CEN are having considerable difficulty reviewing all of the standards in order to confirm that they meet (and, more problematically, are cross referenced to) the EHSRs of the new Directive and I'm told it's unlikely this task will be completed before the new Directive comes into effect in December. The reason that the list published recently under 2006/42/EC does not have all the standards which were on the previous list for 98/37EC is simply that only the ones containing the relevant annex cross referencing the EHSRs of the new Directive can be officially Harmonised under that Directive.
I would not necessarily take the statement regarding EN 954-1 as being an indication that its transition period is not going to be extended so much as an indication that the process of reviewing the standard against the 2006/42/EC EHSRs will not be completed in time for publication by the end of the year. I've just checked and the list published for 2006/42/EC on 8 September contains at least one standard which still refers to EN 954-1 instead of EN 13849-1. Personally I think all of the fuss about the transition between EN 954-1 and EN 13849 is overblown. A manufacturer is free to chose alternative methods to the Harmonised Standards if they are prepared to make the case that their chosen solution provides an equivalent level of safety and compliance with the EHSRs. Given that there are no fundamental differences to the requirements of safety between the old and the new Machinery Directives, and that EN 954-1 has served the machine control system building community very well for a good number of years, I can see no reason why it cannot continue to be used for some time to come, harmonised or not, particularly in the absence of the component data which EN 13849-1 relies on to be properly applied. If you look at who has actually been asking the song and dance about the replacement of EN 954-1 with EN 13849, it is only a very small number people (mainly manufacturers of control gear and standards/compliance 'experts') who have something very direct to gain from the introduction of the new standard - there is certainly no great appetite for it among people who actually have to get their hands dirty building and maintaining machines or enforcing the Regulations. Nick. At 09:49 -0700 24/9/09, g...@garside.us wrote: >Steve Baldwin wrote: > > In reviewing the list of harmonized standards for the new >Machinery Directive, there are no CENELEC > > standards listed, e.g. 60204-1, 62061. Does anyone know if/when a >CENELEC list will be published? >Steve raises a good question. Further, there are several >CENstandards that are no longer listed either. For example, EN >1010-1 /2/3/4/5, "Safety of machinery - Safety requirements for the >design and construction of printing and paper converting machines". >(NOT to be confused with EN 61010-1.) I am wondering if this is >because they reference EN 954-1:1996 and have not yet been updated? > >Meanwhile, I wrote on Sept 11th that it had been widely reported, >but not confirmed, that the EU commission had accepted the CEN >proposal to extend the date of cessation of presumption of >conformity of EN 954-1:1996 until the end of 2012. THESE REPORTS >HAVE NOW BEEN AUTHORITATIVELY CONTRADICTED. > >(By the way, this discussion of dates of cessation of presumption of >conformity only affects the European standards, EN954-1 and ENISO >13849-1. Internationalstandard ISO13849-1 is obviously controlled by >ISO and not by CEN or the EU. The current edition of ISO 13849-1 is >2006, essentially identical to EN ISO 13849-1 : 2008.) > >At this point the possibility of an extension of the transition from >EN 954-1 to EN ISO 13849-1 remains controversial, confused and IMHO >somewhat unlikely. (There's been approx 3 years transition period >already.) If I were still a manufacturer, I would not want to wait >until Dec 29th to find out if I could still ship my product using EN >954-1! > >Could we imagine some compromise to clarify the situation of >standards such as EN 1010-1, and perhaps allow those to live on for >a while? In other words, if your product has a Type C standard that >has not been revised yet, you still should have your "3 years" to >transition. But if you have been basing compliance only on generic >standards such as EN 954-1, you have had 3 years to "get with it", >so "enough already, and quit with the whining". [The EU >Directorate-General for Enterprise and Industry may well use >different wording to express this sentiment.] > >The reports of an extension were based on an email sent earlier this >month (3rd Sept) by a CEN employee. However, the EU Commission never >confirmed the report, and in the last few days, the same CEN >employee, Marie Poidevin, has written, >----------------- >> "We have been informed today by the European Commission [...] that >>contrary to what was expressed in > > my previous message sent on the 3rd of September, EN 954-1 will >not give presumption of conformity > > to the new MD 2006/42/EC until further notice. >> "Indeed, due to discussions following the announcement made below, >>the EC wishes to gather experts' > > views and, therefore, this issue will be discussed at the next >Machinery Working group to be held on > > the 7-8th December." >----------------- > >Regards, >Glyn Garside >- >---------------------------------------------------------------- >This message is from the IEEE Product Safety Engineering Society >emc-pstc discussion list. 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To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@socal.rr.com> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
