MOVES TO ELIMINATE PART HARMONISED ENs
August 1st 2007 There is strong desire by the BSIF and its members to ensure that the EU Commission does not approve as Harmonised ENs, standards that do not cover all the basic health and safety requirements.
This simplistic objective, like everything else connected to the EU, seems to have taken on a life of its own and now appears to have policy infrastructure linkages across many, if not most, of the Directives coming out of the EU Commission.
While the Commission's Expert Group, consisting of member state representatives charged with responsibility for the PPE Directive, is seeking to re-define its guidance on how this directive should be enforced, another section within the Commission is seeking to define the new model for New Approach Directives, which includes the PPE Directive. Unfortunately, while these are being progressed in parallel, the complexity of the infrastructure almost ensures that cross-departmental communication, involving some 27 member states, is not always current and is full of misinformation.
There is a benefit to the UK in that much of this work is carried out in English but when many use English as their second language, differences in interpretation are the rule rather than the exception.
It is now apparent that most people who have a view would prefer all harmonised standards to cover all the basic requirements and that a standard should not be declared as Harmonised (published in the Official Journal to the European Community) unless it does.
The fact that many standards have been Harmonised which do not do this has created a dilemma for the Commission. Many non-PPE product standards, covering such diversity as cars, white goods, fabrics, etc, do not even mention these basic health and safety requirements and their withdrawal would create a major problem regarding the passage of these goods and the need for a level trading playing field.
Coupled with this is the fact that there are some EN product standards that refer to other EN standards, such as test methods. In these cases (and some of these relate to PPE) it will only be the combination of these standards, which will provide conformity. Currently, there is a clause in the draft of the New Approach blueprint, which permits the Commission to publish a standard as harmonised with a reservation or limitation, where it does not cover the basic requirements.
To quote Alain Meyer "Standards that do not cover all essential requirements may lead to discrepancies in conformity assessment and may contribute, as a result of competition between Notified Bodies and manufacturers, to a downward spiral in quality and safety".
While the BSIF might express the consequences differently, it is gratifying to see this in print from an authoritative source for the first time. The BSIF position is relatively clear and simple. The PPE Directive states that a harmonised standard gives a presumption of conformity that cannot be challenged by any member state. On this basis, any harmonised EN standard must include all those health and safety requirements that the Commission decides are ‘basic’ or ‘essential’ by the very act of its publication in the EU OJ.
The BSIF has taken the view that its main focus should be on PPE standards albeit that it needs to understand the global nature of the New Approach revision. The Federation's current thrusts are fourfold. Within the PPE Expert Group at the EU Commission, the BSIF is seeking to prevent this group trying to gain brownie points by second guessing the New Approach review. The second thrust is through its member representation at the Horizontal Group of PPE Notified Bodies, also within the EU Commission. A direct involvement with the UK team negotiating the New Approach blueprint is being pursued directly by the BSIF Secretariat and the BSIF is exerting its influence within the European Safety Federation.
The BSIF would welcome views on the subject of standards' harmonisation and information on how it is affecting your organisation - through the editor please. More articles from BSIF Enterprise: | 
