Fifteen years of the Commission for Occupational Health and Safety and Standardization (KAN)

What is the situation regarding access to standards and participation by stakeholders on standards committees? This was the key question at the colloquium organized by KAN to mark its 15th anniversary. Over 100 delegates met at DIN‘s premises in Berlin on 7 October to discuss the subject of the OSH lobby‘s participation in standardization work (The conference publication (KAN Report 45) containing the positions of the KAN stakeholders and information on KAN). Selected key topics from the event are presented below.

The starting-point for the discussion was the presentation of the study commissioned by the European Commission with the title “Access to standardisation“ and the study conducted on behalf of the German Federal Ministry of Economics and Technology (BMWi) on measures for supporting SMEs in their dealings with standards and standardization activity. The recommendations made in the studies were taken up and discussed in a number of papers and a concluding panel discussion. Access to standardization was considered here from two perspectives: fi rstly, participation in the development of standards, and secondly, the procurement and intelligibility of the fi nal documents.

Participation in standardization activity

One of the principles of standardization is that participation in the development of standards is open to all stakeholders by appropriate means. In practice, however, manufacturers for example are represented much more strongly on standards committees than other groups such as operators or the OSH lobby. The number of 450 experts from the accident insurance institutions who are active in standardization work (170 of these in the capacity of committee chair) should not obscure the fact that in many European committees, the OSH lobby is represented only by a single representative, and in some cases not at all. Besides Germany, very few other countries, most signifi cantly France, the United Kingdom and the Scandinavian countries, also delegate OSH representatives to European standardization activity. Greater participation by more countries would be desirable in this respect.

The use of standards

Employees, in particular, welcome the recommendation of the European study that standards whose purpose is to support legislation should, like the text of the legislation itself, be made available free of charge. This would substantially simplify the implementation of statutory requirements and the monitoring of their observance. As users of standardized products, employees could also submit proposals for improvements more easily. The standards organizations made it clear however that they cannot provide their services free of charge. Laws and the regulations of the accident insurance institutions are, they pointed out, also not free of Fifteen years of the Commission for Occupational Health and Safety and Standardization (KAN) SPECIAL charge, but are financed by taxes or members‘ premiums. A review of dedicated fi nancing models for the different standard types was proposed as a solution. It was also pointed out that with the introduction of access free of charge to draft standards at the public enquiry stage, an important step has already been taken.

The relationship between standards on the one hand and state regulations and those of the accident insurance institutions on the other

In the context of the restructuring of German OSH legislation, duplicate provisions and contradictions between the body of state regulations and that of the accident insurance institutions are to be avoided. Criticism was levelled at references to standards from within state rules and those of the accident insurance institutions concerning the area of the health and safety of workers at work: users expect the body of regulations to be complete, and not to contain a plethora of references to further bodies of regulations, particularly when the latter must be paid for.

The principle of national delegation and the European representation of interests

The European Commission provides funding of a total of four million euro per year to European interest groups such as ANEC (consumers), ETUI (trade unions), NORMAPME (SMEs) and ECOS (environment) in order for them to make their respective positions heard by European standards organizations. The European study however reveals a contradiction between such support at European level and the principle of national delegation. The participants in the discussion were in agreement that the principle of national delegation must be retained as an important element for the broadest possible participation of all interest groups. At the same time, however, European co-ordination and the sustaining of OSH interests must be developed further. This could be attained by networks such as EUROSHNET, up to and including a European body following the KAN model.

Werner Sterk
sterk@kan.de