Regulation Update – Machinery Directive 2006/42/EC

On the 29th December 2009 new UK regulations came into place to govern the safety of new Machinery. This legislation is named The Supply of Machinery (Safety) Regulations 2008, Statutory Instrument No 1597.

The Regulations enact European legislation related to the supply of Machinery. They make significant changes to the previous Machinery Regulations and as a result, suppliers have to put in place design, documentation and administration changes for their products.

The new Regulations will impact on New Stairlifts, Home Lifts, Lifting Platforms, Goods only Lifts, Escalators and Passenger Conveyors (Moving Walkways). 

What are the changes?

New products placed onto the market on or after December 29th 2009 and used to raise passengers or passengers and goods at a speed of 0.15m/s or less will be Machinery and subject to the Regulations.

New Machinery products placed onto the market on or after December 29th 2009 used to raise loads will require load testing before putting into service.

New products placed onto the market on or after December 29th 2009 used to carry goods only and inaccessible to persons will also be subject to the Regulations irrespective of speed.

New products carrying passengers or passengers and goods at speeds greater than 0.15m/s will have to satisfy the existing Lift Regulations 1997. Statutory instrument No 831. The existing Lift Regulations are also modified by the new Machinery Regulations to exclude products carrying persons at a speed of 0.15m/s or less.

What are suppliers required to do?

Suppliers of equipment will be legally obliged to design products to satisfy new Essential Health and Safety requirements stipulated in the Machinery Regulations. This will result in design changes to products such as Escalators, Stair lifts, Lifting platforms, Home lifts and Goods only lifts.

There are a number of standards that support the new Regulations.

Suppliers are required to CE mark compliant products and provide a declaration of conformity to the purchaser.

What are purchasers required to do?

Customers that may have previously had their own specification for a product, based on a Lifting Platform with a speed greater than 0.15m/s should note that this product is no longer permitted if it transports persons. Instead the product will be classified as a Lift and must be designed accordingly, or the specification will need to be amended.

Customers need to ensure products they purchase are in accordance with the new Regulations by making reasonable enquiries before placing orders with suppliers.

Where they exist, harmonised European standards for each product will give guidance for each product grouping. Where harmonised standards do not exist an individual risk assessment must be completed by the manufacturer in order to determine what type of controls for each of their specific product range.

Note: the new Machinery legislation is not retrospective and therefore does not require existing installations to be modified.

Lerch Bates are able to provide advice and assist with Technical Qualifications associated with the new Regulations – so please feel free to give us a call.

Thinking Outside the Box

Question: What do you do when a lift needs modernising and yet it’s the only lift in the building?

Answer: Hire someone to do some creative thinking!

The amount of disruption that can be caused by the removal of lift service in a modern building that only has one lift should not be underestimated. Apart from the obvious issue of discrimination towards disabled people, there are many other facets that can disrupt daily life when stairs are the only option. According to most insurance companies there are more accident claims on stairways than in lifts. The risk therefore shifts to a different area where the potential for accidents increases, especially when stair traffic increases and deliveries via the stairs are introduced.

The problems recently faced by Canterbury City Council when one of their passenger lifts was troublesome and in need of a full modernisation is a case in point. All aspects of the client’s requirements had to be addressed including lift engineering, civil engineering, logistics, cost and the practical and emotional needs of the residents.

The single lift in a nine storey building was due to be modernised and the duration of the works that had been planned would mean that the lift would be out of service for three months. A number of residents would be unable to reach their apartment via the stairs due to their age or disability and it was deemed unreasonable to expect anyone to climb further than five flights (most people will not accept anything over three floors, especially over a three month period). Some lateral thinking was therefore required as the re-housing of residents into temporary accommodation would be costly and not necessarily in the best interests of the residents, both emotionally and practically, bringing as it would significant disruption to their daily lives over the course of three months.

In the past, in similar situations, some building owners have gone to the extreme of adding another lift to the building using a separate lift shaft but the capital cost of that, along with the doubling of future running costs, makes for a costly solution in the long term. The use of a temporary lift such as those used on building sites was considered but ordinarily they do not comply with BSEN81-70 (Particular applications for passenger and goods passenger lifts. Accessibility to lifts for persons including persons with disability).

Lerch Bates carried out a feasibility study and with the cooperation of the council, a temporary hoist manufacturer, a lift modernisation company and a builder, provided a complete solution where tenants did not have to be disrupted, the existing lift could be modernised and brought up to current standards and the building could keep the same appearance in the long term without doubling its ongoing costs for vertical transport. Simple, I hear you say! Well, not quite.

There were many challenges to overcome to enable a temporary lift structure to be built (which was the solution that was settled on – see photo) power, telephones, drainage, sewerage and structural loading had to be considered along with overcoming newly introduced hazards such as the potential for access to the temporary lift structure by climbing and the need to restrict the aperture of those bathroom windows which faced onto the temporary lift so that the passing lift car could not be reached.

Lerch Bates were invited to manage the entire project and the temporary lift was installed after building enabling works. The temporary lift ran for a fortnight in tandem with the existing lift so that reliability and acceptance was assured. When consensus was achieved the existing lift was removed from service and modernisation commenced. The added benefit of having a temporary lift in the building, apart from the obvious advantages of deliveries and public access without using the stairs, was that the modernisation of the existing lift was made easier with the use of a temporary lift to deliver materials and labour. In addition maintenance of the apartments was easier because access by tradesmen with their tools and materials was always available.

The cost of the entire project was less than the costs of temporariliy re-housing the tenants over a three month period and the tenants continued to enjoy access to their apartments thanks to the reliability of the temporary lift.

This short case study highlights just one of a number of different approaches Lerch Bates can take in ensuring continuity of lift service within a building during lift modernisation works. Other techniques have included “no downtime” modernisation plans that enable all the works to be done outside office hours in the case of a commercial property.

It all depends upon the extent of the works being carried out, the hours of use of the building and what opportunities the building itself might afford in access terms. As Phil Kearney, the Lerch Bates consultant responsible for this project, remarked “Our responsibility is to find the best, most practical and cost-effective solution for our clients and sometimes that means thinking outside the box!”