Malcom Kent, senior technical consultant for the UK-based CEA (
If you are in any way involved in the safety of earthmoving machinery you probably already know that there is a problem with the technical standard for specifying what operators need to be able to see from their work station. This goes back several years when a German citizen submitted a petition on the matter to the European Parliament. His claim was that the standard that manufacturers in the design of machinery, ISO 5006, did not provide a sufficient level of safety. After a long process of investigation and consultation, the European Commission came to the conclusion that he was right, and in January 2015 published what is called a Decision, with a capital D. This Decision stated that the standard had been deemed inadequate and that the Commission’s approval of the standard was being withdrawn. This means that, although the standard still exists, manufacturers can no longer rely on it as a means to claim that their machines are safe enough regarding visibility.
There are two areas where visibility is assessed under the 2006 edition of the standard: firstly on a 12m circle around the machine at ground level, and secondly on a 1.5m high post moved around a rectangle set 1m out from the footprint of the machine. The detailed requirements vary depending on machine type and size but the principles are the same for all. Note that there is no requirement to be able to see anything at all between 1m-12m from the machines, although in practice the operator would be able to see a great deal in this range. The main complaint in the original petition was that significant blind spots behind the machine were allowed under the standard and this led to the risk of accidents.
So, what does ‘safe enough’ mean? Well, it depends. It depends on risk assessment that covers the type of machine, the size of machine, how it moves and how fast, how its work equipment (if any) moves and how it is used. That is quite a lot to consider but is what each manufacturer needs to do in the absence of any technical standard that they can hang their hats on. It’s not just manufacturers who are uneasy in the absence of a suitable technical standard: safety authorities across Europe are trying to produce guidance for manufacturers and are supporting the development of a new standard. The [UK] Health and Safety Executive (HSE) has issued their own guidance document (available for download from their website) which covers some key considerations without excessive detail.
So where are we going with the new standard? - and remember it is an international standard. That is really hard to say because there are a lot of fingers in the pie from non-European countries who do not necessarily see the need to plaster machines with mirrors, cameras, radar etc. to countries at the heart of Europe with a culture that demands the highest level of technical risk reduction on products. Because of this, there is real tension over how much to change the ISO standard and it is not clear yet whether the project will succeed in publishing anything. Even if it does, it is by no means certain that the European Commission would deem it as being satisfactory. If they did not, it would mean that the effort had been in vain because the block on the use of the standard would remain in place.
The other possibility is that new requirements on visibility could be written into a European standard, meaning that the influence of the Rest of the World would disappear. On the face of it, this would seem more likely to succeed in producing a standard acceptable to the European Commission, but the focus of work still seems to be missing the target as far as some people see it.
All this means that we are unlikely to have in our hands for several years (yes, years) a standard for machine visibility which will provide the level of clarity manufacturers, customers and safety authorities all crave.
So what are we all to do in the meantime? Many manufacturers will be looking at the HSE guidance, which, amongst other things, tells them to review and update their risk assessments, to review what is available in terms of visibility aids and to keep themselves informed on how work on revising the standard is progressing. That last one is pretty well impossible as the work is going in fits and starts, in two directions at once. The guidance also recommends including ‘visibility maps’ in the machine instructions showing the blind spots around the machine. Given how often instruction manuals are used it is questionable as to whether this will reduce accidents. Some customers are asking manufacturers what they are doing aobut visibility and others are taking things into their own hands, installing after-market camera systems or other aids. Although there is nothing wrong with this, machine owners need to be aware that, along with the system supplier, they are taking over a significant chunk of responsibility for risk assessment.
So, right now there is no clear vision on visibility. Manufacturers have to stand on their own two feet in risk assessment and the provision of visibility aids, and that situation is likely to continue for quite some time.
