Responsible employers make strenuous efforts to keep their employees safe and healthy at work. When workers are involved with machinery there is an almost constant debate about the relationship between the inherent level of safety of the machine and the safety which needs to be provided by operational procedures in the workplace.
When a new machine is delivered to a site nobody in their right mind would assume that it is so safe that anyone could use it without there being any risks. Think of a car. Modern cars are much safer than those of the past, with anti-lock braking, air bags and so on. But even though a non-driver could go out and buy any car, we all hope that they wouldn’t actually get behind the wheel without going through a proper process of instruction and test. And then, when we go out on the road, we all rely for our own safety on other road users sticking to the rules. This is not new in that we all know that in our daily lives, as in the workplace, keeping ourselves and others safe requires a combination of having safe equipment and using it safely. But what does “safe equipment” actually mean? For example, it is simply impossible to make a safe chainsaw or disc cutter, so does that mean that they are dangerous and should not be sold, or does it mean that they should be made as safe as reasonably possible and then used with extreme caution? Well, they are still on the market so the answer is clearly the latter, but how do we define how safe they need to be?
There is a legal duty on machinery suppliers to make their products conform to the European Union (EU) directive on machinery safety. That includes a requirement to meet the safety requirements “taking into account the state of the art”.That means that manufacturers should go as far as is technically and economically possible in reducing the risks presented by their products. However, everyone could come to a different interpretation of what that means in practice, so for many types of machinery manufacturers use published European standards to define what level of safety provision to make. This can lead to disagreements between manufacturers and users because there is always a time lag between the development of new technology and when it gets written into standards. Users would sometimes like new features to be offered as standard immediately they become available, whereas machinery suppliers might take a more cautious view. They often want to share views with experts from other companies and with health and safety professionals, and to conduct extensive testing. The testing that machinery manufacturers always want to see done is not only to check that the new technology performs well, but that it is also robust, durable, and does not have any adverse impacts on the rest of the machine. While this can seem frustratingly slow to users, the manufacturers’ view is that when a standard is published, everyone can be confident that the solution is well proven, and it re-sets the benchmark for everyone to comply with.
What is a harmonised standard?
There are various bodies that develop standards. However, with regards to the EU Machinery Directive the only standards that count are those endorsed by the European standardising body, CEN, and by the European Commission. They then become harmonised, and complying with them provides a manufacturer with a legal protection which means, on the whole, that they can’t be held to be not complying with the law on machinery safety.
Who writes machine safety standards?
The process of writing European standards is open to any group but in practice the most active contributors are safety authorities (like the Health & Safety Executive) and the machine manufacturers. Manufacturers are usually much more involved than the users. This means that people with day-to-day knowledge of machine use are very often not in the room when the issues are being debated.
It doesn’t have to be like this. There is no closed shop for the writing of standards so anyone with expertise to offer, and a real interest in helping, can join in. Greater involvement of machine users in the writing of the safety standards would help in two ways: firstly, the standards would be better in that they would have the experience of users baked in, and secondly the process of arriving at those standards would be better understood by users, meaning that they would better know where machinery inherent safety ends and operational (management) safety needs to take over. Machine users could not only be involved in reviewing existing standards but could help to set the agenda for what new standards should be developed. There is an open door for involvement in the process, and really valuable work to be done.
- Malcolm Kent is senior technical consultant to the Construction Equipment Association