International Model for Technical Harmonization EarthMoving Machine Safety

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International Model for Technical Harmonization
Earth-Moving Machine Safety

• Dan Roley/Jan Mimer/Kenzo Tanaka
• November 3, 2008

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Outline of Presentation

• Outline of International Model for Technical
  Harmonization for Earth-Moving Machines
• Summary of Experience in Promoting the
  International Model for Earth-Moving Machines
• Proposal for Improving the International Model

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Earth-Moving Machines

• Machines for Excavating, Loading, Transporting,
  Spreading and Compacting Earth and Other
  Materials.

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International Model for Technical Harmonization

• Industry Associations From EU, USA, and Japan
  Worked Together to Develop an International Model
  for Earth-Moving Machines.
• The International Model Outlines General
  Principles for Technical Regulations Following
  the WP 6 Guidelines.
• The International Model Is Based on the Technical
  Requirements From the ISO/TC 127 Standards ISO
  20474.

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EMM International Model

• Scope Applies to Earth-Moving Machines Defined
  by ISO 6165
• Technical Requirements Minimize Machine Safety
  Risks During Lifetime of Machines
• Reference to ISO Standards for Compliance
  ISO/TC 127 Standards
• Compliance Clause Use Suppliers Declaration of
  Conformance (SDoC)
• Market Surveillance National Level

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General Experience Promoting the International
Model

• Currently Working With China, Russia, India, and
  Chile. Initial Contact with GCC.
• ISO/TC 127 Standards Are Accepted as National
  Standards, With Some National Differences Due to
  Technology Level
• Must Work Within the Regulatory Process and the
  Format for Regulations in Each Country.
• The General Principles of the International Model
  Regulation Can Be Applied to Different Types of
  Regulatory Processes.
• Additional Guidance is Needed for the Compliance
  Clause in the International Model

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Conformity Assessment Experience

• Japan and the USA Accept SDoC
• Europe Uses 93/465/EEC for Conformity Assessment
  and Certification
• SDoC is Accepted for Earth-Moving Machines
• A New Procedure Is Being Developed to Emphasize
  the Use of Harmonized Standards
• Still Recommends Conformity Assessment by the
  Manufacture
• SDoC Not as Well Accepted in Developing Countries

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Conformity Assessment - Challenges in Developing
Countries

• Manufacturers So Far Are Not Trusted to Do Their
  Own Compliance Declaration
• Some Small and Medium Manufacturers Are
  Considered to Need Help With Conformity
  Assessment and Certification
• Resources for Market Surveillance Are Limited and
  a Third Party Conformity Assessment and
  Certification Process Is Considered As a Way to
  Compensate for the Challenges With Market
  Surveillance

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Additional Compliance Options

• Manufacturer Compliance Testing - Suppliers
  Declaration of Conformity
• Third Party - Conformity Assessment and Issuance
  of Certificate
• Combined Process
• Manufacturer Compliance Testing
• Third Party Review Test Facilities and Quality
  Assurance Systems and Issue Compliance
  Certificates
• References
• ISO CASCO Standards
• New EC Draft Directive

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Recommended Actions

• The Sectoral Initiative Requests the Working
  Party to Revise the CROs That Were Adopted in
  2004, Specifically As Regards the Compliance
  Cause.
• It Further Requests a Mandate to Develop
  Different Options That Can Be Used When
  Suppliers Declaration of Conformity Is Not
  Judged to Be Acceptable.