Cableways Impact Assessment Study - Final Report - saferail.nl

IA Study Concerning the Revision of the Cableways Directive
significantly between Member States, with no clear picture emerging at the EU level.
Given the potential risks associated with Option C3, it is proposed to further consider
implementing Option C2.
5.3.4 Problem Area D: Changing Conformity Assessment of Subsystems
Summary of the Aims of Intervention and of the Relevant Policy Options
As regards the conformity evaluation procedure of the subsystems, Annex VII of the
Cableways Directive does not provide a specific conformity assessment module for
the conformity evaluation of subsystems. The Cableways Directive requires notified
bodies to check subsystems but does not give any indication on how they should do it.
It is suggested that this situation has led to divergent interpretations and
implementation of the conformity evaluation of the subsystems. For this reason, the
introduction of a conformity assessment module specifically conceived for the
subsystems is worthy of consideration.
To this end, the following policy options are considered:
Option D2: Amending the Application Guide to recommend using specific
conformity assessment modules for the assessment of subsystems; and
Option D3: Amending Annex VII to the Cableways Directive to allow the use of
specific conformity assessment modules for the assessment of subsystems.
Additional Information on the Significance of the Problem to be Addressed
Based on consultation, it appears that the current Directive may be interpreted by
some stakeholders to mean that notified bodies have to perform an on-site check of
how subsystems have been assembled and incorporated into the installation. This
appears to relate to Article 2 in Annex VII (Subsystems: Assessment of Conformity)
of the Directive. Article 2 reads as follows:
“The examination of the subsystem is carried out at each of the following stages:
design,
construction and acceptance trials once the subsystem has been
completed.”
In this respect it is of interest that a cableways manufacturer noted that most
subsystems are assembled on-site. However, it has been noted that it is not feasible
for notified bodies that approve subsystems, which are used in a large number of
installations, to carry out on-site inspections for each installation that includes the
relevant subsystem. Therefore, it has been alleged that in practice on-site inspections
are not carried out. Instead, subsystems are widely assessed by means of conformity
assessment modules that do not require an on-site inspection.
Information provided by consultation thus supports the contention that the legal
requirements and practices for the conformity assessment of subsystems may be
interpreted in different ways by different stakeholders.
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