KAN updates its position on fast-track standardization documents

"Fast-track" standardization documents such as DIN SPECs and CWAs are not subject to the full breadth of essential standardization principles, such as participation by all stakeholders in the process. KAN therefore considers such documents fundamentally unsuited to the formulation of provisions governing occupational safety and health.

Special types of document satisfy the needs presented by technological developments in fast-moving industries such as the IT sector, and the need for swift standardization of research results. These documents are published under the umbrella of standards organizations. They include DIN SPECs, VDE SPECs, VDE rules of application, CEN and/or CENELEC Workshop Agreements (CWAs) and International Workshop Agreements (IWAs). They can be developed and published significantly more quickly than standards.

The growing number of fast-track standardization documents being produced is indicative of their increasing acceptance in the market, for example in the area of services and e-business. They are also being produced more and more frequently on topics relating to safety and the protection of health.

Position statement brought into line with developments

KAN's position statement, setting out that safety and health issues should not be addressed in DIN SPECs or CWAs, dates back to 2013. An update of this position statement has now been produced and was published in December 2022. One reason for the update was DIN's change of the designations for fast-track documents during its revision of the DIN 820 series of standards (in German), Standardization. In addition, VDE SPECs, VDE rules of application and IWAs are common document types that were not included in the original KAN position statement. The position statement is also based on an agreement between DIN and KAN, adopted in 2020, on the treatment of DIN SPECs.

The key argument of the position paper is that fast-track standardization documents are not subject to the full breadth of essential standardization principles. Rules governing the following aspects lend significant legitimacy to standardization work:

• The composition of the committees conducting the work
• The means by which stakeholders can participate in the standardization work
• The authorizing procedures by which the final working documents are released for publication

Where European and international standardization work is concerned, the rules also include the principle of national delegation.

Key statements of the position paper

Standards, technical specifications (e.g. DIN/TSs, CEN/TSs, ISO/TSs) and technical reports (e.g. DIN/TRs, CEN/TRs, ISO/TRs) are developed in line with the requirements of the ISO/IEC Directives or the CEN/CENELEC Internal Regulations or DIN 820. Documents of relevance to occupational safety and health should be developed and adopted by committees subject in full to the rules for standardization work, as described above. These requirements contrast with those for fast-track standardization documents, which are prepared outside the normal standards committees and in the shortest possible time. KAN has adopted the following position on such documents:

• In accordance with its agreement with DIN, KAN has a range of options for exerting influence upon DIN SPECs in cases where they could impact upon occupational safety and health issues.
• KAN's position on CWAs has not changed since the position paper was first published: the procedural rules for CENELEC Workshop Agreements already specify that they must not address safety aspects. In KAN's view, CEN Workshop Agreements and IWAs are also unsuitable for regulating occupational safety and health and other safety aspects.
• A new point concerning the rules of procedure for development of VDE rules of application has been added to the position paper. In KAN’s view, the rules of procedure should clarify that VDE rules of application may extend to safety issues only if participation of the stakeholders is ensured and the document is approved by a DKE committee.

The position paper will serve in particular as a basis for KAN comments on fast-track standardization documents. The revision also reinforces the agreement between DIN and KAN, which to date has been productive.

Katharina Schulte
schulte@kan.de

Katharina von Rymon Lipinski
vonrymonlipinski@kan.de