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