Cableways Impact Assessment Study - Final Report - saferail.nl

IA Study Concerning the Revision of the Cableways Directive
Inclined Lifts and Small Funiculars
Responses to the questionnaire and information obtained from discussions with
stakeholders suggest that a degree of confusion has been experienced with regard to
this issue. Table 4.3 shows that action to address potential confusion relating to the
interplay of the Cableways, Lift and Machinery Directives is seen as necessary by
52% (11 of 21) of responding national authorities and by the vast majority (80%) of
notified bodies (4 of 5). Several companies have also pointed to this problem,
suggesting that companies would also welcome improved guidance. Respondents
highlighted specific problems experienced in Germany and in the UK.
Table 4.3: Do you think that it is necessary to clarify the scope of the Cableways Directive as
opposed to the Lifts Directive and the Machinery Directive?
National Authorities
Notified Bodies
No. of Responses % of Responses No. of Responses % of Responses
Yes 11 52% 4 80%
No 9 43% 1 20%
Other 1 5%
TOTAL 21 100% 5 100%
Given that the majority of respondents would welcome further clarification in this
area, this issue is further examined in Section 5 of this report.
Definitions of safety components, subsystems, infrastructure and installations
As shown in Table 4.4, 22% (5 of 23) of national authorities and 40% (2 of 5) of
notified bodies have experienced problems arising from lack of clarity as to the
difference between subsystems and infrastructure. Table 4.5 also shows that around
45% (10 of 22) of national authorities and 60% (3 of 5) of notified bodies have
experienced problems arising from lack of clarity as to the difference between
subsystems and safety components. Although this issue has been mentioned by some
company respondents, overall, this does not seem to be a major problem for most
cableway manufacturers. A manufacturer of electronic equipment/safety components
stated that they experienced issues around the definition of the terms in the Directive
(in particular in the period immediately following the Directive’s entry into force) but
these have always been solved in cooperation with the competent authorities. In
addition, this company also questioned the feasibility of introducing a non-exhaustive
list of safety components. Another company pointed to components that may often be
classed as infrastructure but are in fact series-produced standardised products (such as
line towers); this means that these components are not subject to free movement and
require approval in individual Member States, thus allegedly presenting an
unnecessary burden on cableway manufacturers. It was further suggested that in
order to address this problem, it might be necessary to revisit the definition of
infrastructure given in the Cableways Directive.
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