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Safety Case / Safety Justification: two titles but one meaning

Safety Case / Safety Justification: two titles but one meaning


Posted on Jun 03 Legal Tips Legal Tips, EAEU, and EAC

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Safety Case or Justification Safety we usually called JoS in shorted form. This document required to be provided by several technical regulations of the Eurasian Economic Union (EAEU) (former Customs union – CU) to be provided in order to receive a positive EAC certification decision and so to get the opportunity to export machinery and equipment to EAEU countries such as Russia, Belarus, Kazakhstan, Armenia and Kyrgyzstan. Here we will look over the main features of this documents and its meaning.



Safety Case or Justification Safety

Talking about JoS we should first of all note two main technical regulations of the Customs union (TR CU) that stipulate the obligation for equipment’s designer (manufacturer) to make this document: 

  1. TR CU 032 «On safety of the equipment operating under excessive pressure" (TR CU 032/2013)
  2. TR CU 010 «On safety of machinery and equipment» (TR CU 010/2011)

Both these TR CUs have references to JoS but TR CU 032 additionally has a reference to the standard that standardizes the JoS form – GOST 33855-2016 « Safety justification. Recommendations for preparation»

Let’s see the official definition of JoS according to this standard: 

Safety justification is a set of technical documents or a specially designed document used to confirm the safety of equipment and compliance with TR requirements.
In this case, the safety level is considered in regard to possible damage to human health, damage to property or negative changes in the environment (including fauna and flora) during the equipment operation. 

FAQ on JoS: 

WHEN IS THE JoS SHOULD BE DESIGNED (STAGE OF PRODUCTION)?

JoS should be prepared during the design phase of the equipment. We usually ask manufacturers to add a certain date to the JoS while signing it, so, this date should be in the period of equipment design.

WHAT ARE THE MAIN SECTIONS OF JoS? 

According to the standard the JoS should contain:

  • a general description of the equipment;
  • basic parameters and characteristics of equipment;
  • risk assessment;
  • proof of equipment compliance with the TR CU.

JoS also be allowed to include references to operational manuals, test reports, and other documents.

CAN THE MANUFACTURER PROVE THE SAFETY OF THE EQUIPMENT WITH A SET OF DESIGN DOCUMENTATION?

The definition of JoS says that equipment safety can be proved by a set of technical documents. On the other hand, there are additional requirements to the main JoS sections defined above in the GOST. In practice, expert organizations (certification laboratories and certification bodies) use to work with a separate JoS document elaborated by specialists who know this standard. Our team can elaborate the Jos for any equipment according to all requirements of the standard on the basis of operational documents, drawings, and test reports.

When applying with as a set of documents, it is recommended to include the table "List of documents justifying the safety of equipment" in one of the operational document (IOM, passport) with the designation and title of the relevant documents.

IS IT POSSIBLE TO ELABORATE JOS FOR SEVERAL MODELS?

If all the sections of JoS mentioned above can be true for several models then we can make one unified document that conforms the equipment safety. In other words, we can make JoS for a product type (family).
The main parameters and characteristics are to be given for the models and modifications of the equipment to which the JoS applies.

WHO CAN DESIGN THE JoS?

If the manufacturer cannot provide documents justifying safety to confirm the conformity of the imported equipment, then the document "Safety Justification" is developed by the importer (seller or person performing the functions of a foreign manufacturer – local representative – applicant ). 

In our practice, we face up the bureaucracy from the side of Russian plants and production companies that import different equipment and machinery. This attitude can be explained by strict control from the site of governmental authorizes under construction and operation. So, it is recommended to make the JoS taking into consideration GOST requirements and special notes (list of requirements to the technical documentation) from the buyer side if any.

WorldWideBridge team is always ready to consult you on this matter. Do not hesitate to contact our team.

You can also send your inquiry through [email protected]

Read more articles about the certification:

All you need to know about the Justification of Safety
How to get the EAC certificate for pumping equipment

By Viktoriia Artemenko
Head of Certification Department





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