Modernisation of Machine RoomLess Lifts (MRL)
The MRL type lift began life in the Lift Industry in the late 1990s, but what is a MRL lift.
The MRL type lift will have the Drive Machine or Hydraulic Tank within the lift shaft and the Lift Controller or Interface to the Lift Controller will be at a lobby or corridor area. No requirement to have a SEPARATE room (Machine Room) to house the Drive Machine or Hydraulic Tank, Controller etc.
EN81-1 (Traction Lift) and EN81-2 (Hydraulic) and EN81-20 standards were written for lifts with a Machine Room type lifts and does not consider the MRL type lift. That means that the Lift Industry Innovation was ahead of the ‘In Force’ standard applicable (EN81-1 & 2 started on July 1st1999).
The MRL lift by design did NOT comply with all aspects of EN81-1, 2 & 20 and as there were many types of MRL designs it would not have been practical to write a MRL standard to meet full EN81-1, 2 & 20 compliances.
The Original Equipment Manufacturer (OEM) of a MRL type lift would have to submit the FULL LIFT design to a Notified Body where the Lift Designer would highlight all the areas of the lift that did not comply with EN81-1 or 2 or 20 on a Clause-by-Clause basis. The OEM would offer an alternative solution to the EN81-1 or 2 or 20 clause that was not met.
The result is the Notified Body would accept the alternate solutions, and a MODEL Lift design would be created. The Notified Body would issue a certificate for the specific MRL Lift that is called a ‘Type Examination’ Certificate.
The ‘Type Examination’ Certificate will be particular (have specific identification) to the MRL Lift submitted so due to the many MRL lift designs, there will be many different ‘Type Examination’ Certificates.
As the MRL began lift in the late 1990’s, many of them will be over 20 years old and would be at an age for replacement or Modernisation. For Modernisation the issue of the ‘Type Examination’ Certificate being issued was against the initial MRL lift installed should be considered.
When a MRL lift is Modernised, it can be due to the extent of the Modernisation that the ‘Type Examination’ Certificate no longer applies to the MRL Lift.
The Modernising Company Has a Number of Options
Submit the Modernisation package to the Notified Body that issued the original specific Identification to attain a NEW Modernisation package ‘Type Examination’ Certificate. Usually only OEM will perform.
Modernise the lift WITHIN the ‘Type Examination’ Certificate original parameters.
Just Modernise the Lift.
For POINT 1 the most likely to perform this action is the MRL Lift Designer (OEM) who could submit their Modernisation new design having all the details of the original MRL design known. To have a new ‘Type Examination’ Certificate specific to the modernised MRL Lift.
For POINT 2. Can only occur when the contents of the ‘Type Examination’ Certificate are known.
For POINT 3 this is what is most likely to occur within the Lift Industry. For the Modernising Lift Company they will now be FULLY responsible for the package they have installed, a Design Risk Assessment (DRA) should have been performed. There will be no new Type Examination Certificate issued for the changes to the original lift.
The Modernising Lift Company should do the following as they will take full responsibility for the New Design:
Remove all details of the Original Lift Installer, there should be NO identifying of the Original Lift Installer.
The Original Lift Installer Local Certifying Notified Body is not valid and should not be visible in the lift. Reason – the Local Certifying Notified Body number that was visible in the lift car was for the original MRL Lift installation company.
Consult with their local Certifying Notified Body to attain permission to apply the Modernising Company Local Certifying Notified Body number in the lift car.
Key Considerations
Modernising any CE marked Lift with a Machine Room or an MRL requires consideration to not affect the Essential Health and Safety Requirements of the Lift Directive. In the case of the MRL type lift there can be specific systems in place by the OEM on the lift that may not be considered when being Modernised and it is possible to reduce the level of safety compared to the Originally installed MRL lift.
Conclusion
Lift Original Equipment Manufacturers (OEMs) will most likely have Modernisation packages that will have a new ‘Type Examination’ Certificate issued to meet all the terms required.
NON-Original Equipment Manufacturers will not have a ‘Type Examination’ Certificate for the MOD package and should have performed and retained a Design Risk Assessment (DRA). The NON-OEM should make sure that they understand that they have taken full responsibility for the design and OEM details are fully removed from the lift (name plates etc). There will be no valid CE marking in the lift car (as required) unless they have submitted the DRA to the local Notified Body and they have accepted the DRA solution and allow a new CE marking to be placed in the lift car.
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