KANBrief 4/22
An important step has been taken with the development of a vibration measurement method for use on pedelecs. Overall, however, the treatment of vibration in standards remains patchy.
Pedelecs have become an accepted means of transport. Vocational use is also steadily increasing, for example among bicycle courier services, the police and postal services. Workers in these and other occupational groups may spend many hours a day on pedelecs, and may ride them on unsurfaced roads and roads with cobblestone paving or damaged asphalt. As a result, vibration may be transmitted to the rider that is potentially hazardous to his or her health.
Pedelecs fall within the scope of the European Machinery Directive, which requires machines to be designed and manufactured such that risks caused by vibration are reduced. Manufacturers are also required to provide information on the vibration transmitted from the machine to the user. These two requirements should also be described in the relevant product standards; to date, however, this has not been the case for pedelecs. A recurring argument against vibration being addressed in these standards has been the lack of a standardized vibration measurement method for bicycles (see also KANBrief 1/20).
The generic standard for pedelecs is the harmonized standard EN 15194:2017, Cycles – Electrically power assisted cycles – EPAC Bicycles. This standard governs pedelecs in general and can thus be referred to by standards governing more specific pedelecs. For example, EN 17404:2022 governing EPAC mountain bikes extends the basic standard. Following a comment by KAN, vibration was included in this standard as a potential hazard, but only for intensive vocational use. Beyond that, reference is made to the work currently in progress on the generic standard with regard to vibration, and its treatment is excluded from this standard. Following a KAN comment, the DIN 79010:2022 national standard concerning single-track and multi-track transportation bikes and cargo bikes also refers to the possible hazard posed by vibration. Broad instructions for determining and reducing the vibration occurring were added and information on the vibration was made a requirement. Work is currently underway on a European series of standards governing cargo bikes.
In 2020, the Netherlands submitted a formal objection concerning EN 15194 with regard to the rechargeable batteries. KAN used the subsequent discussion of the standard as an opportunity to address the issue of vibration. The stakeholders agreed upon development of a measurement method and that vibration was to be addressed in the text of the standard. Until this takes place, a warning for inclusion in the EU Official Journal concerning EN 15194, which has also already been formulated, is intended to remove the presumption of conformity with the requirements concerning vibration. As yet however, the European Commission has not published this warning.
The vibration measurement method for bicycles was developed in the German mirror committee and is to be included in EN 15194 as an informative annex by way of amendment A2. During the public enquiry conducted in early 2022, KAN submitted a comment on this amendment, since it fails to include measures to reduce vibration and neither requires nor describes information on it. Moreover, an informative annex is not sufficient: the annex should be normative, so that manufacturers who declare that their pedelecs comply with the standard are required to apply the method described, and the vibration levels determined by it are then comparable.
The national and European comments resolution meeting has already taken place. Publication of the amendment is still pending. As things stand at present, vibration is to be included as a hazard; the other KAN comments however were not adopted. Even following the amendment, EN 15194 thus fails to support the relevant requirements of the Machinery Directive concerning vibration. This should be stated accordingly in Annex ZA, which describes the relationship between the European standard in question and the Machinery Directive. Should this not be the case, the warning that has been prepared still applies and should be published as soon as possible.
Dr. Anna Dammann
dammann@kan.de