EUROSHNET 6th European Conference Dresden – 13-15 June 2019

1. EUROSHNET 6th European ConferenceDresden – 13-15 June 2019 “Session 2: Standardization, testing and certification – keeping pace with change” EU Standardisation systemWhat needs to be improved to make it fit for the future phil@papard.uk

2. EU Standardisation system • The single market is a key pillar of the EU • Harmonisation of health, safety and environmental equipment is the key requirement • The mechanism to get this is harmonised standards • Legislation sets objectives: harmonised standards give details and set the “state of the art” - thus they are part of the EU legal single market acquis • Production and maintenance of standards is given to industry and users via CEN, CENELEC • The various players producing and using work equipment, as well as those enforcing legislation, should be involved to give a balanced approach

3. EU Standardisation system • There was some balance in WGs with members from industry and market surveillance authorities (MSAs) • There was never a significant involvement from user industries, SMEs or users/workers • Due partly to the historical role of agreeing industrial standards, by industry using a democratic system • Industry has vested interests in ensuring standards don't conflict with products: does not apply to user side • This imbalance was partly corrected by involvement of MSAs who had direct knowledge of problems • From mid-1990s MSA input dropped and accelerated since 2000 now hardly any WGs have MSA involvement

4. EU Standardisation system There have been improvements in the system: • EU has changed how it evaluates standards for compliance with the consultants now reporting to the Commission rather than to CEN and CENELEC • This change should ensure standards in breach of legislation are not listed in the OJ and so do not carry any presumption of conformity • This “end game” approach should mean new harmonised standards are compliant, it will not address the need to get information from users into the process • Despite these concerns most standards are good and address key issues, as industry want safe products and put a lot of effort into the process

5. EU Standardisation system • The standards of concern are mainly for final products and in particular industrial machinery such as used in construction, and agriculture. For example: • UK and Germany had concerns about poor visibility from some construction equipment including telehandlers, front wheel loaders and dumper trucks. To get the relevant standards improved they were forced to instigate formal objections to the standards • Similarly with powered gates in the UK where a number of fatal accidents to children showed defects in the complicated suite of standards. Again a formal objection was required to get the needed changes • A concern is the lack of targeting at ergonomic issues in the use of work equipment that can cause chronic health problems. This is partly due to illness not being investigated (unlike accidents) and so remain hidden

6. EU Standardisation system • We have some big improvements: • The new consultant system • The agreement that harmonised standards are part of the EU Acquis • The more rigorous system for listing in the OJ • However, we should prevent standards being developed in the first place that arenot fully compliant

7. EU Standardisation system Suggested changes to improve the system • ADCO system to deal with standards where MSA members have problems • Agree the problem and what needs to be addressed and collate the evidence • Information passed via an ADCO representative to the CEN/CENELEC WG giving help if needed, but not to join formally or take part in all the meetings. • ADCO to monitor progress and advise if compliant • Two trials are running with a joint ADCO/CEN forum to take the matters forward. Some delay due to staff changes, but it is agreed to re-activate this year • If successful it should help to counter the lack of MSA members on key CEN/CENELEC WGs

8. EU Standardisation system Suggested changes to improve the system

9. EU Standardisation system Suggested changes to improve the system • Feedback method • This ergonomic tool was developed in Italy by Fabio Strambi and used in UK, Sweden, Germany • It is now published as CEN/TR 16710-1 - Ergonomics methods - Part 1: Feedback method - A method to understand how end users perform their work with machines • It enlists information from 8–12 workers in a structured off-work environment with facilitators familiar with the method, work equipment and the standards • One output is a technical report for the standards WG and this system should be used by industry and WGs to get data from experts – i.e. the drivers and operators

10. EU Standardisation system Suggested changes to improve the system • Feedback method as a MACHEXproject(MACHEX is a committee of labour inspectors responsible for the use of work equipment reporting to the Senior Labour Inspectors Committee under DG Employment) • This proposed MACHEX project uses the Feedback Method, so labour inspectorates can proactively identify ergonomic problems with the work equipment • It is important as chronic health problems such a musculoskeletal and psychological problems are hard to identify, but cause much absenteeism and ill health • This project will pass critical information to the standard makers if it is agreed with the Commission. If successful it will be a useful tool in feeding critical information into the standards making arena

11. EU Standardisation system Suggested changes to improve the system • No cost access to WGs and use of on-line meetings – to reduce cost and time involved and encourage users and SMEs to take part • System to obtain views from users in a simplified format – for engineers forms are not a problem. But for users it can be an obstacle. I would like the Commission to fund the transfer of “free form” information into the normal CEN/CENELEC format • Development of the new consultant’s role - I would like a closer working relationship with the ADCOs and expert groups. This needs more resources and is therefore a political issue

12. EU Standardisation system Suggested changes to improve the system • Free access to key Standard information – it can be difficult for MSAs, users and SMEs to fund standards. As a start have free on-line access to all of Annex Z plus a list of all normative references. This would allow the sight of what the standard covers and if they are a “complete standard” capable of giving a full presumption of conformity • Free on-line access to Harmonised Standards – as harmonised standards are part of the EU acquis it seems odd that directives have free on-line access, but harmonised standards do not. What is worse is that normative references mean a number of standards have to be purchased for one item of equipment. I would like free access to all such standards! But this may be a step too far at present!

13. EU Standardisation system Suggested changes to improve the system • Political and resource issues • There needs to be a shift in political priorities to put the surveillance of the single market at a higher level • MSAs get less resources, hence withdrawing from standards and proactive market surveillance work • Surveillance is fragmented between various Commission Directorates. I would like a single Directorate responsible for market surveillance and reporting of MSA work to the public and industry • Clearly this is a high-level decision that we can only lobby for via our MEPs and at relevant meetings. The target now should be to develop the ADCO Machinery, MACHEX and similar projects and get good cooperation between these and standards bodies

14. Questions ?