KANBrief 1/20
2019 was a special year for KAN: it marked 25 years of successful advocacy for the inclusion of OSH concerns in standardization activity. On 4 December, 160 guests from eight countries met at the Berlin premises of the DGUV to celebrate the anniversary. They did not, however, only look back. The talks and discussions focused on how standardization and regulation can respond to the issues of digitalization, artificial intelligence and the increasingly rapid pace of technical development.
Dr Stefan Hussy of the German Social Accident Insurance (DGUV) welcomed the guests by stating that over the last 25 years, KAN has become an essential element in Germany's prevention system. In order to ensure that in the future, the body of state rules and regulations and those of the German Social Accident Insurance dovetail with standardization activity in a way that meets the needs of industry, it is particularly important for the philosophy of Vision Zero be integrated into standardization processes at an early stage.
In 1989, the Machinery Directive imposed for the first time a requirement upon the EU Member States to involve the social partners more closely in the standardization process at national level. In Germany, the response was the foundation of KAN. Today, as KAN Vice-Chairman Heinz Fritsche (IG Metall trade union) said in his review, it is a successful project based upon social partnership which benefits more than ever from the social partners' liaison offices being located directly at the KAN Secretariat. KAN is now taken more seriously than ever before and consulted for its advice and support.
Dr Dirk Watermann (Director of the KAN Secretariat) pointed out that over the 25 years, standardization topics have multiplied and that work equipment has developed into high-tech products. Furthermore, standardized requirements are now being formulated for many fields such as biologically effective lighting, services, OSH management systems, human resources management and risk management. KAN's work has thus long ceased to be limited to traditional product standardization; it now actively addresses the new tasks and subject areas for standardization and regulation arising from these developments.
Dr Lars Adolph (Federal Institute for Occupational Safety and Health/BAuA) described the magnitude of the challenges to prevention activity caused by "artificial intelligence"(AI) alone. He pointed out that artificial intelligence offers considerable potential to improve safety and health; at the same time however, it may also give rise to new threats. Restrictions on the use of AI must therefore be made in consideration of certain risks, and the existing regulatory framework must be reviewed for this purpose. AI is changing the interaction between human beings and technology, and raises the question which of them is in charge in cases of doubt.
In the first of three panel discussions, Dr Thomas Zielke (German Federal Ministry of Economics and Energy/BMWi), Christoph Winterhalter (German Institute for Standardization/DIN) and Kevin Behnisch (German Commission for Electrical, Electronic & Information Technologies/DKE) were in agreement that standards still have a vital role to play, despite the developments witnessed in areas such as digitalization and artificial intelligence. In the panellists' view, only standardization is able to describe the state of the art swiftly whilst at the same time involving all stakeholders – and not only nationally, but above all at international level. At the same time, they considered standardization in its conventional form to be a less suitable means of supporting the development of new technologies. They drew attention to DIN SPEC PASs (publicly available specifications), which shadow such developments. This form of document is intended primarily for researchers, and provides an incentive to address the underlying conditions – which include safety aspects – for new technologies from an early stage. Should this not take place, new technologies would not work in practice and would fail to meet with acceptance. If required, the content developed provisionally in DIN SPEC PASs could subsequently be exploited during the development of conventional standards.
Members of the audience commented that the new deliverables should not compromise on the involvement of the stakeholders or the transparency of the processes that are a feature of conventional standards development. Confidence in the new deliverables and by extension in the standards organizations themselves might otherwise suffer as a result, and indeed the safety and health of workers and consumers might be jeopardized.
In a second panel discussion, Stefan Pemp (Lower Saxony Ministry of Social Affairs, Health and Equality) and Dr Christoph Hecker (German Social Accident Insurance Institution for the woodworking and metalworking industries/BGHM) emphasized the traditional core function of standardization within the EU legal framework: that of enshrining primary prevention by defining the "state of the art" for work equipment and consumer products. As they pointed out, the key advantage of harmonized standards is that the machines and products that reach the market as a result are beneficial to occupational safety and health. Participation in the standardization of work equipment, machine safety or measuring methods is a highly efficient way of promoting occupational safety and health.
Attention was however also drawn to the influence of particular stakeholders within the standardization committees, which are generally dominated by manufacturers' representatives. This is not necessarily a drawback, as the manufacturers often act in concert with the OSH community. It would nevertheless be desirable for the OSH lobby to be accorded equal status with other stakeholders in all committees from the outset and as a matter of principle. This, the panellists argued, is particularly important when the safety and health of workers at work is an issue: in many cases, standardization and occupational safety and health are in conflict.
KAN Chairman Peer-Oliver Villwock (German Federal Ministry of Labour and Social Affairs/BMAS) emphasized that good standards, developed with German participation, would acquire even greater importance in tomorrow's digitalized and networked world. Not only would they guarantee the legal and operational correctness of activities, they would also make harmonized safety standards an asset for industrial locations. The changes in underlying conditions to which the new technologies give rise could however result in state technical regulations and those of the accident insurance institutions, and the standards and similar documents produced by the most diverse institutions and consortia, becoming even more complex and difficult to apply. Prevention must respond to this issue and ensure that regulation not only adapts to innovative developments, but is also made more coherent and user-friendly.
Concepts and instruments for prevention have become established over a period of decades at national level in Germany. What we are now observing much more strongly however compared to 10, 15 or even 25 years ago is the desire on the part of other EU Member States to shift to a European view of occupational safety and health and to regulate it Europe-wide, including through standardization. Stefan Olsson (Directorate-General for Employment of the European Commission) does not anticipate the safety and health of workers at work being fully harmonized across Europe in the future. However, a broad consensus exists in the committees of the European Commission for support in risk assessment, strategic framework conditions for occupational safety and health and occupational exposure limits for particularly important carcinogenic substances to be launched at European level.
In a third panel discussion, Peer-Oliver Villwock (BMAS), Carsten Rogge-Strang (employers' association of the private banking industry/AGVBanken), Michael Schleich (employee representative committee of Dillinger Hüttenwerke AG), Dr Stefan Hussy (DGUV) and Stefan Olsson (Directorate-General for Employment of the European Commission) exchanged views on national OSH regulations. It was pointed out that this body of regulations is very complex, owing to the growing complexity of the world of work. The key lies in coordinating the many different regulatory levels even more effectively in the future. Above all, OSH regulations must be made more accessible to users, who must also be aware of which rules and standards are relevant in their respective practical situations. In international terms, Germany's occupational safety and health system is seen to be well positioned and other countries, such as China, are seeking to learn from it. The role of the social partners, to which great importance is attached in Germany, is also of interest in other countries.
KAN Vice-Chairman Kai Schweppe (Südwest-Metall employer's association) brought the anniversary event to a close by venturing a look into the future. In his view, KAN and its activities need to become even better known. The German Social Accident Insurance Institutions and the BMAS support the changes necessary to achieve this, and with their long-term funding have enabled the KAN Secretariat to develop its activities and expand its personnel further. These changes are all necessary in order for the provision of support to workers, employers, industry associations, the state, statutory accident insurance institutions and the general public to continue to be assured in the future. As Mr Schweppe pointed out, KAN ensures that products, processes and services are of safe and ergonomic design; it promotes consistency and practical relevance within the body of rules and regulations; and it presents the position of the OSH lobby at an early stage through active participation on European and international standardization committees. Mr Schweppe called for participation in standardization and appealed to all stakeholders to join with KAN in strengthening occupational safety and health further in the future.