The development, implementation and compliance of standards and regulations affecting equipment manufacturers is one of AEM's greatest priorities.

AEM's Technical and Safety Department works diligently to identify, influence and communicate worldwide standards, regulatory developments and compliance issues on behalf of its member companies, all while advocating for the safe operation of heavy equipment.

"Do it once, do it right, do it globally" is the department's motto. With that in mind, here are seven standards and regulations AEM’s Technical and Safety Department says the association’s members should keep an eye on in 2018:

OSHA’s Crystalline Silica Standard for Construction

The regulations concerning Crystalline Silica Standards for construction are being enforced as of Sept. 23, 2017, with the general industry and maritime provisions being enforced beginning June 23, 2018. The regulation includes a table of prescriptive exposure controls to minimize employee exposure. 

Employers who choose the specified exposure controls option must fully and properly implement protections for the tasks or equipment listed in Table 1 (see below) of the standard. Employers who fully and properly implement the controls in Table 1 do not have to assess employees’ silica exposure levels or keep employee exposures at or below the permissible exposure limit (PEL). 

OSHA

Employers who follow alternative exposure control methods must:

  • Determine the levels of respirable crystalline silica that employees are exposed to
  • Limit employee exposures to a PEL of 50 micrograms per cubic meter of air (50 μg/m3) as an 8-hour time-weighted average (TWA)
  • Use engineering and work practice controls, to the extent feasible, to limit employee exposures to the PEL, and supplement the controls with respiratory protection when necessary
  • Keep records of employee exposure to respirable crystalline silica      

The defined PEL is 50 micrograms per cubic meter, however, action is required at the level of 25 micrograms per cubic meter of air (25 μg/m3) as an 8-hour time-weighted average (TWA).

While this regulation is directed at employers, not equipment manufacturers, equipment manufacturers will be indirectly impacted due to employer demands for equipment that facilitates compliance to the regulation. 

OSHA has recently released a number of new fact sheets providing guidance for specific machine forms and tasks. The new releases increase the number of documents to 29 and are available at https://www.osha.gov

California Prop 65 Requirements

The California Proposition 65 regulation is a Right-to-Know law requiring public notice, prior to exposure or purchase, of the possible hazard due to exposure to a large and growing list of materials deemed by the State of California to cause cancer, birth defects or reproductive harm. It does not outlaw those materials for use. Beginning Aug. 30, 2018, regulatory changes clarifying “occupational exposure” will bring many AEM products, including spare parts, into scope.

AEM recently hosted a webinar concerning Prop 65, which is available to be download for free at https://www.aem.org/safety-and-technical/regulatory/proposition-65/.

China Non-Road IV

China's Ministry of Environmental Protection (MEP) is currently in the process of drafting their next engine emission regulation for diesel engines in non-road mobile machinery titled China Non-Road IV (NR IV).

Chinese regulators are taking into consideration many new ideas and technical solutions in an attempt to ensure that the future non-road IV regulation is not only highly aligned with EU/EPA non-road regulations, but also as stringent and advanced as is necessary.

AEM China has long been involved with the China’s emission regulation development process for the non-road industry sectors. The association is collaborating with the China Internal Combustion Engine Industry Association (CICEIA), the Truck & Engine Manufacturers Association (EMA) and the European Association of Internal Combustion Engine Manufacturers (EUROMOT) to provide technical comments to China’s MEP as they draft the new regulation. The work included two China Non-Road Emissions Workshops held in Beijing, where the regulatory bodies met with AEM China, EMA, EUROMOT and other stakeholders to discuss the draft regulation’s content. The second of the two workshops was held on Jan. 30 of this year, and offered an opportunity for those present to communicate a wealth of feedback to MEP regulators regarding the yet-to-be-released draft.

The final draft was formally released for public comment on Feb. 24 and was translated into English by AEM China with appendices translated by EMA. These documents have been circulated for review and comment. Comments have been collected and consolidated into a joint AEM China, EMA and EUROMOT submission due March 31. After several meetings to review and refine the consolidated comments, they were translated into Chinese. Both the English and Chinese versions will be submitted March 31 to the Chinese MEP for consideration.

Topics of most significance include:

  • Implementation date
  • Requirements concerning PEMS (Portable Emissions Measurement System) testing
  • Definition of responsible entities (equipment manufacturers versus engine manufacturers)
  • Handling of confidential intellectual property
  • Application of particle number (PN) limits
  • Mandatory warranty duration
  • Requirements for engines greater than 560 kw
  • Distinction of stationary engines and non-road mobile machinery

Ontario Tire RequirementsOntario’s New Tire Recycling Requirements

Canada’s province of Ontario recently announced its decision to implement a law placing significant obligations on companies to dispose of used tires throughout a product’s lifecycle.

AEM members who sell, distribute or manufacture tires in Ontario will be greatly affected, as will those who sell, distribute or manufacture products using tires in the province.

The Resource Recovery and Circular Economy Act of 2016 establishes “producer” responsibility for diverting spent tires from the waste stream. In a move unique to the province of Ontario, the law places the burden on manufacturers to account for the recycling of every tire at the end of its lifecycle.

The law will take effect on Jan. 1, 2019.

Companies can fulfill the obligations on their own, or they can use a Producer Responsibility Organization (PRO) to manage tracking, collection, recycling and government reporting requirements. Several industry PROs are forming to help companies fulfill the law’s forthcoming requirements.

AEM strongly advises all member companies doing business in Ontario to consider working with a PRO. Failing to comply with the new law will result in fines and a possible sales ban.

Vacuum and Sewer Equipment Standard

AEM's UEMC (Underground Equipment Manufacturers Committee) created an ad-hoc group to build a standard for vacuum and sewer equipment in 2015. This original ad-hoc group, chaired by Susan Harmon of Charles Machine Works, has been hard at work developing a standard for these two product lines. The ad-hoc group, originally comprised of AEM members, also reached out to the vacuum excavator industry and the sewer equipment industry to recruit volunteers to participate in the SAE MTCS9a Vacuum Excavation and Sewer Equipment standards development group.

With the assistance of AEM's John Somers and the AEM Vacuum and Sewer Equipment Leadership Group, 39 industry individuals representing 21 equipment manufacturers were recruited to participate in building these standards through the SAE International process. 

The first standard, J3106 – Vacuum Excavation and Sewer Cleaning Equipment – Classification and Nomenclature, has been drafted and sent to SAE for ballot. The MTCS9a committee has responded to all comments from this ballot and is now ready to send through the SAE channels for approval.

The second part of MTCS9a’s committee work is reaching completion on the second standard, J3107 – Vacuum Excavation and Sewer Cleaning Equipment – Safety Requirements, to be sent to SAE for ballot and comments. J3107 should reach the SAE members for their review in 2018.

The MTCS9a Committee has worked diligently through numerous emails, web ex conference calls and face-to-face meetings to build an industry standard with the sole purpose of creating a safer vacuum and sewer equipment industries with standards that provide guidance and best practices that everyone can use and support.

National Agricultural Machinery Illumination Safety Act (AMISA)

An AEM committee recently developed an Illustrative Guide to the ASABE S279.17 standard, upon which the National Agricultural Machinery Illumination Safety Act is based. (This Act became law on July 6, 2012 and impacts agricultural equipment produced new after June 22, 2017.)

AEM’s committee members worked diligently to translate the standard into pictures that quickly and efficiently convey the standard’s requirements. This guide provides a visual representation of the content of the Lighting and Marking Standard and will be considered by ASABE for inclusion as an annex to the formal standard.

AEM’s Illustrated Guide to Ag Lighting and Marking is available to be downloaded for free at https://shop.aem.org/en/AEM%20Safety/aem-safety-products/lighting-and-marking-of-agricultural-equipment-on-highways-guide/

ASABE S365.9 Braking Standard Update

Over the past several years, AEM Technical Committee experts have invested countless hours on a proposal to update the ASABE S365.9 Braking Standard. Their efforts have resulted in a five-part proposal that was recently turned over to the ASABE Braking committee. The much-needed proposal includes braking requirements for tractors, self-propelled machinery and implements, and it is expected to move forward as a single body of work, known as ASABE X648:

  • ASABE X648-1: General Requirements
  • ASABE X648-2: Requirements for Agricultural Tractors
  • ASABE X648-3: Requirements for Self-Propelled and Special Self-Propelled Equipment
  • ASABE X648-4: Requirements for Towed Equipment
  • ASABE X648-5: Requirements for the Interface Between Towing Equipment and Towed Equipment

These proposals are intended to provide guidance for enhanced braking systems required due to the increased demands (i.e. increased speed and increased mass) that current equipment designs and industry practices are placing on ag equipment braking systems. This project is now going through the necessary steps in the ASABE process, which included a review of the proposal presented to the ASABE MS-03 committee this past February.

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