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Tracing systems for safety components monitoring
According to its text, the Lifts Directive 2014/33/EU is applicable to new lifts placed on the market and to safety components either manufactured in the EU or imported by third countries. The whole production chain has to implement the measures detailed in the Directive that shares the obligations among the different actors involved.
The point from which any reasoning on how to develop a traceability system should start is the first part of Whereas 17 of the Directive, according to which “ensuring traceability of a safety component for lifts throughout the whole value chain helps to make market surveillance simpler and more efficient. An efficient traceability system facilitates market surveillance authorities’ tasks of tracing economic operators who made non-compliant safety components for lifts available on the market”.
According to the Lifts Directive, the manufacturer of the safety component has to be able to know to whom its product has been sold, and the link between component and manufacturer (most likely based on the brand and the batch number) should be easily recognizable. Likewise, there should be a recognizable connection between the manufacturer, the seller of the component (when they are not the same person), and the final client who bought the component itself and the lift on which it was installed. It is therefore necessary that the national bodies monitoring the supply chain keep track of the life of the components, so as to go back to those responsible if problems arise.
In order to implement as best as possible the Directive, all economic operators (manufacturers, installers, importers, authorised representatives and distributors) must ensure a proper and correct tracing of the safety components.
Safety components manufacturers should have a national database, regularly and constantly updated, to track all the pieces they produce. This database should include all the data that might be useful in tracing and monitoring a component, such as its name, its type, serial or batch number, when and where it was manufactured, the certificate number/EU declaration of conformity, the economic operator to whom it has been supplied. In the same way, installers should create their own database reporting all the relevant data of the lifts they placed on the market and of the incorporated safety components; moreover, they also need to register and track the safety components installed when modernizing or repairing an existing lift. Similar obligations apply to authorized representatives, importers and distributors dealing with safety components for lifts.
EFESME will soon provide its member associations with guidelines and model databases that will support SMEs in the compliance to the traceability requirements of the Lifts Directive.
It would be useful, as a tool for market surveillance, the creation of a safety components database on a national scale, where all the components placed on the market of a given country should be registered. This database should be semi-public and accessible to the national surveillance authorities and should contain all the details previously registered by economic operators. A good example of this could be the Spanish national register, organised and managed by the Autonomous Communities, which could be considered as best practice in the sector.