European Trade Union Institute, ETUI.

Key lines of action for trade unions: reflections and ideas on how to move forward

Trade Unions ask themselves what does "consensus" mean in the European standardisation model. Does the "national consensus" brought into the CEN system reflects a "balanced" representation of all interests concerned in the standardisation process? As each national standardisation organisation can only take a uniform national position in the voting, societal stakeholders will strive to exercise their influence through the national standardisation work and as members of the national "mirror" committees.

Therefore, trade unions need to take every opportunity to participate in national delegations in order to influence the consensus and raise national delegates’ awareness of health and safety at work matters.

Maximum benefit will be achieved when trade unions influence more national delegates, in order to inject health and safety concerns into a whole TC or WG. This means collaborating with trade unions in other Member States and achieving a common trade union view under the coordination of ETUI.

The passage of safety standards from CEN to ISO and back adds new features and brings new challenges for trade unions: the relation of standards to legislation, the duties of manufacturers and users, the framework in which standards are prepared, the representation of legitimate workers' interests.

A combination of trade union pressure into NSBs and European-level coordination through ETUI can help ensure that acceptable standards emerge from CEN/CENELEC work. When moving from CEN to ISO, for European trade unions this shift significantly adds to the costs and so steadily reduces their involvement. Trade unions need to counterbalance the limitations of the consensus achieved in standardisation, where manufacturers are proactive to achieve the economic benefits gained by imposing technical solutions that reflect their know-how. On the other hand, trade unions play in an area where safety has been historically considered as in competition with productivity.

ETUI’s work on standardisation started by focusing on the horizontal fundamental safety standards (called "A" and "B" standards) drafted by CEN technical committees TC 114 and TC 122, with the aim of introducing health and safety concepts of trade union concern. Over the years, attention has turned towards specific vertical standards covering types of machine (called "C" standards). ETUI now wants to take stock of CEN’s technical work on machinery, and look at what impact A & B standards have had on the C-type standards.

At the same time, ETUI is developing a project whereby shop floor feedback on specific equipment is brought up to the standards setters who are drafting the specifications of that equipment. This worker knowledge is collected through a methodology, and complements manufacturers' know-how. The challenge for the future will be how to consolidate the top-down (influence on A & B standards by injecting health and safety at work concepts) and bottom-up (influence on technical specifications by feedback of shop floor experience) trade union approach.

ETUI aims to “go beyond” design: take the example of the interface between the risk assessment carried out by manufacturers, and the risk assessment carried out by employers integrating machinery in a specific working environment. Here the keyword is "interface": ETUI helps trade unions work with other experts in order to create a culture able to deal with such interfaces. The next step is to bring together the bottom-up and top-down knowledge flow, where safety and design condense in a safe by design culture.

Another essential element under trade union scrutiny is the accumulation of knowledge, where machinery evolves with innovation and technological developments; this involves maintenance of standards in a more open public debate.

Design of machinery is based on approximately 600 design specifications drafted by the European standards-making organisations CEN and CENELEC: trade unions need to set priorities before taking action.

The priorities will depend on a number of parameters, like the impact of the standards on the final design of machinery, the significance of the user interface, and the risk level associated with that interface.

Technical knowledge alone provides only a partial solution to taking real work needs into account. It needs to be supplemented by the input of ergonomic analyses of real work situations.

As governments leave it to standardisation to regulate public interests, they are responsible for the participation of public sphere representatives in standardisation.

By the same token, as governments leave it to CEN and CENELEC to interpret the Machinery Directive, facilitate trade, and set the state of the art directly affecting workers health and safety, they are responsible for participation by workers' representatives in standardisation. Standards must be informed by the lessons learned from the use of machinery designed according to them.

In a nutshell the ETUI’s expectations are:

1. A series of health and safety principles must be entrenched in horizontal standards;

2. A bottom-up strategy must be put to work, where a new method of working builds up knowledge that integrates the experience of workers and prevention practitioners;

3. Technological innovation must be reflected in standards in a timely and efficient manner; Consensus alone is not enough.