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The incoming new revision of EN 13015 and the essential requirements
The Lift Directive 2014/33/EU(as well as its predecessor Directive 95/16/EC) requires that, at the time of final testing and before the installation is put into operation, a user and maintenance manual must accompany the plant itself. In particular, the Essential Safety Requirement (EHSR) 6.2 of Annex I requires that
“Each lift must be accompanied by the instructions. The instruction shall contain at least the following documents:
To understand how standards meet this essential requirement, it is necessary to verify the annexes ZA of the EN 81 series of standards. Draft standards prEN 81-20:2018 and prEN 13015:2018 have been updated by CEN TC 10 with a new Annex ZA according to the indications of mandate M/549. The Mandate requires the revision of existing harmonized standards to make them fully compatible with Directive 2014/33/EU. We omit the considerations on the logbook because they are outside the scope of this article
In table ZA.1 of prEN 81-20:2018, in relation to the requirement 6.2 of the Lift Directive, it can be seen that the essential safety requirement is covered by points 7.1, 7.2 and 7.3.
In particular, point 7.2.1 “General”is also a repetition of what is a requirement of the Lift Directive, and should, therefore, be removed from Annex ZA of the standard.
Annex C of prEN 81-20:2018 is an informative Annex; therefore, it is not a suitable part to meet the essential requirements of the Directive.
Consequently, since the standard must be the technical application of what are the essential requirements defined in the Lift Directive, there are no requirements in prEN 81-20:2018 regarding the instructions for use and maintenance. So the Essential Health and Safety Requirements (EHSR) 6.2 of Annex I to the Lift Directive should not be mentioned in Annex ZA while we should expect it to be covered entirely by standard prEN 13105:2018.
prEN 13015:2018 and the essential requirements
Let us check what prEN 13015:2018 says about this.
In table ZB.1 of Annex ZA, it is reported that EHSR 6 of the Lift Directive (and therefore also EHSR 6.2) is covered by all points of the standard, with the exception of some points (220.127.116.11, 18.104.22.168, 22.214.171.124, 126.96.36.199, 188.8.131.52, 184.108.40.206 and 220.127.116.11). These points are excluded as they concern requirements that go beyond what is required by RES 6 of the Lift Directive. Similarly, in table ZA.1 of Annex ZA it is stated that EHSR 1.7.4 of the Machinery Directive is covered by all points of the standard except for some points, which are the same as in table ZB.1 concerning the Lift Directive.
Hence, from Annex ZA of prEN 13015:2018 we can understand that the standard (except for the points mentioned above) covers the essential safety requirements relating to the instructions for use and maintenance for both Directives, the Lift Directive and the Machinery Directive.
This is confirmed by the title of prEN 13015:2018, “Rules for maintenance instructions”, as well as in its aim, described as “this European standard specifies the elements necessary for the preparation of the instructions for the maintenance operations, as in 3.1, which are provided for new installed passenger lifts, goods passenger lifts, accessible goods only lifts, service lifts, escalators and passenger conveyors. […]”.
Therefore, the standard defines how to write instructions for use and maintenance for practically all types of plants that we can find in the sector, from lifts to service lifts to escalators and moving walks. Thus already from this first evaluation, it can be understood how very difficult it can be to find those technical requirements to “translate” RES 6.2 of Annex I of the Lift Directive(for lifts) and RES 1.7.4 of the Machinery Directive(for those installations falling under the Machinery Directive) for such different machines.
In support of this, we can identify some parts of prEN 13015:2018 that deal with requirements that do not apply to all types of equipment defined in the scope of the standard:
Furthermore, in addition to talking about “rescue of persons”, there is a 24-hour service that is required only for certain types of installations (e.g. lifts according to the Lift Directive).
In our opinion, to comply with EHSR 6.2 of Annex I of the Lift Directive, prEN 13015:2018 should indicate the minimum requirements(in the sense of parameter and value) that, for each component (or for identified components other than safety components) must be able to be used during the life of the installation to ensure the initial safety level.
Only the system manufacturer can define which parameters of a component must be verified during maintenance to ensure its functionality (as well as safety).
This is what has been foreseen for some new parts to be included in the next revision of EN 81-20, where not only the technical characteristics of the component are specified, but also the parameters to be included in the use and maintenance manual are defined in detail.
For example, in the proposal to amend EN 81-20concerning ‘alternative suspension and compensations means’, in the requirements relating to the instructions for use, it is indicated in detail what should be included in the instructions (e.g. the criteria for discarding the various types of suspension mean).
Furthermore, in the proposal to amend EN 81-20 concerning the electrical part and specifically the Safety integrity level (SIL) rated circuits, the list of parameters to be included in the instructions for use is even more detailed:
“For SIL-rated circuits, the instruction manual shall inform about:
Therefore, in our opinion, the new revision of EN 13015 should:
Directive 2014/33/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of the Member States relating to lifts and safety components for lifts
European Parliament and Council Directive 95/16/EC of 29 June 1995 on the approximation of the laws of the Member States relating to lifts