Cableways Impact Assessment Study - Final Report - saferail.nl

Risk & Policy Analysts
Innovation and Research
The Slovenian national authority noted that Option C3 may turn out to be too
prescriptive and could potentially hinder research and development of new products.
From this perspective, it was further argued that negative impacts on research and
development could be avoided under Option C2. The French notified body/public
authority stated that an indicative list of safety components would be useful but a
prescriptive list would harm innovation.
Consumers and Households
As noted above, a cableway manufacturer expressed the opinion that even
clarifications may lead to substantive changes in the classification of certain cableway
parts. In this respect, it is of note that safety components appear to be more expensive
than subsystems (all other things being equal).
Specific Regions and Sectors
Impacts are likely to differ between countries due to differences in the size of the
cableways sector as well as due to the possibility (as suggested above) that bigger
problems with applying the Directive may be experienced in countries which possess
comparatively smaller expertise and experience with cableways.
Public Health and Safety
With the exception of a Czech notified body which stated that problems with
interpretation of the relevant terms lead to safety issues, no other stakeholder has
identified specific impacts on passenger safety. Most stakeholders appear to believe
that the policy options across most/all problem areas would have no impacts on
passenger safety. With specific regard to Problem Area C, a rope manufacturer stated
that they do not believe that changing the current system would make their products
any safer.
Conclusion
While many national authorities that provided input into the second round of
consultation support some kind of policy action, stakeholders have provided a wealth
of information on the risks associated with the specific policy options. By means of
example, Option C3A (non-exhaustive list of safety components) is associated with a
number of potential problems, including the possibility that it might be presented by
some not as a list of examples but as a definitive, EU- approved, list. In addition, this
Option would not address problems associated with those product types which can be
both safety components and subsystems (no specific examples have been provided by
consultees). Also, although intended as indicative, if treated as prescriptive, this
Option might hinder innovation.
In conclusion, it is clear that some stakeholders have faced problems when
interpreting these terms. However, the impacts of these options would differ
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