STANDARDS AWARENESS COUNCIL

The Standards Awareness Committee provides a focal point for leaders of all existing Farm Equipment Manufacturers Association Product Councils to discuss topics of common interest and share a common voice in promoting issues that affect the agricultural equipment industry. This Council meets twice each year, at the Association's Marketing & Distribution Convention and at the Supply Summit & Showcase. Anyone is welcome to attend.
Staff from the American Society of Agricultural and Biological Engineers (ASABE) will attend the meetings to answer your questions and provide updates.
For more information, contact:
Chairman: John Fisher, Alamo Group Agricultural Division
Email: jfisher@alamo-group.com
* “Permission is granted by the American National Standards Institute (ANSI) to electronically reproduce draft International Standards for purpose of review and comment related to the preparation of the U.S. position, provided this notice is included. All other rights are reserved.”
X619.1 Safety for Tractor Mounted, Boom Type Post Hole Diggers; Revise and update Normative references. FEMA members have expressed comments that the revision adds unnecessary requirements and have voted against the revision. Eric Smith has made corrective resolutions and revised the standard to address the FEMA members concerns.
Proposed Standard is available for review on FEMA-Standard update web page. Send comments to John Fisher before March 30.
Upcoming ISO ballots.
1) ISO/CD 22494, Disk plough - specifications and test method
2) ISO/CD 22495, Chisel plough specifications and test method
Proposed Standards are available for review on FEMA-Standard update web page. Send comments to John Fisher before March 15.
X583.2 Safety for Agricultural Front Loaders ; Update references, update the scope to match the updated reference terms; add a definition for quick attach loader and make the usage of “attachment” and “allowable attachment” consistent.
Review ISO 4254-18 forage wagons. ISO CD draft comments are due 3/4/19. US will probable disapprove with many comments. US comments so far embedded below.
Template for comments and secretariat observations
Date:2019-02-21
Document: ISO/CD 4254-18
Project: MS-03/2 comments
MB/
NC1Line number
Clause/
SubclauseParagraph/
Figure/TableType of comment2
Comments
Proposed change
Observations of the secretariat
001
GE
Issues from WD were not all addressed
Comments provided below are in addition to WD
002
ge
Need better document information regarding ISO 4254-1:2013 (file was corrupt) unable to view details.
An ASABE standard covering some or all of the following: front unload, rear unload, and 2-way unloading forage boxes along with Combination boxes (able to handle multiple commodities) both mechanically and hydraulically driven with various styles of tailgates. Vote no on this proposal.
ge
The scope of the standard on loader wagons and forage wagons is too large and it places restrictions on many North American products that do not improve the safety of the product.
ge
The draft standard as proposed is crafted based upon a specific regional style of forage handling and conveying equipment, and yet its scope is broadly defined to apply to types and styles of equipment manufactured and used throughout the world. This makes the application of the standard requirements ambiguous at best, and non-applicable at worst. Detailed comments from US manufacturers of forage conveying equipment have pointed out numerous specific instances of this application difficulty, which I certainly would echo after a review of these details. I question the feasibility of being able to sufficiently modify this draft in order to make compliance attainable by US manufacturers and still contain sufficient Type C standard specificity to justify it's incorporation as an international standard
ge
This standard is overly restrictive to the design and use of the simpler, non-self-loading wagons. It must provide provisions for this type of forage wagon or scope restricted to the self-loading wagons only.
003
01
1-5
ge
This scope is too large. The Scope encompasses a large set of products within the “forage transport wagons” that US manufacturers build, but were not looked at when this standard was designed.
Limit this to only “trailed loader wagons” or request further review and input from North American forage transport manufacturers on a standard better fit for North American Forage Wagons.
004
01
2
te
Clarification of “loader wagons and forage transport wagons with discharge other than at the rear of the machine” to better understand why boxes that unload out of both the front and the rear are different than just rear unloading boxes.
Clarify this exemption
005
03.02
1
te
Clarification of “. . . filled from the top from outside the machine” to better understand why forage transport wagons with roofs would be any different.
Clarify this definition.
006
03.07
1
Te
If front unloads are included in this standard, conveyors would be confused with a front unloading conveyor
Potential clarification based on scope changes
007
04
All sub-headings
ge
Corresponding ISO documents should be included for further review. Unable to access referenced ISO documents to provide comments on.
Provide further information regarding these referenced standards.
008
04.02
1-2
te
Most all manual controls on equipment today for front unload boxes would not be able to meet this standard
Front unload boxes, if included in this standard, would need to be exempt or the measurements would need to be redefined to be practical with current machinery.
009
04.03
1-2
te
Current US standards do not require a device to be provided to secure the machine against rolling away. How does this affect all equipment in the US? Need further detail from referenced ISO standard
Remove requirement
010
04.05.2
Figure 4
ed
Item 2, Lateral barrier is included in the index and called out in 4.5.2, but is not labelled in Figure 4a or 4b. From Context, it is the item(s) with the 150mm measurement
Label the Lateral Barrier(s) in Figure 4
011
04.05.2
Paragraph 2
ed
“If the height h is < 500 mm, a distance of at least 100 mm has to be kept (see Figure 4b).”
Front barrier distances are discussed for >500mm and <500mm, but not for =500mm. From Figure 4b, it should be >500mm and ≤500mm measurement
If the height h is ≤ 500 mm, a distance of at least 100 mm has to be kept (see Figure 4b).
012
04.07
All sub-headings
ge
We have been in business for 75 years with these types of products, and 67 years’ experience with products that have live floor chains. There has been no known or recorded incidence of injury due to operator error, incompetence or fatigue. There is also no known or recorded mechanical failure resulting in injury in conjunction with our Forage Wagons. Fixed guarding can be viewed by operators as a nuisance, and then removed in the field. This is an unnecessary regulation which would limit various rear attachment functions. Material build-up causing mechanical failure, rot, and decay. No proven results that show the extra rear guarding will prevent injury from operation of this machinery.
Unnecessary regulation. Remove until further research on US farm equipment has been understood and then propose if regulation is necessary.
Allow for accessible shielding to perform general maintenance. Allow for a wider range of distances from moveable components to fixed parts.
US 013
04.07.1.1.2
2/ figure 8
GE
Protection from the moving path of the conveyor only considers protection by spacing the conveyor away from fixed parts of the machine. It also mentions conveyor to be shall be covered on the sides over the entire length. It seems there are effective other methods in use today to protect this area. For instance if the side cover extends a certain distance (i.e. 100mm) below the conveyor then the guarding of the area is sufficient w/o the spacing of the conveyor to the fixed portion of the machine
Add in additional acceptable guarding options to this section
014
04.07.1.1.4
2
te
This part of the standard does not take into consideration rear attachment options like grain kits or combination box attachments for spreading manure.
Review standard to accommodate rear attachments used within the industry.
015
04.07.1.1.4
3
te
This guarding would inhibit rear unloading operation of forage without damage to this type of safety shielding
Remove requirement
016
04.07.1.2
1-2
te
If this standard included boxes that were both front and rear unloads, then the chain tightener would be under the box in order to tighten. It is more complex than standard front unload or standard rear unload box.
Remove/Modify requirement.
017
04.11.02
1-5
te
This seems to be regarding the part of the standard for equipment with a pick-up device. Would be confused with front unloading boxes.
Clarify
TH 018
04.12
TE
Move the references and redundancies of 4254-1 to the section on closing 4.12.3
The 0.5m/s speed for opening and closing is very slow. The average speed for a person walking is approximately 1.5m/s. Why should the door have to move at a fraction of the speed of a person walking into a stationary object? Also the closing speed should apply to all gates as a benchmark maximum speed for gate movement.
Restructure the requirements so that the closing of the gate needs to meet at least one of the following:
Closing force, or
The requirements of section 4.11 of 4254-1 (2013)
So that the requirements can apply to the different types of gates and provide a similar level of safety in those situations
Utilize to the supporting requirements of 4254-1. This requires that the gate have a locking mechanism that can be activated outside of the hazard zone to prevent unintended lowering of the gate.
The visibility does not offer the same level of protection as the supports or the reduced closing force. The visibility depends on the operator seeing the person in the hazard zone. The supports can be activated by the person before entering the hazard zone and are in line with 4254-1 and other safety standards.
Add a line in the closing force section about even in the case of a failure. If the unit has a barn door style rear door, then locks may not be practical and they can meet the closing force requirement.
The arbitrary time of 10 seconds for closing is lengthy and seemingly baseless and the audible alarm is unnecessary for the application. Follow the abovementioned requirements of 4.11 of 4254-1
Replace section 4.12 with the following:
4.12 Opening and closing of the rear discharge gate
4.12.1 General
The machine shall be designed to avoid:
— impact hazards at the opening of the discharge gate, and
— crushing or shearing hazards at the closing of the discharge gate.
If a control for operating the discharge gate is not part of the tractor (i.e. an integral part of the trailer or a remote), it shall be a hold-to-run control.
Remaining residual risks at opening and closing of the discharge gate shall be identified by safety signs at the discharge gate and indicated by warnings in the operator's manual.
4.12.2 Opening
To avoid impacts of the rear discharge gate with a bystander, the maximum opening speed of the discharge gate shall not exceed 1,5m/s (or even 1,0m/s?).
Verification: The speed shall be measured at the lower edge of the discharge gate and for a pivoting gate, at the point furthest from the pivot.
4.12.3 Closing
The maximum speed at closing of the discharge gate shall not exceed 1.5m/s (or even 1m/s?).
Verification: The speed shall be measured at the lower edge of the discharge gate and for a pivoting gate, at the point furthest from the pivot.
The gate shall also meet at least one of 4.12.3.1 or 4.12.3.2
4.12.3.1 Supports or stops
The gate shall have supports meeting the requirements in 4.11 of 4254-1 (2013) to prevent inadvertent lowering. Endangering persons in the hazard zone between the discharge gate and platform of the load body shall be prevented in case of a leakage / hose breakage, i.e. by means of a hydraulic lock valve or hose breakage protection.
Verification: by functional test.
4.12.3.2 Closing force
Within area B of Figure 15:
— the closing force shall not exceed 250 N, even in case of failure; and
— to allow a trapped person to escape the closing discharge gate, the counter-force required to manually open the discharge gate shall not exceed 250 N.
Verification:
The closing force shall be measured at the lower edge of the discharge gate and for a pivoting gate, at the point furthest from the pivot. The measurement shall be taken when the gap between the measurement point and the body floor is 620 mm.
019
04.12
1-3
ge
Speed of tailgate closure is part of our product design in both performance and function that would need further analysis of the stated regulation. Does not include other rear door styles. (i.e. barn style doors, hydraulically controlled swing and guillotine style gates) No known recorded incidence of injury due to rear gate operation. This allows the operator to safely close the gate from the seat of the tractor or truck.
Unnecessary regulation
Remove requirement.
020
04.12.02
1-3
te
We currently have a patented gate closing system which is operated using gravity and assisted using hydraulics. We would need further understanding of “appropriately visible”. This regulation may take away our current competitive advantage for our products. This may inhibit our mechanical latching system that we currently have in place and may need to be replaced with a more complex system.
Unnecessary regulation
Remove requirement.
021
04.12.03.3
1-2
ge
With the weight of our rear door that has been designed for the rigors of the field and is heavy. This regulation would be very tough if not impossible to meet both a strength requirement while meeting this closing force regulation.
Unnecessary regulation
Remove requirement.
US 022
04.12.03.4
3
GE
This section now covers barn doors and it indicates an audible alarm is required. Today no boxes in the US have audible alarms for the doors and there are no issues. Additionally, if visibility is considered adequate the need for an audible alarm should be eliminated. Additionally see below, the closing time proposed is much too long. If the time is reduced to a more reasonable time the audible alarm will not be effective.
Change requirement to eliminate the audible alarm as a “shall be provided”.
US 023
04.12.03.4
4
GE
This section indicates the time for closing to be 10s. This time is too long, to the point where it is foreseeable the customer base will figure out how to override to make it faster. Currently we make 36’ boxes that can unload the entire box in less than 1 min. Unload speed is important for this market and sitting after the load is unloaded to wait an additional 10s for the doors to close isn’t going to be acceptable. When reading this section I think about products that have rear gates, like round balers. As with those products there is no way a customer is going to accept an extended closing time.
Reduce time to an acceptable level, 1s.
024
04.14
1
ge
Need further information regarding referenced standard
Provide further information regarding these referenced standards.
025
04.15
4
ge
We currently mount boxes to gears in a way that allows the box to move freely vertically, but not horizontally. This is common in the forage box industry. Hard mounting may cause structural damage to machinery in the field that may result in failures during transportation which may be on public roadways.
Unnecessary regulation
Remove requirement.
TH 026
06.01
D
ED
The wording “only be possible” is not an achievable task for an operator’s manual.
Replace “only be possible” with the phrase “only be allowed”
TH 027
06.01
F
ED
This clause does not make sense. It suggests that the person should get out from under the machine when the conveyor is turned on. In fact, they should not be there when it is activated.
Replace the content of (f) with the following:
Do not operate the conveyor until all people are clear of the machine.
TH 028
06.03
ED
“the spreading” does not seem to make sense.
Add the word “device’ after spreading
029
B.2
1
ge
Is this with or without load? Need to review how visibility, if needed, would be handled with a load present.
Remove requirement, or needs clarification
Comments 4254-18 CMeyer 2-18-19.doc: Collation successful
Comments_4254-18_TH FEB2019.doc: Collation successful
ISO4254-18 CD comments HS Mfg.doc: Collation successful
ISO4254-18 MDilts 21FEB19.doc: Collation successful
Collation of files was successful. Number of collated files: 4
SELECTED (number of files): 4
PASSED TEST (number of files conformed to CCT table model): 4
FAILED TEST (number of files conformed to CCT table model): 0
CCT - Version 2018.2
ASABE S639.2 Safety Standard for Large Row Crop Flail Mowers; Standard Revised Normative References and was Published 2-7-2019
X431.4, 2000-RPM Front and Mid PTO for Lawn and Garden Ride-on Tractors; Expand the scope to include compact utility tractors. References will be updated and definitions added. 2nd Ballot vote is open and due February 23. Proposed Standard is available for review on FEMA-Standard update web page. Send comments to John Fisher before February 23.
ISO5673-1PTO drivelines European proposal to require implement input gearbox shafts to be splined. USA and ASABE opposes this proposal. No action taken by the ISO committee at this time.


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