How are European standards developed?
Generally speaking, anyone can file a proposal for a standard to be developed if they explain why it is needed. Such proposals are submitted via the national standards body in the country in question (the DIN in Germany’s case), which forwards them to the European Committee for Standardization (CEN) (or CENELEC).
If a sufficient number of CEN members give their consent and are willing to be involved in the development work and if the financing is secured, CEN assigns the project to a Technical Committee (TC), which in turn forwards the mandate to one of its Working Groups (WGs). At the national level, mirror committees follow the standard’s progress. The CEN members appoint delegates to the TC to act as a bridge between the European and national standardization levels and to represent the national opinion. The experts whom the CEN members appoint to the WGs primarily express their opinion as specialists.
The WG draws up the actual text of the standard (working draft). The TC informs the national mirror committee about how work is progressing. It is also the TC that decides whether the draft is sufficiently advanced to be passed via the national standards bodies to the public enquiry stage as a draft European standard (prEN) or whether the WG has to make amendments first.
During the public enquiry stage, all stakeholders can send in comments on the draft standard. In Germany, they send them to DIN. The mirror committee responsible at DIN combines all of the comments in one common German comment and forwards it to the TC. All national comments are discussed by the WG and incorporated into the draft standard in accordance with the WG’s conclusions. The resulting final draft is submitted to the national standards bodies for voting. Once it has been accepted, the standard is published and must be adopted as a national standard by all CEN members. According to the official schedule, standards should be completed within three years.
Harmonized standards listed in the EU Official Journal give rise to a presumption of conformity.
How can OSH stakeholders influence the European standardization procedure?
Firstly, they can file a proposal for a standard themselves if this is deemed necessary for OSH purposes. This approach enables them to formulate their objectives for the standard at an early stage, thus setting the tone for the content of the future standard. But there are also other ways of exerting influence during the preparation of a standard.
The most important and most effective way is to be actively involved in a standardization committee – be it at the national or the CEN level. During the public enquiry stage, comments can be submitted via DIN. In Germany, the Commission for Occupational Health and Safety and Standardization (KAN) can provide support, if desired, for stakeholders seeking to draw up comments concerning OSH. If a key stakeholder in the standardization process, e.g. the OSH sphere, rejects a draft standard, DIN is not allowed to vote in favour of it at the CEN level (“Block vote by an interested party”). It is also possible to convince DIN to vote “No but...“. By so doing, DIN offers CEN a way to have the standard accepted by Germany as well if certain conditions are met.
It is also helpful to discuss the draft standard with European OSH experts via the internet platform set up by EUROSHNET, the European OSH network, before submitting a national comment.
Once standards have been completed and adopted at the national level, they are reviewed every five years. It is also possible to submit a proposal for revision at an earlier date. Again, KAN can support parties interested in doing so.
In the case of harmonized standards, there is a special way of exerting influence once they have been published if they do not comply with the European level of protection. In such cases, the individual Member States can submit a “formal objection” to the European Commission to prevent the standard from giving rise to a presumption of conformity – either completely or in part.