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Regulatory Frameworks and Standards for Agricultural Robots: what is the state of art?
1. Regulatory Frameworks and Standards
for Agricultural Robotics:
what is the state of the art
10 December 2019
2. Page 2
Future of robotics
No fight
Merge
Big vs small tractor vs
robot
Robot vs
labour
automation Electrification
Intelligence
Optimisation
Adaptation
Flexibility
3. Page 3
Tractor type
approval
Machinery
Directive
Fit for purpose
Needs: legislation and standardisation
1. Terminology
and technical
requirements in
standards
2. New EHSR if
needed
transported
OPTIONS?
Virtual connection
Automotive type
approvalOther – cybersecurity / issue of trust
4. Page 4
Tractor type
approval
Machinery
Directive
Fit for purpose
Needs: legislation and standardisation
1. Terminology
and technical
requirements
2. New EHSR
if needed
Ethical framework
Conditions for risk assessment
Limited to the movement
A field is not a public area
Control: human vs machine
…
5 Levels of automated functions
linked to
Management of automated function
Controls for automated function
and
Supervisory System / Perception System
Requirements for perception systems
Requirements for …
…
Harmonised test methodologies
Collaboration global industry: EU, US, Japan
Looking for initiatives of / and collaboration with other sectors
5. Thank you!
CEMA Secretariat
T +32 (0)2 706 82 27
secretariat@cema-agri.org
Boulevard A. Reyers 80
B-1030 Brussels
www.cema-agri.org
6. THE MACHINERY DIRECTIVE 2006/42/EC
1993 1998 2006 20181989 2009
Machinery
Directive
89/392/EEC
Directive 93/68/EEC
(amendment to MD)
Machinery Directive
98/37/EEC
Machinery Directive
2006/42/EC
Directive 2009/127/EC
(amendment to MD)
Evaluation
Evaluation conclusions (SWD(2018)160)
more legal clarity in provisions and better coherence with wide EU framework is needed
relevant to digital technologies, but following aspects need to be further analysed:
more analysis for human-machine collaboration/coexistence in shared workspaces (AI) is needed
analysis on adding cybersecurity requirements
Revision steps
Open Public Consultation (OPC) launched in Jun-Aug. 2019, targeted consultations on-going
Impact Assessment study in support of the revision of the Machinery Directive to be completed in 2020
Commission proposal for a revised legislation on machinery foreseen in the first half of 2021 (subject to validation by new COM)
Revised
legislation on
machinery
2021
General Objectives of the Directive
1) Ensuring free movement of machinery within the internal market; and
2) Ensuring high level of protection for users and other exposed persons.
Since the amendment 2009/127/EC, the third objective has been added:
3) Ensuring the protection of environment in the context of using machinery for pesticide application.
Follows the EU new approach principles: mandatory Essential Health and Safety Requirements (EHSRs) and voluntary EN standards.
7. STANDARDISATION
Some standards relevant for robots cited in the OJEU under Directive 2006/42/EC:
• EN ISO 10218-1:2011 Robots and robotic devices — Safety requirements for industrial robots — Part 1:
Robots (ISO 10218-1:2011)
• EN ISO 10218-2:2011 Robots and robotic devices — Safety requirements for industrial robots — Part 2:
Robot systems and integration (ISO 10218-2:2011)
• EN ISO 13482:2014 Robots and robotic devices — Safety requirements for personal care robots (ISO
13482:2014)
• EN 50636-2-107:2015 Safety of household and similar appliances — Part 2-107: Particular requirements
for robotic battery powered electrical lawnmowers (IEC 60335-2-107:2012 Modified) EN 50636-2-
107:2015/A1:2018
A new standard, currently in the process of being cited in the OJEU under Directive 2006/42/EC:
• EN ISO 18497:2018 Agricultural machinery and tractors - Safety of highly automated agricultural
machines - Principles for design (ISO 18497:2018)
A new Commission standardisation request to CEN/CENELEC for Machinery is planned in 2020 (indicative).
8. Brief history of the OECD
Tractor Codes
– established in 1959 (inter-governmental
organization)
– 27 participating countries + Equivalence
with the European Union
– 30 Testing Stations worldwide
– 9 Codes – Performance (1), Noise (1),
ROPS (6) and FOPS (1)
– Over 3000 tractors models tested for
performance and more than 10800 tested
for noise levels and driver’s protection in
case of a roll-over or a falling object
hitting the protective structure.
What are the OECD Tractor
Codes?
The OECD Standard Codes for the
official testing of agricultural and
forestry tractors are a set of rules and
procedures for tractor testing with the
aim to facilitate trade by updating
international rules to certify tractors and
their protective structures.
Implementation of the Codes ensures
that protective structures and
performance criteria are carried out on a
comparative basis, thus increase
transparency, simplify international trade
procedures, and open markets.
https://www.oecd.org/agriculture/tractors/
9. How does it Work
2
New
Tractor
Report
Approval
Number
Manufacturer
Testing
Station
Coordinating
Centre
International
Markets
NDA
OECD
Secretariat
https://www.oecd.org/agriculture/tractors/
Advantages
• Global Certificate
• Global Network of
Testing Stations
• Fast Turnaround
• EU Equivalence
• Enhanced Credibility
and Fair Trade
• Operator Safety
• Constant Evolution
• New Markets
• Export Growth
10. Proposal for Agricultural Robots
– Develop a Unique Global System
– Mutual Recognition
– Credibility/trust (Clear responsibilities / to discuss feasibility of third party certification)
– Fast turnaround
– Develop common guidelines and/or standards and/or common regulation
– Focus on performance and safety
– Do not impose, but discuss with all relevant stakeholders
https://www.oecd.org/agriculture/tractors/
11. Robotics in North America| 2019.12.10
Mike Pankonin
AEM
FIRA 2019 Round Table, Labege France
12. US Liability Situation
US Liability Situation
• Consensus Standard
• “Bare Minimum”
• NOT “What is Required”
• No “Presumption of Conformity”
• Liability Exposure
• Court
• Jury
• Risk Assessment
• California Law
13. The California Experience
The California Experience
• Current Law on Automated Ag Eq.
• AEM Petition 65 and our proposal
• Results of the meeting
• Impact of Labor on the decision
14. Whats Next in California?
Automated Ag Equipment in CA
• Get conditional approval to operate Automated
Ag Machinery in California
• Title 8, Section 3441(b) only applies by workers
• Request a variance
• Applicable for all of the locations of the farm
• Each farmer would need to request such a variance
• Repeat our request a regulatory change
• Include Organized Labor
15. Regulatory Frameworks and Standards for the
Agricultural Robots
Australia
10 December FIRA 2019 – Toulouse France
Dr Rohan Rainbow – Managing Director - Director
16. Considerations for farm automation
• Australia is market ready!
• Few regulatory barriers for autonomy on-farm
• Large scale tractor autonomy is a key priority
• Challenges for autonomy of chemical application
• Australian government has a principle of reducing red-tape
and regulation
• Industry code of practice for field machine autonomy
development is underway
17. Fully Autonomous spraying a logical step - But challenges with regulations….
Autonomous weed spraying – Australia was first for camera sprays!
18. The Case for an Autonomy Code of Practice
• There is a clear need and opportunity for the Australian agricultural industry to
develop a Code of Practice for agricultural field machine autonomy
• Development of a Code of Practice will:
– Build confidence for commercial investment
– Build social confidence in its use
– Provide a clear argument reducing the need for overly prescriptive regulation
• Grain Producers Australia has agreed to proceed with the development of a
‘Code of Practice for Agricultural Field Machine Autonomy’
• To better support the commercial introduction of autonomous tractors and
machinery into Australian field based plant industries
• Does not include aerial, UAV’s, forestry or animals
19. Code of Practice would include:
• Safety and risk management processes
• Information, instruction, training and supervision
• General automation hazard control
• Farm planning and design for hazard control
• System planning and design for hazard control and functional safety
• Commissioning, operation and maintenance of hazard controls
• Emergency preparedness and management
• Incident reporting requirements
• Supporting legislative provisions
20. Code of Practice will include:
• Consideration of standards for agricultural field machine automation:
– ISO 18497:2018 Agricultural machinery and tractors -- Safety of highly automated agricultural
machines -- Principles for design ;
– ISO 25119-1:2018 Tractors and machinery for agriculture and forestry
– Programs of the AEF – Agricultural Industry Electronics Foundation
• Common glossary of terms for use under a Code of Practice
• Farm management autonomy project planning and implementation
• Introduction of Code of Practice to industry and government – June 2020
• Managing autonomous farming COP publications
– Farmsite specific risks
– Introduction into an existing farm operations
Come to the Australian market down under – we are ready!