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Cableways Impact Assessment Study - Final Report - saferail.nl

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Risk & Policy Analysts<br />

<br />

<br />

Option 2 (Soft Law): Clarify the above issues in the Application Guide to the<br />

Directive; and<br />

Option 3 (Legislative): Amend the Directive.<br />

Policy Option 1 - Baseline<br />

Option 1 is the do nothing option and involves making no changes to the existing<br />

situation, in particular:<br />

<br />

<br />

<br />

<br />

the existing narrow definitions in the Directive will be retained and there will be<br />

no clarification as regards installations serving both leisure and transport<br />

purposes;<br />

there will be no further guidance regarding the scope of the <strong>Cableways</strong> Directive<br />

as opposed to the Lifts Directive and the Machinery Directive;<br />

there will be no further clarification of the distinction between safety components<br />

and subsystems, and between subsystems and infrastructure; and<br />

no specific conformity assessment module for subsystems will be introduced in<br />

the Directive.<br />

Policy Option 2 – Soft Law<br />

Option 2 involves clarifying a number of key issues in the Application Guide to the<br />

Directive and may entail:<br />

<br />

<br />

<br />

<br />

retaining the existing narrow legal definition of cableways but clarifying that a<br />

broader and more general definition of cableway installations is available in<br />

Recital 1 and clarifying that installations 19 “which are designed for leisure<br />

purposes, but could also be used as a means for transporting persons” are within<br />

the scope of the Directive;<br />

providing more extensive guidance on the implementation of existing provisions<br />

regarding inclined lifts and small funiculars. In this respect, it may also be<br />

advantageous to consider the feasibility of amending the Application Guide to the<br />

Lifts Directive so that (like the Application Guide to the <strong>Cableways</strong> Directive), it<br />

emphasises the importance of companies formally collaborating with the<br />

authorities at an early stage of the installation’s design to determine, on a case-bycase<br />

basis, whether it is preferable to construct an inclined lift or a small funicular;<br />

clarifying the distinction between safety components and subsystems in the<br />

Application Guide, for example, by introducing a non-exhaustive list of safety<br />

components; and<br />

amending the Application Guide to recommend using specific conformity<br />

assessment modules for the assessment of subsystems (conceivably, the same<br />

modules as those applied to safety components could be used).<br />

19<br />

Please note that this o<strong>nl</strong>y refers to installations where suspension and/or traction is provided by cable.<br />

Page 73

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