by Mehmet Cömert
Hello everyone,
Even though many mistakes are made while bringing lifts to market within the scope of lift regulations, there is a more or less established “CE” marking process one way or another. Of course, the mistakes we encounter in the market introduction processes still continue occasionally. However, what I mean to say is that, despite everything, thanks to the 2014/33/EU Lifts Directive and other published regulations aimed at lifts, the subject of lifts has been framed in great detail, and there is an established sectoral culture in this regard.
Unfortunately, the situation is not as clear for some other vertical transport systems when we step outside the scope of the 2014/33/EU Lifts Directive. As is known, when it comes to vertical lifting equipment, the product range is quite extensive. Cranes, escalators, forklifts, load-carrying platforms, vehicle lifts, lifting equipment for disabled individuals and many other products are separate examples of vertical lifting equipment.
In this article, I want to address vertical lifting equipment manufactured for disabled individuals and lifting equipment manufactured for transporting loads. Because we are facing quite serious problems in the market introduction of these products.
The main reason is that those introducing products to the market have not fully understood the European Economic Area.
The image taken from the official website of the European Union shows member countries and candidate member countries. For products with technical regulations published by the European Commission to be placed on the market in the countries shown in the image, it is mandatory to have the “CE” marking. Products for which technical regulations have been published by the European Commission must bear the “CE” marking in order to be marketed in the countries specified in the image. In our country, administrative sanctions are stipulated by Law No. 7223 on Product Safety and Technical Regulations.
Well then, how should the “CE” marking be for vertical lifting equipment manufactured for the purpose of carrying loads and vertical lifting equipment manufactured for the purpose of transporting disabled individuals?
The technical regulation for these two product families is primarily the 2006/42/AT Machinery Safety Directive. The harmonized standards published with reference numbers in the Official Journal of the European Union related to these products can be accessed under the heading “Machinery (MD)”. [1]
Therefore, these products must comply with the provisions of the Machinery Safety Regulation. The Annex IV of the Regulation has dedicated separate sections for certain products. The phrase “Equipment used for lifting persons, or persons and goods, with a vertical height greater than three meters, posing a risk of falling” under this heading is important for us. A manufacturer intending to introduce their product into the market under the conditions covered by this sentence must be aware that self-declaration alone is not sufficient for placing it on the market.
Furthermore, misunderstanding or misinterpretation of self-declaration can also mislead the manufacturer regarding compliance and market entry. That is why the self-declaration must be understood correctly. Regardless of whether the product falls under Annex IV of the 2006/42/AT Directive, a technical file must be prepared for the product before it can be placed on the market. The technical file of the product must include all documents specified in Annex VII of Directive 2006/42/AT, such as its design, circuit diagrams, calculations necessary to confirm compliance with essential health and safety requirements, test results and comprehensive drawings.
As a result, the product must comply with all relevant requirements of Annex I of Directive 2006/42/AT, which outline the essential health and safety requirements. The manufactured product should be placed on the market after demonstrating its compliance through internal control processes and issuing a Declaration of Conformity according to the Machinery Directive.
The chart below illustrates the steps to be followed for the Machinery Safety Regulation in its simplest form.
As can be understood from the chart, after determining the market entry method for the product, it is necessary to refer to harmonized standards. You can see below the chart that outlines the standards that should be set according to the characteristics of the product to be placed on the market for vertical lifting equipment manufactured for the purpose of carrying loads and vertical lifting equipment manufactured for the transportation of disabled individuals. This chart illustrates the fundamental elements and decision points for the harmonized use of regulations and standards.
The chart above has been created with specific scope considerations in mind. It provides guidance at a fundamental level. What I would like to draw attention to here are EN 1570-1, EN 1570-2, EN 81-31, EN 81-40 and EN 81-41 standards within the scope of 2006/42/AT. I believe that these standards are ignored in practice. For example, a home lift designed to transport disabled passengers must be manufactured in accordance with the EN 81-41 standard. Platforms designed for transporting goods must comply with either the EN 1570-1 or EN 1570-2 standards. Finally, lifts designed for carrying loads, with a declared speed not exceeding 1 m/s and without a control panel inside the car, must be manufactured in accordance with the EN 81-31 standard. Technical files should be prepared for these products, and a correct roadmap should be determined under the scope of the Machinery Directive 2006/42/AT to ensure they are placed on the market with the “CE” marking attached. There is no other way to think of it.
In our country, the maintenance and periodic inspections of these products must be conducted in accordance with the criteria outlined in the “Regulation on Health and Safety Conditions in the Use of Work Equipment,” published in the Official Gazette dated 25.04.2013 and numbered 28628.
When it comes to the Lifts Directive 2014/33/EU, processes are relatively clearer; however, significant gaps still exist in this field in our country. There are 3 key standards in the Lifts Directive that we need to prioritize. EN 81-50 sets the essential safety requirements before manufacturing lifts. EN 81-20 or EN 81-22 set the essential safety requirements during the manufacturing process, depending on the operating slope of the system.
Other standards specify the additional requirements depending on the intended use of the lifts. While the intended use of the product should be determined by the “facility owner”, other national legislation should also be considered in this process.
Lifts manufactured in our country must be suitable for disabled passenger use according to the “Regulation on Planned Areas Zoning,” irrespective of the structure’s condition and the lift’s intended use. Other additional requirements that require attention are specified within the “Regulation on Fire Protection of Buildings.”
I hope that this article will help you eliminate the errors experienced when placing such products on the market.
Sources
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