards do not contain satisfactory provisions for hazards arising from dust, vapour, etc. The states of operation to be selected for dust measurement given in the EN 61029 series of standards are deemed to be neither sufficiently representative nor relevant to practical conditions.
The wording employed in EN 50144-1:1998 and prEN 61029-1:1998, whereby dust measurements are required only where the manufacturer declares the efficiency of the dust collecting facility, must be criticised. Part 2 of certain standards in the EN 50144 and EN 61029 series also require dust measurements to be performed in cases where facilities for dust extraction are provided on the tool.
A prohibition for use with certain substances (e.g. asbestos, PCBs) should be specified in the EN 50144 and EN 61029 series of standards similar to that contained in the EN 60335 series of standards.
Draft standard prEN 60335-2-64:1998 (equipment for commercial kitchens) also contains provisions governing noise, vibration and hygiene by the provision for application of corresponding CEN standards. The CEN standards stated in annex ZAA do not however cover the full scope of kitchen equipment. A regulatory deficit, in some cases considerable, thus continues to exist for certain machines.
The electrical, magnetic and electromagnetic fields which arise do not present a risk or are reduced to an acceptable level (e.g. appliances for heating foods by microwave energy, EN 60335-2-25:1996).
A quantitative analysis of the standards to be analysed revealed that the other essential non-electrical hazards are covered or at least referred to.
The provisions established in draft standard prEN 60335-2-64:1998 (equipment for commercial kitchens) governing protection from mechanical hazards arising in connection with the machines not listed in Annex ZAA are inadequate and wholly unsystematic. All standards analysed governing "equipment for commercial kitchens" are to be reviewed for adequate consideration of non-electrical hazards required in the Mandate. Such hazards include in particular thermal hazards, radiation hazards, (e.g. thermal radiation), hazards arising from vapours, fumes, mould fungi, mill dust, fire and explosion, and hazards arising from failure to observe hygiene regulations and by the neglect of ergonomic principles.
The standards analysed in the EN 61029 series of standards make no provision for interlocking of movable guards in accordance with the essential health and safety requirements contained in Annex I of the Machinery Directive.
The state of the art for the prevention of kickback and for braking of the chain as considered in draft prEN 50144-2-13:1996 (particular requirements for chain saws) is out of date.
The test finger described in the analysed standards no longer corresponds to the current anthropometrical reality. This applies in particular to reliable adherence to specified safety clearances.
The specification of particular design solutions in standards (for example the use of a felling wedge for prevention of chain saw kickback) is criticised, as it presents an obstruction to the development of equally valid technical solutions.
Information for use
The EN 51044, EN 60335 and EN 61029 series of standards contain provisions concerning the marking of the product and the content of operating instructions. The requirements differ however from those contained in Section 1.7, "Indicators", of Annex I of the Machinery Directive. Provisions contained in the Machinery Directive are in some cases repeated.
A particular conflict is presented by the fact that the requirements of the Low Voltage Directive differ from those of the Machinery Directive with regard to marking: Consideration given to the requirements of the Machinery Directive in standards which fall within the remit of the Low Voltage Directive may therefore result in products which are manufactured in accordance with harmonized standards being marked completely differently from comparable products manufactured in direct compliance with the provisions of the Low Voltage Directive (for example with regard to noise emission declarations, declaration of the vibration emission values).
Information of this kind is to be understood in the context of the Machinery Directive, Annex I Point 1.7.4c as "useful instructions in particular with regard to safety" and of the Low Voltage Directive, Annex I Point 1a as "essential characteristics, the recognition and observance of which will ensure that electrical equipment will be used safely and in applications for which it was made, (...)".
Reference should be made in the operating instructions to the use, if required, of hearing protective equipment with vacuum cleaners and water suction cleaning appliances (EN 60335-2-2). No reference was made to any further deficiency with regard to this point in consultation of the experts with regard to the remaining standards in the EN 60335 which were the subject of review.
The standards/draft standards in the EN 50144 and EN 61029 series of standards to be analysed in the scope of the study are being or have been reviewed by the CEN/CENELEC consultant. The requirements stipulated by the consultant as a result of the reviews will be incorporated into the draft standards or met in the form of amendments to the standards in question.
Coherent body of CEN and CENELEC standards
Evaluation of the experts’ questionnaires revealed that the hazards presented by chain saws are dealt with differently in the standards prEN 50144-2-13 (CENELEC) and EN 608 (CEN). The states of operation stated in EN 50144 (hand-held electric motor operated tools) for vibration measurements differ from those stated in EN 28662 (hand-held non-electric power tools). Differences were noted between the requirements of the EN 61029 series of standards and those of the corresponding CEN standards in respect of movable guards.
CEN and CENELEC standards for comparable products exhibit fundamental differences in structure, layout and procedure in their treatment of the health and safety requirements. (Compare the structure of the EN 50144, EN 60335 and EN 61029 series of standards with the provisions of EN 414: 1992.)
Reference to generic standards
Reference is made in the standards EN 50144-1:1998 and prEN 61029-1:1998 to CEN basic safety standards and CEN group safety standards. The experts require that recourse be made to further generic standards, in particular with regard to the measurement of emission values.
- The KAN Secretariat be commissioned to draw up detailed comments upon the individual standards based upon the results of the study and to relay these comments to the DIN and DKE standards committees.
- The KAN Secretariat be commissioned to examine the ways in which standards bodies and manufacturers can be supported in implementation of the results of the study.
- The KAN Advisory Committee requests that the DIN and DKE inform their respective standards committees that in accordance with Mandate M/083, reference should be made to generic standards in the affected European standards.
- The KAN Advisory Committee requests that the DIN and DKE inform their respective standards committees that in accordance with the "Guidelines on the application of the Low Voltage Directive" a state of the art procedure for systematic identification of non-electrical hazards exists in the form of standard DIN EN 1050: 1997 "Safety of machinery - principles for risk assessment".