By Mike Pankonin, AEM Senior Director of Safety and Product Leadership
Monitoring and understanding regulatory requirements can be a daunting task for any OEM. This is particularly challenging when dealing with international requirements and the various language and cultural differences that are implicit in international business. Often it is near to impossible to get accurate answers without discussing technical design nuances or application details with those knowledgeable in local requirements. Differences in time zones and the contextual nature of languages such as English further aggravates the challenges. As technology advances -- and equipment relies on advanced electronics or telecommunication -- it becomes even more difficult.
A recent example is the European Radio Equipment Directive or “RED.” The impact of this directive and the nuances of compliance were clarified in a position paper drafted by CEMA, the European Agricultural Machinery Association, titled “Application of Radio Equipment Directive 2014/53/EU with respect to agricultural machinery.”
The CEMA technical experts did an excellent job of distilling the very complex Radio Equipment Directive into a very understandable whitepaper, one which includes a graphic decision tree with supportive text describing the rational and reasoning behind the decision tree. This document provides excellent guidance when attempting to determine the regulatory requirements of radio equipment installed on machinery when introduced to the European marketplace.
This highlights one of the very enjoyable aspects of working in a trade association: the opportunity to coordinate activities with sister organizations. At AEM, we are very fortunate to have global partners with subject matter experts who are willing to facilitate and share their work that assists in safety and product leadership goals to:
- Promote the discipline and best practices concerning safe product design and use
- Maintain market access and remove trade barriers
- Allow for a common product suitable for multiple markets (a common platform)
- Leave “it” better than we found “it”
These partners include associations that focus on both agriculture and construction industries representing Europe, Asia, the Pacific-Rim, and South America.
These associations can leverage subject matter expert’s local knowledge to combine it with a global understanding of the marketplace. By developing guidance documents, they establish a common interpretation of local standard and regulatory requirements. This allows for improved market access to AEM members, who in turn provide their products to the global marketplace.
Some of these requirements can be difficult to interpret, and they are often understood differently depending upon the language and cultural references defining the paradigm of those doing the interpretation. By having local subject matter experts interpret a given requirement, we have a set of clearly defined requirements and a common understanding that can be applied regardless of the OEM’s primary business location or native language.
Another recent example includes a collaborative approach to the translation of the China non-road IV engine emission requirements (NR 4). In this instance, four associations, two in both North America and Europe, shared the cost to have the text of the Chinese regulation translated into English. This provides a common understanding for all stakeholders and reduces the cost of the translation by funding one translation were all participants share the cost, rather than four independent translations compounding the cost of translation and creating the opportunity for discrepancies and varying interpretations.
To take better advantage of local expertise, AEM members and staff participate in international meetings and report back to a larger group of AEM members in AEM committee meetings. One of the more popular international meetings that AEM participates in is the “Joint Technical Liaison Meeting” (JTLM). This is a meeting of seven international construction equipment trade associations, including:
During a typical JTLM meeting, association staff and member representatives present the technical and regulatory requirements which need to be considered when marketing in their respective countries or regions. In addition, participants typically have an opportunity to ask questions of the subject matter expert. One past participant commented, “Where else can I access such a large group of international experts simply for the price of attendance?” Several other members have commented that the JTLM meetings are among the most informative they participate in, and the JTLM minutes are those they most commonly reference throughout the year.
This year the JTLM will be hosted by CEMA of Japan as a virtual event beginning in July with on-line access through September. This will be the 31st annual Construction Equipment JTLM, and it will be the second one held virtually due to the lingering effects of the COVID-19 pandemic.
To summarize, by having regional subject matter experts provide guidance for the regulatory and standards requirements of their area, we enjoy the benefit of a common interpretation, defined by local subject matter experts. This in turn provides a common-global understanding of those requirements, resulting in improved access to markets throughout the world with fewer technical barriers to trade. Ultimately, the end result allows for manufacturers to produce the safest products possible, that meet regulations throughout the globe with a common product in the most sustainable manner, thereby leaving “it” better than we found “it.”
For more information, contact AEM’s Mike Pankonin at mpankonin@aem.org.
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