KANBrief 2/23
The body of official German state rules and regulations governing workplace lighting and those of the German Social Accident Insurance Institutions stand beside requirements set out in standards. A KAN expert report (in German, summary in English) reveals where overlaps, discrepancies and correlations between the different documents exist.
KAN has been addressing EN 12464-1, Light and lighting – Lighting of work places – Part 1: Indoor work places, for several years. The standard includes comprehensive requirements concerning the safety and health of workers at work, such as minimum values for the lighting of different workplaces. In accordance with the policy paper on the role of standardization in the safety and health of workers at work, this area should not be a subject for standardization.
Owing to the many overlaps between the content of EN 12464-1 with state rules and regulations and those of the accident insurance institutions, KAN has already discussed earlier editions of this standard with the responsible DIN standards committee. KAN’s comments resulted in paragraphs concerning safety and health being added to the national foreword and to the scope.
The areas of overlap, deviations and links between the standard on the one hand and the body of German regulations and those of the accident insurance institutions on the other present challenges in practice, for example for persons responsible for the planning of lighting. EN 12464-1 is frequently referenced in contracts governing the planning of lighting systems. At the same time, a state document governing lighting exists in the form of ASR A3.4. This document gives rise to a presumption of conformity with the requirements concerning lighting set out in the German Regulation on Workplaces (ArbStättV) and thus takes precedence over standards.
KAN’s objective is to promote a practical, cohesive body of OSH regulations. Therefore, clarification was first necessary of where OSH documents and the standard coincide in their requirements, and where they differ. The resulting implications for practical application were also to be considered. For this purpose, KAN invited tenders in 2022 for production of an expert report comparing the requirements for workplace lighting in the body of German state rules and regulations and those of the German Social Accident Insurance Institutions on the one hand and those in standards on the other, and tasked the German Federal Institute for Occupational Safety and Health (BAuA) with producing the report.
The report compares the requirements concerning workplace lighting set out in the body of OSH regulations with those formulated in standards. Owing to the presumption of conformity to which it gives rise with the safety and health requirements of the German Regulation on Workplaces (ArbStättV), the focus lies on the content of the ASR A3.4 workplace regulation governing lighting. On the standards side, EN 12464-1:2021 is the key document for the planning of lighting for indoor workplaces. The comparison includes other documents issued by the state or the accident insurance institutions and standards that are closely related to the two documents already referred to.
The requirements and recommendations of the documents under consideration are compared systematically and deviations concerning occupational safety and health evaluated against a scale developed by the author. In the comparison of the ASR with the standardization documents, the author emphasizes the different groups for which they are intended and the divergence in the documents’ binding status. The rules governing workplaces, for example, are directed at employers: they give rise to a presumption of conformity with the occupational safety and health regulations that are to be supported. Conversely, the standards are intended for lighting planners; they are often referenced in contracts between such parties and their customers (typically employers or building owners).
Fundamental differences also exist in the fields of regulation. Outdoor workplaces and safety lighting, for example, are addressed only in ASR A3.4. One clear difference concerns the treatment of daylight, since EN 12464-1 makes no distinction between daylight and artificial lighting. Definitions of terminology differ and affect the entire document concerned. Shadows, flicker and glare are treated differently. More minor deviations can be found in the tables of requirements for specific workplaces/visual tasks in ASR A3.4 and EN 12464-1.
Non-visual effects of light are addressed by a recommendation made by the ASTA committee for working premises which focuses on lighting at night. As yet, this topic is not addressed in the ASR itself. DGUV informative document 215-220 governing the non-visual effects of light on human beings also provides information and broad recommendations in this respect. EN 12464-1 addresses the non-visual effects of light in its informative annex.
In two meetings, experts from among KAN’s stakeholders discussed the report and formulated recommendations based upon it. KAN recommends that the results of the study be made known and made available to the BMAS, the relevant OSH bodies and standardization bodies for further use.
Dr Anna Dammann
dammann@kan.de