Cableways Impact Assessment Study - Final Report - saferail.nl

IA Study Concerning the Revision of the Cableways Directive
There is currently a voluntary reporting scheme which involves notified bodies
sharing information on cableways products approved each year (reporting year end in
March). While the majority of notified bodies (including those which collectively
assess the vast majority of subsystems/safety components brought to the market)
appear to participate in the reporting system, there are several notified bodies that do
not provide information on the numbers of products approved (it has been argued that
the reporting system captures approximately 90% of approvals). While it is
impossible to determine whether some notified bodies do not report because they do
not approve any products under the Cableways Directive or whether they have other
reasons for not reporting, it is clear that Option F3 would improve the reporting
system by making participation compulsory The French notified body, the Service
Technique des Remontées Mécaniques et des Transports Guidés (STRMTG)
publishes the details of the products approved under the Directive on its internet site;
this includes information on the nature of the product, date of approval as well as the
name of the manufacturer.
Comparative differences between notified bodies with regard to experience in
approving cableways subsystems/safety components has not led to significant
problems (although some doubt has been raised in relation to a case where a product
was allegedly certified rather quickly). It was argued by an Austrian notified body
that manufacturers are aware of which notified bodies are more or less active in
relation to the Cableways Directive and tend to opt for those notified bodies which are
known to be highly active with regard to the Cableways Directive and which are
deemed to possess the required technical expertise. In this sense, it was argued, the
market favours those notified bodies which have amassed sufficient expertise and
does not provide the opportunity for notified bodies with lesser experience in the
cableways sector to approve a large number of products. Language capabilities
appear to be a significant criterion for manufacturers choosing specific notified
bodies, thus leading to manufacturers using notified bodies in countries where the
same language is spoken.
A cableway manufacturer states that they use four notified bodies; this is due to the
limited capacity of each of them. Selection criteria include specific expertise (by
means of example, it was noted that only one notified body has experience with
specific electronic components), geographical proximity (this might be an advantage
due to frequent travel) and language capabilities.
From the consultation responses received from a variety of stakeholders, it is clear
that most stakeholders are in favour of alignment with the NLF. Option F3 is
preferred because it is the most sensible approach from a regulatory standpoint and is
binding for all notified bodies. Option F3 would also ensure that there are equal
requirements (and equally stringent requirements) for all notified bodies regardless of
the Member State in which they are operating, which is considered necessary by
notified bodies themselves. Furthermore, according to the respondents, Option F3
would improve the system of information exchange which already exists in the
industry by forcing those who do not share information to do so. Importantly, only
one competent authority stated that alignment with the NLF would be costly for all
stakeholders involved within the Member State.
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