information on emissions in machinery standards...a-5 low-emission machines – an incentive for the...

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Information onEmissions inMachinery Standards

KAN Report 21e

Verein zurFörderung derArbeitssicherheitin Europa

The project "Kommission Arbeitsschutz und Normung" (Commission for OccupationalHealth and Safety and Standardization) is financially supported by the GermanFederal Ministry of Labour and Social Affairs

Published by Verein zur Förderung der Arbeitssicherheit in Europa e.V.

Edited by Kommission Arbeitsschutz und Normung (KAN)SecretariatAlte Heerstraße 111, 53754 Sankt Augustin, GermanyTel: +49 2241 231-3452Fax: +49 2241 231-3464E-mail: [email protected]: www.kan.de

– November 2000 –

Overall production Druckerei Plump oHG

ISBN 3-88383-585-4

Page

Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

1 Introduction and background . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71.2 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81.3 The prominence given to emissions in the Machinery Directive and

in the basic standard for the safety of machinery . . . . . . . . . . . . . . . . . . . 101.4 Terms and definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111.5 State of the art . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2 Recommendations from OH&S on the specificationof emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.1 Strategy of German OH&S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 192.2 Strategy of French OH&S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

3 State of the debate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 213.1 National level (Germany) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 213.2 European and international level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

4 Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 274.1 Revision of EN 292 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 274.2 Noise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 284.3 Vibrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 354.4 Hazardous substances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 394.5 Radiation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 414.6 Databases of emission values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

5 Future Tasks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

6 Literature . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

Annexes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

Contents

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Annexes 1–10

A-1 The minimization and marking of emissions in Annex I of the MachineryDirective 98/37/EC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45A-1.1 Noise hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45A-1.2 Vibration hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46A-1.3 Hazards from hazardous substances . . . . . . . . . . . . . . . . . . . . . . 48A-1.4 Radiation hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

A-2 Extracts from EN 292 “Safety of machinery – Basic concepts, generalprinciples for design” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

A-3 Excerpt from the “Memorandum on health and safety standardization insupport of ‘new approach’ directives” . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

A-4 Recommendations of KAN and COS . . . . . . . . . . . . . . . . . . . . . . . . . . . 54A-4.1 KAN resolution of 9th December 1997: Quantifying emission in

product standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54A-4.2 Results of the deliberations by the French COS on 10th March 1998

relative to quantitative emission values in C-type standards . . . . . 56

A-5 Low-emission machines – an incentive for the operator . . . . . . . . . . . . . 58

A-6 Results of the KAN Study “Noise protection for machinery and workplace –status of and need for occupational health and safety standardization” –Extract . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

A-7 Detailed results of an analysis of machinery safety standards for theirtreatment of emission hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64A-7.1 Treatment of noise emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64A-7.2 Treatment of vibration emissions . . . . . . . . . . . . . . . . . . . . . . . . . 66A-7.3 Hazards from hazardous substances . . . . . . . . . . . . . . . . . . . . . 68

A-8 Results of the KAN Study “Definition of the need for standardization toestablish vibration parameters” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70

A-9 Dust emissions from hand-held woodworking power tools . . . . . . . . . . . 72

A-10 Standardization in the field of non-ionizing radiation – implementationof the specifications of the Machinery Directive in European standards . . 78

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Preface

Standardization on the safety of machin-ery is one of the key focuses of the workof the Commission for OccupationalHealth and Safety and Standardization –KAN. One of the aspects of the safety ofmachinery is emissions in the form ofnoise, vibrations, hazardous substancesand radiation. Standards play a centralrole in this area since their purpose is tolend definite shape to the provisions ofthe Machinery Directive under which themanufacturer is required to minimize theemissions of his machine and inform theuser of any residual risks.

This task of standardization has been thesubject of discussion on the national,European and international levels formany years. Strategies to enhance theprominence given to emissions in stand-ards have been developed and the firststeps towards implementation have beentaken.

To communicate the current state of thedebate and make basic documents avail-able to a broader public, e.g. manufactur-ers, users and supervisory authorities, theKAN Secretariat has issued this report.

This collection of material contains notonly familiar documents and positions(e.g. the reasoning given in the Machin-ery Directive, the latter's implementationin the basic machinery standard EN 292,positions from government, industry andstandards makers, development of aKAN strategy and its implementation), butalso other approaches and developments(e.g. benefit of emission values for theuser or pilot projects in France and Ger-many). This report is designed to serve asa basis for the ongoing discussion oftasks and scope for action as well as ofthe limits of standardization in the im-provement of occupational health & safe-ty in relation to machine emissions.

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Introduction and Background

1.1 Introduction

Machines which people work at and withhave to be safe if they are to be used inthe single European market. This is thelaw in the European economic area.

The hazards which may impair the safetyof machines, plant etc. in the work pro-cess are not confined solely to mechani-cal causes. Rather, they range widely,covering electrical risks, the ergonomicdesign of the machine and health-haz-ardous emissions.

Hazardous emissions - in other words,releases of energy and substances -include noise and vibrations caused bythe machine as well as hazardous sub-stances or radiation released by themachine. High emissions may have aserious effect on persons at their work-places and result in serious illness. Ex-amples of this are hearing loss inducedby exposure to excessive noise, andbone and joint damage to the handsand arms, circulatory disturbances in thehands and damage to the lumbar re-gion of the spine on exposure to exces-sive vibration.

According to the European principles ofoccupational health & safety (Article 95[formerly 100a] of the EC Treaty, Ma-chinery Directive 98/37/EC and its na-

tional implementation), such hazardsmust be reduced as far as possible dur-ing the design and construction of themachine in line with the current state ofthe art (minimization principle). Prefer-ence must be given to risk reduction atthe source. If this alone is insufficient,supplementary technical precautionsmust be taken.

Machine users must then be informed ofany residual risks (principle of informingthe user) and instructed in the machinedocuments about further technical meas-ures, the mode of operation to reducethe emission, and personal protectiveequipment for indirect protection fromthe residual risks.

A design engineer faced with the task ofdesigning a machine with state-of-the-artsafety needs guidance. In his centralwork document, i.e. the standard, hetherefore requires details of the type andscale of possible hazards which the ma-chine may pose.

Nevertheless, the state of informationon the different types of hazard varieswidely. Until now, far greater consider-ation has been given to mechanicaland electrical hazards in Europeanmachinery safety standards (type Cstandards) than those due to emis-sions. As stated in a French paper in

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19971, the C standards developed inthe last few years satisfy the require-ments of the Machinery Directive "interms of the mechanical and electricalrisks in general to a sufficient degree.However, as far as action to preventnoise, vibration, radiation, emissions ofhazardous substances ... are concerned,they do not provide sufficient guidanceto the designer of machines." In machin-ery standards, most progress has beenmade with the treatment of noise-relatedhazards as far as the measurement ofemissions is concerned.

Furthermore, health and safety profes-sionals and standardization experts areundecided as to how this information(e.g. specific values, emission classes)should be included in standards and howthe tasks in hand are to be performed.

KAN has therefore compiled this bro-chure with the aim of making the existingknowledge of the hazards posed by emis-sions and of their determination andreduction more accessible to standardsusers (design engineers, supervisory au-thorities) and machine users. It also high-lights the existing gaps in this knowledgeand suggests how they can be filled. Thissource of information and suggestions is

intended as an aid to argumentation forthe tasks in hand.

The approach taken in addressing thiscentral concern of KAN is described inChapter 2 following an explanation ofthe background and concepts in Chapter1. Chapter 3 reviews the state of thedebate within and outside Germany.Chapter 4 presents examples of activitiesto date and the annexes document thesources of importance for the subject (insome cases in extract form).

1.2 Background

Over the last few years, numerous healthand safety professionals and institutionshave pointed out and criticized the short-comings in the consideration given toemission hazards in machinery standards.There have been many demands to in-clude specific emission values in productstandards. For a long time, however, noprogress was made in the discussion ofthis issue. The Commission for Occupa-tional Health and Safety and Standardi-zation (KAN) has now been addressingitself to the issue since 1996 and hasdeveloped a strategy aimed at improvingthe prominence given to emissions in thestandardization process. The implementa-

1 Jean-Paul Lacore, Recours à des valeurs indicatives (valeurs réalisables d’émission, valeurs repères ...) ouà des „classes d´émission“ dans les normes C.

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tion of this strategy requires deeper dis-cussion and the development of possiblesolutions. For instance, KAN is investigat-ing the central issue of which other bod-ies specializing in health and safety couldjoin with the manufacturers in supportingthe process. KAN has also approachedsafety experts and works councils to in-struct them of their right to informationon emission hazards when purchasing amachine.

The Machinery Directive

The requirement of giving sufficient con-sideration to hazards possibly resultingfrom machine emissions is laid down inthe Machinery Directive 98/37/EC2. Itcontains the essential safety and healthrequirements which a machine must sat-isfy. European standards are designed tomake the satisfaction of these require-ments easier; their purpose is to supportthe fundamental requirements of theDirective and provide technical solutionsfor practical application.

The provisions of the Machinery Directivethus appeal directly or indirectly to twogroups of persons of relevance in thisconnection: product manufacturers andthe European standardization bodies.

Product manufacturers are obligated bythe Directive to minimize the health haz-ards posed by their products (hazardminimization principle) and to inform theuser of any residual risks (principle ofinforming the user).

Standards can help the design engineerto technically apply the essential require-ments of the Directive. The text of theDirective can be supplemented by thestandards bodies in two different ways.Firstly, technical standards can specifythe means, i.e. the manufacturer is giv-en specific design solutions. Alternative-ly, the standard may specify results orprotection targets, in which case themachine manufacturer is obliged to findhis/her own solution for achieving thistarget.

A balancing act for standardization

These two options give the subject aproblematical aspect. On the one hand,specifications made in European stand-ards must not be so rigid as to deprivethe manufacturer of all freedom for ac-tion and thus inhibit technical progress.For this reason, the description of specificdesign solutions in standards is not gen-erally considered particularly helpful. On

2 Directive 98/37/EC of the European Parliament and of the Council of 22 June 1998 on the approxima-tion of the laws of the Member States relating to machinery.

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the other hand, the specifications instandards should provide an added valueto the manufacturer in comparison withthe Directive.

The inclusion of values for machineryemissions in standards which makes iteasier for the manufacturer to complywith the minimization and informationprinciples is therefore both useful andnecessary. These values must not onany account be intended or interpretedas rigid limits. They must reflect thestate of the art and serve the manufac-turer as a practical guide. The lattercan then assess the state of the art be-fore optimizing measures to reducerisks and inform the user of any residu-al risks. By referring to these values, theOH&S authorities are thus able to verifycompliance with the provisions of theDirective. Incidentally, the expediencyof describing the state of the art con-cerning the minimization of emissionhazards by providing emission values instandards was discussed3 and docu-mented4 already at the beginning of the90s.

1.3 The prominence given to emis-sions in the Machinery Direc-tive and in the basic standardfor the safety of machinery

The Machinery Directive 98/37/EC laysdown the "Essential health and safetyrequirements relating to the design andconstruction of machinery and safetycomponents" in its Annex I. Of specialinterest for this report are the require-ments relating to emissions, which arequoted verbatim in Annex 1 of this re-port.

For the hazards of noise and vibrations,the Directive contains a fundamental mini-mization principle (i.e. hazard reduction)at the lowest level in relation to technicalprogress and the means available. Specialattention is devoted to hazards resultingfrom machine mobility. For compliancewith the principle of informing the user,the Directive specifies the duty for theoperating instructions to state values onthe noise or vibrations emitted by the ma-chine. To ensure result comparability, themanufacturer must also inform the user ofthe measuring method employed and theoperating conditions under which themeasurements were carried out.

3 Cf. for instance "Guidance on convenient use of achievable values in C standards", CEN/TC 114/CAGN3, 29th October 1993 and 3rd February 1994.

4 Cf. EN 414:1992 and CEN Report 1100:1994.

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On the subject of the hazards associatedwith hazardous substances and radiation,Annex I of the Directive stipulates that therisks must be eliminated; and, if this isnot possible, that the hazardous sub-stances must be "contained and/or evac-uated" and the radiation limited to a safelevel.

Although the statement of parameters isnot explicitly demanded for these typesof emission, quantification of all emis-sions is nonetheless interpreted by someas the logical consequence of the mini-mization principle (see Chapter 3.1).

The Machinery Directive formulates themost important requirements with regardto machine safety. To give design engi-neers, manufacturers and other interest-ed parties more specific details andinterpretative assistance, the basicstandard on machinery safety EN 292"Safety of machinery" - containing basicconcepts, design principles and generalaspects applicable to all machines,equipment and plant (type A standard) -was created. It can help design engi-neers in the application of type B stand-ards, which deal with a safety aspect ora safety device for a whole series ofmachines, equipment and plant. It alsoserves as an aid to the creation of typeC standards, which contain detailedsafety requirements for a certain ma-

chine or group of machines. It is cur-rently undergoing revision, whereby at-tempts are being made to give greaterprominence to emissions in the stand-ard. For further details, see Chapter 4.1"Revision of EN 292"; quotes from thestandard in its current version are con-tained in Annex 2 of this report.

1.4 Terms and Definitions

Despite the unequivocal demands of theMachinery Directive for minimizationand information, the debate on thestatement of emission values in productstandards has yet to make satisfactoryprogress. One of the reasons for this is,firstly, that clearly defined concepts, e.g.emission and immission, are still beingconfused; and, secondly, that severalterms describing the same thing are incirculation, e.g. achievable values, refer-ence values and indicative values, andseveral terms are indeed (still) in need ofclear definition.

In the present context

Emission is defined as a machine'srelease or discharge of noises, vibra-tions, pollutants and radiation (hazardfactors) into the environment, wherebythe machine's installation and operat-ing conditions are standardized andas close to the practice as possible;

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Immission is defined as the totalityof all energy and substance sharesper hazard factor which act upon anobserved location (workplace); in thecase of noise, for instance, this is thedirect share from all more or lessdistant machines and that reflectedby room surfaces and room installa-tions, generally averaged over a cer-tain period, e.g. 1 work shift.

Exposition is defined as the totality ofall energy or substance shares perhazard factor on the temporal aver-age in relation to a single person.

The following figure illustrates the distinc-tion between emission and immission,taking the example of pollutants.

For each hazard factor there are usuallyparameters quantifying the emission,immission and exposure, e.g. the maxi-mum workplace concentration for pollut-ant exposure. It is usual only to speak ofemission, immission or exposure valueswithout quoting the associated parame-ters if the situation described rules out therisk of misunderstandings.

Limit values

Limit values are legally binding, maxi-mum permitted values, which must nottherefore be given in standards. Thespecification of immission limit valuesand exposure limit values relating to thehealth and safety of workers at the work-

Differencebetween emissionsand immissions

mE = Emission rate MAK = Maximum workplace concentration

mE e.g.MAK

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place is reserved, in accordance with forexample the EU Memorandum on therole of standardization5 and CEN Resolu-tion BT 22/1997, for the political deci-sion-making process and law-making onthe national level.

The specification of machine emissionlimit values, i.e. upper limits for noise,vibrations etc., is not generally consid-ered conducive to progress in competitivelow-emission product design. On theEuropean level such limit values thereforeonly exist - for historical reasons - forcertain types of building machines andmotor vehicles.

Emission values

The values referred to in this report arethus covered by directives subject toArticle 95 (formerly 100a) of the ECTreaty and relate to product safety re-quirements. The hazardous emissionsreleased by a machine in the form ofnoise, vibrations, radiation or hazardoussubstances are expressed in so-calledemission values. These are designed toenable the manufacturer, by referring tothe available values, to compare hisproduct with other products in terms of

emissions and to establish a competitiveedge by undercutting these values. Thisof course presupposes that the emissionvalues defined are interpreted as a sell-ing point by machine users. These val-ues are also intended to serve as anincentive to manufacturers to improvethe state of the art and thus reduce thehazard level.

Range of emission values (cluster ofmeasured values), indicative values

To provide information on emission lev-els, the range of the emission values(cluster of measured values, see figure) ofa type of machine should be summarizedin a standard. The state of the art can bededuced from the range. Indicative val-ues (guide values) represent the meanemission values realizable on products ofthe same type on the market with proventechnical measures. These values shouldbe specified in standards as technicalparameters for machines in a Europe-wide consensus.

The term "achievable value" also used inthis connection, which is employed interalia in the Memorandum on health andsafety standardization in support of "new

5 EU Memorandum "The role of standardization in relation to article 118a of the EC-Treaty", in KAN Report5 "European standardization concerning the safety and health of workers at work", ed. Verein zurFörderung der Arbeitssicherheit in Europa, Sankt Augustin 1996.

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also important to define what is meant by"state of the art". This term is also definedin different ways on the national legallevel and on the European standardiza-tion level.


approach" directives6 to describe a ma-chine's emission, is not helpful. It is notobvious from this term that this valuesimply expresses a mean value rather

1.5 State of te art

Since indicative values are supposed toexpress the "state of the art" and shouldnot be interpreted as limit values, it is

6 DIN German Standards Institute (ed.): DIN Report 40, Memorandum on health and safety standardiza-tion in support of "new approach" directives; application in the field of machinery - CEN Report 1100,Berlin 1994, see also Chapter 4.1.

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than specifying a bottom limit for theemission which cannot be technicallyimproved upon at present.

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the majority of experts8. This practiceis regarded by the majority of expertsas an accurate description of thestate of the art at the time of publica-tion."9

3. State of the art: "State of developmentof progressive processes, installationsor modes of operation which suggestthat the practical suitability of a meas-ure for limiting emissions is estab-lished."10

4. State of science and technology:"State of development of the mostprogressive processes, installations ormodes of operation which, in theopinion of leading experts from sci-ence and technology, is considerednecessary on the basis of the latestscientific findings in relation to thegoal specified in law."11

The above illustrates the difference inemphasis of the "indeterminate legalterms" used in legislation. Technicalstandards and other technical rules have

7 Halbach et al., Übersicht über das Arbeitsrecht, ed. Federal Ministry of Labour and Social Affairs, 6thedition, Bonn, June 1997, p. 522 f.

8 E.g. in § 3 DruckgasV, § 6 DampfkesselV and § 3 AcetV.9 Definition of the term by the joint engineering committee (VDI Bulletin No. 47, 1982, p. 24); see also § 3

Gesetz über technische Arbeitsmittel (Gerätesicherheitsgesetz), BGBl. I 1998, p. 730, 734, and § 3Allgemeine Verwaltungsvorschrift zur Durchführung des Zweiten Abschnitts des Gerätesicherheitsgesetzes.

10 Legal definition in § 3 VI BImSchG.11 Commentary on § 87 Industrial Constitution Law, in: Fitting et al., Handkommentar zum Betriebsverfas-

sungsgesetz, Verlag Franz Vahlen, Munich, 19th edition, 1998, p. 1148 f.

National legal definition of the term"state of the art"

In regulating technical safety, Germanlegislation frequently resorts to "indeter-minate legal terms", e.g. state of the art,state of science and technology, ac-knowledged rules of technology. Theyare given clearer contours mainly in setsof technical rules. The goal of the dy-namic implementation of laws is thusachieved.

The level of safety is graduated7:

1. Established ergonomic findings: "Find-ings which, in the opinion of the over-whelming majority of experts, fulfil thegoals of occupational safety, can berealized with appropriate means, andare ascribed to the field of ergonom-ics ... in so far as they are concernedwith the problem of human labour."

2. Acknowledged rule of technology: "Atechnical solution which is proven inpractice and considered correct by

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the purpose of supporting these legalterms and must thus describe the de-manded state of development in eachcase.

The consideration of the current state ofthe art in meeting health and safety re-quirements is also anchored in Europeanregulations and documents.12 For exam-ple, the European standards bodies arerequested to support the essential safetyrequirements contained in product-relatedEC directives, such as the Machinery Di-rective, by drafting technical specifications"with reference to the state of the art".13

Definition of "state of the art"from the point of view ofEuropean standardization

The "state of the art" and "acknowledgedrule of technology" are not interpreted in

European standard DIN EN 4502014 asembodying different states of develop-ment. Rather, an "acknowledged rule oftechnology" is a description of the stateof the art, accurately in the opinion ofthe majority of experts15, 16.

DIN EN 45020 defines these terms asfollows:

State of the art: Developed stage oftechnical capability at a given time asregards products, processes and serv-ices, based on the relevant consolidat-ed findings of science, technology andexperience.

Acknowledged rule of technology:Technical provision acknowledged bya majority of representative experts asreflecting the state of the art.

12 Cf., for instance, recital 14 along with 1.5.8 and 1.5.9 of Annex I of the Machinery Directive 98/37/EC;Council Decision on the "New Approach in the field of technical harmonization and standardization";CEN Report CR 1100, 1994: Memorandum on health and safety standardization in support of "newapproach" directives; application in the field of machinery.

13 Halbach et al., Übersicht über das Arbeitsrecht, ed. Federal Ministry of Labour and Social Affairs, 6thedition, Bonn, June 1997.

14 DIN EN 45020 "General terms and their definitions concerning standardization and related activities",April 1994.

15 Summarized from an opinion of the DIN legal department of 19.01.95 in response to an inquiry fromBAGUV.

16 At a meeting of the chairmen and convenors of the TCs in June 1994, the EU Commission and the CENConsultant expressed the opinion that an EN describes the state of the art at the time of its publication inthe Official Journal of the EU; cf. Horst Liedtke: Maschinennormung - Kurzbericht aus der Praxis, printedin KAN Report 1, Sankt Augustin 1995, p. 85-88.

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Conclusion

In European and national legislation,the terms "state of the art" and "acknowl-edged rule of technology" describe ahigh level of protection. The state of theart is described in specifications ofstandards developed by a rule-makingstandards body ("the majority of repre-sentative experts") and these can beregarded as acknowledged rules oftechnology.

The Machinery Directive demands thatmachines meet its essential health andsafety requirements, which are given con-crete shape in standards. Machines mustbe designed in fulfilment of these require-ments and in accordance with the state ofthe art. From Article 95 (formerly 100a) ofthe EC Treaty, it can be compellingly con-cluded that the Machinery Directive as-sumes a high level of protection. It can beconcluded that standards as a rule ensurea high level of protection.

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2.1 Strategy of German OH&S

Taking as its point of departure the unsat-isfactory treatment of emission-relatedhazards, KAN - with the involvement ofall interested parties, such as representa-tives of government, the statutory acci-dent insurance institutions, standardsmakers and industry - has developed astrategy, the wording of which is con-tained in Annex 4.1. Representatives fromFrance (Institut National de Recherche etde Sécurité - INRS) and the United King-dom (Health & Safety Executive - HSE)have contributed towards the develop-ment of KAN's position. The goal isgreater prominence given to emissions inmachine safety standards and the state-ment of emission values particularly formass products like hand-held powertools.

To implement this strategy, the followingsteps are necessary:

1. Specifying the available measuringmethods for the various machine typesin type C standards.

2. Defining the representative operatingstates for emission measurements intype C standards.

3. Carrying out measurements on thisbasis.

4. Collecting the measurement results.

5. Compiling the data for each machinetype.

6. Deriving the state of the art for thismachine type from the results andexpressing it in the form of indicativevalues for design engineers in productstandards.

The approach also turns to still unre-solved issues, e.g. which other specialistOH&S bodies, along with the manufac-turers, could support the gradual devel-opment process; and for which ma-chines pilot projects should be encour-aged for the gathering of experience.

2.2 Strategy of French OH&S

Parallel to the German resolution, thestrategic steering committee on "Occu-pational hygiene and safety" (COS HST)of the French standardization body AF-NOR has adopted a similar strategy(wording in Annex 4). Like in Germany,the Machinery Directive is seen as thebasis requiring the inclusion of emissionvalues in product standards, and thetask of machine safety standards is tosupport this requirement. Quantitativedetails in standards are also seen inFrance as giving manufacturers an op-portunity to effectively evaluate theirproducts, minimize hazards and informproduct users.

2 Recommendations from OH&S on the specificationof emissions

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The inclusion of values is consideredsuitable for certain product groups, butnot necessarily for all. The preconditionsthat have to be met are the same asthose proposed by KAN:

Test methods must be available andoperating states defined.

A method of data acquisition must beavailable.

2 Recommendations

The results must express the state ofthe art for the particular machinetype.

A pilot project for hand-held machinesis being carried out as a means of ob-taining information on noise and vibra-tion hazards. Further information on itsimplementation can be found in Chap-ters 4.2 and 4.3.

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On the basis of the strategies adopted byGermany and France, there is now aneed - in addition to the national discus-sion - for a debate on the European andinternational level on such issues as howthe goals can best be achieved in prac-tice, who should be responsible for whichtasks, and which policy should be adopt-ed.

3.1 National level (Germany)

The principles of the KAN strategy aresupported by all the interested parties.

For instance, the Zentralverband derElektrotechnik und Elektroindustrie e.V.(ZVEI) [Central Association of the Electri-cal Engineering Industry]17 is of the opin-ion that emission values given in stand-ards as indications of ranges and as in-dicative values would be a practicableaid to the manufacturer. Firstly, it wouldenable him to assess the state of the artin relation to the hazards posed by hisproduct. And, secondly, it would give himthe opportunity to develop technical solu-tions in fulfilment of the standard. Aslong as standards do not include designsuggestions, emission values are notinterpreted as limit values and a precisedistinction is made between emission and

immission, ZVEI is in favour of treating allsignificant hazards in product standardsand including the statement of the rele-vant emission values. In describing thestate of the art, these would give themanufacturer a guide to how he shoulddesign his product. Emission details inequipment documentation would also, inZVEI's opinion, help the operator to de-sign his operating environment andcodes of practice accordingly.

In the opinion of standards makers, it isabsolutely essential to investigate in detailthe feasibility and financeability of therequired steps.

According to the views expressed by DrPense of the chemical industry (Annex 5),the statement of indicative values forhazard substance emissions is also in theinterests of his branch of industry. Hesees benefits both for the manufacturer,e.g. incentive to conduct measurementsand use of low emission values as a sell-ing point, and for the user, e.g. source ofinformation and aid for the decisionabout additional protective measures atthe workplace, if indicative values areavailable. He also suggests consideringwhether the purchase of low-emissionmachines could be linked to exemption

3 State of the debate

17 Source: Contribution by Mr Huhle, ZVEI, at the KAN Forum on "OH&S-related standardization as ameans of effective prevention - Machine emissions" at "Arbeitsschutz Aktuell 98" in Leipzig.

22


from workplace measurements, e.g. forcertain hazardous substances. The user'sdesire for information on emissions whenpurchasing a machine will put greaterpressure on the manufacturer to measurehis machine's emissions and comparethem with the indicative values.

However, such an exemption linked tothe machine's emissions still requiresexhaustive discussion with the regulatoryand supervisory authorities. As far asusers are concerned there is a fundamen-tal benefit in that the purchase of ma-chines with low emission values maymake additional protective measuressuperfluous at the workplace.

The German Federal Institute for Occu-pational Safety and Health (BAuA) is alsodecidedly in favour of the quantificationof hazardous substance emissions inproduct standards . Its specific suggestionof supplementing the indicative valuereflecting the state of the art with so-called emission classes modifies theemission parameter approach.

In the BAuA's opinion, three emissionclasses for hazardous substances shouldcover the range between zero emissionand the indicative value as the top limit.The demarcation lines between the class-

es should be drawn for each type of ma-chinery on the basis of technical aspects.Under this approach, the manufacturerassigns his machine to an emission classon the basis of the results of emissionmeasurements during conformity testing.Machines which can be assigned to oneof these classes would thus conform tothe directive and be marketable.

From the BAuA's point of view, this ap-proach would yield a whole range ofadvantages.

By adopting emission classes, the riskof confusing emission values withnumerically fixed limit values would beexcluded.

The ongoing technical development ofmachines would be rewarded by as-signment to a lower emission classand thus probably encouraged.

According to the BAuA, the advantageof emission classes over numericalemission values would be that a pur-chase decision would not be solelybased on a numerical comparison ofmeasurement results.

For the purchaser of a machine as-signed to a low emission class, addi-tional OH&S measures on site could

18 Source: BAuA contribution to the KAN meeting 04/96: "Emission classes rather than achievable values".

23

be superfluous, thus yielding econom-ic advantages. Furthermore - as al-ready stressed by the representative ofthe chemical industry - the purchaserwould be able to estimate at the plan-ning stage whether and on what scaleextra measures would be necessary onsite to achieve compliance with theapplicable OH&S regulations. If ma-chines in different emission classeswere available, the purchaser couldchoose the most cost-effective ma-chine for his situation and, in doingso, take account of anticipated futuredevelopments.

Employers for their part would also besupported in their hazard assessmentas knowledge of the emission classeswould usually make it possible to cal-culate on the basis of rough estimateswhether the demanded values arecomplied with.

In the BAuA's opinion, supervisoryservices would generally find it easy toassess local conditions on the basis ofthe machine's emission class. Anyproposals for improving the workplacesituation could be formulated preciselyand their implementation monitoredwith ease.

Regulatory authorities whose compe-tence lies within the scope of Article137 (formerly 118a) of the EC Treatywould find in industry and on the mar-

ket machines with specific emissionclasses which would facilitate preciseand immediately executable meas-ures. Depending on the circumstanc-es, certain OH&S requirements couldbe assigned to a certain emissionclass. In the opinion of the BAuA, thiswould be of benefit to small and me-dium-size enterprises in particular.

In addition to these supplementary com-ments and arguments in favour of thebasic position of the KAN strategy, theindividual steps of the approach are alsodiscussed.

On the issue of whether the statement ofemission values by the manufacturer isonly desirable for the emission of noiseand vibrations, the German Federal Min-istry of Labour and Social Affairs (BMA),which, along with other bodies on thenational level, is responsible for interpret-ing the Machinery Directive, has alsoexpressed its opinion. In this connection,the BMA emphatically opposes the posi-tion of certain Technical Committeesinvolved in European and internationalstandardization which reject quoting suchvalues for hazards other than noise andvibrations. The standards makers oftenargue that since the Machinery Directivedoes not contain any statements on otherhazards the standardization bodies haveno mandate.

24

The BMA is of the view that the quantita-tive statement of emissions, particularlyfor noise and vibrations, but also forhazardous substances and radiation, inproduct standards is compellingly de-manded by the EC directives. The neces-sity for the quantification of all significantemissions is derived not only from themarking requirement, but also from theminimization principle of the MachineryDirective. If hazard minimization is to bedescribed objectively, quantification inproduct standards is indispensable, inthe BMA's opinion. In addition, the BMAalso holds that hazards posed by emis-sions have not so far been given suffi-cient prominence in standards. The BMAtherefore advocates a consistent imple-mentation of the KAN strategy outlinedin Chapters 2 and 4.1 of this report andconsiders it feasible to import the resultsobtained directly into ongoing standardi-zation processes. The first step at thepresent moment should be the specifica-tion of measurement methods in Cstandards and the definition of operatingstates.

According to the Federation of the Stat-utory Accident Insurance Institutions ofthe industrial sector (HVBG), the KANstrategy needs to be more preciselyformulated on this point. The argumentfrom manufacturers and standards mak-ers that the strategy will be difficult to

implement as uniform measuring meth-ods for the specific application are notyet available or fully developed should,in the HVBG's view, be countered bydefining where research is needed. Inthe process, KAN should firstly makeuse of its contacts with the relevantresearch institutions (BAuA, PT AuT,BIA) and secondly attempt to developsuitable solutions with its European part-ners.

3.2 European and internationallevel

In France, the Institut National de Re-cherche et de Sécurité (INRS) has beenengaged for some time now in promot-ing the specification of emission valuesin product standards. It also chaired theworking group CEN/BT 60 in the prepa-ration of the Memorandum on healthand safety standardization in support of"new approach" directives (see DIN Re-port 40, Chapter 4.1).

The INRS's position endorses the strategyof the German OH&S institutions (Chap-ter 2.1 and Annex 4.1) and is reflectedin the resolution of the strategic steeringcommittee on "Occupation hygiene andsafety" of the French standardizationbody AFNOR (Chapter 2.2 and Annex4.2). The resolution, mirroring the pro-posal of the German BAuA, demands


25

"the inclusion of emission classes in cer-tain C standards".

In a general report of 1997, the INRSattempts to find explanations for the hith-erto vain efforts to have emission valuesspecified in product standards. It high-lights, inter alia, the lack of continuityand resolution on the part of designengineers and OH&S professionals interms of joint action, the unfortunatechoice of terminology ("achievable val-ues"), the confusion over emission andimmission values, and the lack of practi-cal experience. The INRS attempts toovercome these deficiencies with its ownactivities and by cooperating with KANand other relevant institutions.

In the meantime, a steering group hasbeen convened by the interested groupson the French level as a means of imple-menting this general report. The stepsplanned initially for noise hazards arepresented in Chapter 4.2.1.

On the CEN level, the standards com-mittee CEN/TC 114 "Safety of machin-ery", which is of great relevance for ma-chine safety, has taken a further impor-tant step. In its Business Plan it has setitself the goal - in response to KAN'ssuggestion - of giving greater promi-nence to emissions in machine stand-ards. From now on, design engineers are

to be provided with tools which makebetter use of the growing knowledge ofthe quantification and minimization ofhealth-hazardous emissions which are tobe used more intensively in machinestandardization.

With his adivsory nucleus, the CEN Rap-porteur for machine safety has investigat-ed the question of who can collect theemission data necessary for the definitionof indicative values and who can alsoconduct the measurements. Collectingdata, he claims, is not the task of indus-try and lies outside the possibilities ofCEN and its standardization bodies. Inaddition, he adds, owing to the largenumber of machine configurations, thenature of the market and limited outputfigures, suitable noise abatement tech-nology is not usually available. This givesrise to the efforts to state indicative val-ues. However, these, if available at all,are difficult to compare.

On the international standardizationlevel, the IEC subcommittee 61F "Safetyof hand-held motor-operated electrictools" has decided that "requirements inconnection with specifications for noisemeasurement, vibration measurementand dust measurement" will not be in-cluded in standards. The reason given isthat the European approach which fo-cuses on directives has little impact

26

world-wide and thus that Europeanviews, which are strongly influenced bythe Machinery Directive, would in somerespects be unenforceable. Clearly inevidence at this meeting were the efforts"to leave more responsibility and greaterfreedom in the hands of manufacturers,whilst at the same time stressing the re-sponsibility of governments and publicauthorities."

This lack of understanding of internation-al standards makers for the Europeansafety concept of the Machinery Directive


and the implementation in standards isby no means confined to the field ofhand-held power tools, but also appliesto the same extent to numerous otherfields. This position overlooks the bene-fits of this safety philosophy and the reg-ularities of the European market. For thisreason it is necessary to convince inter-national standards makers of the factthat, in the long term, their standardsand thus also international products canonly be adopted unchanged in Europe ifthey are compatible with the Europeanconception of machine safety.

27

In Chapter 3, emissions were not dealtwith individually but as "the emissions ofa machine". However, in the implemen-tation of the KAN strategy, a distinctionhas indeed to be made between noise,vibrations, hazardous substances andradiation. Different sources on the ma-chine, transmission routes, effects,measuring methods and also differencesin the state of knowledge make it neces-sary to individually study the hazards,their treatment in standardization andthe manufacturers' information on emis-sions and investigate ways of overcom-ing the shortcomings.

One way of improving the situation is togive greater prominence to emissions inthe basic standard EN 292, which iscurrently undergoing revision (Chapter4.1).

We also wish to present investigations byKAN and various other projects on indi-vidual emissions (Chapters 4.2 to 4.5).The individual approaches underline thatconsiderable difficulties will have to beovercome for all hazards before satisfac-tory quantification will be possible. Nev-ertheless, there are a number of ap-proaches which are worthy of furtherconsideration, e.g.

Surveying manufacturers to obtain areliable picture of the state of the art.

Specifying emission classes rather thanindividual emission values.

Examining manufacturers' informationin the search for shortcomings in theimplementation of the machinery safe-ty standards.

Using indicative values to check haz-ard minimization efforts.

Projects which attend to the collection ofdata required for implementation arepresented in Chapter 4.6.

4.1 Revision of EN 292

As explained, objections have been raisedto the quantification of emission values inproduct standards for a variety of reasons.According to one line of argument fre-quently put forward in this connection, theMachinery Directive explicitly demandsquantification only for hazards posed bynoise and vibrations if these are significantand therefore that the standards makershave no mandate. With clear statementsin terms of the quantification of the otherhealth-impairing emissions in the Machin-ery Directive, it would be possible to en-hance the acceptance of the KAN resolu-tion (Annex 4), particularly among theother CEN members.

The current revision of the basic machinesafety standard EN 292 "Safety of machin-

4 Implementation

28

ery", Parts 1 and 2, also represents anopportunity to give greater prominence toemissions. KAN has therefore joined forc-es with representatives of horizontal CEN/TCs on noise, vibrations, hazardous sub-stances and radiation in advocating addi-tions to the standard in this direction.

The result so far is that the most recentversion of Part 1 of July 1999 (Rev. 16)adopts the terms "emission (section 3.28)"and "emission control performance (sec-tion 3.29)", which result from the emis-sion values of machines of the samedesign. In the strategy of risk reduction,reference is also made to emissions (sec-tion 5.0.3). The design engineer mustestimate the risk, e.g. on the basis ofemission values, for each identified haz-ard and hazardous situation.

In the present version of the revision ofPart 2 of July 1999, major additions re-lating to emissions have been included:

In "taking into account the generaltechnical knowledge regarding ma-chine design and construction", emis-sion values for noise, vibrations, haz-ardous substances and radiation are tobe collected and compared (section3.3c).

In "the enclosure of control stations andintervention zones, combined protec-tion from several risks is to be provided

and emission hazards, e.g. noise, vi-bration, radiation, hazardous substanc-es" are to be included (section 4.1.1).

Section 4.4 covers additional protectivemeasures reducing emission if the re-duction of emissions at source is notachieved to a sufficient extent. Exam-ples are listed for noise (enclosures;screens fitted to the machinery; silenc-ers), vibrations (vibration isolators,additional mass, vibration absorbers,resilient mounting, suspended seat)and hazardous substances (use of dust-reducing procedures, machine encap-sulation, local exhaustion with filtration,wetting with liquids, special ventilationin the area of the machine). Usefulstandards, e.g. for the measurement ofnoise emissions or for the isolation of avibration source, are also listed.

Greater prominence given to emissions inthe basic standard will provide the basisfor the inclusion of indicative values in Cstandards.

4.2 Noise

Results of the KAN Study "Noise protec-tion for machinery and workplace - sta-tus of and need for occupational healthand safety standardization"

The KAN Study "Noise protection formachinery and workplace - status of

4 Implementation

29

and need for occupational health andsafety standardization"19 investigated,amongst other things, the state of stand-ardization in terms of emissions. Thestudy reveals a need for action to betaken to improve the consideration giv-en to noise hazards in national andEuropean standardization. For instance,it criticizes the insufficient implementa-tion of type B standards for noise meas-urement and noise control in the safetystandards for machinery. The precondi-tions for the determination of noise pa-rameters still are not sufficient as not allnoise sources have been encompassedunder the present system or are notmeasured in near-authentic operatingconditions.

The recommendations which KAN derivesfrom this are aimed at improving theprovision of data, experience and materi-als on measuring methods and uniformoperating conditions, emission valuesand noise control measures and on theirinclusion in standard drafting and revi-sion.

The results and the resultant need foraction are presented in greater detail inAnnex 6 of this report.

Prominence given to noise hazards inselected standards

The debate on the quantification of emis-sion values in product standards wasinitiated at KAN in 1996. The KAN Sec-retariat thereupon selected seven ma-chine standards and work items as exam-ples and examined them for their treat-ment of noise emissions.

On the basis of the subsequent review,KAN firstly shows to what extent noisehazards are dealt with in the selectedstandards. It examines whether the haz-ard is mentioned at all. Furthermore,KAN analyzes whether noise controlmeasures, measuring methods, standard-ized operating conditions and, finally,values for the emission are given reflect-ing the state of the art. Detailed analysisresults from two examples are presentedin Annex 7.1.

The results obtained from the examplesare largely identical to those from theKAN Study "Noise protection for machin-ery and workplace - status of and needfor occupational health and safety stand-ardization" and the experience from KANcomments on machine standards. Theyshow that reference is usually made tothe hazard and to design measures to

19 KAN Report 8, ed. Verein zur Förderung der Arbeitssicherheit in Europa, August 1996

30

4 Implementation

reduce the hazard. The measuring meth-ods are not yet specified in all relevanttype C standards. The state of the art israrely quantified in the form of numerical

values. These are often taken from direc-tives, national regulations or ISO stand-ards where they serve as limit values, orare obsolete.

31

DIN EN 774:Gardenequipment -Hand held,integrallypoweredhedge trim-mers (12/1997)

prEN 792 -14: Hand-held nonelectricpower tools -Safety requi-rements -Part 14:Assemblypower toolsfor non-threadedmechanicalfasteners(08/1995)

DIN EN 289:Rubber andplasticsmachinery;compressionand transfermouldingpresses;safety requi-rements forthe design(01/1998)

DIN EN 791:Drill rigs -Safety (01/1996)

prEN 474-7:Earth-movingmachinery -Safety - Part7: Require-ments forscrapers (05/1998)

DIN EN 692:Mechanicalpresses -Safety (08/1996)

DIN EN 608:Agriculturaland forestrymachinery -Portablechain saws(12/1994)

Standard

Criteria

Table 2: Review of the prominence given to noise hazards in selected standards

YesNoValues obtained from the "Baumaschinen-Lärm-VO" (construction machine noise ordinance) or the "Special testing principles for theassessment of the noise of chain saws at the chain saw operator's ear" (1986) of the agricultural accident insurance institutions

Noise cited as a hazard

Reference to technicalnoise reduction measures

Acoustic measuring me-thods given

Operating state for acou-stic measurements defined

State of the art quantified

32

Results of the project of BAuA / NRWOH&S administration / BG for the me-chanical engineering and metal industry

In cooperation with the Federal Institutefor Occupational Safety and Health(BAuA) and the BG for the mechanicalengineering and metal industry, theLandesanstalt für Arbeitsschutz desLandes Nordrhein-Westfalen (Occupa-tional Health & Safety Agency of North-Rhine/Westphalia) has had manufactur-ers' information on noise in their operat-ing instructions checked by the OH&Sauthorities. Information on machinesfrom 1411 manufacturers from 25countries was investigated. It was dis-covered that the details given by manu-facturers and importers were highly defi-cient. 43% of the documents examinedcontained incomplete information and28% none at all, and 56% of the manu-facturers and importers stated that theywere unaware of the legal provisionsand/or measurement standards.

From the data on 1054 machines from571 manufacturers, which were com-piled by the OH&S authorities in NRW,the ranges of the emission values for theindividual machine types have beendetermined.20

Results of a survey of manufacturers bythe central research and testing instituteof the German accident insurance institu-tions

In the context of the debate on the spec-ification of emission values in C stand-ards, manufacturers have frequentlypointed out that in the vast majority ofcases no information was available onthe state of the art and the effort re-quired for conducting such measure-ments was excessive.

Of interest in this connection are theresults of an investigation by the centralresearch and testing institute of theGerman accident insurance institutions(BIA) together with the Austrian andSwiss accident insurance institutionsAUVA and SUVA. In a survey of manu-facturers, measurement data on thenoise emissions from a total of 20 dif-ferent woodworking machines andhand-held tools were gathered. The BIAcompared the data with existing datafrom the literature (VDI ETS Guidelines,BAuA research reports, informationfrom the BG for the woodworking in-dustry) and discussed the results forwoodworking machines with the wood-working BG.

4 Implementation

20 Further information can be obtained on the Internet at http:// www.komnet.nrw.de or from Landesanstaltfür Arbeitsschutz des Landes Nordrhein-Westfalen, Ulenbergstr. 127-131, 40225 Düsseldorf.

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The noise emission values gathered inthe survey of manufacturers had to beassessed differently in terms of their in-formation value. For some of the gath-ered values, reliable statements weredifficult to make as information on theoperating state during measurement waslacking or the number of samples wastoo small. For 50% of the machine typescovered, however, the number of sam-ples was sufficiently large and the emis-sion values relatively sound. The valuesobtained are for the most part some-what lower than the comparison valuesobtained from the literature, the latter,however, were mostly gathered over tenyears ago. The lower values obtained inthe survey can thus be explained bynoise reduction measures undertaken inthe intervening period.

In spite of the reservations mentioned,the authors come to the conclusionthat "it is possible to gain a fairly accu-rate picture of the state of the art formany machines in terms of noise emis-sions from this survey of manufactur-ers", even if the results and experiencestill require further discussion and de-velopment.

Implementation of the resolution of thestrategic steering committee "Occupa-tional hygiene and safety" (COS HST) ofthe French standardization body AFNORin the noise sector

At the beginning of 1999, the FrenchInstitut national de recherche et de sécu-rité (INRS) launched an action pro-gramme concerned with practices in theprovision of information on noise frommachines. This programme is aimed atensuring that full information on noiseemissions from machines, as demandedin Europe, is in fact provided. It compris-es two schemes which are mutually com-patible and are to be carried out in par-allel.

Scheme A: This is a pilot project inwhich the INRS will cooperate with anumber of French manufacturers ofselected machines. (Together withthese manufacturers, the noise emis-sions of products will be measured atthe companies and the resultant read-ings gathered. These will then be in-vestigated as to whether indicativevalues can be derived from them forthe particular machine type and possi-bly included in C standards for these

21 This pilot project is a response to the request to carry out pilot projects/measures, as formulated in theresolution of the French COS "HST" of 10th March 1998 for the statement of indicative values in Cstandards and in the resolution of Kommission Arbeitsschutz und Normung (KAN) of 9th December 1997on the quantification of emissions in product standards.

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machines.) The project will initiallyfocus on hand-held pneumatic screw-drivers.

Scheme B: In this case, a survey ofmanufacturers is planned in which thecompanies concerned are to be ap-proached mainly, though not exclu-sively, at trade fairs. The intention is toquestion manufacturers on the follow-ing subjects: Opinions on the state-ment of noise emissions, the methodsemployed and their practice to informabout noise emissions; knowledge ofand application of standards con-cerned with the measurement of noiseemissions from machines; possibledifficulties of all kinds, particularly interms of the availability of manpowerand materials.

The resources required for carrying outthe programme (manpower and materi-als) are being provided by the INRS, theregional centres for physical measure-ments, which in France belong to thesocial security system, and the FrenchMinistry of Labour.

The steering group for this pilot projectmet for the first time on 18th February1999. It is composed of the followinginterested and "involved" groups: the

French Ministry of Labour, the Fédérationdes industries mécaniques (FIM), theCentre technique des industries méca-niques (CETIM, French research centre),the regional centres for physical meas-urements of the social security system, theUnion de normalisation de la mécanique(UNM), Le Syndicat des industries del'outillage (SIO), the trade unions, the"Occupational hygiene and safety" strate-gic steering committee (COS "HST") ofthe French standardization body AF-NOR22 and the INRS.

The envisaged measures are, if possible,to be combined with other measures witha similar objective, which in Germany arebased on the KAN resolution. The al-ready intensive cooperation with KANand the Federal Institute for Occupation-al Safety and Health (BAuA) is to be ex-panded further. Moreover, the standardi-zation section of the INRS will find outabout comparable projects in otherMember States of the European Union,and above all in the United Kingdom andScandinavia.

The pilot project described in Scheme Ahas already started and is scheduled forconclusion by June 2000. The INRS em-ployed a new member of staff for the

22 At the end of the resolution of COS "HST" 10.03.98, the following is stated: "COS will follow up theseactions."

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35

varied tasks for the duration of theproject. During the initial phase, contactshave been established with manufactur-ers of hand-held pneumatic screwdrivers,e.g. at trade fairs.

The measurement phase has also started.The measurements have to be carriedout on over 60 different models so thatthe readings can be presented as a clus-ter of points, as described in EN ISO11689. As a result of support fromCRAM and the supraregional centres forphysical measurements, technicians fromCETIM and the INRS can use the work-shops of operators of pneumatic screw-drivers for the measurements and thuskeep costs low.

With the aid of the results, it is hoped tobe able to provide either clusters of meas-uring points or, in another way, indicativevalues for noise in a future generation ofmachine safety standards for screwdrivers.These values should reflect the currentstate of the art and serve as an exampleso that the statement of values will be-come standard practice in other type Cstandards as well.

Since this goal is still far from beingreached and will also be difficult toreach, the exchange of experience be-

tween Germany and France is still con-sidered very important.

4.3 Vibrations

Results of the KAN Study "Definition ofthe need for standardization to establishvibration parameters"

The KAN Study "Definition of the need forstandardization to establish vibrationparameters"23 has investigated the stateof standardization in terms of vibrationemissions. The results and conclusions,extracts of which are presented in Annex8, also reveal a need for action in thevibration sector. This concerns, firstly, theprovision of further test standards particu-larly for whole-body vibrations, the speci-fication of operating conditions and thedescription of the state of the art with theaid of collected and managed data. Sec-ondly, the study strongly advises that Cstandardization be supported by vibrationexperts and that a stronger distinction bemade between emissions and immissionsin the standards.

Prominence given to vibration hazards inselected standards

Like for noise (Chapter 4.2), the KANSecretariat has selected representative

23 KAN Report 3, ed. Verein zur Förderung der Arbeitssicherheit in Europa, March 1996.

36

machine standards and work items andinvestigated them for the prominencethey give to vibration emissions.

The following table shows the extent towhich prominence is given to vibrationhazards in the selected standards. Annex7.2 contains more detailed analysis re-sults from two examples, one positiveand the other negative.

The exemplary investigations on vibra-tion hazards also confirm the results of

4 Implementation

the KAN Study "Definition of the needfor standardization to establish vibrationparameters" and the KAN comments inthis emission sector. They show that, sofar, the state of the art is barely quanti-fied with indicative values at all in themachine safety standards. In some cas-es, the necessary measuring methodsare not available and it has proven diffi-cult to specify the operating conditions.By comparison, greater progress hasbeen made with the quantification ofnoise emissions.

37

24 The investigated standards do not usually give any details of the state of the art, but merely - in accordance with the princip leof informing the user - instructions for the manufacturer on the information on vibration to be supplied to the user (DIN EN608 excepted).

25 Forestry machinery - Chain saws - Measurement of hand-transmitted vibration (1986).

prEN 474-7:Earth-movingmachinery -Safety - Part 7:Requirementsfor scrapers(05/1998)

DIN EN 774:Garden equip-ment - Handheld, integrallypoweredhedge trimmers- Safety (12/1997)

DIN EN 632:Agriculturalmachinery -Combine har-vesters andforage harvest-ers - Safety(08/1995)

DIN EN 692:Mechanicalpresses - Safety(08/1996)

E DIN EN1726: Safety ofmachinery - In-dustrial trucks -Self-propelledtrucks up to andincluding10,000 kg ca-pacity and trac-tors with adrawbar pull upto and including20,000 newtons(03/1995)

E DIN EN 792-14: Hand-heldnon electricpower tools -Safety require-ments - Part14: Assemblypower tools fornon-threadedmechanicalfasteners (08/1995)

Standard

Criteria

Table 3: Review of the prominence given to vibration hazards in selected standards

YesNoValue taken from ISO 750525

Vibration cited as a hazard

Technical reduction mea-sures given

Measuring methods given

Operating state for measu-rement defined

State of the art quantified See footnote24

38 4Im

plementation

26 The investigated standards do not usually give any details of the state of the art, but merely - in accordance with the princi-ple of informing the user - instructions for the manufacturer on the information on vibration to be supplied to the user (DINEN 608 excepted).

27 Forestry machinery - Chain saws - Measurement of hand-transmitted vibration (1986).

YesNoValue taken from ISO 750527

DIN EN 474-1:Earth-movingmachinery -Safety - Part 1:General requi-rements (12/1994)

DIN EN 996:Piling equip-ment - Safetyrequirements(04/1996)

DIN EN 608:Portable chainsaws (12/1994)

Table 3: Review of the prominence given to vibration hazards in selected standards (continued)

Vibration cited as a hazard




State of the art quantified Seefootnote26

Seefootnote26

E DIN EN 792-15: Hand-heldnon electricpower tools -Safety require-ments - Part15: Cutting-offand crimpingpower tools(12/1995)

E DIN EN 792-7: Hand-heldnon-electricpower tools -Safety require-ments - Part 7:Grinders (12/1995)

Standard

Criteria

Seefootnote26

Seefootnote26

DIN EN 791:Drill rigs (01/1996)

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4.4 Hazardous substances

In April 1996, KAN approved the resultsof a study entitled "Emission of hazardoussubstances by machinery" . These resultsinclude, amongst other things, the con-clusion that too few type C standardsquote "parameters for the assessment ofthe emission behaviour" of hazardoussubstances and that the inclusion of "in-dicative values" definitely makes senseunder certain conditions.

Prominence given to substance hazardsin selected standards

The KAN Secretariat has again selectedrepresentative machine standards andwork items for the hazardous substancesector and examined them for the promi-nence given to hazardous substanceemissions.

The following table shows the extent towhich prominence is given to hazardous

substance hazards in selected standards.Annex 7.3, like for noise and vibrationhazards, presents detailed analysis resultsfrom two examples, one positive and theother one negative.

The quantification of dust emissions fromhand-held power tools for woodworking

In the context of a project carried out bythe BIA together with the Central Associa-tion of the Electrical Engineering Industry(ZVEI) and the accident insurance institu-tion for the woodworking industry, hand-held power tools for woodworking withintegrated dust extraction were investigat-ed on a test bench in order to determinethe state of the art in terms of dust emis-sions. On the basis of the results of theproject, it would be possible to describethe state of the art with an indicativevalue reflecting the protection level pro-vided by the equipment examined. De-tails of the background and investigationare presented in Annex 9.

28 KAN Report 15, ed. Verein zur Förderung der Arbeitssicherheit in Europa, September 1997.

40

ISO/DIS15012-1:Health andsafety in wel-ding and al-lied processes- Require-ments, testingand markingof equipmentfor air filtrati-on (06/99)

prEN454:Foodprocessingmachinery -Planetary mi-xers - Safetyand hygienerequirements(11/1994)

DIN EN608:Portablechain saws(12/1994)

prEN 746-7:Industrialthermopro-cessingequipment -Part 7: Speci-al safety re-quirementsfor vacuumthermopro-cessingequipment(06/1994)

prEN 12757-1:Mixing ma-chinery forcoating ma-terials - Safe-ty require-ments - Part1: Mixingmachinery foruse in vehiclerefinishing(02/1997)

Standard

Criteria

Table 4: Review of the prominence given to hazards from hazardous substances in selected standards

YesNo

Hazardous substancescited as a hazard




State of the art quantified

prEN12840:Safe-ty of machi-ne-tools -Manuallycontrolledturning ma-chines (04/1997)

DIN EN50144-1:Safety ofhand-heldelectric motoroperatedtools - Part 1:General re-quirements(05/1998)

4Im

plementation

41

4.5 Radiation

The Machinery Directive demands ofmanufacturers that "any emission of radi-ation is limited to the extent necessaryfor its operation and that the effectson exposed persons are non-existentor reduced to non-dangerous propor-tions."

A European B standard prEN 12198-1is currently being drafted to preciselydefine these "non-dangerous propor-tions". The text of a paper - printed inAnnex 10 - by Dr Eggert from the FederalInstitute for Occupational Safety andHealth in Berlin describes these standard-ization activities of the working group ofTC 114 "Safety of machinery" (WG 13"Radiation of machinery"). The three-partstandard specifies categories for machineemission values relating to radiation:

Category 0 applies to machineswhose emission values are beneathexisting reference values (not limitvalues!) for exposure of the generalpopulation. There is no marking obli-gation or a special obligation to in-form the user.

Category 1 machines have emissionvalues above the reference values forexposure of the general population,but beneath those for exposure at theworkplace. The machine has to bemarked with "1" and the user has tobe informed.

In the case of category 2 machines,the reference value for exposure at theworkplace is exceeded. The machinehas to be marked with "2" and theuser has to be informed.

According to Dr Eggert, and as alreadymentioned in Chapter 3.1, the assign-ment of machines to one of the men-tioned categories facilitates "considerablythe work of the persons responsible forprotection from non-ionizing radiation inthe working environment and thus helpsto break down trade barriers under theterms of Article 95 (formerly 100a) of theEC Treaty". This approach roughly corre-sponds to the fundamental position ad-vocated by the BAuA and by the FrenchINRS for the quantification of emissionsin product standards, which involves sup-porting indicative values by so-calledemission classes.

29 prEN 12198 - 1 Safety of machinery - Assessment and reduction of risks arising from radiation emittedby machinery - Part 1: General principles, Part 2: Radiation emission measurement procedure, Part 3:Reduction of radiation by attenuation or screening

42

4.6 Databases of emission values

An important point, and a central aspectof the KAN resolution of December 1997on the quantitative statement of emissionvalues in product standards, is the gath-ering of measured values.

In this connection, it has been frequentlypointed out that in many sectors thereare at present no suitable measuringmethods. The survey of manufacturersdescribed in Chapter 4.2.1 shows onthe other hand that there are alreadysectors in which there are not onlymeasuring methods available, but alsothe requisite measurement values. Eitherway, however, the data are not collectedsystematically. The conditions underwhich data could be collected (suitableinstitutions, funding etc.) remain to besettled as well as the updating of suchdatabases as the state of the artprogresses.

Efforts to gather data in databases haveso far proven difficult for the reasonsgiven. A move by the Directorate-Gener-al V of the European Commission to

bring together the data on emissions isnot being pursued further at present.Information on an existing emission data-base from Umeå, Sweden, is availableon the Internet at http://umetech.niwl.se.This database, supported by the "Biomed2" programme of the European Commis-sion, brings together data on hand-armvibrations from hand-held power toolsand whole-body vibrations from earth-moving machines. In some cases, thehand-arm vibrations are accompanied bynoise emission values.

Certain accident insurance institutionshave data collections relating to certainmachines (e.g. woodworking equipment);at the BIA, emission data are being col-lected in the context of investigations intoproceedings for the recognition of occu-pational diseases.

So far, however, there has not been acontrolled, interdisciplinary procedure,even though the database tools areavailable. Collecting the existing data isa necessary task in advancing towardsthe goal of quantification.

4 Implementation

43

The conclusion from this collection ofdocuments is that compliance with theMachinery Directive in terms of emissionsis not satisfactory. Action still needs to betaken in a number of areas. Yet to beclarified as well is who is responsible forwhich task.

Examples of which tasks can be handledby whom are:

Provision of the measuring methodsrequired for measuring emissions, defi-nition of the operating states and inclu-sion of these methods in the machinesafety standards by research institutionsand standardization bodies.

Measurements carried out by manu-facturers, test institutes and by otherOH&S institutions.

Provision of the available data bymanufacturers and accident insuranceinstitutions.

Collection of the data by OH&S insti-tutions and KAN.

Establishing pan-European contactswith manufacturers and OH&S expertsby KAN.

KAN will also continue to accompanythese activities, e.g. by submitting itscomments on the relevant type A, B andC standards, by exchanging informationwith the relevant parties in Germany andthe rest of Europe (particularly France)and by supporting activities to bring datatogether.

5 Future Tasks

44

[1] CEN Report 1100: Memorandum onhealth and safety standardization in sup-port of "new approach" directives; appli-cation in the field of machinery. DIN-Fachbericht 40, DIN Deutsches Institut fürNormung (ed.), Beuth Verlag GmbH,Berlin, 1994

[2] CEN Resolution BT 22/1997 in KANReport 11 "The standardization of OH&Smanagement systems", Sankt Augustin,1997, p. 75 f.

[3] DIN EN 45020: General terms andtheir definitions concerning standardizati-on and related activities, April 1994

[4] EU-Memorandum "The role of stand-ardization in relation to article 118a ofthe EC Treaty", in: KAN Report 5 “Euro-pean standardization concerning thesafety and health of workers at work”,1996

[5] Fitting et al., Handkommentar zumBetriebsverfassungsgesetz, Verlag FranzVahlen, Munich, 19th edition, 1998, p.1148 f.

[6] Halbach et al., Übersicht über dasArbeitsrecht, ed. German Federal Ministryof Labour and Social Affairs, 6th edition,June 1997, p. 522 f.

[7] KAN Report 3, Definition of the needfor standardization to establish vibrationparameters, March 1996

[8] KAN Report 8, Noise protection formachinery and workplace - status of andneed for occupational health and safetystandardization, August 1996

[9] KAN Report 15, Emission of hazar-dous substances by machinery, Septem-ber 1997

[10] Lacore, Recours à des valeurs indi-catives (valeurs réalisables d'émission,valeurs repères...) ou à des "classesd'émission" dans les normes C

[11] Liedtke, Maschinennormung - Kurz-bericht aus der Praxis, printed in KANReport 1, Sankt Augustin, 1995, p. 85-88

[12] prEN 12198-1, Safety of machinery- Assessment and reduction of risks ari-sing from radiation emitted by machinery- Part 1: General principles; prEN12198-2, Radiation emission measure-ment procedure; prEN 12198-3, Reduc-tion of radiation by attenuation or scree-ning

[13] Directive 98/37/EC of the EuropeanParliament and of the Council of 22ndJune 1998 on the approximation of thelaws, regulations and administrative pro-visions of the Member States concerningmachines (OJ EC L 207 of 23.7.1998,p. 1)

6 Literature

45

Annex 1 The minimization and markingof emissions in Annex I of theMachinery Directive 98/37/EC(Annex I: Essential health and safety requirements relating to thedesign and construction of machinery and safety components)

A-1.1 Noise hazards

Minimization of noise hazards

“1.5.8 Noise

Machinery must be so designed and con-structed that risks resulting from the emis-sion of airborne noise are reduced to thelowest level taking account of technicalprogress and the availability of means ofreducing noise, in particular at source.

3 Essential health and safety require-ments to offset the particular hazards dueto the mobility of machinery

3.2.1 Driving position

... Where the machinery is fitted with acab, this must be designed, constructedand/or equipped to ensure that the driverhas good operating conditions and is pro-tected against any hazards that might exist(for instance: inadequate heating andventilation, inadequate visibility, excessivenoise and vibration, falling objects, pene-tration by objects, rolling over, etc.).

Statement of parameters for noisehazards

1.7.4 Instructions

d) Any literature describing the machinerymust not contradict the instructions as

regards safety aspects. The technicaldocumentation describing the machinerymust give information regarding the air-borne noise emissions referred to in (f) ...

e) Where necessary, the instructions mustgive the requirements relating to installa-tion and assembly for reducing noise orvibration (e.g. use of dampers, type andmass of foundation block, etc.).

f) The instructions must give the followinginformation concerning airborne noiseemissions by the machinery, either theactual value or a value established onthe basis of measurements made onidentical machinery:

equivalent continuous A-weightedsound pressure level at workstations,where this exceeds 70 dB(A); wherethis level does not exceed 70 dB(A),this fact must be indicated,

peak C-weighted instantaneous soundpressure value at workstations, wherethis exceeds 63 Pa (130 dB in relationto 20 µPa),

sound power level emitted by the ma-chinery where the equivalent continu-ous A-weighted sound pressure levelat workstations exceeds 85 dB(A).

In the case of very large machinery,instead of the sound power level, theequivalent continuous sound pressure

46

levels at specified positions around themachinery may be indicated.

Where the harmonised standards are notapplied, sound levels must be measuredusing the most appropriate method forthe machinery.

The manufacturer must indicate the oper-ating conditions of the machinery duringmeasurement and what methods havebeen used for the measurement.

Where the workstation(s) are undefinedor cannot be defined, sound pressurelevels must be measured at a distance of1 metre from the surface of the machin-ery and at a height of 1,60 metres fromthe floor or access platform. The positionand value of the maximum sound pres-sure must be indicated.”

A-1.2 Vibration hazards

Minimization of vibration hazards

1.5.9 VibrationsMachinery must be so designed and con-structed that risks resulting from vibra-tions produced by the machinery arereduced to the lowest level, taking ac-count of technical progress and the avail-ability of means of reducing vibration, inparticular at source.


3.2.1 Driving position

... Where the machinery is fitted with acab, this must be designed, constructedand/or equipped to ensure that the driverhas good operating conditions and isprotected against any hazards that mightexist (for instance: inadequate heatingand ventilation, inadequate visibility, ex-cessive noise and vibration, falling ob-jects, penetration by objects, rolling over,etc.).

3.2.2 Seating

... The seat must be designed to reducevibrations transmitted to the driver to thelowest level that can be reasonablyachieved.

Statement of parameters for vibrationhazards

1.7.4 Instructions

d) Any literature describing the machinerymust not contradict the instructions asregards safety aspects. The technicaldocumentation describing the machinerymust give information regarding the air-borne noise emissions referred to in (f)and, in the case of hand-held and/or

Annex 1

47

hand-guided machinery, informationregarding vibration as referred to in 2.2.

e) Where necessary, the instructions mustgive the requirements relating to installa-tion and assembly for reducing noise orvibration (e.g. use of dampers, type andmass of foundation block, etc.).

2 Essential health and safetyrequirements for certain categories ofmachinery

2.2 Portable hand-held and/or hand-guided machinery

Instructions

The instructions must give the followinginformation concerning vibrations trans-mitted by hand-held and hand-guidedmachinery:

the weighted root mean square accel-eration value to which the arms aresubjected, if it exceeds 2,5 m/s² asdetermined by the appropriate testcode. Where the acceleration doesnot exceed 2,5 m/s², this must bementioned.

If there is no applicable test code, themanufacturer must indicate the measure-ment methods and conditions underwhich measurements were made.


3.6.3 Instruction handbook

Apart from the minimum requirements setout in 1.7.4, the instruction handbookmust contain the following information:

(a) regarding the vibrations emitted bythe machinery, either the actual value ora figure calculated from measurementsperformed on identical machinery:

the weighted root mean square accel-eration value to which the arms aresubjected, if it exceeds 2,5 m/s²,should it not exceed 2,5 m/s², thismust be mentioned,

the weighted root mean square accel-eration value to which the body (feetor posterior) is subjected, if it exceeds0,5 m/s², should it not exceed 0,5m/s², this must be mentioned.

Where the harmonised standards are notapplied, the vibration must be measuredusing the most appropriate method forthe machinery concerned.

The manufacturer must indicate the oper-ating conditions of the machinery duringmeasurement and which methods wereused for taking the measurements; ...

48

A-1.3 Hazards from hazardoussubstances

Minimization of hazards from hazard-ous substances

1.5.13 Emissions of dust, gases, etc.

Machinery must be so designed, con-structed and/or equipped that risks dueto gases, liquids, dust, vapours and otherwaste materials which it produces can beavoided.

Where a hazard exists, the machinerymust be so equipped that the said sub-stances can be contained and/or evacu-ated.

Where machinery is not enclosed duringnormal operation, the devices for con-tainment and/or evacuation must besituated as close as possible to thesource emission.


3.5.3 Emissions of dust, gases, etc.

Where such hazards exist, the contain-ment equipment provided for in section1.5.13 may be replaced by other means,for example precipitation by water spray-ing.

The second and third paragraphs of sec-tion 1.5.13 do not apply where the mainfunction of the machinery is the sprayingof products.

5 Essential health and safety require-ments for machinery intended for under-ground work

5.7 Emissions of dust, gases, etc.

Exhaust gases from internal combustionengines must not be discharged up-wards.”

Statement of parameters for hazardsfrom hazardous substances

The Machinery Directive does not de-mand the statement of parameters forhazards from hazardous substances.

A-1.4 Radiation hazards

Minimization of radiation hazards

1.5.10 Radiation

Machinery must be so designed and con-structed that any emission of radiation islimited to the extent necessary for its op-eration and that the effects on exposedpersons are non-existent or reduced tonon-dangerous proportions.

Annex 1

49

1.5.12 Laser equipment

Where laser equipment is used, the fol-lowing provisions should be taken intoaccount:

laser equipment on machinery mustbe designed and constructed so as toprevent any accidental radiation,

laser equipment on machinery mustbe protected so that effective radia-tion, radiation produced by reflectionor diffusion and secondary radiationdo not damage health,

optical equipment for the observationor adjustment of laser equipment onmachinery must be such that nohealth risk is created by the laser rays.

1.7 Indicators

1.7.2 Warning of residual risks

Where risks remain despite all the meas-ures adopted or in the case of potentialrisks which are not evident (e.g. electricalcabinets, radioactive sources, bleeding ofa hydraulic circuit, hazard in an unseenarea, etc.), the manufacturer must pro-vide warnings.

Statement of parameters for radiationhazards

The Machinery Directive does not de-mand the statement of parameters forradiation hazards.

50

Part 1: Basic terminology, methodol-ogy, November 1991

In Part 1, section 4 of the standard, thepossible emissions from machinery arelisted in detail:

4.5 Hazards generated by noise

Noise may result in

permanent loss of hearing acuteness,tinnitus,tiredness, stress etc.other effects such as loss of balance,loss of awareness etc.interference with speech communica-tion, acoustic signals etc.

4.6 Hazards generated by vibration

Vibration may be transmitted to thewhole body and particularly to handsand arms (use of hand-held machines).

The most severe vibration (or less severevibration over a long time) may generateserious disorders (vascular disorders suchas white-finger, neurological, osteo-artic-ular disorders, lumbago and sciaticaetc.).

4.7 Hazards

information on emissions in machinery standards...a-5 low-emission machines – an incentive for the...

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