1. Massimo Bezzi - Vice President
European Federation for Elevator Small and Medium-sized Enterprises
Importance of instructions for use: how to improve availability
Luciano Faletto
SBS Forum «Lifts reaching the Cloud»
18nt December 2018

2. Massimo Bezzi - Vice President
Importance of instructions for use:
how to improve availability
Table of contents
The Great Baltimore Fire – 1904 – Consequences
Importance of standards by National and International bodies
Performance-based standards: the New Approach Directives
MD & LD Requirements for Maintenance and Instructions
ISO : Global Essential Safety Requirements for Lifts
Comparison of LD EHSRs and ISO GESRs
Conclusions

3. Massimo Bezzi - Vice President
The Great Baltimore Fire – Consequences
Causes
fire hose attachments lacked commonly shared standardization
Very often, standards were developed by contributors imposing their own products:
for same products, different standards were developed by different contributors
practically, many standards were hiddenly imposing products as alternative to patents
most of the equipment was patented by its manufacturer
efforts to establish standards failed: each city had its own system
Consequences
most firefighters from other locations could not contribute to fighting the fire:
no ways to connect their firefighting equipment
more than 1500 buildings were destroyed
In 1905, the National Fire Protection Association established a national standard for hose couplings and fire hydrants:
The “Baltimore standard”

4. Massimo Bezzi - Vice President
Importance of standards by National & International bodies
Deliverables of the technical standardization activities concern:
“interface standards”, which specify how products interconnect with each other, or
"safety standards”, which prescribe the characteristics necessary to guarantee that a product or process is safe for humans, animals, and the environment.
The standards are voluntary:
they do not have the force of law.
When adopted by a government,
they assume the role of "technical regulations" such as
the mandatory EHSR for Machinery Directive & Lifts Directive
as performance-based Technical Regulations in the EU Market

5. Massimo Bezzi - Vice President
Performance based standards: New Approach Directives
Products implementing new technologies had constraints: why?
The generally accepted need to comply with the current safety standards
The late revision of standards for products that could benefit from rapid utilization of the new technologies, made available on the market quite fast,
Why not to specify the effects of requirements instead of giving specific prescriptions? Performance-based Vs Prescriptive !!
This approach was first developed in Europe and led to the New Approach Directives with the scope to provide:
directives allowing flexible introduction of innovation
a competitive edge for EU products against those limited by conventional standards. (benefits from standards!)
Examples are Machinery Directive in 1989 and Lifts Directive in 1995.

6. Massimo Bezzi - Vice President
MD & LD requirements for «Maintenance» and Instructions
Now the “MD & LD” Directives allow the direct implementation of new technologies/solutions long before they are commonly used in the market, when no proper information is yet available :
Previously, a team composed by a master and a mate performed maintenance together: the mate learned from the master all the necessary know how.
With the new technologies, nobody has any experience built on new products and would not be able to transfer any appropriate know-how about them.
The EHSR of the LD are a well-structured compendium of legislative requirements, to eliminate/sufficiently mitigate the hazards faced in new lifts
By applying the ISO/IEC Guide 51, the MD and LD give a detailed list of the information which shall be provided by the lift manufacturer:
suggested plans for periodic verifications and tests, including replacement of any worn components, to guarantee:
the necessary level of safety for the whole life of the product,
that the product continues to be fit for its purpose

7. Massimo Bezzi - Vice President
ISO :Global Essential Safety Requirements for Lifts
In 1994 the WTO - TBT Agreement acknowledged the importance of
“performance-based” standards as “global relevance standards” being suitable for implementing global standards accepted by all WTO members.
This almost imposed an obligation, accepted by ISO, to develop, adopt and publish “globally relevant” standards, under “specific conditions”
The EU publication of Machinery Directive and Lift Directive 95/16/CE urged ISO to develop the project “Global Barrier-free Trade” for lifts that initiated with the drafting of a performance-based document:
ISO TS which established
the Global Essential Safety Requirements” (GESR) for lifts
Where most hazardous situations were considered, analyzed and duly specified
with a finely tuned wording matching that of lift safety standards

8. Massimo Bezzi - Vice President
Comparison of LD EHSRs and ISO GESRs
One of the major tasks for ISO TC178/WG4 was comparing:
GESR of ISO (former ISO TS – 1 ) and
EHSR of Annex 1 to LD 95/16/CE (and the applicable MD 2006/42/EC)
Most of the articles of the Lift Directive, which deal with the instructions for the owner or linked to point of Annex 1 to the Machinery Directive, are the main differences that emerged from such comparison
The comparison on these points, carried out in ISO TC 178 / WG4 and included in its Annex C to ISO , highlights that this standard does not list any practical GESRs to highlight those specific hazards
the tables that follow summarize the few differences, that we consider important and are shown in italics and underlined font of larger size

9. Massimo Bezzi - Vice President
Comparison of LD EHSRs and ISO GESRs (cont.)
LD Annex 1
1.1.
Application of Directive 89/392/EEC, as amended by Directives 91/368/EEC, 93/44/EEC and 93/68/EEC.
ISO
Clause (partial)
Where the relevant hazard exists and is not dealt with in this Annex, the essential health and safety requirements of Annex I to Directive 89/392/EEC apply.
The essential requirement of Section of Annex I to Directive 89/392/EEC must apply in any event.
When designing a lift or its component, a review of the intended use, foreseeable misuse (see of ISO 14798:2009, ) and the design shall be made, in which all possible risk scenarios are formulated, and risk assessment is performed, in order to find out which, if any, GESRs are applicable to the design.
All risk scenarios that can occur during operation and use shall be considered, as well as during the maintenance or inspection of the lift-
Where the relevant hazard exists and is not dealt with in this Annex, the essential health and safety requirements of Annex I to Directive 2006/42/EU apply
All risk scenarios that can occur during operation and use shall be considered, as well as during the maintenance or inspection of the lift-

10. Massimo Bezzi - Vice President
Comparison of LD EHSRs and ISO GESRs (cont.)
MD Annex 1
1.1.2
Principles of safety integration
ISO
Understanding and implementing GESRs.
Machinery must be designed and constructed so that it is fitted for its function, and can be operated, adjusted and maintained without putting persons at risk when these operations are carried out under the conditions foreseen but also taking into account any reasonably foreseeable misuse thereof. The aim of measures taken must be to eliminate any risk throughout the foreseeable lifetime of the machinery including the phases of transport, assembly, dismantling, disabling and scrapping.
Machinery must be supplied with all the special equipment and accessories essential to enable it to be adjusted, maintained and used
The principle of safety integration is addressed in this document.
Equivalence is achieved when all risks including residual ones are mitigated in using this document as a “standard”.
MD addresses risks arising during the life cycle of the lift.
For lifts in the EU, the MD requirement as specified shall be complied with
Equivalence is achieved when all risks including residual ones are mitigated in using this document as a “standard”.
MD addresses risks arising during the life cycle of the lift.
Machinery must be supplied with all the special equipment and accessories essential to enable it to be adjusted, maintained and used

11. Massimo Bezzi - Vice President
Comparison of LD EHSRs and ISO GESRs (cont.)
LD Annex 1
6.2
6. Instructions
ISO
GESR 6.2.2
Lift maintenance and repair instructions
Each lift must be accompanied by documentation drawn up in the official language(s) of the Community, which may be determined in accordance with the Treaty by the Member State in which the lift is installed.
The documentation shall contain at least: — an instruction manual containing the plans and diagrams necessary for normal use and relating to maintenance, inspection, repair, periodic checks and the rescue operations referred to in Section 4.4,
— a logbook in which repairs and, where appropriate, periodic checks can be noted
Where maintenance or repair is required to ensure continued safety, appropriate instructions shall be provided emphasizing that suitably trained personnel perform any required work. NOTE This applies to lifts and lift components that are subject to wear and tear.
Adequate maintenance is a key element in keeping the lift in safe operating condition.
This GESR aims to prevent the performance of maintenance and repair work by incompetent persons
In addition to GESR 6.2.2, LD also requires instructions for normal use and relating to inspection, repair and periodic checks.
The documentation shall contain at least: — an instruction manual containing the plans and diagrams necessary for normal use and relating to maintenance, inspection, repair, periodic checks and the rescue operations referred to in Section 4.4,
— a logbook in which repairs and, where appropriate, periodic checks can be noted
Where maintenance or repair is required to ensure continued safety, appropriate instructions shall be provided emphasizing that suitably trained personnel perform any required work. This GESR aims to prevent the performance of maintenance and repair work by incompetent persons
In addition to GESR 6.2.2, LD also requires instructions for normal use and relating to inspection, repair and periodic checks.

12. Massimo Bezzi - Vice President
Comparison of LD EHSRs and ISO GESRs (cont.)
MD Annex
Principles of safety integration
ISO
Understanding and implementing GESRs.
Machinery must be designed and constructed so that it is fitted for its function, and can be operated, adjusted and maintained without putting persons at risk when these operations are carried out under the conditions foreseen but also taking into account any reasonably foreseeable misuse thereof.
The aim of measures taken must be to eliminate any risk throughout the foreseeable lifetime of the machinery including the phases of transport, assembly, dismantling, disabling and scrapping.
Machinery must be supplied with all the special equipment and accessories essential to enable it to be adjusted, maintained and used
No Equivalent GESRs
Only a declaration saying that:
The principle of safety integration is addressed in this document.
Equivalence is achieved when all risks including residual ones are mitigated in using this document as a “standard”.
MD addresses risks arising during the life cycle of the lift.
For lifts in the EU, the MD requirement as specified shall be complied with.
The aim of measures taken must be to eliminate any risk throughout the foreseeable lifetime of the machinery including the phases of transport, assembly, dismantling, disabling and scrapping.
Equivalence is achieved when all risks including residual ones are mitigated in using this document as a “standard”.
MD addresses risks arising during the life cycle of the lift.
Machinery must be supplied with all the special equipment and accessories essential to enable it to be adjusted, maintained and used

13. Massimo Bezzi - Vice President
In conclusion…

14. Massimo Bezzi - Vice President
In conclusion…
We must acknowledge that:
Instructions listed in existing standards are not covering the new solutions
b. Built competence of senior maintenance personnel is no longer sufficient
c. New solutions/technologies. now directly implemented. need to be supported by adequate instructions for:
maintenance & repairs, at least such as
Periodic checks
planned maintenance and components replacement

15. Massimo Bezzi - Vice President
In conclusion…
Ask ISO to modify the ISO , for the benefit of users and standardisers, to include more practical references to:
“Principles of Safety Integration” by the ISO Guides
Focus on information and special tools
to be supplied to the lift owner
together with the lift

16. Massimo Bezzi - Vice President
In conclusion…
More complicated lifts need more detailed instructions for:
planned maintenance for verifications and timely replacement of components
making available the lift’s information and instructions to be accessed via internet connection to the installer’s website or to a suitable “IoT” Platform where:
-- Link and Access codes are provided with the lift!
-- Cybersecurity provisions are duly implemented!
-- Consider Blockchain applications? Costs?

17. Massimo Bezzi - Vice President
In conclusion…
A few proposals to SMEs for the future:
Make worldwide known that SMEs are providing all the necessary instructions specified in the Lifts Directive!!!
At least via a website where all the lift owners can access the information for maintenance and repairs suitable for : their lift’s whole life!!!
Favour the implementation of systems, such as the Spanish example, where this mandatory information is collected and managed by some Supranational or Local Authority !!

18. Massimo Bezzi - Vice President
In conclusion…
…further proposal for the future…
When all new lifts will have all the necessary tools and instructions
How could the existing lifts be brought to a similar level of safe working operation?
Should we plan a way to “recall” recent or old lifts that are not provided with the necessary tools and instructions?

19. Massimo Bezzi - Vice President
Importance of instructions for use:
how to improve availability
Thank you for your kind attention
Luciano Faletto
SBS Forum «Lifts reaching the Cloud»
18nt December 2018

20. SBS Forum «Lifts going to the Cloud»
SBS Forum «Lifts going to the Cloud»
18nt December 2018

21. Massimo Bezzi - Vice President
In conclusion…