EMF Lift Sector Conference

1. EMF Lift Sector Conference Mike Smallwood EMF Lift Sector Chairman Elewijt Center 25/09/08

2. Objectives of Conference Initiating and coordinating cross-border European actions aimed at enforcing union demands in the European metal industry

3. Aims and objectives To transfer knowledge and experiences To build up motivation To influence Directives & Standards To face « globalisation » Advantages to national training programs

4. EMF Lift Sector Committee Background • As we know the Lift sector is dominated by 4 major companies • Kone, Otis, Schindler and Thyssen Krupp • Initially we established a small EMF adhoc working party to get involved with the Lifts directive

5. EMF Lift Sector CommitteeAims and objectives Initial work areas • A Strict focus on the Lifts directive (95/16/EC) • EMF in DG Enterprise work group providing feedback (actual workplace experience, HS, etc.) • Also in Technical Committee 10 (standardisation) • ETUI-REHS are active Partner in our programme

6. Cooperation EMF – ETUI-REHSLift Sector: the program The creation of a Task Force… … to collect and elaborate lift workers concerns and claims… … to increase the presence of lift TUs in CEN.. … and to become fully involved in EU Lift Committee

7. Cooperation EMF – ETUI-REHSLift Sector: the concerns A summary of issues at stake: • The interconnection between MD (Machinery Directive) and LD (Lift Directive) • Installation and Maintenance staff • The role of notified bodies • The conformity assessment • Market surveillance

8. Promote national & international experiences for improving communication between private & public players; and for improving product design through workplace feedback Make the Commission & CEN aware that revision of harmonised standard can benefit from the knowledge accumulated through these experiences Two main directions Action at European level Action at member states level

9. The Data Attempt to collect and share data on accidents, incidents and near misses occupational diseases and syndromes, stress, data on poor working conditions and data on risk assessments. Statistics, registers of accidents, registers of sick leave or absenteeism any reports from labour inspectorates, through workplace visits (either unannounced or after an accident / incident) and any other formal recording systems. Data on the market: range and presence of new machines, new initiatives, developments or advancements, new technical safety solutions, applicable standards, state of the art market situations and data on market-monitoring.

10. All mechanical equipment to be used at work, or put on the european market for the first time is regulated by the Machinery Directive, this tells manufacturers how machinery must be designed, and suggests applying the design solutions described in the harmonised standards drafted by the european national standardisation bodies. • The directive (art.5) provides Trade Unions to participate in the preparation and monitoring of such « harmonised » standards, and along with Stefano I attend sector meetings with the objective of ensuring this happens. • We are formally involved to improve trade union influence on harmonised standards in order to: • Devise safer design solutions for machinery and put them to work in all workplaces

11. The Machinery Directive contains administrative and technical obligations addressed to manufacturers. The technical obligations are based on a list of essential health and safety requirements (EHSRs) that make up the Annex I of the directive. The European Commission requires the European Committee for Standardisation (CEN) to draw up harmonised standards as a voluntary aid to interpretation of the EHSR.

12. NSB NSB NSB The harmonised standards are prepared in Technical Committees (TCs) [we belong to and attend lift sector TC10] and working groups (WGs) [we are active in the Lift Sector WG and the Chairperson will address you this afternoon]. Committees arecomposed by delegates supplied by the national standards bodies (NSB) of the EU, EFTA and some Eastern and Central European countries NSB’s are the National Members of CEN. NSBs vote for and implement European Standards as national standards, they are largely financed by industry, sales of standards and government grants.

13. Study of application of the Lifts Directive : • Information on the lift (Elevator) market • Views of stakeholders at European level • Views of authorities and stakeholders in Member States • Visits to a sample of lift installations

14. Findings • The Lifts Directive is generally well applied but some problem areas remain • Conformity assessment procedures need simplification and adjustment • Guidance on application and improved harmonised standards • Better market surveillance

15. Scope • Clarification of the borderline between new and existing lifts : A replacement is a new lift, even when the guides are kept • Clarification of the borderline with the Machinery Directive • Revision of the MD : for lifts speed < 0.15 m/s

16. Harmonised standards • Amendment of EN 81-1 & 2 to deal with machine room-less lifts • Revision of the standards : • taking into account the need to integrating correct access, working conditions and safety of inspection and maintenance staff in lift design

17. Conclusion of findings forImprovement of market surveillance • Review of the New Approach : • Stricter rules for Member States • Development of cooperation: • Use of common check-lists for market surveillance inspection

18. Conformity Assessment • Contrast in the choice of procedures in the Member States • Uneveness of Notified Bodies • Growing importance of quality assurance • Possible simplification via the review of the New Approach : fewer modules based on ISO 9001

19. Essential health and safety requirements • Monitor closly section 2.2 (free space) • National procedures differ • Prior authorisation is cumbersome • Are alternative solutions safe ? • The Commission to embark on a study.

20. Paper Discussed at 28 April 2008 LWG 2 Permanent free spaces in lift headroom Many discussions are taking place concerning the “Free Safety Spaces” on top of the lift car at its extreme position It is debated if the requirements given in the EN 81-1 and EN 81-2 standards are sufficient or need to be improved The recent HSL (Health and Safety Laboratories UK Government Organisation) report rates the permanent free spaces in conformity with the standards, much worse than many temporary alternative solutions.

21. Permanent free spaces in lift headroom The HSL Report: Identifies the permanent free spaces in the headroom with the “Rectangular block” Gives very little importance to the required “Free height” of 1.0m above the areas for standing

22. A width of 0.6m does accommodate the shoulders. The refuge length does not allow the torso and legs to fit into the space provided. Sitting height (1.04m) exceeds the refuge length, and the refuge height (0.5m) does not allow sufficient space to bend the legs (buttock knee length 0.69m). With the pit space is in this orientation, indicates that a largest European workers may have difficulty fitting into this volume. Their trunk length means that even with the legs curled up and the neck flexed there is not enough room to accommodate the knees and feet easily.

23. SUMMARY: Height 1.0m : Does not allow user to lie flat body does not fit Body and legs combined do not fitWidth 0.6m : Shoulders only just fit, Legs do not fitLength 0.5m : Users must stoop as low as possible does not . allow the legs to bend, legs do not fit

24. Permanent free spaces in lift headroom Lets show that there is some ambiguity in one clause (8.13.2) of the English text of EN 81-1 and EN 81-2 This ambiguity might explain why people not familiar with might make wrong assumptions concerning the permanent free spaces on top of the lift car, but this is not sufficient to justify wrong conclusions by lift experts I will attempt to comment on the proposed equivalence between the “permanent free spaces”and some “temporary alternative means”

25. Permanent free spaces in lift headroom In EN 81-1 and EN 81-2 The English version of Clause 8.13.2 reads: The car roof shall have at one point a clear area for standing of at least 0,12 m2, in which the lesser dimension is at least 0,25 m The French version of clause 8.13.2 reads: The car roof shall have at one piece a clear area for standing of at least 0,12 m2, in which the lesser dimension is at least 0,25 m

26. Permanent free spaces in lift headroom The surfaces for standing (8.13.2) must be in one piece

27. Permanent free spaces in lift headroom The requirement in clause 5.7.1.1 d) reads: d) there shall be above the car sufficient space to accommodate a rectangular block not less than 0,50 m x 0,60 m x 0,80 m resting on one of its faces . For lifts with direct roping , the suspension ropes and their attachments may be included in this space , provided that no rope centre line shall be at a distance exceeding 0,15 m from at least one vertical surface of the block.

28. Permanent free spaces in lift headroom Conclusions The specifications for the free space require first a minimum height on all the standing areas The requirement for the rectangular block is in addition to the free height on all the standing areas. Current assumptions that the standards require only a volume of refuge (the rectangular block) restricted to one specific place appears to be a debatable point amongst experts. I therefore wrote to the European Commission.

29. Correspondence with the Commission Ian Fraser European Commission Directorate Enterprise & Industry Ian.FRASER@ec.europa.eu 21 February 2008 Dear Ian I write to advise you that the EMF Lift Sector Committee consider that the proposed changes that have come to our . attention in connection with amending the Lift Directive in relation to the “refuge space” are in our opinion in direct conflict . with providing a safe system of work for lift engineers. We consider that the requirement to provide a permanent safety (refuge) space is as critical today to ensure workers . safety as it has ever been. The recent HSL report defined that a safety space (block) measuring 1.25m x 0.8m x 0.7m is . the minimum that should be provided, to ensure that in the event of “overrunning” of the lift a worker has a chance of . avoiding a possible crushing fatality. The proposal as we understand to allow artificial spaces (trap doors within the lift car) would not provide a suitable . alternative as certain maintenance routines can only be carried out whilst outside and on top of the car. The EMF therefore calls upon the Commission to refuse to allow any amendment from the current Lift Directive that . would lead to serious or fatal injuries to lift engineers by reducing the size of (or replacing with an artificial space) the . current long established safety refuge area. Yours Sincerely Mike Smallwood EMF Lift Sector Chairman

30. Brussels, 2nd April 2008 DG ENTR/I4/BP/ep D(2008) Brussels, 2nd April 2008 DG ENTR/I4/BP/ep D(2008) Mr Mike Smallwood Lift Sector Chairman EMF/International Trade Union House (ITUH) Boulevard du Roi Albert II, 5 (bte 10);B-1210 Brussels Re: Lifts Directive 95/16/EC – refuge space Dear Mr Smallwood, Thank you for your letter of February 2008 with important remarks from EMF concerning the lifts refuge space. Mr. Fraser has asked me to reply. The position of EMF is very important for the Commission as it gives the us the opportunity to take account of the experience of workers in the lifts sector. It will help us to keep a proper balance when drafting the position of the Community. I would like to inform you that we have received several other comments relating to the findings of the Report on technical assessment of means of preventing crushing risks on lifts subject to Directive 95/16/EC. They have been made available on the CIRCA database for the Lifts Working Group: If you agree, I would like to upload your letter as a contribution to the debate. The issue will be discussed during our next Lifts Working Group meeting foreseen to be held on 28-29 April 2008. You are invited to present your remarks during the discussion. Should you have any other proposals on the issues to be discussed, please do not hesitate to contact us. Yours sincerely, Beata PICH c/c Mr. Stefano Boy, ETUI-REHS.

31. Enforcement of Standards? • In conclusion it appears self evident that the Authorities need to adopt EU Wide Market Surveillance to ensure: • The checking of conformity and safety of lifts once they are installed • Use of the safeguard procedure • Market surveillance is also a check on Notified Bodies and standards • Periodic inspection is no substitute

32. Universal Transferable Skills Verification After discussions in the Standardisation Committee attended by Stefano and myself it has become apparent that the original concept of seeking a “standardised” verifiable Lift Sector Qualification is not now possible. The issue surrounds a “minimum” level whereas our objective is for “maximum” high grade skills verification. Therefore we need to put pressure on each of the big 4 Companies to attempt to get a “Quality” skills level for all engineers who work on Lifts, as it is in there interest to ensure that only skilled engineers work on lifts. We will continue to lobby to try to make qualifications to make qualifications to work on Lifts an EU wide legal requirement in the same way as Electricians or Gas Engineers!

33. Thank you for your kind attention.