Unrealistic/Conflicting Harmonized Standard

[farmer2]

Has anyone had to deal with a new EN standard for their product where there are several new requirements that are unrealistic or impossible to attain?

I have been told the standard is ratified and there is no chance of changes prior to or 2 years after the effective date. It takes effect in 2 years and frankly 5 years would not be adequate time to make the changes from a practical and economic standpoint. I was told it would be reviewed in 4 years for possible changes.

So far, I have talked to 4 competitors who have been shipping their CE marked product to Europe and none have even heard of the new standard. They also will have the same problems my company has in trying to meet the new standard.

It would be good if someone has been through this and could let me know of their experiences and approach.

 

[ozmosis]

what's the standard?
Some standards (and it is not just confined to EN) allow you to insert clauses in your self-declaration that state what you can actually do. A lot of standards are not black/white and the grey area is where most people sit. The important point is to stipulate where you do comply and where you don't or more specifically what the user must do to ensure compliance.

 

[PeterCharles]

Please post the example(s) you are talking about then maybe I could comment.

 

[farmer2]

I am talking about EN 14492-1 Winch Standard. It covers all pulling winches from boat trailer winches, off-road self recovery winches to industrial wrecker winches-any pulling winch.

This is not a "grey area" case where you can comply to part and explain where you do not comply. If you can find an equal or higher standard, you can use that. The point is that there is no equal or higher standard.

For example, a winch that has been rated at 50,000 lbs would now be downrated to 26,000 lbs unless it is completely redesigned to the new standard. Redesign will add about 25% to the weight and overall dimensions not to mention the effect on price.

I thought perhaps someone in some industry had faced this and wanted to know how they proceeded.

Thanks,

 

[farmer2]

The winches become downrated because of the requirements of the harmonized std which were not present in the machinery directive. There was no harmonized std so everyone could interpret the mach directive as they wished, then along comes these specs which most current products do not meet. The safety factor of wire rope went from no requirement to a 2 to 1 and the required drum diameter was also increased for a given rope diameter.