Cableways Impact Assessment Study - Final Report - saferail.nl

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IA Study Concerning the Revision of the Cableways Directive safety components (i.e. a list that is not legally binding) and this appears to be working well as there have been no major discussions/disagreements on this issue in the past two to three years. A similar point was also made by a notified body. In addition, it is possible that some of these problems may have been caused by insufficient expertise and experience in some Member States, thus suggesting that solutions based on guidance may be sufficient in assisting stakeholders in these Member States. The Slovenian national authority noted that for people with sufficient expertise in the cableways sector these issues do not pose problems but could be a problem for authorities which do not have a lot of experience. However, the Slovenian national authority also noted that the explanations given in the Application Guide are not always unambiguous. Similarly, an Austrian notified body stated that these definitions are clear to all notified bodies that are active with regard to assessing cableway products (as opposed to bodies which hold a valid notification for the Cableways Directive but rarely approve any products). Summary of Stakeholder Views As noted in Table 4.4, in the first round of consultation most national authorities (15 of 22) and notified bodies (3 of 5) that responded to consultation agreed that it is necessary to introduce a non-exhaustive list of safety components in the Directive in order to clarify the differences between safety components and subsystems. However, from the second round of consultation it is evident that stakeholders hold a wide variety of views on how problems with the relevant terms could be solved. Importantly, the wide variety of views does not make it possible to identify one option that would be preferred by all stakeholders. However, the following general observations can be made on the basis of the information provided: all but one competent authority that expressed an opinion (12 of 13) would support some kind of change (either under Option C2 or C3); and a number of stakeholders, in particular cableway manufacturers, fear that Option C3A (inclusion of a non-exhaustive list of safety components in the Directive) may limit manufacturers’ flexibility. Several manufacturers are also opposed to Option C3 in general. As regards competent authorities, notified bodies and manufacturers, those stakeholders that expressed support for Option C2 do so because it permits the creation of a non-exhaustive list which could be updated and amended when necessary in the Application Guide. Also, Option C2 is preferred by some stakeholders because Option C3 (particularly Option C3A) is thought to be too rigid, prescriptive and inflexible. Some respondents also consider that Option C3 is not feasible, would be counterproductive and would limit the flexibility, innovation and research and development activities of manufacturers. However, those respondents who support Option C3 do so because it is a more sensible approach from a regulatory viewpoint which would ensure that all explanations are located within one document which would avoid the potential for confusion. Furthermore, there are some Page 102
Risk & Policy Analysts respondents who consider that both Options C2 and C3 could be harmful and that neither would have any beneficial impacts for the industry. This is because the current regulations are considered sufficient and because the authorities are not aware of any issues with regards to this specific problem area. In addition, the majority of cableways operators associations consulted (Austria, Germany, Finland, France and Slovenia) do not believe that there is any lack of clarity between subsystems, safety components or infrastructure. FIANET also expressed preference for Option C1; if policy action were to be taken then Option C2 would be more acceptable. 34 Only Switzerland indicated that there may be issues with clarity between subsystems and infrastructure. Furthermore, none of the operators associations consulted believed that it was necessary to introduce a non-exhaustive list of safety components. Impact on the Internal Market and Competition A cableways manufacturer suggested that it is possible that Option C3A may distort competition if companies wish to gain competitive advantage by means of presenting, when in contact with potential customers, the non-exhaustive list as exhaustive. If these options were to lead to reduced flexibility for manufacturers, this may result in reduction of consumer choice. There is currently no strong evidence that the proposed options would result in higher prices due to less competition, the creation of barriers for new suppliers, the emergence of monopolies or market segmentation. Impact on Competitiveness, Trade and Investment Flows Should manufacturers’ flexibility be impacted and should this restrict manufacturers’ freedom in developing new technical solutions, it is possible that the global competitive position of EU companies may be impacted. Operating Costs and Conduct of Business/SMEs The impacts of introducing a non-exhaustive list of safety components are difficult to estimate but it can be expected that this would weaken the current system which is based on safety analysis, thus amounting to automatic designation of certain products as safety components. This may have negative cost impacts, as the cost of bringing a product to the market as a safety component is higher than the cost of bringing an identical product to the market as a subsystem. In this respect, it is also possible that cableway operators may put pressure on cableway manufacturers so that products that are not on the list of safety components are certified as subsystems (rather than safety components), thus reducing the cost of the installation. 34 Please note that a FIANET response to the consultation exercise undertaken by the European Commission in 2010 also highlighted the need to better define the term ‘infrastructure’. Page 103
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