KANBrief 4/11
The division of functions between legislation and standardization as embodied in the New Approach has proved effective in many product areas. The result is a common body of technical regulations applicable throughout Europe which has been developed with a strong degree of commitment. However, growing internationalization, shorter innovation cycles, changes in statutory requirements and the availability of only limited resources for participation present standardization work with new challenges.
The topical discussion concerning revision of the European standardization system (see KANBrief 3/11) prompted KAN to consider certain fundamental aspects of the quality of standards. The resulting working paper was submitted to the CEN Strategic Advisory Body for Occupational Health and Safety (CEN/SAB OHS) for consideration. The paper describes proposals for improvements in four areas.
Incomplete standards
In order for a manufacturer to draw the greatest possible benefit from the presumption of conformity to which European standards give rise, the standards should support all relevant requirements of the directives if at all possible. This is also called for in the Cracow Memorandum formulated by EUROSHNET, the European network for occupational safety and health experts. This objective is however not (yet) always attained. As a result, manufacturers are forced to find solutions of their own in order to satisfy the requirements of the directives. This may result in differences in the level of safety, which in turn distort competition.
The standards committees are responsible for indicating clearly to the user of the standard which relevant requirements of the directive are not addressed by the standard. Statements of the standard's limitations should be made mandatory in its scope and in the annex. Reference to the standard's deficiencies should also be made in the listing in the Official Journal of the EU. This would underline the mandate to the standards bodies to launch concrete measures, such as the development of new solutions by which loopholes could be closed at the next revision of the standard.
Out-of-date content in standards
The capacity of the body of standards to adapt swiftly to changes is one of the major arguments for the proven division of functions under the New Approach. Under the standardization rules, the up-to-dateness of harmonized standards must be reviewed at intervals of no more than five years. Cases nevertheless exist in which standards are revised insufficiently promptly or not at all, despite clearly needing to be updated.
In order for the content of standards to be regularly brought up to date with the state of the art, it is important for feedback from users, OSH experts, market surveillance authorities and test bodies to the standards committees to be improved, and for these bodies' experience to be exploited systematically.
Changes in statutory principles
In the area of machine safety, a number of standards exist which have formally been brought into line with the new 2006/42/EC directive, but whose content has not been adequately reviewed. However, changes to the statutory principles necessitate correction of the requirements formulated in the standards. It would be advantageous if, in the future, amendments to directives could be accompanied by appropriate deadlines for transition, and if appropriate, for funds to be made available for mandates for prompt adaptation of the standards to the new requirements.
Difficulty of implementing standards
Some standards lack specific criteria or test requirements; at the other extreme, some standards require tests which users, however well-intentioned, are able to perform only at considerable expense. Either scenario may lead to these standards being applied incompletely or not at all, or to preventing direct determination of whether the requirements of the standard have actually been met. The unreasonable complexity and increasingly academic character of provisions in standards could for example be countered effectively by the provision of opportunities for practitioners in the field to be involved more closely in the standardization process.
For this purpose, KAN calls upon all stakeholders to be proactive in demanding that the body of standards be maintained and to conduct the corresponding work as systematically and promptly as possible. Only by this means can the sound principle of the division of tasks in accordance with the New Approach be safeguarded. Many proven mechanisms exist within the existing system; consistent use must however be made of them.
Werner Sterk
sterk@kan.de