Cableways Impact Assessment Study - Final Report - saferail.nl

Risk & Policy Analysts
6.2 Problem Area B: Confusion over Inclined Lifts and Small Funiculars
Generally speaking, Option B3 cannot be expected to have any discernible impacts as
it is unlikely to affect current practices and is thus unlikely to deliver any benefits or
result in additional running costs for businesses, notified bodies, national authorities
or cableway operators. However, while again depending on whether it would be
transposed in isolation or in a package with other changes to the Directive, Option B3
is seen as associated with comparatively high transposition costs. Given the absence
of clear benefits, the cost-benefit ratio for this Option is seen as unfavourable.
On the other hand, Option B2 can be expected to have a positive impact, primarily on
companies in the lifts sector. These impacts would arise with regard to increased
awareness of the need to reach a formal agreement on an installation’s classification
at an early stage in the planning and design process. The costs associated with this
Option can also be expected to be low/moderate and would arise in the course of
changing Application Guides to the Lifts and Cableways Directives.
Taking the above into account and (in particular) the absence of specific benefits, it
can be concluded that the cost-benefit ratio for Option B2 is better than for Option B3.
6.3 Problem Area C: Definition of Safety Components, Subsystems and
Infrastructure
It is clear that all the issues under this problem area listed in Section 4 are perceived
by some EU stakeholders as problems. However, the opinions and the information on
impacts of the proposed options provided to the consultants by stakeholders are so
diverse that it has not been possible to comprehensively and reliably assess the extent
of impacts that the proposed options would have (beyond a qualitative overview of
stakeholder preferences and perceived risks associated with some of the proposals).
While many national authorities that provided input into the second round of
consultation support policy action, stakeholders have provided information risks
associated with the specific policy options. By means of example, Option C3A (nonexhaustive
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 amounting to 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, given the potential risks associated with Option C3, it is proposed to
further consider implementing Option C2.
Page 123