Digital systems in agriculture are nothing new, but now that they are moving rapidly into the sphere of automation and machine control, the EU is updating its legislation to address the safety aspect.
Consultation on the proposed revision of Machinery Directive 2006/42/EC is now underway. CEMA – European Agricultural Machinery Association – is naturally taking a keen interest in developments.
In its latest bulletin the trade body states:
“One of the main pillars for the revision of the Machinery Directive has been to ensure that new technologies, when they impact safety of the operator or potentially domestic animals, are well taken into account.”
Categories of digital technology
New technologies fall into three main categories. The first is ‘robots’ which are referred to as “autonomous mobile machinery”.
Although not stated directly this will no doubt encompass driverless tractors, as well as smaller machines built to carry out specific tasks, such as spot spraying.
The second is artificial intelligence (AI) and machine learning (ML). This has been deemed a separate area of concern, and new legislation is being drawn up to address the issue. It is likely to be published at the same time as the new Machinery Directive.
The third category is the ‘Internet of Things’ or IoT. What is of concern here is cybersecurity and the potential for corruption of a machine’s operating system to create a dangerous situation.
The EU places the safe operation of machinery above all other criteria, and it is this aspect which is most likely to cause headaches for companies wishing to place a product on the market.
As any manufacturer will point out, the paperwork involved in satisfying the competent authorities that a new machine is safe, is already burdensome. Adding software to the equation introduces a whole new dimension to the complexity of doing so.
This is spelled out by the European Agency for Safety and Health at Work which makes it clear that the responsibility of manufacturers includes ensuring that machines can be operated safely.
This requires a thorough risk assessment and certifying the conformity of their machinery to the provisions of the directive.
Risk assessment and certification include, not only the mechanical aspects of the machine, but also any software that controls it, and it is at this juncture that problems may well arise.
Digital problems ahead
In response to the proposed revision of the directive, Bosch has brought to the attention of the commission that software quality can only be assessed during its development.
The company notes that software and hardware have to be tested as one system, if any safety assessment is to be valid.
This may be a reasonable expectation for relatively simple advances such as the digital spot spraying system developed in conjunction with Amazone and BASF.
However, autonomous tractors or robots are a different kettle of fish altogether, especially as software is updated, either by developers or through machine learning.
Will each new update require a separate risk assessment? Does machine learning count as software updates, requiring a new round of certification each time? These are the sorts of questions that may well deflate the optimism currently driving in-field robotics.