EN 954-1 for CE-marking can now be used until December 31st, 2011

December 29^th the new Machinery Directive, 2006/42/EC became effective. On the same day, the Official Journal of the European Union, published a two year extension of the validity of EU safety standard, EN 954-1.

The new date of cessation of presumption of conformity for EN 954-1 is 31 Dec 2011. The two-year extension granted by the EU Commission is less than the three years requested by the EU Standards-making bodies.

The official announcement can be read at

http://eur-lex.europa.eu/JOHtml.do?uri=OJ:C:2009:321:SOM:EN:HTML

During the transition period, which started in 2006, machinery manufacturers can assess compliance of their control systems to the EU Machinery Directive (for CE marking) using either the superseded standard, EN 954-1, or its successor standards, EN ISO 13849-1 (2006 and 2008 editions) and EN 62061 (2005).

Impact on machinery destined for USA and Canada

“It is increasingly likely that machinery purchasers will specify the use of the latest standards (including ISO 13849-1 and EN ISO 13849-1), regardless of whether an “old” standard is still allowed for presumption of conformity in EU.  They have good reason to do this.  They are assured that their equipment meets all of the current EU and International standards, which is extremely important if they choose to re-locate the equipment at a later date when the “older” standards are no longer valid.  And of course from a liability standpoint, machinery purchasers may choose to use the latest standards as an element of their risk management programs,” says Roberta Nelson Shea, General Manager of Michigan-based Pilz Automation Safety.

International Impact

It should be noted that while EN 954-1 is recognized throughout the world, it is not an international standard. This is an important aspect, particularly for machine manufacturers and users that operate internationally. At an international level, ISO 13849-1:2006 (second edition) has already replaced the first edition of ISO 13849-1: 1999, which was based on EN 954-1.

EN 954-1 no longer represents the state of the art

First and foremost, the EN 954-1 represented the state-of-the-art in machinery safety design in 1996. There have been many changes in machine safety and control technology in the last 14 years.

Product-Specific Standards

Many Type B and Type C (product-specific) standards listed under the current Machinery Directive already refer to EN ISO 13849-1 and EN/IEC 62061. These include, for example:

• EN 61496: Safety of machinery – Electro-sensitive protective equipment
• EN ISO 13850: Safety of machinery – Emergency stop – Principles for design
• EN 848: Safety of woodworking machines

Other C standards will gradually be amended accordingly. Once these standards are amended, application of EN 954-1 would no longer enable presumption of conformity for these standards. This leaves machine builders and integrators with the unsettling situation where they either use

• EN 954-1, but instead of using the applicable C level standard instead they comply with the Machinery Directive

OR

• the applicable C level standard which requires EN ISO 13849-1 or EN/IEC 62061

Builders and integrators would then have to ask themselves, What does this mean from a liability standpoint if the machinery is different depending on the approach used?  What does this mean if the machinery is moved in two years? 

Support in converting to the new standards

Pilz has already certified its products to EN ISO 13849-1 and EN/IEC 62061 and has also tailored its services to suit, from training to implementation of providing CE marking services.

What’s more, Pilz’s PAScal Safety Calculator provides a convenient software tool for calculating the performance level and safety integrity level that safety functions can achieve based on the components used. A free trial copy of PAScal is available for download from www.pilz.us. Unlike SISTEMA, PAScal supports EN/IEC 62061 as well as EN ISO 13849-1.

Pilz supports design engineers in the United States, Canada and around the world who have already converted to EN ISO 13849-1 and EN/IEC 62061. At the same time, Pilz continues to provide products, services and technical support for those design engineers who have chosen to continue to apply EN 954-1.

Pilz, the company

The world leader in SAFE automation; Pilz offers a full range of leading-edge safe automation products and services. The company’s innovative technologies and safety expertise provides customers with the leanest and safest solutions.

Products include sensor technology, electrical monitoring relays, and automation solutions with motion control, safety relays, programmable safety and control systems and an operating and monitoring range. Wireless and safe bus systems are also available for industrial networking.

Pilz also provides a comprehensive range of consulting, engineering and OSHA-approved training services. Certified consultants provide a wide range of services in USA, Canada and worldwide including risk assessment, safety concept, safety design, LeanSafe™ services, CE-marking and safety sign-off. Pilz also performs facility safety reviews for due diligence relating to mergers and acquisitions.

For more information visit www.pilz.us or call 1-888-650-PILZ (7450)

The New Machinery Directive is Here!

The directive stipulates that:

Particular attention must be given to the following points:

• the machinery must not start unexpectedly
• the parameters of the machinery must not change in an uncontrolled way, where such change may lead to hazardous situations"

Parameter monitoring systems, such as low speed run, which through risk assessment are considered as a risk reduction measure must be implemented in accordance with appropriate devices and systems. Risk assessments must also identify normal or abnormal conditions which could lead to an unexpected start up and prevent such start up through the safety related control system.

Ready to go?

http://www.pilzamerica.com/articles/Pilz-Ready-to-go.pdf

Calculated Safety: SIL Calculation in accordance with IEC 61508/61511 in process-based applications

http://www.pilzamerica.com/articles/Calculated-Safety.pdf

the New Directive?

How will the new machinery directive be enforced?

Freedom of movement of machinery is guaranteed with the "passport of the CE mark". As most machines are placed on the market without independent certification by notified bodies, surveillance is essential to the fair and effective operation of the single market for the supply of machinery. Directive 98/37 dopes not use the term "market surveillance". However, in the new MD the framework for market surveillance is now clearly stated ina new Article 4 specifically dealing with this aspect.

• member states must take measures against non-complying products
• there must be a known national competent authority
• tasks and powers of such authority must be clearly defined and transparent

Properly applied, this strengthening of the "policing" aspects will ensure a fair market place with a high standard of safety. In addition, such authorities in each member state are obliged to consider machines that may be unsafe when used for their intended purpose but also machines that could be unsafe "under conditions which can reasonably be foreseen".

My company receives machinery from our parent company in the USA. What are the implications of the new machinery directive?

You need to ensure that the machine conforms to all applicable directives including the new machinery directive. Additionally, you need to designate a person established in the community to be responsible for the compilation of the technical construction file. This could be a competent person in your own organization or a third party you appoint.

What is an authorized representative?

The machinery directive anticipates that machine builders may require appointing competent persons to carry out some or all of the administrative and assessment procedures required to CE mark a machine. The new machinery directive defines an authorize representative as "...any natural or legal person established in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this directive..."

What happens if a worker is injured as a result of safety defect on a machine?

Many factors come into consideration in answering this question. The new Machinery Directive requires member states to implement penalties that are effective, proportionate and persuasive. However, it is up to each member state to decide on the appropriate penalties. Other national laws may come into play in relation to civil or criminal prosecutions. It should be understood that the "Product Liability Directive" applies in cases where a product "does not provide the safety which a person is entitled to expect."

Is this the only directive impacting suppliers and users of machinery?

No. There are a number of other directives, many dating back to the 1980's, that you need to be aware of. When creating the single market, the social partners agreed that protection of the Health, safety and Welfare of workers was a key value within the community. This led to the enactment of the "Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work."

Another important directive is "Council Directive 89/655/EEC of 30 November 1989 concerning the minimum safety and health requirements of the use of work equipment by workers at work" (and subsequent amending directives 95/63/EC and 2001/45/EC). This directive impacts employers who use machinery and sets out minimum requirements for existing machinery and requires that all new machinery should meet the requirements of all applicable directives, including the machinery directive.

Q. Did the original directive result from the creation of the single market in Europe?

A. Yes, the single market depended on the elimination of barriers to trade between member states and enshrined protection for the freedom of movement of capital, people, goods and services. The Engineering and Machine building sectors were and are important sectors of the European economy. However, prior to the first machinery directive there were no common regulaions or standards for machinery supplied on the market. The aim of the EU in introducing the Directive 89/392/EEC and it's amending Directive 98/37/EC, generally known as the "Machinery Directive", was to ensure the free movement of the products within the scope by guaranteeing a high and common level of protection in the areas of health, safety and consumer rights.

Why Did the European Commission Create a New Machinery Directive?

A.
As with all laws drafting is not perfect and the commission recognized gaps between the effects that were intended and achieved in the original drafting. A commissioned study by a high level group of independent experts into the practical application of the machinery directive resulted in the "Molitor Report". This report issued in November 1995 contained 12 recommendations for simplifying the application of the Machinery Directive. Most of these recommendations have been followed in Directive 2006/42/C. The objectives in introducing a new directive are to: provide a better definition of key concepts within the directive, to clarify certain aspects and requirements which were perceived as ambiguous, to ensure uniform application, to consolidate and simplify the application of the directive in harmony with other EU directives and to provide greater legal certainty for buyers and suppliers.