KANBrief 1/14
Jean Jacques has been the CEN Noise Consultant (Machinery Directive) since 2000. He can look back on 35 years of experience working for the INRS, France's OSH institute, initially in the sound laboratory and then in the area of standardization. In the course of his professional life, he has identified a number of areas in which improvements need to be made in order for products to be made safer and for greater weight to be given to occupational safety and health during standardization activity.
What is your overall assessment after 35 years as an OSH expert in standardization?
Very positive, and at the same time very differentiated. The New Approach has forged a close link between legislation and standards, and has made preventive activity without the tool of standards inconceivable. The following are particularly worth mentioning: the generic EN ISO 12100 standard, which European occupational safety and health experts have elevated to international status; the European standards, over 700 in number, covering practically all machine groups; the Cracow Memorandum (EUROSHNET “Cracow Memorandum” – Standardisation for Safe Products), with its proposals for improvements to prevention, which should be consulted regularly and passed on to newcomers to occupational safety and health as a reference for their work; the EUROSHNET network and its conferences, which are intended to facilitate communication between occupational safety and health experts; the interest on the part of EU authorities in improving standards, which is reflected in EU Regulation 1025/2012 on the subject; the willingness of the Member States to work closely together in the area of market surveillance; and the increasing number of standardization topics relating to occupational safety and health, for example concerning services and OSH management.
We still have a lot of work ahead of us, however. Machine safety standards govern the mechanical and electrical hazards and noise – not least, I hope, owing to the work of the CEN Noise Consultant. But other hazards are given only superficial attention: ergonomics, dust, hazardous substances. It is also important for the occupational safety and health lobby to continue to make its presence felt, particularly when standardization activity shifts from the national and European level to the international level. The current trend for everything to be standardized also requires a high degree of vigilance on the part of the occupational safety and health lobby. A further ongoing challenge is that of creating conditions under which standards are actually used.
Is there evidence that standards are not being adequately applied?
The results of the NOMAD study into noise emissions from machinery are clear: 80% of the 1,500 machine instruction handbooks studied violate the legislation in force (Documentation on NOMAD), even though the safety standards specify the mandatory content of the handbooks. All stakeholders have a responsibility here: first and foremost the manufacturers, but also users, purchasers, public authorities, OSH experts and notified bodies.
Could improvements be made to the standardization process itself?
An important rule, the observance of which is monitored closely by the CEN Consultants, is the obligation for a standard to state clearly which hazards it covers. A standard rarely has the good fortune of being revised by the same experts who originally developed it. This gave rise to the idea of recording the history of each standard, in order for greater transparency to be created. The idea met with wide approval, but implementing it has proved difficult.
Despite all the efforts made to date, we have also not succeeded in systematically and efficiently requesting, recording and evaluating feedback from the users of standards. It may simply be that the political will is lacking for the necessary measures and instruments to be set out permanently. It would perhaps be a good idea for an e-mail address to be stated on Page 1 of each standard to which the user could report problems in implementation, deficiencies that have been noted, or proposals for improvement.
How can occupational safety and health be made more efficient?
An ounce of prevention is better than a pound of cure. Occupational safety and health experts should therefore be involved at the earliest possible stage when the European Commission is drawing up a standardization mandate. This would ensure that a mandate contains all the specifications required for the development of safe product standards. In view of the growing internationalization of standardization, it is also more important than ever for OSH experts in Europe to co-operate closely. One major goal of EUROSHNET is to pave the way for the OSH experts of one country to represent the opinions of other countries on a standards committee. A suitable instrument is still needed however for organization and co-ordination of this division of labour.