News | January 2022
New tool for control-independent parameterisation
Kübler now has a new tool available to ensure that the implementation process at control manufacturers will in future be easier and faster.
Following the pandemic and Brexit, Nick Mellor gives an overview of the UK lift and escalator industry and the new rules around UKCA marking.
He is Managing Director of LEIA (Lift and Escalator Industry Association), the UK trade association and advisory body for the lift and escalator industry.
The UK industry is recovering from the pandemic but also the immediate effects of Brexit – the UK’s departure from the European Union (EU). The UK actually left the EU on 31 January 2020 with a transition phase until 31 December 2020. While there are very many implications of Brexit still, this article focusses on the implications for the lift and escalator industry.
From 1 January 2021, UK Lifts Regulations and the Supply of Machinery (Safety) Regulations ("Machinery Regulations"), which were previously the UK implementations of the EU Lift Directive and EC Machinery Directive, were "de-coupled" from EU legislation and established as standalone UK regulations.
As from 1 January 2021, the essential requirements of the UK Lifts Regulations and Machinery Regulations were identical to those of the EU Directives. The general conformity assessment procedures were equivalent to previously.
However, there were initially some important changes:
• Notified Bodies in the UK became "Approved Bodies". This means approvals from UK Approved Bodies are no longer recognised in the EU.
• UK regulations refer to "designated standards" to give a presumption of conformity to their essential requirements. As of 1 January 2021, the list of UK designated standards was identical to the list of EU harmonised standards. Since then, standards cited in the Official Journal (such as EN 81-20:2020, EN 81-50:2020, EN 81-72:2020, EN 81-73:2020) have been listed as designated standards.
• New conformity marking requirements (UKCA marking) were introduced to replace the CE-mark. CE-marked equipment may still be put onto the UK market until 31 December 2022. Much of this article looks at UKCA-marking requirements.
• To avoid a hard border between the Republic of Ireland and Northern Ireland (the only land border between EU and UK), under the Protocol on Ireland/Northern Ireland (also known as the Northern Ireland Protocol), Northern Ireland is formally outside the EU single market; but EU free movement of goods rules and EU Customs Union rules still apply. In Northern Ireland, CE-marked equipment will continue to be acceptable.
The rules are different between Northern Ireland and Great Britain (the UK excluding Northern Ireland). This article concentrates on the use of UKCA marking in Great Britain (GB) focusing on the marking and conformity assessment procedures for lifts, safety components for lifts, and machinery within our scope being placed onto the UK market.
The UK Government issued guidance in September 2020 setting out a new UK Conformity Assessment (UKCA) mark to replace the use of the CE mark. This consistent with having UK Conformity Assessment bodies which are no longer able to conformity assess against EU directives.
Since the UK regulations have been de-coupled from EU legislation, the possibility for UK requirements to diverge from EU requirements also requires a separate mark.
At present, the technical requirements for lifts, safety components for lifts, and relevant machinery in the UK and EU are identical. LEIA knows of no plans to revise either the UK Lifts or Machinery Regulations.
However, the European Commission is working on new EU Machinery Regulation, and this is likely to include many important new essential health and safety requirements (EHSRs). We know that many of the concerns of the European lift industry might not be considered fully by the European Commission.
An early indication of the UK Government’s attitude to remaining aligned will be from its response to a new EU Machinery Directive/Regulation. Will the UK implement the EU legislation, modify or even add further requirements? LEIA’s position is that essential requirements of UK regulations should be aligned with EHSRs of EU Directives and believes that there is a good argument from product safety to remain aligned.
The UK Government held a product safety consultation earlier this year. LEIA made a submission including many comments also made on the revision of the Machinery Directive. When the UK Government publishes details of the consultation submissions and its response to the consultation, there will be a clearer view of the UK Government’s attitude toward alignment or divergence. It is clear that, having de-coupled UK regulations from EU legislation, divergence is possible.
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