Dealing with platforms not compliant with the Machinery Directive
As seen in a previous article on this topic, the possibility for any manufacturer to consider platforms using commands that are not "hold to run", even in the presence of a load carrier "not completely enclosed", as compliant with the Machinery Directive was definitely over at the end of 2019. So, what to expect from now on? The first thing that should be guaranteed to the market and consumers is that the sale of products, not complying with the Directive, is stopped immediately, so that competition in the European single market is finally fair. The second objective, not less important, but more difficult to achieve, is the modification of the already installed systems to make them compliant with the essential health and safety requirements (EHSRs) of the Directive. The fact that these systems have been considered to be not compliant means they have a different, and unfortunately lower, level of safety than required by the Directive. Although this objective is far more difficult to implement, it is nevertheless necessary for the consumer who, by using these platforms every day, exposes himself to greater risks than those foreseen by the laws currently in force. Therefore, to date, the only systems classified as lifting platform that can operate with controls that are not "hold to run" are those with the load carrier completely closed. Which standard must be used to certify such an installation, given that EN 81-41 deals exclusively with platforms with open load carrier? At present, as there is no specific standard for this kind of machine, the only way for manufacturers to put a CE marked product on the market is to get an EC type-approval of the machine from a notified body. In this case, the manufacturer must give a risk analysis based on the Machinery Directive. The most widely used method to perform this risk analysis is to take inspiration from the "closest" and most similar available standard, which in this case is EN81-41, while, for the points relating to car doors (not in the scope of the standard), reference is made to the norms relating to lifts. The latest news expected regarding updates from our sector is the arrival of the new EN81-42. But at what point is the development of this specific standard, right now? What is its status? And how long will it be before it is approved? The WG13, part of CEN/TC10 ‘Lifts, escalators and moving walks’, started its preliminary work in 2015. The work started with a risk analysis made from scratch, and now, a few years later, the first draft of the standard (prEN 81-42) is almost ready to be sent to CEN to start its formal approval process. Of course, this is not the only thing happening on this major topic. The world and the sector are constantly changing, just as technology is constantly evolving. In 2019, the Commission proposed a questionnaire on the possibility and need to update the current Machinery Directive to new market needs and newly available technologies . As far as the lift sector is concerned, the proposals are, on the one hand, related to the possibility of reopening to the existence of platforms with automatic manoeuvre even in the presence of open cabins, but subject to the use of newly designed light curtains systems with higher levels of safety. This would be the follow-up to the Commission's request to the Notified Bodies on the need to investigate this issue further, perhaps with a Reference for Use (RfU). On the other hand, there is the proposal, which probably has been urged by pressure from various stakeholders, to increase the speed of this product from 0.15m/s to 0.5m/s. This subject will certainly be a source of debate in the near future. For the moment, there are many proposals for such an important subject. There are those proposing to keep things as they stand at present; those who propose an intermediate speed (for example the 0.3m/s already used in various non-EU countries such as Australia and Russia);those who propose a double speed; and those who are in favour of increasing the speed significantly (0.5m/s), even if for the moment this position seems to be a minority one. In any case, the evolution will probably be rather long, but it is important that it is followed and monitored.
