SICK AG
SICK
Hersteller von Sensoren im Bereich Industrie- Logistik- und Fabrikautomation, insbesondere Sicherheitsbauteile nach Maschinenrichtlinie.
ID: 27481463425-10
Lobbying Activity
Meeting with René Repasi (Member of the European Parliament)
30 Mar 2022 · Maschinenprodukteverordnung
Response to Standardisation Strategy
5 Aug 2021
We are concerned about the emerging of standardization replacements through the empowerment to issue Technical Specifications in the future as proposed in 1025/2012/EU Standardisation Act and the current revision of the EU Blue Guide. It must be seriously doubted if a Technical Specification issued by the commission and drafted by consulting companies can reflect the state of the art better than a standard developed as a result of consensus of experts representing all stakeholders in a transparent process.
It is still important that the industry is involved in the whole standardization process as well in the process that relates standard in regulations (listing in OJEU), since industry is where the essential product, applications and innovations knowledge is present.
Furthermore, instead of adding new obstacles in the standardization process, the EU Commission shall ensure that the respective national authorities (e.g. occupational safety and health authorities, market surveillance, consumer protection, etc.) are actively involved in the international standardisation process right from the start. The European standardisation organisations are not intended and shall not be misused to merely implement the decisions of the Commission. The European commission shall also ensure a better implementation of the Vienna and Frankfurt agreement by CEN and CENELEC and adapting the formal listing procedures to the standardizing processes of ISO and IEC.
Nevertheless, all these possible improvements of the standardization policies are meaningless when the concerned EU regulations do not take the state of the art reflected in the standards, into account. As an example, EN 60825-1:2014 “Safety of laser products - Part 1: Equipment classification and requirements”, which represents the state-of-the-art and science, states limits for optical radiation that have not been adopted into the concerned EU directive AORD (2006/25/EC). Meanwhile EN 60825-1:2014 has been harmonized under the LVD (2014/35/EU). Thus a product according the LVD cannot be used according to 2006/25/EC. Such an inconsistency cannot be solved by standardisation but by the Commission and the European Parliament.
Read full responseResponse to Revision of the Machinery Directive
5 Aug 2021
SICK AG welcomes the revision of the European Machinery Directive and the opportunity to provide feedback for important improvements to the MD. The current MD has not been revised since the NLF and therefore requires many alignments.
Refering to Article 5 of the proposal SICK AG recommends retaining the proven conformity assessment procedure from the current version of the Machinery Directive 2006/42/EC or continuing to allow the option of internal production control for "HIGH-RISK MACHINERY PRODUCTS" as well. The proposed regulation does not provide clarity in the process of the definition of High-Risk-Products and will lead to arbitrary decisions and legal uncertainty.
A mandatory third party assessment, irrespective of the availability of harmonized standards, is inappropriate and undermines the European standardization. We are in deep sorrow that the proposed regulation relies too much in the judgements of third parties especially considering their failures in the recent past.
The goal must be equal treatment of the various economic operators. Software (including AI) that is placed on the market separately must not be treated differently (third party obligation) than software (including AI) that is placed on the market together with an installation by the manufacturer of the machine and offers the possibility of conformity assessment with internal production control.
AI applications will significantly improve production and therefore increasingly used outside countries in which the legal requirements for AI applications are not disproportionate. This is a considerable risk that jobs in the manufacturing industry will move outside EU countries.
SICK AG welcomes the proposal of the EU Commission to regulate cybersecurity with the horizontal Regulation (EU) 2019/881. Nevertheless the related requirements in the draft machinery regulation are ambiguous and require urgent redrafting.
Furthermore, SICK AG supports the proposal of the EU Commission to make operating instructions available in digital form.
Read full responseResponse to Requirements for Artificial Intelligence
22 Jul 2021
The proposed regulation is a welcome initiative but needs significant improvement in some details to be applicable in practice to the cases for which it is intended.
SICK AG urgently recommends the deletion of the "Bayesian estimation" from the ANNEX I (Paragraph C).
Bayesian techniques are not artificial intelligence, but well-proven mathematical formulas. These methods are well established in several applications in the machinery sector. For these mathematical methods the proposed requirements are unreasonable and will lead to excessive costs and to disadvantages for the European mechanical engineering industry.
Bayesian techniques are deterministic and do not require any training (e.g. machine learning), unlike the AI techniques from Annex I (a) and (b).
Therefore the requirements for transparency ("sufficiently transparent") as well as for the behavior of the output as stated in Article 13 (paragraph 1) are not applicable for Bayesian methods.
Article 10 Data and data governance/ Paragraph 3: "free of errors and complete.
SICK AG urgently recommends the deletion of the point "free of errors and complete" from the Article 10. Absolute freedom from errors and completeness of the data obtained is not possible. The risk management measures from Article 9 (4) already take into account the residual risk sufficiently and thus also the occurrence of errors and natural statistical coverage (completeness).
Read full responseMeeting with Günther Oettinger (Commissioner)
26 Feb 2016 · digitisation