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December 16, 2019

Are “Lifting Platforms” becoming more and more popular, and can they still be safe?

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Are “Lifting Platforms” becoming more and more popular, and can they still be safe?

What is a lifting platform? Often, to explain what a platform is, one starts by saying what it is not: a lifting platform is not a lift, although this is a relatively common mistake. Platforms are machines used to transport people, often with impaired mobility, and/or things on a vertical path, which move with a maximum speed of 0.15m/s. Contrary to the lift market, the platform market is largely in the hands of SMEs. This is because a platform is a very flexible product, in terms of both size and solutions, where customisation is often the central point. In many cases, this product becomes the only solution to overcome architectural barriers. Over time, a legislative and normative framework has been defined, first at the national and then at the European level. This laid the foundations for the evolution of this product, both in technical and safety terms, not only for users but also for those involved in their maintenance.   Lifting platforms and the Machinery Directive This type of product entered the market in a very meaningful way, thanks to the publication of the Machinery Directive in 1998 (98/37/EC[1]). Initially, platforms were generally an open load carrier that moved along a closed travel compartment in which the user, in order to move, had to keep his finger pressed on the button (action-held actuation/hold-to-run)[2]. The old directive in point 6.2 of ANNEX I said: Machinery Directive 98/37/EC - ANNEX I ESSENTIAL HEALTH AND SAFETY REQUIREMENTS applicable for design and manufacturing of machines – general principles

6.2. Controls

6.2.1. Where safety requirements do not impose other solutions: The carrier must, as a general rule, be designed and constructed so that persons inside have means of controlling movements upwards and downwards and, if appropriate, of moving the carrier horizontally in relation to the machinery. In operation, those controls must override the other devices controlling the same movement, with the exception of the emergency stop devices. The controls for these movements must be of the maintained command type, except in the case of machinery serving specific levels.

  With the publication of the new Machinery Directive 2006/42/EC[3], the possibility of having lifting platforms with automatic operation in the presence of a completely closed load support was explicitly introduced[4]. The text says: Machinery directive 2006/42/CE - ANNEX I ESSENTIAL HEALTH AND SAFETY REQUIREMENTS relating to the design and construction of machinery
  1. SUPPLEMENTARY ESSENTIAL HEALTH AND SAFETY REQUIREMENTS FOR MACHINERY PRESENTING PARTICULAR HAZARDS DUE TO THE LIFTING OF PERSONS Machinery presenting hazards due to the lifting of persons must meet all the relevant essential health and safety requirements described in this chapter (see General Principles, point 4).

6.2. CONTROL DEVICES Where safety requirements do not impose other solutions, the carrier must, as a general rule, be designed and constructed in such a way that persons in the carrier have means of controlling upward and downward movements and, if appropriate, other movements of the carrier. In operation, those control devices must override any other devices controlling the same movement with the exception of emergency stop devices. The control devices for these movements must be of the hold-to-run type except where the carrier itself is completely enclosed.

In 2010, the first standard for lifting platforms EN81-41 was published with the title “Safety rules for the construction and installation of lifts - Special lifts for the transport of persons and goods - Part 41: Vertical lifting platforms intended for use by persons with impaired mobility”. This standard, currently under revision by the CEN TC10 WG8, deals with platforms where the carrier is not completely enclosed. It is a very comprehensive document, which has supported manufacturers to increase the safety of these machines. It must be reminded here that the application of the standards is voluntary and that they give the presumption of conformity to the Directive. The introduction of the possibility of having automatic operation on this type of system has allowed an exponential growth of the market for this product, which has gone from being a very simple product, where its importance was given solely by the functionality, to a more complex design product to be inserted in houses generally of two or three floors.   The growth of the market, and its subsequent distortion Although this Directive has allowed for growth, it has also allowed for some distortion in the market. The very definition of "completely enclosed" might have been misunderstood over time, in the sense that some manufacturers and notified bodies seem to understand it not to require a physical closure, but only a "protected area". Based on this interpretation, the automatic operation of the system is being allowed for platforms where the "protected area" has been created with photocell barriers, which, in the event of  signal interruption, block the operation of the platform itself and thus protect the user. But is this protection of the users really “at least equivalent” to that provided by an imperforated physical enclosure? The guide to the application of the Machinery Directive in point 371 states that, “hold-to-run control devices are required for all movements of the carrier, whether or not the control devices are in the carrier, unless the carrier is completely enclosed. Completely enclosed carriers are carriers with full-length walls, fitted floors and ceilings included (with the exception of ventilation apertures) and full-length doors.” Despite this clarification, surprisingly, the two interpretations continue to coexist, and, with them, the two lines of products. Clearly, products certified according to these two different approaches have important differences in their cost and also in the level of safety provided to the users. This creates a situation of unfair competition among producers since the rules do not seem to be the same for all. To try to put an end to this disparity in interpretation, in February 2014 EPSA (European Platform and Stairlift Association) wrote to the European Commission via the Machinery Directive Working Group to understand what the correct interpretation was. This was not to push for and support one interpretation over the other, but  to ensure equal product safety levels and allow manufacturers and the market to have a uniform interpretation of what is required by the Directive. During the meeting, the Commission pointed out that “The use of light barrier curtains instead of physical barriers (walls and doors) for a carrier does not fulfil the definition of "completely enclosed carrier".[5] The Machinery Directive WG also agreed to invite the European Coordination of Machinery Notified Bodies to run a risk assessment and to issue a Recommendation for Use (RfU) in order to enlist which are the criteria for:

a) applying a completely enclosed carrier and

b) for using other technical protective measures instead of hold-to-run to lifts having a speed not greater than 0,15 m/s.

  1. Based on such data, to update The Guide to application of the Machinery Directive 2006/42/EC will be updated following this investigation by adding comments on the conditions to use light barrier curtains.
This raises some relevant questions about theplatforms currently installed in Europe. Do these machines, used with an automatic operation, even though they do not have a closed load carrier, at least meet the requirements of the RfU? Are the Essential Health and Safety Requirement (EHSRs) of the Directive respected?   And, once this question has been definitively solved, how should the legislator deal with these machines? Will they remain in operation without any modification? Will they be converted to the hold-to-run operation? On this point there is a major problem of market surveillance. The responsible bodies will have to deal with it directly and clearly. Pending a follow-up to the Commission's proposal to close this long-standing problem, these two types of machines are now sharing the market. This is the question to ask: is the safety level of these comparable machines the same or not? References: [1]Directive 98/37/EC of the European Parliament and of the Council of 22 June 1998 on the approximation of the laws of the Member States relating to machinery. https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A31998L0037 [2]See point 6.2.1 of Annex 1 of Directive 98/37/EC. [3]Directive 2006/42/EC of the European Parliament and of the Council of 17 May 2006 on machinery, and amending Directive 95/16/EC. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32006L0042 [4]Point 6.2 of Annex I of Directive 2006/42/CE [5]Source: Consolidated minutes of the meeting  

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