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Setting The Standard…
A response from The Baby Products Association to the open letter from Carol Ainge

Referring to Carol Ainge’s comments on Safety Gates in Ni Opinion in the March issue we feel a fuller account should be given.

Firstly, Standards Committee Meetings for BSI (British Standards Institute), CEN (European Committee for Standardisation) and ISO (International Organisation for Standardisation) are made up of experts from all sectors of the industry. These include; child safety experts from consumer associations, manufacturers, test laboratories, specialist consultancies, trade associations and specialist organisations.

Obviously BSI is concerned with British Standards (prefix BS) but also the harmonisation and interpretation of European Standards (prefix BS EN). European Standards (EN) are the province of CEN Committees. For an expert to represent their country on a CEN Committee they must first be on the local standards institute’s committees e.g. BSI in the UK. There are some pan European organisations however that also sit on CEN Committees.

The CEN mission is to foster the European economy in global trading and promote the welfare of European citizens and the environment. Through its services, it provides a platform for the development of standards and other technical specifications. The Members work together to develop voluntary European Standards (ENs) in various sectors to build a European Single Market for goods and services and to position Europe in the global economy. More than 60,000 technical experts, as well as business federations, consumer and other societal interest organisations, are involved in the CEN network that reaches over 460 million people.

The process of setting standards is an iterative procedure. Each country discusses the standard at the local level and puts forward their requirements for change and amendment. This goes to the CEN Committee where the 37 National and Associate member countries discuss the changes and requirements of all the EC countries’ input. Throughout a three-year process of review a new standard will emerge.

The Committees themselves may consist essentially of elected representatives who are the experts in their field and the meetings may therefore be held in camera but the process is far from closed. Could you imagine a situation where the standards setting committees in Europe were open to the general public? There would be chaos! Managing the needs and inputs of all the EC countries is hard enough when they are knowledgeable and familiar with the process, managing an open debate with people all working from different agenda and with less experience or knowledge of the products, market or the process would be impossible.

Returning to the process; any member of the public can submit their query, comment, opinion or statement to BSI for inclusion on the relevant committee’s agenda. This will then be discussed and if appropriate passed on to the relevant CEN committee for inclusion in that agenda for the next meeting. Ms Ainge has been made aware of this process by ourselves, we have even offered to submit her queries via the proper channels on her behalf.

The point that Ms Ainge has mentioned in her letter to Ni has been discussed many times over many years and has been championed by one particular manufacturer who already has representation on the appropriate CEN committee and believes all safety gates should have "screw fixed" wall cups and no others should be permitted. The same manufacturer does only supply such product. The EC member states have discussed this subject at committee level and agreed that packaging should identify when and how wall cups should be fitted and whether they should be fixed by screws or aggressive adhesive.

If it is still felt that this is inadequate then further representation can be made to the committees to request change that meets the consensus view of all of the EC.

Why is it done this way?

To ensure that all products sold in the EC conform to a standard that ensures a level of safety for all. This process also provides a level playing field for all suppliers in as much that the investment required for compliance will be required from all suppliers. It provides a standard to which consumers can attach some comfort and provides the enforcement authorities with a benchmark with which to measure and ban non compliant product.

We said earlier it is an iterative process and standards are often immediately referred back for review and amendment as soon as they are issued. The various meetings and discussions that take place in the review process usually means a revised standard will emerge towards the end of a further three year cycle.

Clearly this process is a slow and deliberate one and it has certainly become more difficult and cumbersome to introduce changes to standards since the enlargement of the EC but where would we be if in each country any person or organisation with a particular axe to grind initiates a forum and attempts to petition the committee?

I think Ms Ainge found that to get ‘one voice’ on this subject is not as easy as it seems because frankly when things are a matter of opinion it’s hard to reach a consensus. Any Convenor of any of the CEN Committees will tell you that. The standards are created as part of a healthy debate and discussion of hundreds of opinions and views from all over the EC. Ms Ainge and her associates view is just one of many and by putting them through the proper channels they too will get the airing they are seeking.

The current Safety Barrier standard (BS EN 1930) is under revision and many of the points raised by Ms Ainge have been addressed. A copy of this revised standard will be made available as a DPC (Draft for public comment) in the near future which will allow comments/opinions to be made directly to BSI before the standard is published.

Peter White
BPA


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