The strategy committee for occupational safety and health of AFNOR, the French standards institute (Comité stratégique sur la sécurité et santé au travail (CoS SST)), has for some time been addressing how the quality of harmonized European standards can be improved further in the course of their revision. The most important proposals for improvements resulting from the discussions are presented below.
Since harmonized European standards are closely linked to European legislation through the instrument of the New Approach, great care has been – and continues to be – exercised in their development. The quality of a harmonized European standard depends above all upon the quality of the consensus reached by the experts, the active and balanced participation of the stakeholders, and the care taken in formulating the text.
In the areas of machinery (governed by directive 2006/42/EC, the first version of which dates back to 1989) and personal protective equipment (governed by 89/686/EEC), a wealth of experience in the development of harmonized European standards has been built up in the course of over 20 years. To date, several hundred harmonized standards have been published in these two areas. The initial development phase was followed by a phase of revisions. Standards, whether harmonized or not, are living documents and must keep pace with ongoing development of the technology and with growing globalization.
A key aspect of the strategic committee's deliberations was that the development of a harmonized European standard should be traceable. A standard is the result of deliberations and decisions by the experts meeting in the standards committee. Once the standard has been published, however, no record exists at present either in the standard itself or in other documents of the deliberations, the decisions taken, or the essential reasons for them. This information may however be of crucial importance during the revision of a standard, work that is frequently performed by other experts. One basic question is which significant hazards are addressed, or – as may be the case – not addressed, by the standard. Although the scope of a standard generally states explicitly any significant hazards that are not covered by the standard, the reasons why they have not been addressed is not normally indicated.
Feedback of experience gained during application of the standard is also an important element during revision. Obtaining such information is extremely difficult and requires great effort on the part of the European and national standards organizations, the national authorities, and the experts themselves. Feedback also carries an administrative overhead. For this reason, it has been suggested that a file be created systematically for each standard, containing the following information:
• Feedback from the field
• Recommendations for further development of the standard, submitted by the CEN/CENELEC Consultants during their final assessment
• Reasons for the failure of the standard to address certain significant hazards
• Results of studies and research which are relevant to future revisions, where these become known following publication of the standard
It is evident that standards of high quality can be produced only when all parties involved have sound knowledge of the standards development procedures and the legal significance of standards. In the area of machinery, training of experts on topics such as the New Approach and its successor, the New Legislative Framework, the requirements and essential philosophy of the Machinery Directive, the history of standardization in the area of machinery, and the formulation of safety standards as described in CEN Guide 414 and EN ISO 12100, would be useful for sustained safeguarding of the achievements made to date.
The proposed improvements apply equally to standards developed at international level. Harmonized European standards increasingly form the basis of ISO and IEC standards on the same topics, for the purpose of which they are revised. It is in the interests of all parties involved, regardless of where they come from and the interests they represent, to have high-quality documents at their disposal as a basis, together with all relevant information required for the conducting of standardization work to a high standard.
Jean Jacques (on behalf of the CoS SST)