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C O N T E N T S :
1. Introduction
2. Objectives of the seminar
3. Feedback, the method agreed with the project partners
4. The national data collection exercise
5. Round table
6. Overall conclusions and future plans/perspectives
B R U S S E L S , 2 7 M A R C H 2 0 0 6
A European system to improvemachinery safety by drawing onusers
experience
Stefano Boy, ETUI-REHS Officer, Machinery Safety and
Standardisation
Summary of the seminar organisedby the Health and Safety
Department of the EuropeanTrade Union Institute for Research,
Education,Health and Safety (ETUI-REHS)
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P A G E 2
1. Introduction
This publication summarises the results of a seminar (27 March
2006, Brussels), orga-nised by the European Trade Union Institute
for Research, Education, Health and Safety(ETUI-REHS) to unveil its
strategy for improving machinery standards through usersfeedback.
Under the chairmanship of Bart Samyn, Deputy General Secretary of
theEuropean Metalworkers' Federation (EMF), the five ETUI-REHS
national partners Finland, France, Germany, Italy, United Kingdom
presented the main findings of aproject on forklift trucks (FLTs),
together with a selection of design issues arisingdirectly out of
users' experience.
The seminar was the culmination of a five-year research project,
during which ETUI-REHS was involved in two studies that developed
and refined a method to acquire userknowledge on selected machines,
structure it and make it available in a format usable
tostandard-setters. The first study investigated woodworking
machinery in Italy; thesecond investigated FLTs in Germany and
Italy.
The projects outcomes were then used to develop a wider European
project across fiveMember States, centred on FLTs covered by the
harmonised standard EN 1726-1:1998Safety of industrial trucks
Self-propelled trucks up to and including 10 000 kg capa-city and
industrial tractors with a drawbar pull up to and including 20 000
N Part 1:General requirements.
1. The so-called Vienna Agreement establishes technical
cooperation between ISO and CEN. The agreementsets out two
essential modes for collaborative development of standards: the
mode under ISO leadand the mode under CEN lead, whereby documents
developed within one body are notified for simultaneousapproval by
the other.
EN 1726-1:1998 Safety of industrial trucks was published in the
Official Journal on 30May 2000. It is being revised under the
Vienna Agreement1 as EN ISO 3691-1. Afirst DIS (Draft International
Standard) enquiry was concluded in April 2004, and theresulting
comments have been examined, together with the assessments of the
CENConsultants Machinery and Noise. On 9 February 2006 a second DIS
enquiry waslaunched, its deadline being 9 May 2006. Since some
hazards have been excludedfrom the scope of ISO 3691-1 (i.e. noise
and vibrations), CEN TC 150 has decided toadd to ISO 3691-1 a
European complement, with the objective of having a finaldocument
(ISO 3691-1 + European complement) that gives presumption of
confor-mity to the Machinery Directive requirements. The European
complement will be draf-ted by a new working group of TC 150. Its
composition will be decided shortly.
EN 1726-1 is a so-called Type C standard, according to the
definition adopted by CEN for the purposes of itscontract with the
European Commission. More precisely, the harmonised standards
programme suppor-ting the Machinery Directive 98/37/EC is
structured as follows:
Type A standards lay down basic concepts, principles for design
and general aspects that can beapplied to all machinery;
Type B standards deal with one safety aspect (e.g. minimum
distances, noise, temperatures) or onetype of safeguard that can be
used across a wide range of machinery;
Type C standards cover detailed safety requirements for a
particular machine or group of machines.
The machinery safety programme assists the standards users to
claim 'Presumption of Conformity' with theMachinery Directive.
So far 638 Harmonised European Standards have been referenced in
the Official Journal of the EuropeanUnion, including 116 type A
& B standards together with 522 type C standards. Some type C
standardsdeal with complete machines and others deal with specific
safety components for a given machine or par-ticular parts of a
given machine.
The list of harmonised standards supporting the machinery
directive can be found at the following
page:http://europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/reflist/machines.html
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P A G E 3
COUNTRIES FINLAND FRANCE GERMANY ITALY UNITED-KINGDOM
(between 1987 (between 1990 (between 1994 (between 2001and 2003
and 2003) and 2000) and 2005)
ACCIDENTS 5 315 (between 141 852 191 325 117 904 Partially
know1993 and 2001) (3 530 for over
3-days injuries)
PERMANENTINVALIDITY Not Know 10 823 8 905 10 354 1 563
FATAL 31 (between 205 309 152 29ACCIDENTS 1985 and 2001)
Key FactsForklift accidents have increased dramati-cally in
recent years. Most forklift acci-dents involve the driver hitting a
co-wor-ker. Blocked vision, blind intersectionsand operator
inattention are often factorsin accidents that involve forklifts
runningover pedestrians. Most forklift fatalitiesoccur when lift
trucks overturn.
Accidents also occur when workers violatesafe work procedures
and fall from raisedforks or from pallets on the forks used
aslifts. Other accidents involve pedestrianswho are struck by
falling loads or getcrushed between the forklift and a fixedobject
or other vehicle. Operators areoften injured when their arms, legs
orother body parts are struck or caught asthe lift truck sideswipes
a wall or storagerack. The following table summarises theaccident
data provided by the ETUI-REHS partners involved in the project
onFLTs:
There is little doubt that forklift driving isa skilled
operation, requiring constant vigi-lance and alertness in regard to
vehiclemanoeuvring, hazard perception and safeload handling. In
this connection, high-quality driver training and licensing
requi-rements are an important step in ensuringthat at least
minimum aptitude and skilllevels are achieved.Good training must
complement inherentdesign measures. Exclusive reliance on trai-ning
and driver skill to overcome deficien-cies in vehicle design (poor
visibility anddifferent control layout on different forkliftmodels,
for example) should be avoided.
ETUI-REHS shares the view that effectiveinjury risk reduction
can be achieved byusing sound ergonomic design to reducethe ongoing
performance demands madeon the operator to avoid accidents.
Theforklift truck project was carried out withthis key prevention
principle in mind, inthe belief that it is more effective to
removeand/or control the hazard to achieve saferworkplaces. This
means designing worksystems (the equipment, the environmentand the
job) so that they are inherently safeor more accurately expose
their users tolower levels of risk. In this connection, it isworth
mentioning that the safety integra-tion method enshrined in the
MachineryDirective 98/37/ EC has been furtherconsolidated during
its revision: the textrecently adopted by the Council includes anew
paragraph on risk assessment in thenew introductory section to
Annex I.
2. Objectives of the seminar
The seminar brought together an audienceof representatives of
the European Com-mission, CEN, labour inspection authori-ties,
social partners and European enterpri-ses. It provided an
opportunity to engagein debate on what practical steps needto be
taken to help set up a permanentmechanism for feeding users'
experienceinto a knowledge base that can guide stan-dardisation
work, market surveillance acti-vities and Community initiatives to
streng-then the legislative framework regulatingthe single
market.The two distinct legislative frameworksregulating the
working environment andproducts moving within the Single
Marketshould complement each other. Time andagain ETUI-REHS has
stressed the needto mount research projects aimed at achie-ving a
better understanding of the rela-tionship between the risk
assessment requi-red of manufacturers by the MachineryDirective
98/37/EC and the risk assess-ment required of employers by the
WorkEquipment Directive 89/655/EEC.The day was structured around
two mor-ning sessions presenting the ETUI-REHSstrategy, and two
sessions in the afternoondealing with more technical
standardisa-tion issues. Three national OHS Officialsinvolved in
the ETUI-REHS forklifttrucks project were invited to present
theircase studies to illustrate how machinerydesign shortcomings
could be successfullyrevealed by applying the ETUI-REHSmethodology
based on the feedbackmethod developed by Fabio Strambi,Director of
the OHS service at the LocalHealth Authority Unit (USL) in
Siena.
This publication is based on speeches andcomments made during
the seminar ses-sions and the round table discussions thatfollowed
them.
ETUI-REHS shares the viewthat effective injury risk
reduction can be achievedby using sound ergonomic
design to reducethe ongoing performance
demands made onthe operator
to avoid accidents.
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2. Fabio Strambi et al. Ergonomia e norme tecniche di sicurezza:
il contributo degli utlizzatori. La sicurezza dellemacchine per la
lavorazione del legno, Franco Angeli Editore, Milano 2001.
P A G E 4
3. Feedback, the method agreedwith the project partnersFabio
Strambi, European Ergonomist,Director of the Occupational Healthand
Safety Service, A. USL 7 Siena,Regione Toscana.Massimo Bartalini,
Safety Officer,Occupational Health and SafetyService, A. USL 7
Siena, RegioneToscana.
The methodology agreed with the ETUI-REHS project partners aims
at improvingType C standards by means of user feed-back. To achieve
that objective, it was deci-ded to use the Feedback Method,
alreadydemonstrated to be a valid tool for accu-mulating users
knowledge, structuring itand making it available to
standard-setters.
BackgroundFollowing a data collecting project run incooperation
with the Swedish union LO in1997, ETUI-REHS in 1998
commissionedSindNova, an Italian trade union institute, todevelop a
research project to involve workersand firms in assessing the
effectiveness oftechnical standards on the safety of wood-working
machinery.The project was carried out in 1999 inTuscany, Italy, by
Fabio Strambi and collea-gues from the Siena Local
OccupationalHealth and Safety Unit (USL)2. Theoutcomes were
published under the title:Ergonomics and technical safety
standards:users experience and suggestions. Safety ofwoodworking
machinery.
The project, run in Val dElsa,Tuscany Region, aimed to introduce
a parti-cipatory model in a specific high-risk indus-trial
environment, collecting input frommachinery users and integrating
it into a stra-tegy for improving machinery technical
stan-dards.
Message from the Chairman The European MetalworkersFederation
(EMF) represents the economic and social inte-rests of workers in
the metal industry at European level. Thegreat majority of
metalworkers use and construct machines:this explains our interest
in the ETUI-REHS strategy inten-ded to progress toward a real
involvement of workers in thedesign of the equipment they use every
day. This objectivecan be achieved by bringing workers experience
into stan-dardisation. Workers are the people who know the job and
working conditions best;they are also the ones bearing the health
and safety impact of machinery defects andshortcomings. Their
insights into machinery health and safety issues are
thereforeessential. Recent trade union experiences have shown the
promising future of exploi-ting workers knowledge to improve
equipment design and use. EMF is convincedthat more opportunities
must be explored for collaborative work between
engineers,employers, workers, manufacturers, researchers and
governments who can all contri-bute to better health and safety
through the consideration of design issues. This willbe a high
priority for many years to come, as part of the constant search for
new ini-tiatives to further drive down the rate of machinery
accidents at work. Bart Samyn.
Message from the ETUI-REHS Director This seminar is the
culmination of alongstanding research strategy whereby we had the
privilege of working with nationalpartners and bringing European
standardisation closer to the world of users. Even ifETUI-REHS
currently has a limited role in the CEN system following the work
ofTC 114 and TC 122 we build bridges day after day to better
communicate andexchange information with standard-setters. The
cases logged in many Europeanworkplaces show us that trade unions
can be the eyes and ears of CEN when itcomes to health and safety
matters. People who could lose their lives at work have aright to
information, consultation and participation in the design of the
work systemas a whole, in its environmental, organisational and
technological dimensions.In this connection the ETUI-REHS strategy
seeks to move from workplace experience to better machinerydesign.
Being aware of the limited resources available to standard-setters
and policy-makers, we wish to keepthe debate alive among the
different stakeholders to search for win-win procedures,
opportunities and mecha-nisms, whereby business and productivity
pressures go hand in hand with the highest level of social
protec-tion dictated by the European Union Treaty. In the search
for sustainable mechanisms to benefit from machi-nery users
experience, ETUI-REHS will put forward structured proposals to
standard-setters and policy-makers, in order to construct a new
policy framework tailored to trade union research objectives. Marc
Sapir.
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In 2003 the Bilbao Agency sponsored theFeedback Methodology3 in
the context of theSME Funding Scheme 2003-2004, when Italy(Regione
Toscana) and Germany (GrolaBG)decided to apply feedback to forklift
trucks.This project was carried out in 29 SMEs wherea total of 192
forklift trucks were used.
The feedback methodCollection of machine documentation(Machine
Dossier)The feedback method is applied wheneverstakeholders
identify a machine (and a cor-responding harmonised standard)
whichmerits closer examination and analysis.The first step of the
method is to collectany available technical documentation onthe
machine under review, so as to beaware of the main safety features
(i.e. nor-mal and abnormal use, residual risks).In this preliminary
phase safety expertsassemble a machine dossier, which insummary
includes whenever available information on: relevant harmonised
stan-dards; safety guidelines elaborated by tech-nical bodies or
research organisations; sta-tistics on undesired events associated
withthe machine (together with any specificaccident
investigations); safeguard actionsagainst the machine; market
surveillanceinformation; information provided by themachine
manufacturer about the territo-rial/geographical diffusion of the
machineand its different models and/or configura-tions;
instructions accompanying themachine.
Identification of companiesand workplace inspectionsAfter
identifying the territory and the pro-duction sector where the
method will beapplied, safety experts select the
compa-nies/enterprises to be inspected and whereskilled machine
users will be recruited;trade unions and employers associationshelp
with this step.
Inspections are carried out by using formscontaining the
following elements: generalcompany data; description of
workingenvironment where the machine underinvestigation is used and
the relevant wor-king methods; characteristics of the machi-nes
used in the company; information onaccidents (and near misses)
which haveoccurred in the company and involved themachine in
question; information aboutthe training provided for workers
assignedto operate the machine.
This information will be used during thejob ergonomic analysis,
carried out in wor-king groups, when users will be guided
inreconstructing their job based on machineactivities carried out
daily.
Working groupsWorking groups (WG) are then formed,each group
being made up of 5 to 9 users:besides drivers, the group may
includecompany engineers, craftsmen or em-ployers with knowledge
and experience inthe use of the machine (ideally these peo-ple
should be the ones who use themachine in the normal course of
produc-tion).
It is essential that the participants comefrom different working
situations, with atleast three operators from different compa-nies,
in order to attenuate the inevitable
specificities connected with a single com-pany, and to provide a
job reconstructionrepresentative of the daily tasks across
dif-ferent working contexts. If working groupsrepresent different
productive sectorsand/or territorial areas, diverse practicesand
habits in operating the machine underinvestigation and different
methods oforganising production could be brought tolight.
The working group activity is based ontwo preliminary steps.
Firstly, the expertsprovide the users with basic documenta-tion
(the relevant technical standards, thedescription of the most
important residualrisks indicated by the manufacturers in
theinstructions, a description of the dynamicsof the most serious
accidents, etc.).Secondly, each working phase is split intobasic
operational tasks, on the basis of theinformation collected during
the companyinspections, from the initial setting-upoperations to
maintenance and cleaningoperations after the work is finished.
After these two preparatory phases, the lea-ding experts
introduce the job ergonomicanalysis through which the group
willreconstruct the daily work phases and thenstart a systematic
analysis of each workphase with the help of a table like the onein
Fig. 1 (see p.6).
For each work phase, the job tasks areidentified, and for each
of them the follo-wing elements are put in writing: the individual
operations and the
methods of executing the task; the training, knowledge and
experience
that the worker must possess in order toexecute such operations
competently;
the risks associated with executing thetask;
suggestions for prevention and anysafety procedures to adopt in
order toavoid accidents.
P A G E 5
Working groups (WG)are then formed, each
group being made up of5 to 9 users: besides
drivers, the group mayinclude company engineers,
craftsmen or employerswith knowledge
and experience in the useof the machine.
3. Presented at the International Conference Design process and
human factors integration Nice,1-3 March 2006.
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It is important to note that the experts lea-ding the discussion
allow the workers toact as key players in evaluating their
ownworking environment. The experts roleconsists in supplying
information, spee-ding up the participants contribution tothe
reconstruction of the job, and guidingthe users evaluations of the
safety issuesand possible preventive action.
Written WG documentand its validationAt the end of the process,
the researcherstransfer the results onto a "legible copy" ofthe
Feedback grid and deliver it to everyparticipant for their
validation and/or forany corrections/additions. This step
isessential, not least so that the more reticentmembers have an
opportunity to contri-bute their opinions and suggestions.
Theindications provided by users will be adop-ted and marked in the
final report. Theconsolidated and validated WG reportrepresents a
basic document that can befine-tuned to better highlight lessons
lear-ned and suggestions.
Project overviewand final technical reportThe final phase of the
Feedback Methodconsists in the drafting of the project over-view
and the final technical report. The pro-ject overview describes all
the different pro-ject phases and outcomes, from the assem-bling of
the machine dossier to the consoli-dation and validation of the WG
report.
Afterwards the researchers draft a synthesisof the WG report,
drawing together andpresenting the prevention indications
andsuggestions that emerged from the WGs,in order to facilitate the
transition fromwords to deeds. This final technical reportis
structured in such a way that its contentis addressed to:
standard-setters, for modification andimprovement of the
standard on thespecific issues that emerged from theWG (i.e.
ergonomics, maintainability,operating modes);
designers and manufacturers, in orderto assess the feasibility
of the WG sug-gestions and compare them with thecurrent state of
the art;
employers/users, so that they can improveand manage maintenance
operations,provide effective safety training andadequate job
organisation; in order toimprove the purchase and safe
incorpora-tion of work equipment into the com-pany-specific
environment;
workers, so that they pay careful atten-tion to the safety
indications suppliedby the manufacturers and by the
usersthemselves.
This final technical report therefore beco-mes the centrepiece
of the job carried outand constitutes a technical synthesis of
thecontributions made by users both duringthe inspections and
within the workinggroup debates. The concluding report is
asynthesis of the suggestions to be addressedto all stakeholders
involved in machinerysafety issues: standard-setters,
manufactu-rers, employers, workers representatives,inspection
bodies, etc.
ResultsThe following table summarises the mainresults obtained
by applying the Feed-back method to forklift trucks.
P A G E 6
Tasksequence
Operatingconditions
(for execution oftask)
Knowledge(necessary for
optimal executionof task)
Risk associatedwith taskexecution
Suggestions forprevention
Job phase
Fig. 1 Table used to record the job reconstruction carried out
by the working group
Main proposals and suggestions - Forklift trucks Technical
standard
Improvement of active and passive means from overturning risks
EN 1726-1:1998; clauseImprovement of devices which keep the driver
in his seat. 4.1.11, 5.2.3, 5.6.3.4, 5.7,
5.8, 7.2.2, 7.3
Improvement of battery handling methods. EN
1726-1:1998;Harmonisation of travelling and stopping control
devices (placing and typology) EN 1726-1:1998; clausewith layout
used in cars. 1.7.4, 5.4.2, 5.4.2.1
EN 281:1988; clause 7
Harmonisation of control levers for every type of forklift
truck. Control devicesmust be designed so that, where a risk is
involved, the desired effect cannot be EN 1726-1:1998;
clauseachieved without an intentional operation. 5.4.4, 5.4.5
Fastening and insulation of battery bonnet. EN 1726-1:1998;
clause5.5.3, 5.7
Improvement of access to operating position. Compulsory handles.
EN 1726-1:1998;clause 5.7.2
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Final observationsFeedback confirms the need to
integratemachinery design with information basedon the real
experience of machinery opera-tors so as to improve its quality and
reliabi-lity. The application of Feedback tomachinery highlights
what lessons stan-dards bodies could learn from
participatoryapproaches to equipment design based onthe knowledge
that final users possess onthe equipment they work with.
Application of the Feedback methodmakes it possible both to
collect contribu-tions from machinery users for the impro-vement of
the specific reference standardand at the same time to prepare a
system tomonitor the effectiveness of any improve-ments introduced.
In connection with thismethod an optimal solution would be
theestablishment of observatories, located inseveral Member States,
able to collect reac-tions from users of the same machine
indifferent production sectors.
Such a system of continuous feedback, bet-ween standard-setters
and users, is there-fore the only viable method derivedmoreover
from human physiology ofachieving and maintaining an improve-ment
in safety and in health safeguards formachinery users/workers, by
means of acontinuous adaptation of the standards.
Using this method it is possible for workerrepresentatives or,
more generally, forrepresentatives of consumers and users toset
about collecting indications for impro-vements in various types of
machinery.
The recommendations can then be forwar-ded to the appropriate
technical commis-sions and committees.
The key factor for the effectiveness of themethod, however, is
the human factor andabove all else the full cooperation of
expertusers and technicians. They must not onlybe familiar with the
machine under investi-gation but also be able to guide the wor-king
group, collect the information andexpress it in suitable language
for the for-mulation of proposals to be addressed tothe
standard-setters and manufacturers.
P A G E 7
The German-Italian Project 5711/IT on forklift truck safety
under theSME Funding Scheme 2003-2004 sponsored by the Agency of
Bilbao was carriedout by the following experts:
R.CIANOTTI, M.N.TINI (ISPESL National Institute of Occupational
Safetyand Prevention Department of Safety Technologies,
Roma/Italy)
C.STANZANI (SindNova, Roma/Italy) F. ROVEDO (Grola BG,
Mannheim/Germany) G. TOGNOCCHI, A. ZALLOCCO (A. USL 4 di Prato U.F.
PISLL, Prato/Italy) M. MASI (General Directorate for Health and
Solidarity Policies Regione
Toscana, Firenze/Italy)The Project holder was IAL-CISL, the CISL
trade union institute for professional trai-ning.
4. National datacollection exercise
4.1 United Kingdom
Phil Papard, Head of ProductSafety Section, Health and
SafetyExecutive (HSE)
The data collection exercise on FLTs wascarried out under the
supervision of theProject Manager Clare Field, Health andSafety
Inspector at HSE, and the ProjectFacilitator Tim Harris, working in
theWorkplace Transport Safety policy team atHSE. A UK working group
was set upcomprising representatives from the HSE,local
authorities, the operator trainingindustry, FLT manufacturers, FLT
opera-tive employers and a trade union represen-ting FLT
operators.
Members of the working group undertookto identify dutyholders
who would partici-pate in the project, relying on the coopera-tion
of dutyholders. The working groupagreed that subject FLTs should be
CE-marked and well maintained: this wouldensure that the project
was able to focus ondesign issues, rather than issues relating
to
maintenance of the vehicle. The workinggroup also agreed that
subject operatorsshould have been trained to the standardset out in
the UK Approved Code ofPractice4 for training operators of
rider-operated lift trucks.
Members of the working group intervie-wed FLT operators in their
workplace,using open questions to identify designfeatures the
operators considered affectedtheir safety. Background information
onthe workplace and FLT was also recorded.The interviews resulted
in the completion
4. HSE booklet L117 Rider-operated lift trucks:operator
training
The working group agreedthat subject FLTs should
be CE-marked and wellmaintained: this would
ensure that the projectwas able to focus on design
issues, rather than issuesrelating to maintenance
of the vehicle.
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of questionnaires that were collated by theHSE: a second working
group was conve-ned to discuss the findings and the metho-dology
used in the UK, and to constructan enriched Job Ergonomic
Analysis.
A total of 21 operators were interviewedacross 11 workplaces,
where nearly 90% ofthe FLTs were manufactured in 2002-2005. Nearly
90% of the comments wererelated to vehicle design: the majority
ofthem related to visibility, controls and ope-rator comfort. Some
issues are not new,but some are, and are being made
publiclyavailable for the first time. More precisely:
Visibility screen wipers and motorpositioned at the top centre
of thewindscreen.
Controls lack of space to operate footpedals especially when
wearing safetyshoes.
Operator comfort concern about backinjury from twisting to
access/egressvehicles.
Certain comments related to areas notcovered by standards, like
overhead andside weather protection:
Quality and suitability varied Concern was expressed that
materials
used scratch easily when cleaned orwhen passed under plastic
strip cur-tains.
With some refinement concluded PhilPapard the method could be
applied toother types of machinery. The project hasproduced data
which deal with the moresubtle factors affecting operator safety,
suchas ergonomics. Accident data are morelikely to focus on issues
which do notaffect the day-to-day comfort of the opera-tor.
However, over time day-to-day com-fort issues may have a
significant effect onsafety, such as through fatigue and
muscu-loskeletal disorders.The working group all thought the
part-nership working was successful, and couldbe improved by
involving more externalstakeholders at an earlier stage. Themethod
could be taken forward andimproved by trade associations and
unionsundertaking the interviewing: interviewingoperators was a
time consuming but effec-tive way of obtaining useful, detailed
infor-mation. And standardisation needs infor-mation to be fed back
from the users, inparticular to minimise ergonomic
residualrisks.
4.2 France
Genevive Rendu,Machinery SafetyBureau, Ministry of
Employment,Social Cohesion and Housing
Recital 16 of the Machinery Directive setsout the principle of
employers andemployees making a necessary contribu-tion to the
process of developing standards.
Article 5 of the Directive specifies that'Member States shall
ensure that appro-priate measures are taken to enable thesocial
partners to have an influence atnational level on the process of
preparingand monitoring the harmonised stan-dards'.
The objective is thus clearly stated: workersare entitled to
their say on the design ofmachinery. This is self-evident given
that itis the workers, after all, who are the end-users of the
machinery and the first to haveaccidents or suffer from
occupationaldiseases.
The precise manner of their participationis left to the Member
States to determine.So it is up to the national public authori-ties
to take the initiative in this respect.
But what should they do, and how?The French Ministry of
Employment hasexplored several options:
The option of involving employees inthe process of developing
standards inthe manner proposed by the standardi-sation system. We
quickly came to seethis option as something of a fallacy:-
employees and their representatives
do not have the requisite resources,time, availability or skills
to take partin activities of a highly technicalnature that are
clearly extremelytime-consuming;
- the world of standardisation on thebasis of consensus between
'interes-ted' parties is alien to French wor-kers and their
representatives. Theyare used to a world of negotiationsor conflict
between 'representative'parties;
- those involved in the standardisationprocess, mainly the
manufacturers,consider their participation to bemore legitimate
than that of theworkers.
The option of using an incident reportform (fiche d'alerte) to
channel feed-back to the Ministry of Employment.This option was
abandoned because itwas not 'realistic'.
The survey option. This consists ofasking a consultant to carry
out a sur-vey of workers' concerns in the work-place and to draw
conclusions formachinery design. This option wasfirst implemented
at national level witha study of household refuse collectiontrucks.
We viewed this as the most pro-mising option.
This is why the Ministry of Employmentfollowed with the greatest
interest theETUI-REHS initiatives to gather userfeedback at
European level using specificmethodology.
We considered that the choice of forklifttrucks for a trial of
this feedback methodwas highly suitable for several reasons:
- the importance of accidentology;- the existence of a mandate
given to
CEN in the 1990s to amend theEuropean standard, not only to
gua-rantee better protection for the driver ifa truck overturns,
but also to preventthe risk of overturning;
- what is at stake in the revision ofEuropean standards under
the ViennaAgreement.
The Ministry of Employment was involvedin the operation in two
ways:
- examining accidentology data relatingto the use of forklift
trucks;
- financing a survey for gathering infor-mation in
companies.
P A G E 8
This is whythe Ministryof Employment followedwith the
greatestinterest the ETUI-REHSinitiativesto gather user feedbackat
European level usingspecific methodology.
-
Accidentology in France Statistical dataFor just under ten
years, the number ofaccidents at work has remained largelyconstant,
with around 8,000 to 9,000 acci-dents annually, of which 10 to 20
havebeen fatal and 500 to 800 have resulted ininvalidity.
Qualitative dataFollowing an analysis of nearly 200 reportsof
serious and/or fatal accidents providedby the Labour Inspectorate
and involvingforklift trucks between 1993 and 2003, thefollowing
five major risk categories havebeen identified:
> The risk of a truck overturning andcrushing the driver or
another per-son;
> The risk of a truck colliding withpedestrians or
objects;
> The risk of the load falling off;> The risk of a truck
moving unexpec-
tedly;> The risk of falling due to the use on
a truck of an adapted, improvisedworking platform.
The Ministry of Employment drew thefollowing conclusions:
A proportion of these accidents could havebeen avoided if the
employers had takenpreventive action based on risk assessment,the
choice of appropriate equipment, orga-nisational measures and
driver training inaccordance with Framework Directive89/391/EEC and
Directive 89/655/EECon the Use of Work Equipment.However, given the
prevalence of certainkinds of accidents, it is also reasonable
tohighlight deficiencies in truck design, sincethe standards do not
cover all situations of'atypical' use which can, nonetheless,
beanticipated.
In-company survey carriedout by Clid5
MethodologyThe reliability of the results of this type ofsurvey
depends on the methodology, thesurvey locations and the people
surveyed.
> The methodology used was that ofETUI-REHS and combined
ques-tionnaires, interviews, visits to com-panies and working
groups. Twocompanies participated in the fullsurvey (interviews,
questionnaires,visits and working group), while theother companies
accepted the ques-tionnaire (without interviews) orvice versa.
> The choice of survey locations reflec-ted the diversity of
situations:- a company from the nuclear sector
with 3,300 employees us ingaround 50 trucks;
- a tyre manufacturer with 1,500employees using around 70
trucks;
- a paper manufacturer with 750employees using around 50
trucks;
- a warehouse of a major distributioncompany using over 100
trucks.
> Responses were gathered from aheterogeneous mix of people:-
in companies, responses came from
people at different levels of thecompany hierarchy and from
avariety of departments: truck dri-vers, safety officers,
ergonomicsofficer, training officers, ergono-mist, works manager,
companydoctor, trainer, maintenance super-visor, etc;
- in the training centres, responsescame from truck drivers and
trai-ners;
- people from outside institutions(labour inspectors, prevention
ser-vices etc.).
ResultsRequests from the users for improvementsto truck design
relate to the followingmain points:
> improvement of aids to safe driving(stability, visibility,
limit on speedintegral to design, etc.);
> improvement of the design of thedriver's cab;
> improvement of the conditionsunder which maintenance is
carriedout.
P A G E 9
5. Franoise Habasque and Eloise Galioot, Tmoignages
d'utilisateurs de chariots automoteurs. Etudesdemandes par le
ministre de l'Emploi et de la Solidarit et l'AFNOR, Clid, November
2005. The Celide isa bureau of experts established by the CFDT
(French Trade Union) for the purpose of providing support to
workersrepresentatives involved in occupational health and
safety.
Conclusion> Methodology: the main advantage of the
methodology proposed by ETUI-REHS
is that it necessitates comparison and cross-checking of
responses from differentpeople. Conclusions arrived at by people on
the ground can therefore be consideredreliable.
> In considering the results of this methodology applied to
forklift trucks, we havenoted two prominent points:- some of the
concerns and proposals voiced by the users corroborate the
findings
of the Ministry which were based on a single study of serious
occupational acci-dents. The issues involved are aids to driving,
visibility and stability;
- other concerns and proposals voiced by the users substantially
supplement thissingle study of serious accidents. Issues involved
are design of the driver's cab andimproving the conditions under
which truck maintenance is carried out.
On the basis of these points, we can conclude that:- this trial
is conclusive and could be repeated for other types of machinery;-
a summary of the various contributions ought to serve as valuable
input for the
revision of forklift truck standards currently under way
internationally within theVienna Agreement providing, of course,
that those carrying out the standardisa-tion process agree to
consider the concerns of people on the ground.
-
4.3 Finland
Tapio Siiril, Safety Engineer,Occupational Health and
SafetyAdministration
In Mr Siirils view, FLTs represented agood choice for carrying
out such a pro-ject, given their diffusion in so many diffe-rent
working environments. The availableaccident data tell us that in
the period1993-2000 as many as 5,315 accidentswere registered, with
32 fatal events from1985 to 2002. Falling of load, tipping overand
pedestrian hitting were the most com-mon causes. Interviews also
disclosed highnumbers of near misses.
Mr Siiril recalled that stability one ofthe most relevant safety
issues is extensi-vely dealt with in normative annexes B toH of EN
1726-1. Interviews with usersindicated the need to review stability
tes-ting requirements by taking into accountthe real conditions of
use (at maximumtruck speed and maximum load), especiallywhen it
comes to the trucks dynamicbehaviour when driving and turning.
A second critical safety factor is the drivingspeed. Here,
operators expressed the wishto have whenever possible FLTs
equip-ped with a device determining the speedon the basis of the
route or area where thetruck is travelling. The presence of
anautomatic limitation of the trucks speeddepending on the turning
radius and loadmass and elevation was also mentionedduring
interviews.
Poor visibility is one of the major safetyproblems with forklift
trucks. In MrSiirils opinion the requirements laiddown in standard
EN 1726-1 (paragraph5.10.1) are quite vague. During the inter-views
design proposals (open structure ofthe mast, a rotating seat and
controls forbackward driving, and a closed circuit tele-vision
system) were raised.
Control devices whose requirements areconsidered too general and
vague by MrSiiril were commented on at length byFLT users. As for
all mobile machinery,control devices play a crucial role for
FLTs.Their use must be self-evident, their layoutmust ensure an
instinctively correct opera-tion, and they must be adjustable to
suitdifferent users. In this connection, MrSiiril collected users
complaints about thedifferent layouts of pedals allowed by EN1726-1
by means of the normative refe-rence to EN ISO 212816.
By the same token, some lever configura-tions increase the
probability of operatorconfusion and consequently increase
thelikelihood of errors with potentially dange-rous consequences.
Mr Siiril, on thisissue, proposed that EN 1726-1 be revie-wed by
adding normative references to therelevant ergonomic harmonised
standardsdealing with the design of control opera-tions and control
devices.
Other proposals were put forward by theoperators and users
interviewed in Finland.Users asked for better design of
operatoraccess and egress (steps were consideredeasier to use);
they expressed the opinionthat all FLT should have a cabin
(againstnoise, uncomfortable temperatures, impu-rities in the air,
and of course as a protec-tion against FLT overturning or
collisions);
the maximum allowed opening of over-head protection was asked to
be smaller;users also asked for better design for main-tenance, to
ease access to maintenancelocations and the handling of the
battery.
Mr Siiril ended his contribution with acomment on loading
control. Here hepointed out that the standard EN 1726-1still does
not cover the loading controlrequirements of the Machinery
Directive(clause 4.2.1.4 of Annex I), as explained inthe
informative Annex N. In this connec-tion, Mr Siiril emphasised that
the ETUI-REHS strategy could help provide stan-dard-setters with
additional data for thepurpose of reviewing EN 1726-1 and cove-ring
this critical safety issue.
P A G E 1 0
6. ISO 21281:2005 Construction and layout of pedals of
self-propelled sit-down rider-controlled industrial trucks.Rules
for the construction and layout of pedal.
Control devices whoserequirements areconsidered too generaland
vague by Mr Siiril were commented onat length by FLT users.As for
all mobile machinery,control devices playa crucial role for
FLTs.
-
5. Round table
The round table that followed the seminarsess ions were
moderated by UlrichBamberg, from the Office of the SocialPartners
(Employees) in the Commissionfor Occupational Health and Safety
andStandardisation (KAN), and by RobertoCianotti, Director of the
Safety Tech-nology Department of ISPESL, the Na-tional Institute
for Prevention and Safety atWork. Contributions were made by
repre-sentatives of employees, employers, policy-makers,
standard-setters, and by nationalOHS officials:
Norbert Anselmann, Head of Unit "Standardisation", DG Enterprise
and Industry,European Commission;
Angel Fuente Martin, Principal Administrator, DG Employment and
Social Affairs,European Commission;
Martin Eifel, Chairman of the Working Group of Committee
98/37/EC Machinery,DG Enterprise and Industry, European
Commission;
Ian Fraser, DG Enterprise and Industry, European Commission;
Corrado Mattiuzzo, DG Enterprise and Industry, European
Commission;
Brenda OBrien, Brussels Liaison Officer, European Agency for
Safety and Health atWork;
Claudio Stanzani, President of the Trade Union Research
Institute SindNova, Rome,Italy.
Lennart Ahnstrm, Chairman of the Working Group MACHEX of the
Senior LabourInspectors Committee (SLIC);
Pascal Etienne, Director, Machinery Safety Bureau, Ministry of
Employment, SocialCohesion and Housing, France;
Gerhard Steiger, Rapporteur to the CEN BT7 of the Machinery
Safety Sector, CEN;
Stefan Joannin, Programme Manager for Safety of Machinery at the
CENManagement Centre;
Werner Tannhuser, Chairman of the ISO Technical Committee TC 110
IndustrialTrucks, senior member of CEN TC 150 Safety of industrial
trucks;
Franck Gambelli, Olivier Franois, Mouvement des Entreprises de
France (MEDEF),France;
Doug Russell, National Health and Safety Officer, Union of Shop,
Distributive, andAllied Workers (USDAW), United Kingdom;
Georges Fleury, Safety Officer, AREVA8, France;
The round table discussed the implications of the ETUI-REHS
strategy and how thismay be translated into effective technical and
policy initiatives for the future. This sectionincludes a summary
of some of the round table members contributions.
P A G E 1 1
7. The CEN BT (Technical Board) is the technical body which
controls the full standards programme andpromotes its speedy
execution by the Technical Committees (TC), the CEN Management
Centre (CMC) and otherbodies.8. AREVA NC is the French
Government-owned nuclear group, suppliers of uranium throughout the
world,active at every stage of the nuclear fuel cycle in the
industry, from mining to waste management.
-
Messages from the Chairmen
Ulrich Bamberg
Since 1994 the Commission for OH&Sand Standardisation (KAN)
has beenmonitoring the standardisation process toensure that
standard-setters devote suffi-cient attention to the needs of
OH&S. AtKAN we share the ETUI-REHS commit-ment to promoting
public debate on therole of standardisation to improve
workequipment safety. In our organisation wevalue the exchange of
opinions of all thestakeholders involved in the functioningof the
Single Market. In fact, the OH&Sinterests of various public
institutions thesocial partners, the State, the statutoryaccident
insurance institutions and DIN,the German national standardisation
body(members of KAN) are collectively repre-sented in opinions on
current and plannedstandardisation projects.
Coming from this background, we agreewith ETUI-REHS that
occupationalhealth and safety interests are representedpoorly, if
at all, in the European and inter-national standards committees.
The resultis that requirements regarded by OH&S asnecessary and
which are pursuant to theprovisions of the Machinery Directive
areoften given at best inadequate considera-tion.
For this reason we regard the forklift truckproject as a
valuable experience, indicatinghow the social partners experience
canimprove the quality of machinery technicalstandards. Greater
weight should be givento safety in the area of industrial
truckstandardisation: this is why KAN welco-med the possibility to
undertake theGerman-Italian forklift truck safety projectsupported
by the Bilbao Agency in 20039.
With the support of European policy-makers, ETUI-REHS efforts
have thepotential to establish a permanent mecha-nism through which
social partner feed-back and viewpoints may be
collected,coordinated and fed into the standardisa-tion process to
help manufacturers producesafer equipment.
Roberto Cianotti
ISPESL has for many years supported theETUI-REHS research
methodology, so farapplied to three types of machines. It is
amethodology developed in line with boththe New Approach and the
social directivesregulating health and safety at work.
We are here today to reaffirm the healthand safety implications
of the role given tostandards by the New Approach. But wealso want
to stress today the role played byemployers, who are responsible
for the cor-rect choice of machine and for the designof the tasks
that workers will carry outusing that machine.
In this connection it is important to seehow the design
solutions chosen by stan-dard-setters to comply with the
relevantessential safety requirements attain theobjectives in terms
of productivity, opera-tor health and safety, user-friendliness.
Webelieve that to improve the quality of stan-dards, the wealth of
information madeavailable by ETUI-REHS is a necessaryknowledge base
to be further developedand exploited.
ISPESL follows the activity of CEN TC150 through its Italian
mirror committee.We recognise how standards are evolving.This
evolution in terms of design contentshould be accompanied by the
same levelof attention to issues related to informa-tion for users,
and should not prevent usfrom taking into account the role playedby
training. In this connection the ETUI-REHS strategy can help
improve both thedesign dimension and the training obliga-tions
incumbent on employers.
P A G E 1 2
9. A summary of the project has been published in KAN Brief 1/05
(http://www.kan.de/pdf/brief/eng/2005-1-Gabelstapler-e.pdf). The
articles author is Franco Rovedo, working at GrolaBG, Project
Facilitator of the Germandata collection exercise.
The result is thatrequirements regardedby OH&S as
necessaryand which are pursuantto the provisionsof the Machinery
Directiveare often given atbest inadequateconsideration.
We believe thatto improve the qualityof standards,the wealth of
informationmade availableby ETUI-REHS isa necessary knowledgebase
to befurther developedand exploited.
-
Social stakeholders influenceon standardisation:which way
forward?
The discussion on the social dimension ofstandardisation under
the New Approach,and the difficulties faced by trade
unionsstruggling to help workers give their inputinto the European
technical work at CEN,was introduced by Claudio Stanzani10:
Workers involvement, either direct or bymeans of specific
representation frame-works, is one of the pillars of all
Europeandirectives dealing with health and safety atwork. Workers,
individually and collecti-vely, possess knowledge and experienceof
the technological and organisationaldimensions of their work
systems. Thisknowledge and experience, if adequatelycollected and
valued, is indispensable to:
Identify and assess the risks associa-ted with the work system
(worktasks, work environment, job);
Design and improve the work sys-tem;
Plan prevention strategies.
Worker participation is aimed at influencinga companys
decision-making in relation toits health and safety obligations.
Workersand trade unions have the right to concludecollective
agreements with the line manage-ment in their enterprises, together
with theright to be trained, informed and consultedon the
prevention of occupational risks.
Experience and ergonomic culture confirmthat training,
information and consultationimprove the competitiveness and
perfor-mance of all sectors of activity; dialogue andcooperation
with workers can improve thequality of line management decisions.
TheETUI-REHS strategy starts from theseprinciples, by involving
workers in analysingand re-designing their own work systems.
The ETUI-REHS tool seeks to legitimisethe ideas and experience
that workers accu-mulate in doing their jobs, which they candraw on
to suggest their own solutions tomachinery-related problems. As a
matter of
fact, the ETUI-REHS toolbox for channel-ling users knowledge to
standard-settersaims to provide a context in which designexperts
can gain the practical understan-ding they need for successful
design.
Social stakeholders involvement in stan-dardisation ultimately
reflects the signifi-cance of a participatory design approach,an
indispensable ingredient for the success-ful design of any work
system. Unfor-tunately, many limitations still exist. Inmany Member
States there is almostno official provision for informing
andconsulting the social partners on Europeanstandards mandated
under directives.
One consequence of this failure to ack-nowledge the trade unions
right to partici-pate is that financial resources have notbeen made
available. Moreover, workersrepresentatives find it hard to get
thenecessary time off to play an active part inwhat is a
time-consuming, complex pro-cess; they are also confronted by the
needfor adequate technical training and the dif-ficulty of
remaining independent of thecompanys interests.
Finally, trade unions are facing the chal-lenge of how to
organise systematic feed-back of users experience so as to
turnworkplace experience into significant tech-nical knowledge,
which can then be usedin framing equipment design standardsand
European training programmes.
P A G E 1 3
Some discussion points : Social stakeholders influence on
standardisation: which way forward? Participation at national and
European level Policy issues: do we need structural changes?
10. Claudio Stanzani, in cooperation with the ETUI-REHS,
supervised the German-Italian project 5711/ITon forklift truck
safety carried out under the SME Funding Scheme 2003-2004 sponsored
by the Bilbao Agency.
Social stakeholdersinvolvementin standardisationultimately
reflectsthe significanceof a participatorydesign approach,an
indispensableingredient forthe successful designof any work
system.
-
In this line of thought, Norbert Anselmannrecalled the
importance of social stakehol-ders contribution to standardisation
underthe New Approach:
The accountability of European standar-disation supporting New
Approach legisla-tion a factor in the successful functioningof the
Single Market in goods over the past20 years is directly linked to
the partici-pation of social stakeholders, making stan-dards more
representative by strengtheningthe quality of the consensus they
are basedon.
This principle reflects the fundamentalobjectives set out in the
Treaty establishingthe European Community: to ensure highlevels of
protection for the public interest(in its environmental, consumer,
andhealth and safety dimensions). As a result,the European
standardisation system has abroad responsibility to industry,
workers,consumers, environmental interests andpublic authorities,
who all have a legiti-mate interest in the outcome of this
tech-nical work.
Ensuring that the views of all interestedgroups are adequately
taken into account isessential. In particular, since
machinerystandards quantify the level of protectionthat the
Machinery Directive seeks to pro-vide, workers representatives have
the rightto demand standards providing a high levelof protection in
line with the technologicalstate of the art.
We are aware that trade union participa-tion is not yet
sufficiently well guaranteed,neither at the European Standards
Orga-nisations nor within all Member States.Although its
methodology still needs somerefinements to make it applicable
horizon-tally to other products, the ETUI-REHSstrategy should be
presented to the98/34/EC Committee in order to debatehow to improve
the mandates given to theEuropean Standardisation Organisation(ESO)
and their execution, and to includein them the mechanisms and
methodsenvisaged by ETUI-REHS to improve thesocial partners
contribution to standardisa-tion.
CENs commitment to openness, impartiality andconsensus was
confirmed by Gerhard Steiger, whorecalled that the key objective of
standardisation isaccess to everyone who wishes to participate in
thetechnical work:
The whole CEN system and the system functioning at national
level are both designedaccording to this basic principle: anyone
can take part in the technical work at nationallevel and perhaps
become a delegate at European level. Both tracks should now be
usedby ETUI-REHS to put forward the findings of this important
exercise.
We are of the opinion that the national dimension is the most
important: through actionat national level, ETUI-REHS could
duplicate its achievements while trade unions could in several
countries influence the national opinion building process.
In this connection, it is also important to remember that
national delegates are expectedto represent a national opinion:
this explains the importance of compromise among allstakeholders to
achieve consensus at national level. The standardisation rule of
consensusalso applies to the findings of the ETUI-REHS project.
P A G E 1 4
Participation at nationaland European level
The question of how to feed workers know-ledge into
standardisation still remains.The opportunities to have a say in
thenational and European dimensions wereexplained by Stefan
Joannin, who first of allrecommended consolidating workers
feed-back and knowledge at national level byinteracting with
national mirror commit-tees. He added that:
This way of operating does not precludethe possibi l i ty of
acting direct ly atEuropean level, speaking with one voiceabout the
results of such experiences, sinceETUI-REHS, as a CEN associate
member,receives draft standards at the CENenquiry stage and could
submit the com-
Trade unionrepresentatives
should bring thesame 'workers
feedbackreports' to thenational mirrorcommittees of
their NSB.
We are aware thattrade union participationis not yet
sufficientlywell guaranteed,neither at the EuropeanStandards
Organisationsnor within allMember States.
We are of the opinionthat the nationaldimension is the
mostimportant: throughaction at national level,ETUI-REHS
couldduplicate itsachievementswhile trade unionscould influencethe
national opinionbuilding process.
-
ments at this stage. The question remainsas to how effective
this 'track' would be.
There is great value in consolidating theconcerns of workers
from all MemberStates and centralising it within ETUI-REHS; that is
why the methodology isworth exploiting further. For it to be
effec-tive, the consolidation of comments andinput from workers
should be fed throughevery National Standards Body (NSB)
par-ticipating in that domain.
Trade union representatives should bringthe same 'workers
feedback reports' to thenational mirror committees of their NSB.In
so doing, when the CEN workinggroup itself meets, there will be a
betterchance of having the concerns and recom-mendations put
forward in that workersreport taken on board.
In conclusion, workers input should beput forward using as many
channels aspossible, to increase its chances of beingconsidered
during discussion in theEuropean working groups. Having a
tradeunion representative present at the relevantworking group
meetings could help in thisrespect.
The national and European dimensions of partici-pation were
further analysed by Ian Fraser, whodrew attention to the human
resources dimension:
The most important work on any standard is donetwice: the first,
most important work is to draft thestandard. Once the initial
drafting has been donemodifications are possible, but the basic
content ofthe standard is often largely determined. The secondkey
phase is the enquiry on the standard, whencomments made by the
national standardisation bodies are discussed and taken
intoaccount.
Those two phases are not carried out at national level but at
European level in the CENWGs. In this connection, we have noted the
frustration of stakeholders, including thepublic authorities, who
have been trying to influence the standardisation process over
thelast ten years, when they are not directly present in the WG
drafting the standard anddealing with the comments received during
the enquiry then the best that can be achie-ved is a marginal
influence over the content of the final standard.
The public enquiry, the work of the national mirror groups, the
fact that all stakeholderscan contribute to the building of a
national position, are all positive elements that shouldnot be
neglected.
However, to exercise real influence, there is no alternative to
being present at the key mee-tings to defend your point of view.
Trade unions are in a weak position here, as participa-ting in
meetings requires not only time and financial resources, but also
human resources:experts who can be effective advocates of their
positions, able to stand up to the pressureand criticism of the
other interest groups represented in the WG.
The ETUI-REHS experiment has so far produced an impressive
amount of useful data:we believe that if the methodology is applied
to other classes of machinery, similar goodresults will be
achieved.
The challenge now is to see how this information can be
introduced into standardisation.We consider that it is not
sufficient to have workers feedback stored in a library or
madeavailable in written form. There must be people putting
proposals based on workers feed-back on the table during WG
meetings and arguing the case meeting after meeting.Other
interested parties, who are physically present at the meetings, put
forward theirown agenda and argue their views, strongly defending
their interests, and will probablyleave aside the trade union
document.
The question remains as to how the CEN system can help integrate
workers feedback,taking into account the challenge represented by
direct participation in WGs and TCs.
P A G E 1 5
The public enquiry,the work of the national
mirror groups, the factthat all stakeholders can
contribute to the buildingof a national position,
are all positive elementsthat should not be
neglected.
-
The heterogeneity displayed by the stan-dardisation world in
terms of balancedrepresentation was confirmed by DougRussell, who
also provided hands-on infor-mation on the situation in the UK,
where:
There is very little involvement of thetrade unions in the NSB,
and there is evenless involvement of employers who buyequipment to
be used at work. However,some success stories in terms of
balancedinvolvement in standardisation can be toldby stakeholders
involved in the use of spe-cific machinery like meat machinery
andprinting machinery. In the UK, there arelarge numbers of FLTs in
bakery and in the
paper-making industry.In these areas there has been a
strongtripartite stakeholder group involvingemployers/trade
unions/HSE officials.Through this group, a consensus was deve-loped
very quickly about what the Britishline was on what we wanted to
see in thestandard, so there was only marginal dis-pute amongst
those stakeholders themsel-ves.
When it comes to the financial dimensionof participation, other
stakeholders facedifficulties, as Stefan Joannin indicated:
Maintaining a high level of participationfrom industry in
standardisation is notalways easy. Experts having participated
formany years are retiring, and it is not alwayseasy to find new
experts to replace them.The cost for industry is not
negligible.SMEs may find it hard to invest theirresources in
allowing operators to partici-pate in interviews and working
groups,collecting their opinions and preparingdraft
recommendations. One can onlyhope that the ETUI-REHS exercise
hasshown them that this system can work,and is worth the
investment.
The need for trade unions to ensure their influence by using
different channels - influen-cing the positions of National
Standardisation Bodies (NSBs) and mirror WGs and TCs,via national
public authorities - was shared by Martin Eifel, who recalled the
importanceof taking into account the views of all stakeholders:
When it comes to the stakeholders participation and influence,
the standardisationworld embraces a wide range of situations. On
the one hand, the ideal situation where
NSB representatives speak on behalf of all stakehol-ders; on the
other, there are situations where an inte-rest group has been able
to influence the NSBs in anumber of Member States and achieve a
near mono-poly on what will be actually put into the standard.
One example would be multinational companies thathave the
resources to invest in several different NSBrepresentatives,
thereby having a lot of influence.Such unbalanced situations are
against the principlesof standardisation, which should not favour
the inte-rests of a particular supplier or country.
P A G E 1 6
This success story caused Lennart Ahnstrm to emphasise the role
played by public autho-rities but also the difficulties they
face:
In addition to users feedback into standardisation, the
experience gained by authoritiesthrough market surveillance is
essential. However, public authorities participation
instandardisation is likely to decrease as time passes because of
the lack of human and finan-cial resources. Therefore, if we really
want the experiences of users of different machinesto be
incorporated into standards, we must find a pragmatic solution. And
the solutioninvolves the role of national mirror committees and
WGs. The question remains as tohow to pass information to the
mirror committees: a certain degree of centralisation ofthis user
information is necessary, because small countries could find it
difficult to makesuch information available to national bodies.
One example would be multinational companies that have the
resources to invest in several different NSB representatives,
thereby having a lot of influence.
If we really wantthe experiencesof users of differentmachines to
beincorporated intostandards, we must finda pragmatic solution.
Somesuccess stories
in terms of balancedinvolvement in
standardisation can betold by stakeholders
involved in the useof specific machinery like
meat machinery andprinting machinery.
-
The discussion then moved on to the natio-nal dimension of
standardisation. HereStefan Joannin depicted possible
practicalsteps that ETUI-REHS might want to taketowards NSB. He
began by observing thattechnical changes are feasible even after
thedraft standards have been written:
P A G E 1 7
However, it was pointed out by Werner Tannhuser that users
insights should be presentedin the form of concrete proposals:
In standardisation work, making general comments on the quality
of standards is veryoften useless. WGs welcome concrete proposals
and recommendations, if possible with arange of technical solutions
to be debated and agreed on. Failure to do so would imply
asignificant delay in managing such information, since someone else
would be obliged toextract factual proposals from generic
suggestions.
This observation was supported by TapioSiiril, who stressed the
need to attend mee-tings to make the most of users insights:
In my experience with CEN and ISOworking groups Ive seen the
amount oftechnical work that experts have to carryout: they meet
for a few days, a few times ayear, with the task of dealing with a
largenumber of comments coming from thenational standardisation
bodies. Onlycomments including detailed proposals formodifications
are seriously taken intoaccount.
And most importantly, it is necessary to besitting in the
meetings of the workinggroups, so as to explain the
proposedmodifications and answer the questions,criticisms and
comments: taking part inthe discussion is essential.
Therefore, the crucial step of the ETUI-REHS methodology is not
only the elabo-ration of technical recommendations to bepresented
to standard-setters, but also ascheme to ensure the participation
ofexperts supporting and advocating theusers concerns and
recommendations.And this trade union participation couldprove very
difficult when it comes tomachines like FLTs, whose standards
areelaborated in the framework of the ViennaAgreement at
international level.The difficulty of influencing standards that
cover the global market was confirmed by
Werner Tannhuser, who observed that:
Standardisation activity on FLTs is probably one of the best
examples of the role playedby globalisation. FLTs are sold
worldwide, in countries with very diverse safety, technolo-gical
and regulatory cultures.
Experts in ISO and in CEN have the difficult task of producing
standards that reflect theconsensus of different players operating
in different working environments. It is true thatthe elaboration
of FLT standards is a difficult exercise at European level. Moving
to theinternational dimension, it is even more difficult to agree
on some safety design issues.For this reason, participation and a
continuous exchange of views is primordial. And whenresearch
projects like the one carried out by ETUI-REHS produce suggestions
and recom-mendations, they should be integrated into draft
standards as soon as is practicable.
Of course, changes and modificationshave a better chance of
being included ina draft standard when they are requestedby many
stakeholders. That is why it isimportant that the users concerns
raisedby reports such as the one presented todayby ETUI-REHS, be
well known to theNSBs.
With this objective in mind, such reportscould first of all be
presented to the mirrorcommittees established within the NSBs,where
they exist, of the Member Statestaking part in the ETUI-REHS
project.This would increase the chances of theusers insights being
included in the posi-tions of the NSBs when they make com-ments or
vote at the CEN enquiry or for-mal vote stages.
WGs welcomeconcrete proposals
and recommendations,if possible with a range
of technical solutionsto be debated
and agreed on.
It is true thatthe elaboration of FLTstandards is a
difficultexercise at European level.Moving to the
internationaldimension, it is even moredifficult to agreeon some
safety design issues.
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Workers concerns are takeninto account at present,
but it is true that thesituation can be improvedby making this
integration
of users concerns moresystematic.
And whenever practical recommendations are made, the CEN and ISO
systems are ableto take due account of them continued Gerhard
Steiger, who confirmed that: many ofthe specific issues raised at
this seminar have been brought up in the WGs and TCs overthe years,
and this is reflected in the quality of CEN standards. CEN
standard-setters areaware of the importance of feedback on the use
of existing safety standards.
This is a requirement of CEN Guide 41411, the basic document
specifying requirementsfor the drafting and presentation of
European machinery safety standards. Workersconcerns are taken into
account at present, but it is true that the situation can be
impro-ved by making this integration of users concerns more
systematic.
Policy issues: do we need structural changes?
The discussion on what regulatory responses could support the
new ETUI-REHS strategywas introduced by Corrado Mattiuzzo, who gave
the audience a timely synthesis summari-sing some key points of the
discussion so far.
We all agree that ETUI-REHS has designed a very interesting
approach to improvemachinery safety. We are all aware that in order
to make the most of such an exercise byfeeding its outcomes into
standardisation, participation is necessary.
We are also aware that standardisation does not offer a level
playing field for all stakehol-ders: the social partners are worst
off in this regard. We have also heard how difficult ithas been to
carry out such a project: the key question is what we all can do to
make surethat such an exercise does not represent a one-off
episode, rather a permanent mechanismto help standardisation attain
the highest quality in terms of productivity and workershealth and
safety.
The fact that the Machinery Committee and WG led by the European
Commissionservices should have a leading role in helping find
appropriate policy answers to thesocial partners expectations is,
in principle, uncontested. However, in order to stimulateaction,
ETUI-REHS together with the pool of Bodies that carried out the
forklift truckstudy should elaborate and present some sort of plan
to be forwarded to the appropriateCommission services.
P A G E 1 8
Discussing how to move from words to deeds, Martin Eifel
suggested that ETUI-REHSshould:
take the experience of the project to the political level within
the context of theMachinery Directive and other pertinent
directives, in order to establish a permanentmechanism to feed
users concerns into standardisation. In relation to this it would
beinteresting to monitor the application of Article 5 of the
Machinery Directive.
Article 5 of the Machinery Directive requires Member States to
ensure thatappropriate measures are taken to enable the social
partners to have an influence atnational level on the process of
preparing and monitoring the harmonised stan-dards.This requirement
is complemented by Recital No.18, which recalls the need toimprove
the legislative framework in order to ensure an effective and
appropriatecontribution by employers and employees to the
standardisation process.
11. CEN Guide 414:2004 Safety of machinery Rules for the
drafting and presentation of safety standards. The guide is
publicly available on the CEN website at the following address:
http://www.cenorm.be/BOSS/supporting/reference+documents/cenguide41420041215.pdf
We all agree thatETUI-REHS hasdesigned a veryinteresting
approachto improvemachinery safety.
-
This monitoring is to be performed by the Commission services.
In this regard Martin Eifelsuggested that ETUI-REHS should present
the project and their concerns at the nextMachinery Working Group
meeting:
We believe that this ETUI-REHS strategy should be discussed in
the next MachineryWG. Member States should share their experiences
of implementing Article 5 of theDirective. If necessary, as a
practical application of Article 5 of the Machinery Directive,
itcould be envisaged to render obligatory a guarantee that the
social stakeholders have beenadequately consulted when issuing a
standard, in order to safeguard that the standardisa-tion process
functions well.
Alternatively (or additionally), one could imagine a system
similar to the one associated tothe recommendations for use issued
by the European coordination of notified bodies,that are open to
scrutiny of the Member States, before they are endorsed by
theMachinery WG. We might find it useful to do the same with the
harmonised standards,in order to pick up those where Member States
or the Commission believe that theconsultation procedure has not
worked properly. However, we have to remain realistic inorder to
take account of available resources and avoid creating unneces-sary
red tape.
P A G E 1 9
The opportunity to address Article 5 of theMachinery Directive
with the objective ofhelping to achieve a balanced input ofsocial
concerns into standardisation waswelcomed by attendees. On the one
hand, areference to Article 5 would strengthen therole of the
Machinery WG, as indicated byPascal Etienne:
ETUI-REHS should call on the Com-mission to monitor the Article
5 require-ments, because it would help achieve a levelplaying field
for any further discussion anddecisions taken in the Machinery
WG.Authorities value the role of the MachineryWG headed up by the
Commission, as itrepresents a forum where all stakeholderscan
contribute to a better design and incor-poration of machines into
the workplace.
The ETUI-REHS study is an impressiveexample of questions raised
about the qua-lity of certain standards. Stakeholders areasked to
respond to such concerns: autho-
rities on the one hand, by reporting onmeasures taken to ensure
that social part-ners can influence national standardisationwork;
standard-setters on the other, byanalysing and taking on board at
theappropriate time the suggestions formula-ted by people acting in
the field wheremachinery is used.
The Commission would politically steerthis new way of working
together throughthe Machinery WG. The French authori-ties have
already invested resources in thedirection of the ETUI-REHS
strategy andare willing to continue doing so.
This is felt necessary given the authoritiesresponsibility to
implement product andsocial directives by means of a
coherentapproach. The ETUI-REHS demand tomonitor Article 5 is also
in line with theobjectives of the New Approach revision:to provide
a better regulatory frameworkfor the functioning of the Single
Market.
A stronger role for the Machinery WG would also help optimise
the scarce resources of national authorities responsible for
ensuring theprotection of workers using machinery at work, as
indicated by Lennart Ahnstrm, who also recalled that:
The New Approach and the role given to standards has contributed
to the existence of safer machines, by providing a commonEuropean
platform where stakeholders can agree on technical solutions
complying with the legislative requirements. Participation is
crucial, and we recognise that not everyone has the same
possibility of influencing European standardisation work. This
situation needsto be improved. And market surveillance is more and
more resource-consuming, especially if we are to take balanced
decisions against manufacturerswithout distorting competition.
Reactive initiatives cannot be the sole means to ensure that only
safe machines are put on the market.Everyone realises how expensive
actions against machines and harmonised standards can be in terms
of resources. Thats why it would be better to anticipate problems
instead of reacting to them. In this connection, better cooperation
among MemberStates, and better use of any experience like that
gained from the ETUI-REHS project, represent the right way
ahead.
The French authoritieshave already
invested resourcesin the direction
of the ETUI-REHSstrategy and are willing
to continue doing so.
We might find it usefulto do the same with theharmonised
standards,in order to pick up thosewhere Member Statesor the
Commission believethat the consultationprocedure has not
workedproperly.
-
Cooperation and an intelligent interpre-tation and enforcement
of the Article 5requirements were stressed by Phil Papard,who also
stated that:
The legal status of the standards that arethe object of the
seminar today should bealways kept in mind: yes, they are theresult
of a process where consensus, lob-bying, resources come into play,
but theyare expected to deliver the presumption ofconformity to the
relevant legal require-ments of the Machinery Directive.And we all
know how resource-consuming
it can be to challenge a standard once it hasbeen published in
the Official Journal.This is the reason why HSE considers
theETUI-REHS strategy worthwhile as ithelps identify health and
safety problemsin the field that could be brought to CEN,to see
which of them could be addressedtaking into account the current
state of theart, and which ones require furtherresearch work.We do
not need to change the currentCEN system: we probably need only
toadapt it to take advantage of workers feed-back in an efficient
manner. Having a
champion in WGs and TCs is important,but realistically we cannot
probably have achampion in every MS for every standardwe are
working on.I would like to point out that when HSEembarked upon
this project, it did not seeit as a trade union project: the
project wasseen as a way to benefit from users know-ledge to
improve the design of machineryused at work, by bringing together
manystakeholders and working out feasibleimprovements both in
design and in theworking environment.
P A G E 2 0
The need to address both design and the working environment,
improving communica-tion between those who construct and those who
use the machines, was shared by AngelFuente Martin, with a focus on
SMEs:
The ETUI-REHS strategy has the potential to influence European
political decisionmaking. Without it remaining a purely academic
exercise, reality tells us that SMEs veryoften lack the technical
knowledge and know-how needed to make sound choices of
workequipment. As a result, SMEs are very often subject to the
whims of market players whosell products but not quality
products.In this connection, we feel that the ETUI-REHS strategy
could open up a debate withinthe framework of the Advisory
Committee on Safety and Health at Work12. In additionto acting
through the Advisory Committee and DG Employment officials,
ETUI-REHSshould maintain continuous contact with the Senior Labour
Inspectors Committee(SLIC) officials and explore new ways to
cooperate with market surveillance authorities.ETUI-REHS should
also draw policy-makers attention to the essential role played by
therisk assessment done by employers. Risk assessment is not an
academic exercise; rather, itrepresents a dynamic tool to
continuously monitor the balance between productivityobjectives and
workers wellbeing.Today we are discussing how all the information
emanating from users can be channelledtowards the right targets. It
is important to think about a European level playing field,because
some small countries do not have the human, financial and
administrative resour-ces to collect information from the field on
how machinery is really used.Therefore, cooperation among market
surveillance authorities and a continuous know-ledge transfer on
workplace experience with machinery is essential. We should also
keepin mind that other stakeholders like insurance companies could
be asked to play an activerole, since they are the bodies that pay
for sick leave, injuries, etc.
The attention given to SMEs health andsafety needs by the
European Agency forHealth and Safety at Work is a
continuouscommitment, recalled Brenda OBrien:
Europe's small and medium-sized enter-prises are key drivers of
economic growthand job creation. However, due to a lack offinancial
and organisational resources,many SMEs have only limited
occupatio-nal health and safety knowledge and capa-city. That is
why the Bilbao-based Eu-ropean Agency for Safety and Health atWork
keeps on organising SME fundingschemes focused on reducing safety
andhealth risks in Europe's SMEs.Forklift trucks are the most
widely usedpieces of equipment for moving materials
around worksites and warehouses in nume-rous industrial and
manufacturing sectors.But their use results in a high rate of
acci-dents involving drivers and other workers,especially in SMEs.
Forklift drivers are alsoexposed to many other risks, as a result
ofpoor ergonomic design, awkward postures,repetitive movements and
additionalmanual handling of goods.Against this background, the
transnationalproject where ETUI-REHS was involvedsome years ago,
was considered worthy ofthe Agency Award because it aimed toreduce
these risks by working with drivers,designers, dealers and national
authorities
towards improving forklift truck design,and by setting up
training activities. I amdelighted to see that the Agency
Awarddrove trade unions towards another suc-cessful European
experience.
12. The role of this standing Advisory Committee is to assist
the Commission in the preparation and implementation of decisions
taken in the field of safety and health at work and to facilitate
cooperationbetween national administrations, trade unions and
employers' organisations. ETUI-REHS acts as coordinator of the
workers interest group.
Forklift drivers are alsoexposed to many otherrisks, as a result
of poorergonomic design, awkwardpostures, repetitivemovements and
additionalmanual handling of goods.
It is important to thinkabout a European
level playing field,because some small
countries do not havethe human, financial
and administrativeresources to collect
information from the fieldon how machinery
is really used.
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It is in this spiritthat national monitoring
bodies have helpedthe trade unions to collect
information in the fieldand organise it
in such a waythat it can be fed intostandardisation work.
Insights into how the ETUI-REHS strategyaffected a multinational
enterprise wereprovided by Georges Fleury, who observedthat:
The employees at AREVA NC had noqualms about participating in
this type ofsurvey. The procedure used in the newmethod proposed by
ETUI-REHS is verysimilar to our way of working on a dailybasis in
many areas, such as dealing withquality, the environment and safety
mana-gement. In these three areas we base oursel-ves on standards
ISO 9001, ISO 14001and specification OHSAS 18001 respecti-vely.
The basic principle behind this sort ofapproach is a process of
continuous impro-vement. Under this principle, and in thepresent
case of machinery standards, it isimportant to take as many factors
as possi-ble into account, most notably users opi-nions. Of course
it is vital to analyse all theinformation gathered, and this forms
part
P A G E 2 1
of the proposed new method.It has become part of our regular
practiceto involve employees in this kind of conti-nuous
improvement process, and theyconsider it necessary if not
indispensable.What is more, they were even more enthu-siastic once
we told them that the outcomeof the survey they were involved in
wouldbe incorporated into a revision of Euro-pean-level standards.
Its the first time theyveever asked for our opinion at such a
highlevel, they said. But in actual fact, the wor-kers involved in
the survey also asked usabout the outcomes.
Under the previous method, still beingused to draw up and revise
standards, thefact that it is not possible to collect usersopinions
and generally take them intoaccount is a weak link in the existing
pro-cess. So the proposed new method solvesthis problem, or at
least considerablyimproves things. This new method sitswell with a
process of continuous improve-ment, and it certainly suits us.
Finally, the need to integrate the ETUI-REHS strategy into the
'CEN system' was unders-cored by Franck Gambelli and Olivier
Franois, who began by acknowledging the impor-tance of users'
feedback:
It is not just legitimate for employees the users of machinery
and personal protectionequipment to have an input into
standardisation, but it is in the undeniable interest oftheir
employers and of the employers suppliers. Employees are the people
directly expo-sed to residual risk, and prior risk reduction helps
employers comply with their safetyobligations. Operators use the
devices on a daily basis and are often more familiar thananyone
else with all their attributes, both positive and negative. In some
cases employeesmake purchasing decisions that are important for
companies and hence manufacturers.The user feedback exercise
organised by ETUI-REHS can contribute valuable experienceto
standard-setters deliberations.
However, the role played by Member States monitoring bodies in
this type of operationrequires some clarification. Member States
are obliged to ensure that the goals of theMachinery Directive are
attained in their country, particularly as regards
involvingemployees in the standardisation process. It is in this
spirit that national monitoringbodies have helped the trade unions
to collect information in the field and organise it insuch a way
that it can be fed into standardisation work. Nevertheless, the
companies par-ticipating in standardisation groups cannot be bound
by comments made by employersrepresentatives in response to this
type of survey.
Furthermore, as we understand it, this user feedback is being
'taken' to CEN by ETUI-REHS and not by Member States
representatives. So this is not some kind of 'commonposition'
between Member States and trade unions that enjoys a special legal
status, whe-reby non-compliance by the other standardisation
parties would automatically triggerthe threat of a safeguard
clause. A new and 'exceptional' standardisation procedure,
alludedto by one Member State representative taking part in this
exercise, would bypass CENsrules of procedure and would not be
acceptable to us. Subject to these few remarks, wewelcome the
high-quality work done by ETUI-REHS and hope it will help ensure
thatstandards take better account of reality on the ground.
The basicprinciple behindthis sortof approach isa processof
continuousimprovement.
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6. Overall conclusionsand future plans/perspectives
Laurent Vogel, ETUI-REHS, ActingHead of the Health and
SafetyDepartment
The ETUI-REHS strategy seeks to res-pond to indications given by
the EuropeanCommission. Two EC communications13
stress the importance of informationexchanges to enhance the
implementationof the New Approach Directives. Theproject that we
discussed together is asignificant practical challenge in terms
ofresearch effort. It addresses the humancosts associated with the
use of forklifttrucks every year. So it is a big challengenot least
for the sake of human beings.
On a general level, the ETUI-REHS stra-tegy enables us to assess
the credibility ofthe whole New Approach. In fact, underthe New
Approach, policy-makers havedelegated some of their functions to
pri-vate or semi-private bodies. This delega-tion of power
necessitates respect for aseries of conditions, and one of the
funda-mental conditions is the possibility for allinterested
parties to efficiently participatein the definition of technical
standards.
In this connection we trade unionistsbelieve that the present
situation is notsatisfactory. There are a series of causes,reasons
that conspire to create a particularstate of affairs, and there is
no guarantee aswe speak that all the parties involved
canparticipate in the standardisation process.
What we need to see is how an exercise likethe one presented
today can be not just anice show, a nice session identifying
pro-blems and difficulties. We must ensure thatthis actually leads
to a number of changes and I would say that these need to
bestructural changes. And we dont want togive the term structural
an exclusively regu-latory meaning.
We think that in a number of cases organi-sational roles can
remain what they are butstructural changes need to happen in
prac-tice. This change, in my opinion, is anissue for all
stakeholders so the idea is notjust to say that changes need to
focus onthis or that particular structure or group,because it would
not correspond to thepresent situation.
P A G E 2 2
We believe that a guiding role must beplayed by the European
Commission, andmore particularly DG Enterprise, becausethe quality
of standardisation is a funda-mental issue for the implementation
of theNew Approach. Only the Commission canconvince all the
stakeholders concerned tocooperate on health and safety matters
soas to make the New Approach more credi-ble.
Our Seminar today has shown how impor-tant is