Europe makes its machinery seem safer than equipment built to US standards, because it claims to have unified standards with impressive-sounding standards numbers like IEC 13849, or EN 62061, calling them directives with annexes. But I think they're trying to baffle us with BS. Either that, or they're trying to kill us -- I'm not sure which.
Recently, I had the opportunity to watch a vertical storage system supplied from a EU country undergo troubleshooting soon after it was commissioned. This storage system had a central elevator, which could raise tooling to one of 20 levels in the tower. The elevator could be loaded from either side. The large loading areas, about 3 feet by 12 feet, were protected by light curtains, and you could not fake those light curtains. They were sensitive enough to detect a fly passing through the planes of the curtain and stop the storage system. Really impressive safety light curtains, indeed!
Then, I observed something astounding. Something wasn't working right, so the mechanic stepped through the light curtain, which stopped the elevator as one would expect of a safe system, climbed over the loading area, and stood within the elevator footprint, peering up at whatever it was he thought wasn’t working. His partner then reset the system and started the elevator moving again. The mechanic went completely undetected by the safety system, relying totally on his and his partner's ability to avoid potential injury.
The European safety mandates are nice. They at least give a reasonably central place to look at the rules, but if they're not implemented properly, then all the nice marks on the side of the machine that imply confidence in safety are worthless. This piece of machinery is unsafe in the eyes of OSHA. The end user company is providing a potentially dangerous work environment. Sure, a policy could be implemented as part of the user instruction manual, but an essentially verbal policy will be violated more than it will be followed.
The European model for safety puts the burden of protecting the users on the machinery manufacturer. Someone who purchases a piece of machinery in Europe will look for that CE mark and say, "This is a safe machine because it has the CE mark and must conform to all those directives to have that mark." The example I noted above proves the flaw in this model. The machinery came from an EU country and had the CE mark but wasn't safe.
The US model for safety puts the burden on the end user company; the company must provide a safe workplace for its employees. The end user company can insist on a machine designed to those European standards, but it is still up to that company to make sure the work environment is safe. I think that model goes further to ensure safety; there's another layer of checks that the European model lacks. For all the mandated safety requirements (all those shalls and musts), the European model drops the ball at the last step.
If you're feeling sleepless in Seattle, you can take a look at Swedish Standards Institute’s technical report on safety of machinery. Otherwise, there are plenty of companies selling products relating to machine safety that would be happy to interpret these standards for you, such as Rockwell Automation, Siemens, or Phoenix Contact.
As you point out, TJ, it's not about meeting the letter of the standard as much as it is implmenting it in true spirit. It's analogous to security, where you can tweak your IT infrastructure so you pass a security audit, or you can do things which really protect you against hackers. The two aren't mutually exclusive, and don't have to be. The problem arises -- and it's the same case with the unified standards that apply to machinery -- because the standards often impose such a large cost that there's no money left over to do the "real" stuff too (and meeting the std is prioritized over "real") because then you're in a (finanically) losing situation. I should add that this whole back and forth only really comes into play because the real world is a moving target, while standards take time (eons) to create and agree up, and often by the time they're released the "real" world has passed them by.
The standard-setting bureaucracy, either here or in Europe, is indeed baffling at times. It seems like an ASTM committee can spend 18 months to come up with a definition of something that seems pretty obvious. Safety standards play an important baseline role. They set a foundation. But my takeaway from your post is that the old law applies: caveat emptor. Just because something has a fancy label stamped on it (European, Japanese, Chinese or American) doesn't necessarily mean squat if you're not careful and continue to take the prudent measures you always should.
Standards bodies and safety agencies everywhere are notoriously slow to comprehend and fix safety issues. I don't know how one would go about comparing one continent's safety standards to another's. As Doug so accurately points out: The best policy is always "buyer beware."
Charles, comparing one country's safety to another is done all the time here. The safety seminars I attend discuss the liability US companies face if they sell machines that conform to one standard of safety to be sold in the EU, and another standard of safety in the USA.
The implication is that if someone were to be hurt by the machine built to USA standards, the plaintiff would have a strong case by asking; "why wasn't the better safety design used?"
My point is that the EU model for safety (burden of safety is on the machine supplier) fails if the machinery manufacturer misses something. The CE mark on the side is invalid then. The USA model for safety adds an additional layer of responsibility, that of the end-user company to provide a safe work place for its workers. The lawsuits that arise from work-place injuries always name the employer and the equipment manufacturer. They're both liable.
As much as we like to complain about the litigious nature of U.S. society (I once lost my job thanks to a outrageous tort settlement which bankrupted the company I worked for) it does have some advantages. It helps trial lawyers become very rich, and occasionally destroys companies which have done nothing wrong, while rewarding stupidity - but it also helps deter companies from doing things they shouldn't.
When I worked as a quality manager at one former employer (not the one which went bankrupt, by the way), bringing up the possibility of lawsuits if defective parts were to make it into the field was sometimes the only way to force upper management to sit up and take notice of quality issues they might have preferred to ignore. Regretably, many companies will sacrifice quality in order to save a few pennies per part, unless they have the threat of a multimillion dollar lawsuit hanging over their heads if anyone gets hurt. All of a sudden those pennies start to look insignificant.
The system may be crazy, but that doesn't mean it's always wrong. I suspect T.J. is probably right about the safety of European machinery versus U.S. machinery. If so, we have our crazy legal system to thank.
The example you gave here in the article is another fine demonstration that all the safety devices and regulations in the world are not going to solve the problems if common sense is not applied. Unfortunately, nobody's passed a simple regulation yet that says (to the user) "Don't be dumb".
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