What’s the difference between OSHA and the EU? We Know.

Companies that want to export machinery to the European Union and manufacture machines need to understand the standards and laws that are applicable in both America and the European Union.   Failure to understand the different legal landscapes of the two areas could lead to costly fines and a failure to sell any products.  Manufacturers can get help navigating compliance issues from companies like Pilz.  Pilz specializes in addressing issues like below and can help local companies become global on either side of the ocean.

What are the differences and similarities between OSHA and EU standard? 
An OSHA standard defining the requirements for machine safeguarding is law in the United States of America. A European directive such as the machinery directive is law in each of the 27 member states. A European Union (EU) harmonized standard is not law but enables machine builders and users to gain a presumption of conformance with the law. A standard produced by ANSI through Standard Development Organizations such as PMMI may not enable employers and machine users to show compliance with an OSHA regulation. If this is confusing, it may be time to call Pilz.

Product Liability Laws
Both the EU and the USA have a product liability law which allows individuals to recover damages for injuries sustained due to a defective product. In the case of a worker injured by machinery, the product liability law may apply for the machinery owner. However, the incidence of product liability law cases with regard to machinery accidents is much higher in the USA than in the EU.
In the EU, if a statutory body is involved, it is more likely that the machinery directive will be applied to ascertain whether the machinery was/is in conformance with EU regulations. Was the machine CE marked by the manufacturer? Did the end user import the machine from outside the EU? Has the end user modified it or created an assembly therefore requiring it to be re certified? Is the employer complying with Use of work equipment regulations? 

End-users of machinery must not only meet the obligation to provide a safe place of work. They also need to ensure compliance with local regulations. The challenge lies in ensuring that the workplace is a safe place for employees and that safety is not compromised because of lack of awareness of all applicable legislation, be it local or international. 

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