Machine Safety Regulation In The Eu And The Us

Background This paper discusses the results of a study focusing on the differences of regulation around product safety, especially machines for use at work, between the European Union (EU) and the United States of America (US). Authors analyse how the differences effect on European companies manufacturing machines for use at work and what kind of compliance management practices the companies have to tackle the differing regulation. Methods The results of the study were gathered by literature review and interviews. The semi-structured interviews were conducted to representatives of six globally operating companies manufacturing machines for use at work and to representatives of organisations formulating and/or influencing EU legislation and standardisation. Results European integration has clarified the companies’ operations significantly within the EU. At present the legislation and standards on machinery are mostly harmonised. By contrast the European companies consider that US market is difficult because of the state-specific regulation and completely different framework to consider safety issues. Especially the costs of possible legal actions induce uncertainty. Conclusions The differing requirements between market areas may hinder export, and hence the globally operating machine manufacturing companies need tools and practices for recognising and applying safety requirements more effectively. In addition, the proposed Transatlantic Trade and Investment Partnership (TTIP) between the EU and the US can have significant effects on the field of requirements as well as the legislative framework in the future.