Cableways Impact Assessment Study - Final Report - saferail.nl

IA Study Concerning the Revision of the Cableways Directive
A cableway manufacturer stated that even where a change is intended to clarify the
current situation, it may lead to changes in current practices and as such may have an
impact on manufacturers. The manufacturer thus anticipates medium-strength
impacts from clarifications with regard to the distinction between infrastructure and
subsystems/safety components. In this respect, it is of interest that it is cheaper and
easier to approve infrastructure (which falls within the competence of EU Member
States) than subsystems. It is more burdensome to approve a subsystem as
infrastructure checks may be performed by means of calculations while for
subsystems there are extensive requirements on the type of supporting documents to
be provided. The cost of having subsystems approved is approximately double that of
having a similar component approved as infrastructure. However, for subsystems, a
one-off cost which is incurred regardless of how many installations the subsystem is
used in, but for infrastructure, the cost may be incurred more than once.
Two manufacturers (of cableways and ropes) also pointed to the possibility that the
implementation of either Options C2 or C3 would increase costs due to the need to
change their operating procedures. The rope manufacturer believes these changes
would be significant and stated that the previous audit by the notified body (to comply
with the current legislation) was extremely costly for the company and they would not
want to have to occur such an expense again.
No additional costs for notified bodies have been identified.
Administrative Burdens on Businesses
Changes would require that companies familiarise themselves with the new
requirements and adapt their procedures. It was noted that large companies have
dedicated members of staff for compliance issues while small companies have to
devote a portion of their normal working time to these activities (which do not
generate any revenue). In the context of an SME, these costs could be significant; the
Director of an SME cableway manufacturer noted that during the period when the
Directive was initially implemented, he used to spend one working day every week on
familiarising himself with the new requirements.
The time required to familiarise themselves with the new obligations would depend
on the exact changes to be implemented. However, as these options rather seek to
clarify the existing requirements rather than implement new ones, it is assumed that
these costs would be of substantially lower order of magnitude than those incurred
during the initial implementation of the Cableways Directive.
Public Authorities
Public authorities would incur costs of transposing any changes implemented under
Option C3 but may subsequently accrue cost savings due to avoiding problems of
interpretation of the relevant terms. The German authorities expect increased
administrative burden from Options C2 and C3 associated with providing advice.
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