C O N T E N T S :

1. Introduction

2. Objectives of the seminar

3. Feedback, the method agreed with the project partners

4. The national data collection exercise

5. Round table

6. Overall conclusions and future plans/perspectives

B R U S S E L S , 2 7 M A R C H 2 0 0 6

A European system to improvemachinery safety by drawing onusers experience

Stefano Boy, ETUI-REHS Officer, Machinery Safety and Standardisation

Summary of the seminar organisedby the Health and Safety Department of the EuropeanTrade Union Institute for Research, Education,Health and Safety (ETUI-REHS)

P A G E 2

1. Introduction

This publication summarises the results of a seminar (27 March 2006, Brussels), orga-nised by the European Trade Union Institute for Research, Education, Health and Safety(ETUI-REHS) to unveil its strategy for improving machinery standards through usersfeedback. Under the chairmanship of Bart Samyn, Deputy General Secretary of theEuropean Metalworkers' Federation (EMF), the five ETUI-REHS national partners Finland, France, Germany, Italy, United Kingdom presented the main findings of aproject on forklift trucks (FLTs), together with a selection of design issues arisingdirectly out of users' experience.

The seminar was the culmination of a five-year research project, during which ETUI-REHS was involved in two studies that developed and refined a method to acquire userknowledge on selected machines, structure it and make it available in a format usable tostandard-setters. The first study investigated woodworking machinery in Italy; thesecond investigated FLTs in Germany and Italy.

The projects outcomes were then used to develop a wider European project across fiveMember States, centred on FLTs covered by the harmonised standard EN 1726-1:1998Safety of industrial trucks Self-propelled trucks up to and including 10 000 kg capa-city and industrial tractors with a drawbar pull up to and including 20 000 N Part 1:General requirements.

1. The so-called Vienna Agreement establishes technical cooperation between ISO and CEN. The agreementsets out two essential modes for collaborative development of standards: the mode under ISO leadand the mode under CEN lead, whereby documents developed within one body are notified for simultaneousapproval by the other.

EN 1726-1:1998 Safety of industrial trucks was published in the Official Journal on 30May 2000. It is being revised under the Vienna Agreement1 as EN ISO 3691-1. Afirst DIS (Draft International Standard) enquiry was concluded in April 2004, and theresulting comments have been examined, together with the assessments of the CENConsultants Machinery and Noise. On 9 February 2006 a second DIS enquiry waslaunched, its deadline being 9 May 2006. Since some hazards have been excludedfrom the scope of ISO 3691-1 (i.e. noise and vibrations), CEN TC 150 has decided toadd to ISO 3691-1 a European complement, with the objective of having a finaldocument (ISO 3691-1 + European complement) that gives presumption of confor-mity to the Machinery Directive requirements. The European complement will be draf-ted by a new working group of TC 150. Its composition will be decided shortly.

EN 1726-1 is a so-called Type C standard, according to the definition adopted by CEN for the purposes of itscontract with the European Commission. More precisely, the harmonised standards programme suppor-ting the Machinery Directive 98/37/EC is structured as follows:

Type A standards lay down basic concepts, principles for design and general aspects that can beapplied to all machinery;

Type B standards deal with one safety aspect (e.g. minimum distances, noise, temperatures) or onetype of safeguard that can be used across a wide range of machinery;

Type C standards cover detailed safety requirements for a particular machine or group of machines.

The machinery safety programme assists the standards users to claim 'Presumption of Conformity' with theMachinery Directive.

So far 638 Harmonised European Standards have been referenced in the Official Journal of the EuropeanUnion, including 116 type A & B standards together with 522 type C standards. Some type C standardsdeal with complete machines and others deal with specific safety components for a given machine or par-ticular parts of a given machine.

The list of harmonised standards supporting the machinery directive can be found at the following page:http://europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/reflist/machines.html

P A G E 3

COUNTRIES FINLAND FRANCE GERMANY ITALY UNITED-KINGDOM

(between 1987 (between 1990 (between 1994 (between 2001and 2003 and 2003) and 2000) and 2005)

ACCIDENTS 5 315 (between 141 852 191 325 117 904 Partially know1993 and 2001) (3 530 for over

3-days injuries)

PERMANENTINVALIDITY Not Know 10 823 8 905 10 354 1 563

FATAL 31 (between 205 309 152 29ACCIDENTS 1985 and 2001)

Key FactsForklift accidents have increased dramati-cally in recent years. Most forklift acci-dents involve the driver hitting a co-wor-ker. Blocked vision, blind intersectionsand operator inattention are often factorsin accidents that involve forklifts runningover pedestrians. Most forklift fatalitiesoccur when lift trucks overturn.

Accidents also occur when workers violatesafe work procedures and fall from raisedforks or from pallets on the forks used aslifts. Other accidents involve pedestrianswho are struck by falling loads or getcrushed between the forklift and a fixedobject or other vehicle. Operators areoften injured when their arms, legs orother body parts are struck or caught asthe lift truck sideswipes a wall or storagerack. The following table summarises theaccident data provided by the ETUI-REHS partners involved in the project onFLTs:

There is little doubt that forklift driving isa skilled operation, requiring constant vigi-lance and alertness in regard to vehiclemanoeuvring, hazard perception and safeload handling. In this connection, high-quality driver training and licensing requi-rements are an important step in ensuringthat at least minimum aptitude and skilllevels are achieved.Good training must complement inherentdesign measures. Exclusive reliance on trai-ning and driver skill to overcome deficien-cies in vehicle design (poor visibility anddifferent control layout on different forkliftmodels, for example) should be avoided.

ETUI-REHS shares the view that effectiveinjury risk reduction can be achieved byusing sound ergonomic design to reducethe ongoing performance demands madeon the operator to avoid accidents. Theforklift truck project was carried out withthis key prevention principle in mind, inthe belief that it is more effective to removeand/or control the hazard to achieve saferworkplaces. This means designing worksystems (the equipment, the environmentand the job) so that they are inherently safeor more accurately expose their users tolower levels of risk. In this connection, it isworth mentioning that the safety integra-tion method enshrined in the MachineryDirective 98/37/ EC has been furtherconsolidated during its revision: the textrecently adopted by the Council includes anew paragraph on risk assessment in thenew introductory section to Annex I.

2. Objectives of the seminar

The seminar brought together an audienceof representatives of the European Com-mission, CEN, labour inspection authori-ties, social partners and European enterpri-ses. It provided an opportunity to engagein debate on what practical steps needto be taken to help set up a permanentmechanism for feeding users' experienceinto a knowledge base that can guide stan-dardisation work, market surveillance acti-vities and Community initiatives to streng-then the legislative framework regulatingthe single market.The two distinct legislative frameworksregulating the working environment andproducts moving within the Single Marketshould complement each other. Time andagain ETUI-REHS has stressed the needto mount research projects aimed at achie-ving a better understanding of the rela-tionship between the risk assessment requi-red of manufacturers by the MachineryDirective 98/37/EC and the risk assess-ment required of employers by the WorkEquipment Directive 89/655/EEC.The day was structured around two mor-ning sessions presenting the ETUI-REHSstrategy, and two sessions in the afternoondealing with more technical standardisa-tion issues. Three national OHS Officialsinvolved in the ETUI-REHS forklifttrucks project were invited to present theircase studies to illustrate how machinerydesign shortcomings could be successfullyrevealed by applying the ETUI-REHSmethodology based on the feedbackmethod developed by Fabio Strambi,Director of the OHS service at the LocalHealth Authority Unit (USL) in Siena.

This publication is based on speeches andcomments made during the seminar ses-sions and the round table discussions thatfollowed them.

ETUI-REHS shares the viewthat effective injury risk

reduction can be achievedby using sound ergonomic

design to reducethe ongoing performance

demands made onthe operator

to avoid accidents.

2. Fabio Strambi et al. Ergonomia e norme tecniche di sicurezza: il contributo degli utlizzatori. La sicurezza dellemacchine per la lavorazione del legno, Franco Angeli Editore, Milano 2001.

P A G E 4

3. Feedback, the method agreedwith the project partnersFabio Strambi, European Ergonomist,Director of the Occupational Healthand Safety Service, A. USL 7 Siena,Regione Toscana.Massimo Bartalini, Safety Officer,Occupational Health and SafetyService, A. USL 7 Siena, RegioneToscana.

The methodology agreed with the ETUI-REHS project partners aims at improvingType C standards by means of user feed-back. To achieve that objective, it was deci-ded to use the Feedback Method, alreadydemonstrated to be a valid tool for accu-mulating users knowledge, structuring itand making it available to standard-setters.

BackgroundFollowing a data collecting project run incooperation with the Swedish union LO in1997, ETUI-REHS in 1998 commissionedSindNova, an Italian trade union institute, todevelop a research project to involve workersand firms in assessing the effectiveness oftechnical standards on the safety of wood-working machinery.The project was carried out in 1999 inTuscany, Italy, by Fabio Strambi and collea-gues from the Siena Local OccupationalHealth and Safety Unit (USL)2. Theoutcomes were published under the title:Ergonomics and technical safety standards:users experience and suggestions. Safety ofwoodworking machinery.

The project, run in Val dElsa,Tuscany Region, aimed to introduce a parti-cipatory model in a specific high-risk indus-trial environment, collecting input frommachinery users and integrating it into a stra-tegy for improving machinery technical stan-dards.

Message from the Chairman The European MetalworkersFederation (EMF) represents the economic and social inte-rests of workers in the metal industry at European level. Thegreat majority of metalworkers use and construct machines:this explains our interest in the ETUI-REHS strategy inten-ded to progress toward a real involvement of workers in thedesign of the equipment they use every day. This objectivecan be achieved by bringing workers experience into stan-dardisation. Workers are the people who know the job and working conditions best;they are also the ones bearing the health and safety impact of machinery defects andshortcomings. Their insights into machinery health and safety issues are thereforeessential. Recent trade union experiences have shown the promising future of exploi-ting workers knowledge to improve equipment design and use. EMF is convincedthat more opportunities must be explored for collaborative work between engineers,employers, workers, manufacturers, researchers and governments who can all contri-bute to better health and safety through the consideration of design issues. This willbe a high priority for many years to come, as part of the constant search for new ini-tiatives to further drive down the rate of machinery accidents at work. Bart Samyn.

Message from the ETUI-REHS Director This seminar is the culmination of alongstanding research strategy whereby we had the privilege of working with nationalpartners and bringing European standardisation closer to the world of users. Even ifETUI-REHS currently has a limited role in the CEN system following the work ofTC 114 and TC 122 we build bridges day after day to better communicate andexchange information with standard-setters. The cases logged in many Europeanworkplaces show us that trade unions can be the eyes and ears of CEN when itcomes to health and safety matters. People who could lose their lives at work have aright to information, consultation and participation in the design of the work systemas a whole, in its environmental, organisational and technological dimensions.In this connection the ETUI-REHS strategy seeks to move from workplace experience to better machinerydesign. Being aware of the limited resources available to standard-setters and policy-makers, we wish to keepthe debate alive among the different stakeholders to search for win-win procedures, opportunities and mecha-nisms, whereby business and productivity pressures go hand in hand with the highest level of social protec-tion dictated by the European Union Treaty. In the search for sustainable mechanisms to benefit from machi-nery users experience, ETUI-REHS will put forward structured proposals to standard-setters and policy-makers, in order to construct a new policy framework tailored to trade union research objectives. Marc Sapir.

In 2003 the Bilbao Agency sponsored theFeedback Methodology3 in the context of theSME Funding Scheme 2003-2004, when Italy(Regione Toscana) and Germany (GrolaBG)decided to apply feedback to forklift trucks.This project was carried out in 29 SMEs wherea total of 192 forklift trucks were used.

The feedback methodCollection of machine documentation(Machine Dossier)The feedback method is applied wheneverstakeholders identify a machine (and a cor-responding harmonised standard) whichmerits closer examination and analysis.The first step of the method is to collectany available technical documentation onthe machine under review, so as to beaware of the main safety features (i.e. nor-mal and abnormal use, residual risks).In this preliminary phase safety expertsassemble a machine dossier, which insummary includes whenever available information on: relevant harmonised stan-dards; safety guidelines elaborated by tech-nical bodies or research organisations; sta-tistics on undesired events associated withthe machine (together with any specificaccident investigations); safeguard actionsagainst the machine; market surveillanceinformation; information provided by themachine manufacturer about the territo-rial/geographical diffusion of the machineand its different models and/or configura-tions; instructions accompanying themachine.

Identification of companiesand workplace inspectionsAfter identifying the territory and the pro-duction sector where the method will beapplied, safety experts select the compa-nies/enterprises to be inspected and whereskilled machine users will be recruited;trade unions and employers associationshelp with this step.

Inspections are carried out by using formscontaining the following elements: generalcompany data; description of workingenvironment where the machine underinvestigation is used and the relevant wor-king methods; characteristics of the machi-nes used in the company; information onaccidents (and near misses) which haveoccurred in the company and involved themachine in question; information aboutthe training provided for workers assignedto operate the machine.

This information will be used during thejob ergonomic analysis, carried out in wor-king groups, when users will be guided inreconstructing their job based on machineactivities carried out daily.

Working groupsWorking groups (WG) are then formed,each group being made up of 5 to 9 users:besides drivers, the group may includecompany engineers, craftsmen or em-ployers with knowledge and experience inthe use of the machine (ideally these peo-ple should be the ones who use themachine in the normal course of produc-tion).

It is essential that the participants comefrom different working situations, with atleast three operators from different compa-nies, in order to attenuate the inevitable

specificities connected with a single com-pany, and to provide a job reconstructionrepresentative of the daily tasks across dif-ferent working contexts. If working groupsrepresent different productive sectorsand/or territorial areas, diverse practicesand habits in operating the machine underinvestigation and different methods oforganising production could be brought tolight.

The working group activity is based ontwo preliminary steps. Firstly, the expertsprovide the users with basic documenta-tion (the relevant technical standards, thedescription of the most important residualrisks indicated by the manufacturers in theinstructions, a description of the dynamicsof the most serious accidents, etc.).Secondly, each working phase is split intobasic operational tasks, on the basis of theinformation collected during the companyinspections, from the initial setting-upoperations to maintenance and cleaningoperations after the work is finished.

After these two preparatory phases, the lea-ding experts introduce the job ergonomicanalysis through which the group willreconstruct the daily work phases and thenstart a systematic analysis of each workphase with the help of a table like the onein Fig. 1 (see p.6).

For each work phase, the job tasks areidentified, and for each of them the follo-wing elements are put in writing: the individual operations and the

methods of executing the task; the training, knowledge and experience

that the worker must possess in order toexecute such operations competently;

the risks associated with executing thetask;

suggestions for prevention and anysafety procedures to adopt in order toavoid accidents.

P A G E 5

Working groups (WG)are then formed, each

group being made up of5 to 9 users: besides

drivers, the group mayinclude company engineers,

craftsmen or employerswith knowledge

and experience in the useof the machine.

3. Presented at the International Conference Design process and human factors integration Nice,1-3 March 2006.

It is important to note that the experts lea-ding the discussion allow the workers toact as key players in evaluating their ownworking environment. The experts roleconsists in supplying information, spee-ding up the participants contribution tothe reconstruction of the job, and guidingthe users evaluations of the safety issuesand possible preventive action.

Written WG documentand its validationAt the end of the process, the researcherstransfer the results onto a "legible copy" ofthe Feedback grid and deliver it to everyparticipant for their validation and/or forany corrections/additions. This step isessential, not least so that the more reticentmembers have an opportunity to contri-bute their opinions and suggestions. Theindications provided by users will be adop-ted and marked in the final report. Theconsolidated and validated WG reportrepresents a basic document that can befine-tuned to better highlight lessons lear-ned and suggestions.

Project overviewand final technical reportThe final phase of the Feedback Methodconsists in the drafting of the project over-view and the final technical report. The pro-ject overview describes all the different pro-ject phases and outcomes, from the assem-bling of the machine dossier to the consoli-dation and validation of the WG report.

Afterwards the researchers draft a synthesisof the WG report, drawing together andpresenting the prevention indications andsuggestions that emerged from the WGs,in order to facilitate the transition fromwords to deeds. This final technical reportis structured in such a way that its contentis addressed to:

standard-setters, for modification andimprovement of the standard on thespecific issues that emerged from theWG (i.e. ergonomics, maintainability,operating modes);

designers and manufacturers, in orderto assess the feasibility of the WG sug-gestions and compare them with thecurrent state of the art;

employers/users, so that they can improveand manage maintenance operations,provide effective safety training andadequate job organisation; in order toimprove the purchase and safe incorpora-tion of work equipment into the com-pany-specific environment;

workers, so that they pay careful atten-tion to the safety indications suppliedby the manufacturers and by the usersthemselves.

This final technical report therefore beco-mes the centrepiece of the job carried outand constitutes a technical synthesis of thecontributions made by users both duringthe inspections and within the workinggroup debates. The concluding report is asynthesis of the suggestions to be addressedto all stakeholders involved in machinerysafety issues: standard-setters, manufactu-rers, employers, workers representatives,inspection bodies, etc.

ResultsThe following table summarises the mainresults obtained by applying the Feed-back method to forklift trucks.

P A G E 6

Tasksequence

Operatingconditions

(for execution oftask)

Knowledge(necessary for

optimal executionof task)

Risk associatedwith taskexecution

Suggestions forprevention

Job phase

Fig. 1 Table used to record the job reconstruction carried out by the working group

Main proposals and suggestions - Forklift trucks Technical standard

Improvement of active and passive means from overturning risks EN 1726-1:1998; clauseImprovement of devices which keep the driver in his seat. 4.1.11, 5.2.3, 5.6.3.4, 5.7,

5.8, 7.2.2, 7.3

Improvement of battery handling methods. EN 1726-1:1998;Harmonisation of travelling and stopping control devices (placing and typology) EN 1726-1:1998; clausewith layout used in cars. 1.7.4, 5.4.2, 5.4.2.1

EN 281:1988; clause 7

Harmonisation of control levers for every type of forklift truck. Control devicesmust be designed so that, where a risk is involved, the desired effect cannot be EN 1726-1:1998; clauseachieved without an intentional operation. 5.4.4, 5.4.5

Fastening and insulation of battery bonnet. EN 1726-1:1998; clause5.5.3, 5.7

Improvement of access to operating position. Compulsory handles. EN 1726-1:1998;clause 5.7.2

Final observationsFeedback confirms the need to integratemachinery design with information basedon the real experience of machinery opera-tors so as to improve its quality and reliabi-lity. The application of Feedback tomachinery highlights what lessons stan-dards bodies could learn from participatoryapproaches to equipment design based onthe knowledge that final users possess onthe equipment they work with.

Application of the Feedback methodmakes it possible both to collect contribu-tions from machinery users for the impro-vement of the specific reference standardand at the same time to prepare a system tomonitor the effectiveness of any improve-ments introduced. In connection with thismethod an optimal solution would be theestablishment of observatories, located inseveral Member States, able to collect reac-tions from users of the same machine indifferent production sectors.

Such a system of continuous feedback, bet-ween standard-setters and users, is there-fore the only viable method derivedmoreover from human physiology ofachieving and maintaining an improve-ment in safety and in health safeguards formachinery users/workers, by means of acontinuous adaptation of the standards.

Using this method it is possible for workerrepresentatives or, more generally, forrepresentatives of consumers and users toset about collecting indications for impro-vements in various types of machinery.

The recommendations can then be forwar-ded to the appropriate technical commis-sions and committees.

The key factor for the effectiveness of themethod, however, is the human factor andabove all else the full cooperation of expertusers and technicians. They must not onlybe familiar with the machine under investi-gation but also be able to guide the wor-king group, collect the information andexpress it in suitable language for the for-mulation of proposals to be addressed tothe standard-setters and manufacturers.

P A G E 7

The German-Italian Project 5711/IT on forklift truck safety under theSME Funding Scheme 2003-2004 sponsored by the Agency of Bilbao was carriedout by the following experts:

R.CIANOTTI, M.N.TINI (ISPESL National Institute of Occupational Safetyand Prevention Department of Safety Technologies, Roma/Italy)

C.STANZANI (SindNova, Roma/Italy) F. ROVEDO (Grola BG, Mannheim/Germany) G. TOGNOCCHI, A. ZALLOCCO (A. USL 4 di Prato U.F. PISLL, Prato/Italy) M. MASI (General Directorate for Health and Solidarity Policies Regione

Toscana, Firenze/Italy)The Project holder was IAL-CISL, the CISL trade union institute for professional trai-ning.

4. National datacollection exercise

4.1 United Kingdom

Phil Papard, Head of ProductSafety Section, Health and SafetyExecutive (HSE)

The data collection exercise on FLTs wascarried out under the supervision of theProject Manager Clare Field, Health andSafety Inspector at HSE, and the ProjectFacilitator Tim Harris, working in theWorkplace Transport Safety policy team atHSE. A UK working group was set upcomprising representatives from the HSE,local authorities, the operator trainingindustry, FLT manufacturers, FLT opera-tive employers and a trade union represen-ting FLT operators.

Members of the working group undertookto identify dutyholders who would partici-pate in the project, relying on the coopera-tion of dutyholders. The working groupagreed that subject FLTs should be CE-marked and well maintained: this wouldensure that the project was able to focus ondesign issues, rather than issues relating to

maintenance of the vehicle. The workinggroup also agreed that subject operatorsshould have been trained to the standardset out in the UK Approved Code ofPractice4 for training operators of rider-operated lift trucks.

Members of the working group intervie-wed FLT operators in their workplace,using open questions to identify designfeatures the operators considered affectedtheir safety. Background information onthe workplace and FLT was also recorded.The interviews resulted in the completion

4. HSE booklet L117 Rider-operated lift trucks:operator training

The working group agreedthat subject FLTs should

be CE-marked and wellmaintained: this would

ensure that the projectwas able to focus on design

issues, rather than issuesrelating to maintenance

of the vehicle.

of questionnaires that were collated by theHSE: a second working group was conve-ned to discuss the findings and the metho-dology used in the UK, and to constructan enriched Job Ergonomic Analysis.

A total of 21 operators were interviewedacross 11 workplaces, where nearly 90% ofthe FLTs were manufactured in 2002-2005. Nearly 90% of the comments wererelated to vehicle design: the majority ofthem related to visibility, controls and ope-rator comfort. Some issues are not new,but some are, and are being made publiclyavailable for the first time. More precisely:

Visibility screen wipers and motorpositioned at the top centre of thewindscreen.

Controls lack of space to operate footpedals especially when wearing safetyshoes.

Operator comfort concern about backinjury from twisting to access/egressvehicles.

Certain comments related to areas notcovered by standards, like overhead andside weather protection:

Quality and suitability varied Concern was expressed that materials

used scratch easily when cleaned orwhen passed under plastic strip cur-tains.

With some refinement concluded PhilPapard the method could be applied toother types of machinery. The project hasproduced data which deal with the moresubtle factors affecting operator safety, suchas ergonomics. Accident data are morelikely to focus on issues which do notaffect the day-to-day comfort of the opera-tor. However, over time day-to-day com-fort issues may have a significant effect onsafety, such as through fatigue and muscu-loskeletal disorders.The working group all thought the part-nership working was successful, and couldbe improved by involving more externalstakeholders at an earlier stage. Themethod could be taken forward andimproved by trade associations and unionsundertaking the interviewing: interviewingoperators was a time consuming but effec-tive way of obtaining useful, detailed infor-mation. And standardisation needs infor-mation to be fed back from the users, inparticular to minimise ergonomic residualrisks.

4.2 France

Genevive Rendu,Machinery SafetyBureau, Ministry of Employment,Social Cohesion and Housing

Recital 16 of the Machinery Directive setsout the principle of employers andemployees making a necessary contribu-tion to the process of developing standards.

Article 5 of the Directive specifies that'Member States shall ensure that appro-priate measures are taken to enable thesocial partners to have an influence atnational level on the process of preparingand monitoring the harmonised stan-dards'.

The objective is thus clearly stated: workersare entitled to their say on the design ofmachinery. This is self-evident given that itis the workers, after all, who are the end-users of the machinery and the first to haveaccidents or suffer from occupationaldiseases.

The precise manner of their participationis left to the Member States to determine.So it is up to the national public authori-ties to take the initiative in this respect.

But what should they do, and how?The French Ministry of Employment hasexplored several options:

The option of involving employees inthe process of developing standards inthe manner proposed by the standardi-sation system. We quickly came to seethis option as something of a fallacy:- employees and their representatives

do not have the requisite resources,time, availability or skills to take partin activities of a highly technicalnature that are clearly extremelytime-consuming;

- the world of standardisation on thebasis of consensus between 'interes-ted' parties is alien to French wor-kers and their representatives. Theyare used to a world of negotiationsor conflict between 'representative'parties;

- those involved in the standardisationprocess, mainly the manufacturers,consider their participation to bemore legitimate than that of theworkers.

The option of using an incident reportform (fiche d'alerte) to channel feed-back to the Ministry of Employment.This option was abandoned because itwas not 'realistic'.

The survey option. This consists ofasking a consultant to carry out a sur-vey of workers' concerns in the work-place and to draw conclusions formachinery design. This option wasfirst implemented at national level witha study of household refuse collectiontrucks. We viewed this as the most pro-mising option.

This is why the Ministry of Employmentfollowed with the greatest interest theETUI-REHS initiatives to gather userfeedback at European level using specificmethodology.

We considered that the choice of forklifttrucks for a trial of this feedback methodwas highly suitable for several reasons:

- the importance of accidentology;- the existence of a mandate given to

CEN in the 1990s to amend theEuropean standard, not only to gua-rantee better protection for the driver ifa truck overturns, but also to preventthe risk of overturning;

- what is at stake in the revision ofEuropean standards under the ViennaAgreement.

The Ministry of Employment was involvedin the operation in two ways:

- examining accidentology data relatingto the use of forklift trucks;

- financing a survey for gathering infor-mation in companies.

P A G E 8

This is whythe Ministryof Employment followedwith the greatestinterest the ETUI-REHSinitiativesto gather user feedbackat European level usingspecific methodology.

Accidentology in France Statistical dataFor just under ten years, the number ofaccidents at work has remained largelyconstant, with around 8,000 to 9,000 acci-dents annually, of which 10 to 20 havebeen fatal and 500 to 800 have resulted ininvalidity.

Qualitative dataFollowing an analysis of nearly 200 reportsof serious and/or fatal accidents providedby the Labour Inspectorate and involvingforklift trucks between 1993 and 2003, thefollowing five major risk categories havebeen identified:

> The risk of a truck overturning andcrushing the driver or another per-son;

> The risk of a truck colliding withpedestrians or objects;

> The risk of the load falling off;> The risk of a truck moving unexpec-

tedly;> The risk of falling due to the use on

a truck of an adapted, improvisedworking platform.

The Ministry of Employment drew thefollowing conclusions:

A proportion of these accidents could havebeen avoided if the employers had takenpreventive action based on risk assessment,the choice of appropriate equipment, orga-nisational measures and driver training inaccordance with Framework Directive89/391/EEC and Directive 89/655/EECon the Use of Work Equipment.However, given the prevalence of certainkinds of accidents, it is also reasonable tohighlight deficiencies in truck design, sincethe standards do not cover all situations of'atypical' use which can, nonetheless, beanticipated.

In-company survey carriedout by Clid5

MethodologyThe reliability of the results of this type ofsurvey depends on the methodology, thesurvey locations and the people surveyed.

> The methodology used was that ofETUI-REHS and combined ques-tionnaires, interviews, visits to com-panies and working groups. Twocompanies participated in the fullsurvey (interviews, questionnaires,visits and working group), while theother companies accepted the ques-tionnaire (without interviews) orvice versa.

> The choice of survey locations reflec-ted the diversity of situations:- a company from the nuclear sector

with 3,300 employees us ingaround 50 trucks;

- a tyre manufacturer with 1,500employees using around 70 trucks;

- a paper manufacturer with 750employees using around 50 trucks;

- a warehouse of a major distributioncompany using over 100 trucks.

> Responses were gathered from aheterogeneous mix of people:- in companies, responses came from

people at different levels of thecompany hierarchy and from avariety of departments: truck dri-vers, safety officers, ergonomicsofficer, training officers, ergono-mist, works manager, companydoctor, trainer, maintenance super-visor, etc;

- in the training centres, responsescame from truck drivers and trai-ners;

- people from outside institutions(labour inspectors, prevention ser-vices etc.).

ResultsRequests from the users for improvementsto truck design relate to the followingmain points:

> improvement of aids to safe driving(stability, visibility, limit on speedintegral to design, etc.);

> improvement of the design of thedriver's cab;

> improvement of the conditionsunder which maintenance is carriedout.

P A G E 9

5. Franoise Habasque and Eloise Galioot, Tmoignages d'utilisateurs de chariots automoteurs. Etudesdemandes par le ministre de l'Emploi et de la Solidarit et l'AFNOR, Clid, November 2005. The Celide isa bureau of experts established by the CFDT (French Trade Union) for the purpose of providing support to workersrepresentatives involved in occupational health and safety.

Conclusion> Methodology: the main advantage of the methodology proposed by ETUI-REHS

is that it necessitates comparison and cross-checking of responses from differentpeople. Conclusions arrived at by people on the ground can therefore be consideredreliable.

> In considering the results of this methodology applied to forklift trucks, we havenoted two prominent points:- some of the concerns and proposals voiced by the users corroborate the findings

of the Ministry which were based on a single study of serious occupational acci-dents. The issues involved are aids to driving, visibility and stability;

- other concerns and proposals voiced by the users substantially supplement thissingle study of serious accidents. Issues involved are design of the driver's cab andimproving the conditions under which truck maintenance is carried out.

On the basis of these points, we can conclude that:- this trial is conclusive and could be repeated for other types of machinery;- a summary of the various contributions ought to serve as valuable input for the

revision of forklift truck standards currently under way internationally within theVienna Agreement providing, of course, that those carrying out the standardisa-tion process agree to consider the concerns of people on the ground.

4.3 Finland

Tapio Siiril, Safety Engineer,Occupational Health and SafetyAdministration

In Mr Siirils view, FLTs represented agood choice for carrying out such a pro-ject, given their diffusion in so many diffe-rent working environments. The availableaccident data tell us that in the period1993-2000 as many as 5,315 accidentswere registered, with 32 fatal events from1985 to 2002. Falling of load, tipping overand pedestrian hitting were the most com-mon causes. Interviews also disclosed highnumbers of near misses.

Mr Siiril recalled that stability one ofthe most relevant safety issues is extensi-vely dealt with in normative annexes B toH of EN 1726-1. Interviews with usersindicated the need to review stability tes-ting requirements by taking into accountthe real conditions of use (at maximumtruck speed and maximum load), especiallywhen it comes to the trucks dynamicbehaviour when driving and turning.

A second critical safety factor is the drivingspeed. Here, operators expressed the wishto have whenever possible FLTs equip-ped with a device determining the speedon the basis of the route or area where thetruck is travelling. The presence of anautomatic limitation of the trucks speeddepending on the turning radius and loadmass and elevation was also mentionedduring interviews.

Poor visibility is one of the major safetyproblems with forklift trucks. In MrSiirils opinion the requirements laiddown in standard EN 1726-1 (paragraph5.10.1) are quite vague. During the inter-views design proposals (open structure ofthe mast, a rotating seat and controls forbackward driving, and a closed circuit tele-vision system) were raised.

Control devices whose requirements areconsidered too general and vague by MrSiiril were commented on at length byFLT users. As for all mobile machinery,control devices play a crucial role for FLTs.Their use must be self-evident, their layoutmust ensure an instinctively correct opera-tion, and they must be adjustable to suitdifferent users. In this connection, MrSiiril collected users complaints about thedifferent layouts of pedals allowed by EN1726-1 by means of the normative refe-rence to EN ISO 212816.

By the same token, some lever configura-tions increase the probability of operatorconfusion and consequently increase thelikelihood of errors with potentially dange-rous consequences. Mr Siiril, on thisissue, proposed that EN 1726-1 be revie-wed by adding normative references to therelevant ergonomic harmonised standardsdealing with the design of control opera-tions and control devices.

Other proposals were put forward by theoperators and users interviewed in Finland.Users asked for better design of operatoraccess and egress (steps were consideredeasier to use); they expressed the opinionthat all FLT should have a cabin (againstnoise, uncomfortable temperatures, impu-rities in the air, and of course as a protec-tion against FLT overturning or collisions);

the maximum allowed opening of over-head protection was asked to be smaller;users also asked for better design for main-tenance, to ease access to maintenancelocations and the handling of the battery.

Mr Siiril ended his contribution with acomment on loading control. Here hepointed out that the standard EN 1726-1still does not cover the loading controlrequirements of the Machinery Directive(clause 4.2.1.4 of Annex I), as explained inthe informative Annex N. In this connec-tion, Mr Siiril emphasised that the ETUI-REHS strategy could help provide stan-dard-setters with additional data for thepurpose of reviewing EN 1726-1 and cove-ring this critical safety issue.

P A G E 1 0

6. ISO 21281:2005 Construction and layout of pedals of self-propelled sit-down rider-controlled industrial trucks.Rules for the construction and layout of pedal.

Control devices whoserequirements areconsidered too generaland vague by Mr Siiril were commented onat length by FLT users.As for all mobile machinery,control devices playa crucial role for FLTs.

5. Round table

The round table that followed the seminarsess ions were moderated by UlrichBamberg, from the Office of the SocialPartners (Employees) in the Commissionfor Occupational Health and Safety andStandardisation (KAN), and by RobertoCianotti, Director of the Safety Tech-nology Department of ISPESL, the Na-tional Institute for Prevention and Safety atWork. Contributions were made by repre-sentatives of employees, employers, policy-makers, standard-setters, and by nationalOHS officials:

Norbert Anselmann, Head of Unit "Standardisation", DG Enterprise and Industry,European Commission;

Angel Fuente Martin, Principal Administrator, DG Employment and Social Affairs,European Commission;

Martin Eifel, Chairman of the Working Group of Committee 98/37/EC Machinery,DG Enterprise and Industry, European Commission;

Ian Fraser, DG Enterprise and Industry, European Commission;

Corrado Mattiuzzo, DG Enterprise and Industry, European Commission;

Brenda OBrien, Brussels Liaison Officer, European Agency for Safety and Health atWork;

Claudio Stanzani, President of the Trade Union Research Institute SindNova, Rome,Italy.

Lennart Ahnstrm, Chairman of the Working Group MACHEX of the Senior LabourInspectors Committee (SLIC);

Pascal Etienne, Director, Machinery Safety Bureau, Ministry of Employment, SocialCohesion and Housing, France;

Gerhard Steiger, Rapporteur to the CEN BT7 of the Machinery Safety Sector, CEN;

Stefan Joannin, Programme Manager for Safety of Machinery at the CENManagement Centre;

Werner Tannhuser, Chairman of the ISO Technical Committee TC 110 IndustrialTrucks, senior member of CEN TC 150 Safety of industrial trucks;

Franck Gambelli, Olivier Franois, Mouvement des Entreprises de France (MEDEF),France;

Doug Russell, National Health and Safety Officer, Union of Shop, Distributive, andAllied Workers (USDAW), United Kingdom;

Georges Fleury, Safety Officer, AREVA8, France;

The round table discussed the implications of the ETUI-REHS strategy and how thismay be translated into effective technical and policy initiatives for the future. This sectionincludes a summary of some of the round table members contributions.

P A G E 1 1

7. The CEN BT (Technical Board) is the technical body which controls the full standards programme andpromotes its speedy execution by the Technical Committees (TC), the CEN Management Centre (CMC) and otherbodies.8. AREVA NC is the French Government-owned nuclear group, suppliers of uranium throughout the world,active at every stage of the nuclear fuel cycle in the industry, from mining to waste management.

Messages from the Chairmen

Ulrich Bamberg

Since 1994 the Commission for OH&Sand Standardisation (KAN) has beenmonitoring the standardisation process toensure that standard-setters devote suffi-cient attention to the needs of OH&S. AtKAN we share the ETUI-REHS commit-ment to promoting public debate on therole of standardisation to improve workequipment safety. In our organisation wevalue the exchange of opinions of all thestakeholders involved in the functioningof the Single Market. In fact, the OH&Sinterests of various public institutions thesocial partners, the State, the statutoryaccident insurance institutions and DIN,the German national standardisation body(members of KAN) are collectively repre-sented in opinions on current and plannedstandardisation projects.

Coming from this background, we agreewith ETUI-REHS that occupationalhealth and safety interests are representedpoorly, if at all, in the European and inter-national standards committees. The resultis that requirements regarded by OH&S asnecessary and which are pursuant to theprovisions of the Machinery Directive areoften given at best inadequate considera-tion.

For this reason we regard the forklift truckproject as a valuable experience, indicatinghow the social partners experience canimprove the quality of machinery technicalstandards. Greater weight should be givento safety in the area of industrial truckstandardisation: this is why KAN welco-med the possibility to undertake theGerman-Italian forklift truck safety projectsupported by the Bilbao Agency in 20039.

With the support of European policy-makers, ETUI-REHS efforts have thepotential to establish a permanent mecha-nism through which social partner feed-back and viewpoints may be collected,coordinated and fed into the standardisa-tion process to help manufacturers producesafer equipment.

Roberto Cianotti

ISPESL has for many years supported theETUI-REHS research methodology, so farapplied to three types of machines. It is amethodology developed in line with boththe New Approach and the social directivesregulating health and safety at work.

We are here today to reaffirm the healthand safety implications of the role given tostandards by the New Approach. But wealso want to stress today the role played byemployers, who are responsible for the cor-rect choice of machine and for the designof the tasks that workers will carry outusing that machine.

In this connection it is important to seehow the design solutions chosen by stan-dard-setters to comply with the relevantessential safety requirements attain theobjectives in terms of productivity, opera-tor health and safety, user-friendliness. Webelieve that to improve the quality of stan-dards, the wealth of information madeavailable by ETUI-REHS is a necessaryknowledge base to be further developedand exploited.

ISPESL follows the activity of CEN TC150 through its Italian mirror committee.We recognise how standards are evolving.This evolution in terms of design contentshould be accompanied by the same levelof attention to issues related to informa-tion for users, and should not prevent usfrom taking into account the role playedby training. In this connection the ETUI-REHS strategy can help improve both thedesign dimension and the training obliga-tions incumbent on employers.

P A G E 1 2

9. A summary of the project has been published in KAN Brief 1/05 (http://www.kan.de/pdf/brief/eng/2005-1-Gabelstapler-e.pdf). The articles author is Franco Rovedo, working at GrolaBG, Project Facilitator of the Germandata collection exercise.

The result is thatrequirements regardedby OH&S as necessaryand which are pursuantto the provisionsof the Machinery Directiveare often given atbest inadequateconsideration.

We believe thatto improve the qualityof standards,the wealth of informationmade availableby ETUI-REHS isa necessary knowledgebase to befurther developedand exploited.

Social stakeholders influenceon standardisation:which way forward?

The discussion on the social dimension ofstandardisation under the New Approach,and the difficulties faced by trade unionsstruggling to help workers give their inputinto the European technical work at CEN,was introduced by Claudio Stanzani10:

Workers involvement, either direct or bymeans of specific representation frame-works, is one of the pillars of all Europeandirectives dealing with health and safety atwork. Workers, individually and collecti-vely, possess knowledge and experienceof the technological and organisationaldimensions of their work systems. Thisknowledge and experience, if adequatelycollected and valued, is indispensable to:

Identify and assess the risks associa-ted with the work system (worktasks, work environment, job);

Design and improve the work sys-tem;

Plan prevention strategies.

Worker participation is aimed at influencinga companys decision-making in relation toits health and safety obligations. Workersand trade unions have the right to concludecollective agreements with the line manage-ment in their enterprises, together with theright to be trained, informed and consultedon the prevention of occupational risks.

Experience and ergonomic culture confirmthat training, information and consultationimprove the competitiveness and perfor-mance of all sectors of activity; dialogue andcooperation with workers can improve thequality of line management decisions. TheETUI-REHS strategy starts from theseprinciples, by involving workers in analysingand re-designing their own work systems.

The ETUI-REHS tool seeks to legitimisethe ideas and experience that workers accu-mulate in doing their jobs, which they candraw on to suggest their own solutions tomachinery-related problems. As a matter of

fact, the ETUI-REHS toolbox for channel-ling users knowledge to standard-settersaims to provide a context in which designexperts can gain the practical understan-ding they need for successful design.

Social stakeholders involvement in stan-dardisation ultimately reflects the signifi-cance of a participatory design approach,an indispensable ingredient for the success-ful design of any work system. Unfor-tunately, many limitations still exist. Inmany Member States there is almostno official provision for informing andconsulting the social partners on Europeanstandards mandated under directives.

One consequence of this failure to ack-nowledge the trade unions right to partici-pate is that financial resources have notbeen made available. Moreover, workersrepresentatives find it hard to get thenecessary time off to play an active part inwhat is a time-consuming, complex pro-cess; they are also confronted by the needfor adequate technical training and the dif-ficulty of remaining independent of thecompanys interests.

Finally, trade unions are facing the chal-lenge of how to organise systematic feed-back of users experience so as to turnworkplace experience into significant tech-nical knowledge, which can then be usedin framing equipment design standardsand European training programmes.

P A G E 1 3

Some discussion points : Social stakeholders influence on standardisation: which way forward? Participation at national and European level Policy issues: do we need structural changes?

10. Claudio Stanzani, in cooperation with the ETUI-REHS, supervised the German-Italian project 5711/ITon forklift truck safety carried out under the SME Funding Scheme 2003-2004 sponsored by the Bilbao Agency.

Social stakeholdersinvolvementin standardisationultimately reflectsthe significanceof a participatorydesign approach,an indispensableingredient forthe successful designof any work system.

In this line of thought, Norbert Anselmannrecalled the importance of social stakehol-ders contribution to standardisation underthe New Approach:

The accountability of European standar-disation supporting New Approach legisla-tion a factor in the successful functioningof the Single Market in goods over the past20 years is directly linked to the partici-pation of social stakeholders, making stan-dards more representative by strengtheningthe quality of the consensus they are basedon.

This principle reflects the fundamentalobjectives set out in the Treaty establishingthe European Community: to ensure highlevels of protection for the public interest(in its environmental, consumer, andhealth and safety dimensions). As a result,the European standardisation system has abroad responsibility to industry, workers,consumers, environmental interests andpublic authorities, who all have a legiti-mate interest in the outcome of this tech-nical work.

Ensuring that the views of all interestedgroups are adequately taken into account isessential. In particular, since machinerystandards quantify the level of protectionthat the Machinery Directive seeks to pro-vide, workers representatives have the rightto demand standards providing a high levelof protection in line with the technologicalstate of the art.

We are aware that trade union participa-tion is not yet sufficiently well guaranteed,neither at the European Standards Orga-nisations nor within all Member States.Although its methodology still needs somerefinements to make it applicable horizon-tally to other products, the ETUI-REHSstrategy should be presented to the98/34/EC Committee in order to debatehow to improve the mandates given to theEuropean Standardisation Organisation(ESO) and their execution, and to includein them the mechanisms and methodsenvisaged by ETUI-REHS to improve thesocial partners contribution to standardisa-tion.

CENs commitment to openness, impartiality andconsensus was confirmed by Gerhard Steiger, whorecalled that the key objective of standardisation isaccess to everyone who wishes to participate in thetechnical work:

The whole CEN system and the system functioning at national level are both designedaccording to this basic principle: anyone can take part in the technical work at nationallevel and perhaps become a delegate at European level. Both tracks should now be usedby ETUI-REHS to put forward the findings of this important exercise.

We are of the opinion that the national dimension is the most important: through actionat national level, ETUI-REHS could duplicate its achievements while trade unions could in several countries influence the national opinion building process.

In this connection, it is also important to remember that national delegates are expectedto represent a national opinion: this explains the importance of compromise among allstakeholders to achieve consensus at national level. The standardisation rule of consensusalso applies to the findings of the ETUI-REHS project.

P A G E 1 4

Participation at nationaland European level

The question of how to feed workers know-ledge into standardisation still remains.The opportunities to have a say in thenational and European dimensions wereexplained by Stefan Joannin, who first of allrecommended consolidating workers feed-back and knowledge at national level byinteracting with national mirror commit-tees. He added that:

This way of operating does not precludethe possibi l i ty of acting direct ly atEuropean level, speaking with one voiceabout the results of such experiences, sinceETUI-REHS, as a CEN associate member,receives draft standards at the CENenquiry stage and could submit the com-

Trade unionrepresentatives

should bring thesame 'workers

feedbackreports' to thenational mirrorcommittees of

their NSB.

We are aware thattrade union participationis not yet sufficientlywell guaranteed,neither at the EuropeanStandards Organisationsnor within allMember States.

We are of the opinionthat the nationaldimension is the mostimportant: throughaction at national level,ETUI-REHS couldduplicate itsachievementswhile trade unionscould influencethe national opinionbuilding process.

ments at this stage. The question remainsas to how effective this 'track' would be.

There is great value in consolidating theconcerns of workers from all MemberStates and centralising it within ETUI-REHS; that is why the methodology isworth exploiting further. For it to be effec-tive, the consolidation of comments andinput from workers should be fed throughevery National Standards Body (NSB) par-ticipating in that domain.

Trade union representatives should bringthe same 'workers feedback reports' to thenational mirror committees of their NSB.In so doing, when the CEN workinggroup itself meets, there will be a betterchance of having the concerns and recom-mendations put forward in that workersreport taken on board.

In conclusion, workers input should beput forward using as many channels aspossible, to increase its chances of beingconsidered during discussion in theEuropean working groups. Having a tradeunion representative present at the relevantworking group meetings could help in thisrespect.

The national and European dimensions of partici-pation were further analysed by Ian Fraser, whodrew attention to the human resources dimension:

The most important work on any standard is donetwice: the first, most important work is to draft thestandard. Once the initial drafting has been donemodifications are possible, but the basic content ofthe standard is often largely determined. The secondkey phase is the enquiry on the standard, whencomments made by the national standardisation bodies are discussed and taken intoaccount.

Those two phases are not carried out at national level but at European level in the CENWGs. In this connection, we have noted the frustration of stakeholders, including thepublic authorities, who have been trying to influence the standardisation process over thelast ten years, when they are not directly present in the WG drafting the standard anddealing with the comments received during the enquiry then the best that can be achie-ved is a marginal influence over the content of the final standard.

The public enquiry, the work of the national mirror groups, the fact that all stakeholderscan contribute to the building of a national position, are all positive elements that shouldnot be neglected.

However, to exercise real influence, there is no alternative to being present at the key mee-tings to defend your point of view. Trade unions are in a weak position here, as participa-ting in meetings requires not only time and financial resources, but also human resources:experts who can be effective advocates of their positions, able to stand up to the pressureand criticism of the other interest groups represented in the WG.

The ETUI-REHS experiment has so far produced an impressive amount of useful data:we believe that if the methodology is applied to other classes of machinery, similar goodresults will be achieved.

The challenge now is to see how this information can be introduced into standardisation.We consider that it is not sufficient to have workers feedback stored in a library or madeavailable in written form. There must be people putting proposals based on workers feed-back on the table during WG meetings and arguing the case meeting after meeting.Other interested parties, who are physically present at the meetings, put forward theirown agenda and argue their views, strongly defending their interests, and will probablyleave aside the trade union document.

The question remains as to how the CEN system can help integrate workers feedback,taking into account the challenge represented by direct participation in WGs and TCs.

P A G E 1 5

The public enquiry,the work of the national

mirror groups, the factthat all stakeholders can

contribute to the buildingof a national position,

are all positive elementsthat should not be

neglected.

The heterogeneity displayed by the stan-dardisation world in terms of balancedrepresentation was confirmed by DougRussell, who also provided hands-on infor-mation on the situation in the UK, where:

There is very little involvement of thetrade unions in the NSB, and there is evenless involvement of employers who buyequipment to be used at work. However,some success stories in terms of balancedinvolvement in standardisation can be toldby stakeholders involved in the use of spe-cific machinery like meat machinery andprinting machinery. In the UK, there arelarge numbers of FLTs in bakery and in the

paper-making industry.In these areas there has been a strongtripartite stakeholder group involvingemployers/trade unions/HSE officials.Through this group, a consensus was deve-loped very quickly about what the Britishline was on what we wanted to see in thestandard, so there was only marginal dis-pute amongst those stakeholders themsel-ves.

When it comes to the financial dimensionof participation, other stakeholders facedifficulties, as Stefan Joannin indicated:

Maintaining a high level of participationfrom industry in standardisation is notalways easy. Experts having participated formany years are retiring, and it is not alwayseasy to find new experts to replace them.The cost for industry is not negligible.SMEs may find it hard to invest theirresources in allowing operators to partici-pate in interviews and working groups,collecting their opinions and preparingdraft recommendations. One can onlyhope that the ETUI-REHS exercise hasshown them that this system can work,and is worth the investment.

The need for trade unions to ensure their influence by using different channels - influen-cing the positions of National Standardisation Bodies (NSBs) and mirror WGs and TCs,via national public authorities - was shared by Martin Eifel, who recalled the importanceof taking into account the views of all stakeholders:

When it comes to the stakeholders participation and influence, the standardisationworld embraces a wide range of situations. On the one hand, the ideal situation where

NSB representatives speak on behalf of all stakehol-ders; on the other, there are situations where an inte-rest group has been able to influence the NSBs in anumber of Member States and achieve a near mono-poly on what will be actually put into the standard.

One example would be multinational companies thathave the resources to invest in several different NSBrepresentatives, thereby having a lot of influence.Such unbalanced situations are against the principlesof standardisation, which should not favour the inte-rests of a particular supplier or country.

P A G E 1 6

This success story caused Lennart Ahnstrm to emphasise the role played by public autho-rities but also the difficulties they face:

In addition to users feedback into standardisation, the experience gained by authoritiesthrough market surveillance is essential. However, public authorities participation instandardisation is likely to decrease as time passes because of the lack of human and finan-cial resources. Therefore, if we really want the experiences of users of different machinesto be incorporated into standards, we must find a pragmatic solution. And the solutioninvolves the role of national mirror committees and WGs. The question remains as tohow to pass information to the mirror committees: a certain degree of centralisation ofthis user information is necessary, because small countries could find it difficult to makesuch information available to national bodies.

One example would be multinational companies that have the resources to invest in several different NSB representatives, thereby having a lot of influence.

If we really wantthe experiencesof users of differentmachines to beincorporated intostandards, we must finda pragmatic solution.

Somesuccess stories

in terms of balancedinvolvement in

standardisation can betold by stakeholders

involved in the useof specific machinery like

meat machinery andprinting machinery.

The discussion then moved on to the natio-nal dimension of standardisation. HereStefan Joannin depicted possible practicalsteps that ETUI-REHS might want to taketowards NSB. He began by observing thattechnical changes are feasible even after thedraft standards have been written:

P A G E 1 7

However, it was pointed out by Werner Tannhuser that users insights should be presentedin the form of concrete proposals:

In standardisation work, making general comments on the quality of standards is veryoften useless. WGs welcome concrete proposals and recommendations, if possible with arange of technical solutions to be debated and agreed on. Failure to do so would imply asignificant delay in managing such information, since someone else would be obliged toextract factual proposals from generic suggestions.

This observation was supported by TapioSiiril, who stressed the need to attend mee-tings to make the most of users insights:

In my experience with CEN and ISOworking groups Ive seen the amount oftechnical work that experts have to carryout: they meet for a few days, a few times ayear, with the task of dealing with a largenumber of comments coming from thenational standardisation bodies. Onlycomments including detailed proposals formodifications are seriously taken intoaccount.

And most importantly, it is necessary to besitting in the meetings of the workinggroups, so as to explain the proposedmodifications and answer the questions,criticisms and comments: taking part inthe discussion is essential.

Therefore, the crucial step of the ETUI-REHS methodology is not only the elabo-ration of technical recommendations to bepresented to standard-setters, but also ascheme to ensure the participation ofexperts supporting and advocating theusers concerns and recommendations.And this trade union participation couldprove very difficult when it comes tomachines like FLTs, whose standards areelaborated in the framework of the ViennaAgreement at international level.The difficulty of influencing standards that cover the global market was confirmed by

Werner Tannhuser, who observed that:

Standardisation activity on FLTs is probably one of the best examples of the role playedby globalisation. FLTs are sold worldwide, in countries with very diverse safety, technolo-gical and regulatory cultures.

Experts in ISO and in CEN have the difficult task of producing standards that reflect theconsensus of different players operating in different working environments. It is true thatthe elaboration of FLT standards is a difficult exercise at European level. Moving to theinternational dimension, it is even more difficult to agree on some safety design issues.For this reason, participation and a continuous exchange of views is primordial. And whenresearch projects like the one carried out by ETUI-REHS produce suggestions and recom-mendations, they should be integrated into draft standards as soon as is practicable.

Of course, changes and modificationshave a better chance of being included ina draft standard when they are requestedby many stakeholders. That is why it isimportant that the users concerns raisedby reports such as the one presented todayby ETUI-REHS, be well known to theNSBs.

With this objective in mind, such reportscould first of all be presented to the mirrorcommittees established within the NSBs,where they exist, of the Member Statestaking part in the ETUI-REHS project.This would increase the chances of theusers insights being included in the posi-tions of the NSBs when they make com-ments or vote at the CEN enquiry or for-mal vote stages.

WGs welcomeconcrete proposals

and recommendations,if possible with a range

of technical solutionsto be debated

and agreed on.

It is true thatthe elaboration of FLTstandards is a difficultexercise at European level.Moving to the internationaldimension, it is even moredifficult to agreeon some safety design issues.

Workers concerns are takeninto account at present,

but it is true that thesituation can be improvedby making this integration

of users concerns moresystematic.

And whenever practical recommendations are made, the CEN and ISO systems are ableto take due account of them continued Gerhard Steiger, who confirmed that: many ofthe specific issues raised at this seminar have been brought up in the WGs and TCs overthe years, and this is reflected in the quality of CEN standards. CEN standard-setters areaware of the importance of feedback on the use of existing safety standards.

This is a requirement of CEN Guide 41411, the basic document specifying requirementsfor the drafting and presentation of European machinery safety standards. Workersconcerns are taken into account at present, but it is true that the situation can be impro-ved by making this integration of users concerns more systematic.

Policy issues: do we need structural changes?

The discussion on what regulatory responses could support the new ETUI-REHS strategywas introduced by Corrado Mattiuzzo, who gave the audience a timely synthesis summari-sing some key points of the discussion so far.

We all agree that ETUI-REHS has designed a very interesting approach to improvemachinery safety. We are all aware that in order to make the most of such an exercise byfeeding its outcomes into standardisation, participation is necessary.

We are also aware that standardisation does not offer a level playing field for all stakehol-ders: the social partners are worst off in this regard. We have also heard how difficult ithas been to carry out such a project: the key question is what we all can do to make surethat such an exercise does not represent a one-off episode, rather a permanent mechanismto help standardisation attain the highest quality in terms of productivity and workershealth and safety.

The fact that the Machinery Committee and WG led by the European Commissionservices should have a leading role in helping find appropriate policy answers to thesocial partners expectations is, in principle, uncontested. However, in order to stimulateaction, ETUI-REHS together with the pool of Bodies that carried out the forklift truckstudy should elaborate and present some sort of plan to be forwarded to the appropriateCommission services.

P A G E 1 8

Discussing how to move from words to deeds, Martin Eifel suggested that ETUI-REHSshould:

take the experience of the project to the political level within the context of theMachinery Directive and other pertinent directives, in order to establish a permanentmechanism to feed users concerns into standardisation. In relation to this it would beinteresting to monitor the application of Article 5 of the Machinery Directive.

Article 5 of the Machinery Directive requires Member States to ensure thatappropriate measures are taken to enable the social partners to have an influence atnational level on the process of preparing and monitoring the harmonised stan-dards.This requirement is complemented by Recital No.18, which recalls the need toimprove the legislative framework in order to ensure an effective and appropriatecontribution by employers and employees to the standardisation process.

11. CEN Guide 414:2004 Safety of machinery Rules for the drafting and presentation of safety standards. The guide is publicly available on the CEN website at the following address: http://www.cenorm.be/BOSS/supporting/reference+documents/cenguide41420041215.pdf

We all agree thatETUI-REHS hasdesigned a veryinteresting approachto improvemachinery safety.

This monitoring is to be performed by the Commission services. In this regard Martin Eifelsuggested that ETUI-REHS should present the project and their concerns at the nextMachinery Working Group meeting:

We believe that this ETUI-REHS strategy should be discussed in the next MachineryWG. Member States should share their experiences of implementing Article 5 of theDirective. If necessary, as a practical application of Article 5 of the Machinery Directive, itcould be envisaged to render obligatory a guarantee that the social stakeholders have beenadequately consulted when issuing a standard, in order to safeguard that the standardisa-tion process functions well.

Alternatively (or additionally), one could imagine a system similar to the one associated tothe recommendations for use issued by the European coordination of notified bodies,that are open to scrutiny of the Member States, before they are endorsed by theMachinery WG. We might find it useful to do the same with the harmonised standards,in order to pick up those where Member States or the Commission believe that theconsultation procedure has not worked properly. However, we have to remain realistic inorder to take account of available resources and avoid creating unneces-sary red tape.

P A G E 1 9

The opportunity to address Article 5 of theMachinery Directive with the objective ofhelping to achieve a balanced input ofsocial concerns into standardisation waswelcomed by attendees. On the one hand, areference to Article 5 would strengthen therole of the Machinery WG, as indicated byPascal Etienne:

ETUI-REHS should call on the Com-mission to monitor the Article 5 require-ments, because it would help achieve a levelplaying field for any further discussion anddecisions taken in the Machinery WG.Authorities value the role of the MachineryWG headed up by the Commission, as itrepresents a forum where all stakeholderscan contribute to a better design and incor-poration of machines into the workplace.

The ETUI-REHS study is an impressiveexample of questions raised about the qua-lity of certain standards. Stakeholders areasked to respond to such concerns: autho-

rities on the one hand, by reporting onmeasures taken to ensure that social part-ners can influence national standardisationwork; standard-setters on the other, byanalysing and taking on board at theappropriate time the suggestions formula-ted by people acting in the field wheremachinery is used.

The Commission would politically steerthis new way of working together throughthe Machinery WG. The French authori-ties have already invested resources in thedirection of the ETUI-REHS strategy andare willing to continue doing so.

This is felt necessary given the authoritiesresponsibility to implement product andsocial directives by means of a coherentapproach. The ETUI-REHS demand tomonitor Article 5 is also in line with theobjectives of the New Approach revision:to provide a better regulatory frameworkfor the functioning of the Single Market.

A stronger role for the Machinery WG would also help optimise the scarce resources of national authorities responsible for ensuring theprotection of workers using machinery at work, as indicated by Lennart Ahnstrm, who also recalled that:

The New Approach and the role given to standards has contributed to the existence of safer machines, by providing a commonEuropean platform where stakeholders can agree on technical solutions complying with the legislative requirements. Participation is crucial, and we recognise that not everyone has the same possibility of influencing European standardisation work. This situation needsto be improved. And market surveillance is more and more resource-consuming, especially if we are to take balanced decisions against manufacturerswithout distorting competition. Reactive initiatives cannot be the sole means to ensure that only safe machines are put on the market.Everyone realises how expensive actions against machines and harmonised standards can be in terms of resources. Thats why it would be better to anticipate problems instead of reacting to them. In this connection, better cooperation among MemberStates, and better use of any experience like that gained from the ETUI-REHS project, represent the right way ahead.

The French authoritieshave already

invested resourcesin the direction

of the ETUI-REHSstrategy and are willing

to continue doing so.

We might find it usefulto do the same with theharmonised standards,in order to pick up thosewhere Member Statesor the Commission believethat the consultationprocedure has not workedproperly.

Cooperation and an intelligent interpre-tation and enforcement of the Article 5requirements were stressed by Phil Papard,who also stated that:

The legal status of the standards that arethe object of the seminar today should bealways kept in mind: yes, they are theresult of a process where consensus, lob-bying, resources come into play, but theyare expected to deliver the presumption ofconformity to the relevant legal require-ments of the Machinery Directive.And we all know how resource-consuming

it can be to challenge a standard once it hasbeen published in the Official Journal.This is the reason why HSE considers theETUI-REHS strategy worthwhile as ithelps identify health and safety problemsin the field that could be brought to CEN,to see which of them could be addressedtaking into account the current state of theart, and which ones require furtherresearch work.We do not need to change the currentCEN system: we probably need only toadapt it to take advantage of workers feed-back in an efficient manner. Having a

champion in WGs and TCs is important,but realistically we cannot probably have achampion in every MS for every standardwe are working on.I would like to point out that when HSEembarked upon this project, it did not seeit as a trade union project: the project wasseen as a way to benefit from users know-ledge to improve the design of machineryused at work, by bringing together manystakeholders and working out feasibleimprovements both in design and in theworking environment.

P A G E 2 0

The need to address both design and the working environment, improving communica-tion between those who construct and those who use the machines, was shared by AngelFuente Martin, with a focus on SMEs:

The ETUI-REHS strategy has the potential to influence European political decisionmaking. Without it remaining a purely academic exercise, reality tells us that SMEs veryoften lack the technical knowledge and know-how needed to make sound choices of workequipment. As a result, SMEs are very often subject to the whims of market players whosell products but not quality products.In this connection, we feel that the ETUI-REHS strategy could open up a debate withinthe framework of the Advisory Committee on Safety and Health at Work12. In additionto acting through the Advisory Committee and DG Employment officials, ETUI-REHSshould maintain continuous contact with the Senior Labour Inspectors Committee(SLIC) officials and explore new ways to cooperate with market surveillance authorities.ETUI-REHS should also draw policy-makers attention to the essential role played by therisk assessment done by employers. Risk assessment is not an academic exercise; rather, itrepresents a dynamic tool to continuously monitor the balance between productivityobjectives and workers wellbeing.Today we are discussing how all the information emanating from users can be channelledtowards the right targets. It is important to think about a European level playing field,because some small countries do not have the human, financial and administrative resour-ces to collect information from the field on how machinery is really used.Therefore, cooperation among market surveillance authorities and a continuous know-ledge transfer on workplace experience with machinery is essential. We should also keepin mind that other stakeholders like insurance companies could be asked to play an activerole, since they are the bodies that pay for sick leave, injuries, etc.

The attention given to SMEs health andsafety needs by the European Agency forHealth and Safety at Work is a continuouscommitment, recalled Brenda OBrien:

Europe's small and medium-sized enter-prises are key drivers of economic growthand job creation. However, due to a lack offinancial and organisational resources,many SMEs have only limited occupatio-nal health and safety knowledge and capa-city. That is why the Bilbao-based Eu-ropean Agency for Safety and Health atWork keeps on organising SME fundingschemes focused on reducing safety andhealth risks in Europe's SMEs.Forklift trucks are the most widely usedpieces of equipment for moving materials

around worksites and warehouses in nume-rous industrial and manufacturing sectors.But their use results in a high rate of acci-dents involving drivers and other workers,especially in SMEs. Forklift drivers are alsoexposed to many other risks, as a result ofpoor ergonomic design, awkward postures,repetitive movements and additionalmanual handling of goods.Against this background, the transnationalproject where ETUI-REHS was involvedsome years ago, was considered worthy ofthe Agency Award because it aimed toreduce these risks by working with drivers,designers, dealers and national authorities

towards improving forklift truck design,and by setting up training activities. I amdelighted to see that the Agency Awarddrove trade unions towards another suc-cessful European experience.

12. The role of this standing Advisory Committee is to assist the Commission in the preparation and implementation of decisions taken in the field of safety and health at work and to facilitate cooperationbetween national administrations, trade unions and employers' organisations. ETUI-REHS acts as coordinator of the workers interest group.

Forklift drivers are alsoexposed to many otherrisks, as a result of poorergonomic design, awkwardpostures, repetitivemovements and additionalmanual handling of goods.

It is important to thinkabout a European

level playing field,because some small

countries do not havethe human, financial

and administrativeresources to collect

information from the fieldon how machinery

is really used.

It is in this spiritthat national monitoring

bodies have helpedthe trade unions to collect

information in the fieldand organise it

in such a waythat it can be fed intostandardisation work.

Insights into how the ETUI-REHS strategyaffected a multinational enterprise wereprovided by Georges Fleury, who observedthat:

The employees at AREVA NC had noqualms about participating in this type ofsurvey. The procedure used in the newmethod proposed by ETUI-REHS is verysimilar to our way of working on a dailybasis in many areas, such as dealing withquality, the environment and safety mana-gement. In these three areas we base oursel-ves on standards ISO 9001, ISO 14001and specification OHSAS 18001 respecti-vely.

The basic principle behind this sort ofapproach is a process of continuous impro-vement. Under this principle, and in thepresent case of machinery standards, it isimportant to take as many factors as possi-ble into account, most notably users opi-nions. Of course it is vital to analyse all theinformation gathered, and this forms part

P A G E 2 1

of the proposed new method.It has become part of our regular practiceto involve employees in this kind of conti-nuous improvement process, and theyconsider it necessary if not indispensable.What is more, they were even more enthu-siastic once we told them that the outcomeof the survey they were involved in wouldbe incorporated into a revision of Euro-pean-level standards. Its the first time theyveever asked for our opinion at such a highlevel, they said. But in actual fact, the wor-kers involved in the survey also asked usabout the outcomes.

Under the previous method, still beingused to draw up and revise standards, thefact that it is not possible to collect usersopinions and generally take them intoaccount is a weak link in the existing pro-cess. So the proposed new method solvesthis problem, or at least considerablyimproves things. This new method sitswell with a process of continuous improve-ment, and it certainly suits us.

Finally, the need to integrate the ETUI-REHS strategy into the 'CEN system' was unders-cored by Franck Gambelli and Olivier Franois, who began by acknowledging the impor-tance of users' feedback:

It is not just legitimate for employees the users of machinery and personal protectionequipment to have an input into standardisation, but it is in the undeniable interest oftheir employers and of the employers suppliers. Employees are the people directly expo-sed to residual risk, and prior risk reduction helps employers comply with their safetyobligations. Operators use the devices on a daily basis and are often more familiar thananyone else with all their attributes, both positive and negative. In some cases employeesmake purchasing decisions that are important for companies and hence manufacturers.The user feedback exercise organised by ETUI-REHS can contribute valuable experienceto standard-setters deliberations.

However, the role played by Member States monitoring bodies in this type of operationrequires some clarification. Member States are obliged to ensure that the goals of theMachinery Directive are attained in their country, particularly as regards involvingemployees in the standardisation process. It is in this spirit that national monitoringbodies have helped the trade unions to collect information in the field and organise it insuch a way that it can be fed into standardisation work. Nevertheless, the companies par-ticipating in standardisation groups cannot be bound by comments made by employersrepresentatives in response to this type of survey.

Furthermore, as we understand it, this user feedback is being 'taken' to CEN by ETUI-REHS and not by Member States representatives. So this is not some kind of 'commonposition' between Member States and trade unions that enjoys a special legal status, whe-reby non-compliance by the other standardisation parties would automatically triggerthe threat of a safeguard clause. A new and 'exceptional' standardisation procedure, alludedto by one Member State representative taking part in this exercise, would bypass CENsrules of procedure and would not be acceptable to us. Subject to these few remarks, wewelcome the high-quality work done by ETUI-REHS and hope it will help ensure thatstandards take better account of reality on the ground.

The basicprinciple behindthis sortof approach isa processof continuousimprovement.

6. Overall conclusionsand future plans/perspectives

Laurent Vogel, ETUI-REHS, ActingHead of the Health and SafetyDepartment

The ETUI-REHS strategy seeks to res-pond to indications given by the EuropeanCommission. Two EC communications13

stress the importance of informationexchanges to enhance the implementationof the New Approach Directives. Theproject that we discussed together is asignificant practical challenge in terms ofresearch effort. It addresses the humancosts associated with the use of forklifttrucks every year. So it is a big challengenot least for the sake of human beings.

On a general level, the ETUI-REHS stra-tegy enables us to assess the credibility ofthe whole New Approach. In fact, underthe New Approach, policy-makers havedelegated some of their functions to pri-vate or semi-private bodies. This delega-tion of power necessitates respect for aseries of conditions, and one of the funda-mental conditions is the possibility for allinterested parties to efficiently participatein the definition of technical standards.

In this connection we trade unionistsbelieve that the present situation is notsatisfactory. There are a series of causes,reasons that conspire to create a particularstate of affairs, and there is no guarantee aswe speak that all the parties involved canparticipate in the standardisation process.

What we need to see is how an exercise likethe one presented today can be not just anice show, a nice session identifying pro-blems and difficulties. We must ensure thatthis actually leads to a number of changes and I would say that these need to bestructural changes. And we dont want togive the term structural an exclusively regu-latory meaning.

We think that in a number of cases organi-sational roles can remain what they are butstructural changes need to happen in prac-tice. This change, in my opinion, is anissue for all stakeholders so the idea is notjust to say that changes need to focus onthis or that particular structure or group,because it would not correspond to thepresent situation.

P A G E 2 2

We believe that a guiding role must beplayed by the European Commission, andmore particularly DG Enterprise, becausethe quality of standardisation is a funda-mental issue for the implementation of theNew Approach. Only the Commission canconvince all the stakeholders concerned tocooperate on health and safety matters soas to make the New Approach more credi-ble.

Our Seminar today has shown how impor-tant is