KAN Report 15
|Emission of hazardous substances by machinery - European standardization and parameters, 09/1997
K. Wagner (523 KB)
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Definition of the need for standardization
1. The study comes to the conclusion that generally speaking the requirements of the EU Machinery Directive relating to the emission of dust and hazardous substances are satisfactorily taken into account in the standards.
2. Action is deemed to be required for CEN/TC 12 (petroleum and gas industry). Standardization here is predominantly carried out by ISO so there are no European standards complying with the basic safety and health requirements of the Machinery Directive.
3. There is a need for action for CEN/TC 197 (Pumps). The study recommends that the emission allowances from VDI Richtlinie 2440 (Emission control - oil refineries) be adopted in a European standard for pumps with permissible leakage.
Analysis of the machine-specific standardization concepts concerning the conditions defined for occupational health and safety
4. The standardization concept is deemed to be well suited to the implementation of the requirements of the Machinery Directive with regard to the emission of hazardous substances.
The present A and B standards (or drafts) represent a good basis for minimizing the hazard that arises from the emission of hazardous substances.
The C standards (or drafts) analyzed generally prescribe protective measures against the hazards arising from emissions. Constructive solutions are described, sometimes with rather generally formulated aims towards protection ("Emissions shall be avoided as far as possible", "be as small as possible", etc).
5. Parameters for assessment of emission behaviour are only specified in a few C standards. The study proposes that, wherever it is meaningful and possible, "achievable values" should be specified in the product standards. This will enable design engineers to assess their machines on the basis of a defined requirement level. Operator would also indirectly be given an evaluation guide to verify compliance with the standard using parameters.
However, it is noted that
- "achievable values" are frequently not specified, as agreement is not reached in the standards bodies due to differing assessments and interests, and
- it is very expensive, if at all possible, to set out standardized measuring procedures for every type and size of machine taking into account the particular conditions so that comparable and reproducible values can be specified.
Conclusions on the state of the art
6. The study assumes that the state of the art is defined by a majority of representative technical specialists. With regard to standardization this means that the standards represent the state of the art at the time they are written, as they are produced by the technical specialists in question. The author of the study infers from this that the operator of a machine can assume on the basis of the declaration of compliance that the protection aims of the Machinery Directive have been complied with.
National regulations for the assessment of the imission
7. The study establishes that there is an extensive system of regulations for the assessment of imission at national level.
8. VDI Richtlinie 2262 "Workplace air - Reduction of exposure to air pollutants" is considered to be helpful in the design of machinery. It cannot however be converted into a European standard in its entirety, as it addresses operators as well as designers and manufacturers.
9. Action is required at national level to specify the workplace-related limit values in the event of accidents.
Areas of regulation which relate to the "German consensus statement" (GDS)
10. With the exception of those fields in which standardization deviating from the principle is possible and meaningful (e.g. standardized measuring procedure, specification of emission values), operational specifications relevant to safety shall enter standardization by means of the operating instructions to be produced in accordance with the Machinery Directive.
The author of the study proposes that standardization should provide more details concerning the information to be given by the manufacturer. This concerns specification of maintenance cycles for filter and exhaust air decontamination and information on the safe installation of sets of the same type of machinery.
11. A control deficit is established for the areas excluded from standardization according to the GDS. Therefore the definition of a method outside standardization is considered to be desirable in order to guarantee a European minimum level for the safe installation and operation of machinery, which is acceptable from the perspective of occupational health and safety.
The study emphasizes that with regard to the emission of hazardous substances it is the operator who is often the first to be able to largely guarantee the safety and health of workers. This applies for example to machinery classes for which the manufacturer cannot foresee whether work will be carried out on dangerous substances (e.g. pumps, plastics processing machinery).
This study gives a good picture of the present situation relating to the implementation of requirements laid down in the Machinery Directive by means of standards in the field of the emission of dangerous substances by machinery. KAN agrees with the study’s conclusion that the basic requirements of the Machinery Directive with regard to the emission of dangerous substances are generally taken into account in standardization and that the standard concept is seen as basically appropriate for implementing requirements laid down in the Machinery Directive in the field of the emission of dangerous substances. This is true in particular of the A and B standardization projects already published. In the assessment of the C standardization drafts that were examined, it was ascertained that protective measures are prescribed in most cases. KAN however leaves open the assessment as to whether occupational health and safety is adequately guaranteed in every case, as the concrete assessment of the remaining risk in each case was only limited in the study. Furthermore, in most cases only drafts and working papers are available which may differ from the final versions.
KAN agrees with the study’s conclusion to the extent that the standards correspond to the state of the art defined in DIN EN 45020. Article 100a, clause 3 of the EC Treaty implies conclusively that the Machinery Directive is based on a high level of protection. Thus, the requirement of the Machinery Directive demanding that harmonized standards shall correspond to the state of the art means in fact that harmonized standards shall reflect a progressive state of development in safety measures. Therefore KAN points out that in the absence of parameters or clear criteria it is difficult to establish whether a machine corresponds to this "progressive state" KAN points out, further to the statement by the author of the study (see summary, point 6), that hazards can still arise from a machine marked with the CE mark. The manufacturer is then required to warn of remaining hazards which still exist despite all the precautions taken.
Notwithstanding the requirement in the study, KAN takes the advice of the Normenausschuß Maschinenbau im DIN (NAM = machinery standardization committee), that there is no need for action concerning CEN/TC 12 (petroleum and gas industry), as the standards to be taken over from ISO are not safety standards. Nor does KAN envisage any need for action at national level with regard to the definition of workplace-related limit values in the event of accidents. It is also pointed out that the specification of maintenance cycles as required in the study is already one of the conditions for the standards bodies and the requirement relating to advice on installation applies to the health and safety of workers at work and therefore goes beyond the task of standardization.
Need for DIN to take action
1. CEN/TC 197 "Pumps" is requested via DIN to examine and comment on whether the emission allowances from VDI Richtlinie 2440 (Emission control - oil refineries) can be adopted in an EN for pumps with permissible leakage.
2. DIN is asked to start work on the conversion of the national standard DIN 33894 (Determination of the dust emissions of technical equipment; drilling devices ....) into an EN (Working Group proposal).
3. KAN asks the standards bodies, via DIN, to specify "achievable values" as far as possible in product standards. The B standards (or drafts) produced by CEN/TC 114/WG 15 (Safety of machinery) need to be implemented and to be made more specific in the C standards. The (draft) standards of the DIN EN 1093 (Evaluation of the emission of air-borne hazardous substances) series in particular should be taken into account in product standards. The requirements of the Machinery Directive for minimizing the emission of hazardous substances, made more specific by the specification of "achievable values", shall guarantee a high level of occupational health and safety taking into account the state of the art.
4. The Kommission Reinhaltung der Luft of the VDI and DIN (Air Pollution Abatement Committee) is asked to examine VDI Richtlinie 2262 to see which points could be adopted into European standardization taking into account the GDS.
Need for KAN to take action
5. In accordance with the Machinery Directive, operational instructions shall contain specifications relating to the health and safety of workers at work. There is a need for clarification as to how specific normative specifications should be, in order on the one hand to comply with the requirements of the Machinery Directive and on the other hand not to contradict the GDS. KAN will make a recommendation on this.
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