The exact number of lift-up doors in use in Estonia today is not known. However, it is estimated by industry operators that the number exceeds 100,000 units and may even be as high as half a million doors. Ensuring the safety of such a large number of installations is no easy task. There are several parties involved in ensuring the safety of lifts, with different rights and obligations.
What to do if a lift-up door looks unsafe?
If there is a suspicion of danger, the first step is to assess how great the risk is. In the case of imminent danger, you must act as prescribed in the emergency instructions. In the case of a minor threat, there are more options, but it is important not to leave it to yourself and, if possible, take photos and inform all concerned in writing. Avoid actions that may increase the risk or damage the door.
What can happen to me if I use the lift-up door?
The greatest risk when using a lift-up door is the risk of impact if the door leaf, when raised, should for any reason start to move downwards (fall). If the door is broken, this movement can be rapid and, due to the heavy weight of the door leaf, the impact on the head or other parts of the door could be so severe that it could kill you. In the event of a problem with the latches or fasteners, the door may also fall flat. There are also hazards associated with moving parts that can be trapped by different parts of the body (usually fingers) or, for example, hair. A lift-up door can catch you when moving upwards (especially if there is a pedestrian door on the lifting door), while moving downwards can crush your toes if you are too close to it. To avoid all this, keep away from a moving door, don't stand or let children play under a raised door, and regularly check and maintain the safety devices.
If you are using a vehicle, there is a risk of injury, particularly to the car's front and rear, if the door is not fitted with the correct safety devices.
How can I avoid risks?
Risks are reduced by proper design, installation, and maintenance. If these preconditions are met, the user can already prevent accidents and emergencies by following all safety instructions.
How often do I have to maintain the door?
Lift-up doors must be serviced according to the intervals specified by the door manufacturer, and maintenance is mandatory.
Which doors are more dangerous?
The following are considered to be factors that make the use of a door unsafe:
- Opening into a public space
- Inappropriate use (e.g. uninstructed people/sick/old/children);
- A large number of people who may come into contact with the door;
- High level of automation of the door;
- Low threshold
On the other hand, non-automatically operated lift-up doors used by a single family and do not open into a publicly accessible space are considered lower-risk products.
Should I buy a more expensive or cheaper door?
You can buy a more expensive or a cheaper door as long as it meets all the requirements. However, the buyer should always clarify why a particular door is offered at a lower price than others. Is the quality inferior? Has the cheapness been achieved at the expense of safety? Am I buying what I really need?
I have a problem. Can the Consumer Protection and Technical Regulatory Authority help?
The Consumer Protection and Technical Regulatory Authority checks the conformity of lift-up doors but does not carry out expert assessments. The Consumer Protection and Technical Regulatory Authority cannot represent you or get involved in civil disputes. The Consumer Protection and Technical Regulatory Authority has the power to issue injunctions to stop the use of unsafe hoists and bring them into conformity. The Consumer Protection and Technical Regulatory Authority can also give you safety advice.
The lift-up door owner must use the door in accordance with the instructions provided by the door manufacturer (instruction manual and safety label). This is subject to the availability of the instruction manual.
Users and owners must be aware that if a large lift-up door does not have a pedestrian passage, pedestrians cannot open the door to pass through – it is for vehicles only. If necessary, a pedestrian passage must be provided.
The owner must keep the door in a good state of repair by contracting maintenance and repairs to a competent person in good time. Maintenance intervals are given by the door manufacturer either in terms of time (e.g. 3-6 months) or depending on the intensity of use (e.g. 1000-5000 operating cycles). Maintenance is compulsory (see § 4(1) and § 6(2)(4) of the Equipment Safety Act). Owners and users should not wait until the door breaks down, but prevent it by maintenance. In order to avoid neglect, it is wise to sign a maintenance contract with a reliable company.
Although the person who maintains and repairs the lift-up door must be competent, it is still the responsibility of both the owner and the user to ensure that the door is safe for use after maintenance or repair, i.e., that it is working as intended, that it is not missing any parts (especially safety devices) and that it has not been rebuilt. A door which is technically unsound or which poses an imminent danger must not be made available (allowed) to users by the owner and must not be used by the user.
Where necessary, the owner, the owner's representative or a competent door maintenance/repair person must instruct unskilled users on how to use the door safely.
The owner (or his authorised manager) must also be prepared for an emergency situation where it is necessary to place 2 warning signs (one on, one off) on or near the door to indicate that the door is broken and life-threatening. Such warning labels, which are large enough and weatherproof, should be in place from the moment the door is put into service, otherwise there is nowhere to take them in an emergency.
When purchasing a lift-up door, the buyer must choose a door that meets the building's specific characteristics, satisfies the needs of the door users, and complies with the requirements laid down. A satisfactory door shall be fitted with all the safety devices necessary to prevent accidents and emergencies, bear the CE marking, and be accompanied by a declaration of conformity and instructions for use and maintenance in an official language of the Contracting Party to the Agreement on the European Economic Area understood by the end-user. To increase safety, it is recommended to mark the danger area on the door's base with a bright color.
Checking the presence of the CE marking and the Declaration of Conformity, and carrying out simple safety tests on the door before putting it into service, can save the purchaser a lot of time and effort should the door later prove to be dangerous or cause damage. Who and what is declared in the Declaration of Conformity is of utmost importance – see examples of different types of declarations with comments.
If the lift-up door is purchased directly from a third country without intermediaries, for example, for personal use, the buyer must consider the additional obligations of the importer.
The buyer must have the door installed by a competent person. Self-installation, or having an incompetent person install the door, entails significant security risks and potential problems for the door's subsequent use. Avoid novice installers, especially seasonal workers from construction companies. Installation must comply with the door manufacturer's instructions (installation manual).
Under no circumstances shall the purchaser take into use, or allow anyone to take into use, a lift-up door that is not ready for use or is not safe because of the method of installation or the door's design.
On receipt of the door, the purchaser shall ensure that all the required documentation (final declaration of conformity, instructions) has been handed over to him and that the door bears safety warnings or pictograms.
The lift installer and the repairer/maintainer must be competent to carry out the work and install the lift-up door and its components (e.g., drive, automation) following the instructions (installation instructions) provided by the door manufacturer and the component manufacturers. The installer must provide the contracting entity with instructions for the door's use and maintenance and a declaration of conformity. Both the door's installer and the subsequent repairer and maintainer must have all the necessary tools (e.g., torque wrenches) and measuring instruments.
If the installer installs a partially assembled lift-up door or rebuilds the lift-up door during installation (tampering with components), or if the repairer/maintainer modifies the door assembly, such activities may be considered as machine manufacturing.
For example, suppose an actuator with a control system is added to an existing manually-operated hoistway. In that case, the person who carried out the additions is considered the manufacturer of the automated hoistway with all the machine manufacturer's obligations.
The installer should prevent the risk in the event of an immediate or delayed hazard, i.e., as appropriate:
- not to start the installation of the lift-up door (or its components).
- (or any of the components of the hoist), stop the installation work in progress and preserve the hoist door in a safe condition, and do not hand over the dangerous equipment for commissioning until the door as a whole is safe.
It is the installer and the maintainer's responsibility to prevent the use of the unsafe door (e.g., bracing, fixing the door leaf, disconnecting the door from the mains). If the door is modified (e.g., components are replaced), the modification must be documented in writing and handed over to the owner.
The repairer/maintainer must always be aware of a particular door's requirements not to break the law through ignorance.
The lift-up door vendor must sell only safe and proper doors. The seller must ensure that the door bears the manufacturer's label and is accompanied by a declaration of conformity and instructions for use and maintenance in the European Economic Area Contracting Party's official language, which is understood by the end-user. The manufacturer's name, address, CE marking, product identification, and many other details must appear on its label.
If the lift-up door sold is not in conformity, the vendor must bring it in accordance himself and not offer it for sale or buy back doors already sold.
The seller needs to understand the extent of his responsibility, i.e., whether he is selling somebody else's product or whether he is the manufacturer of the final, complete lift-up door. Based on the business scheme used, the door's delivery to the end-user can be roughly divided into types A to D.
An importer of lift-up doors from a third country (e.g., Belarus) has some additional obligations compared to the seller. For example, the importer has to ensure that the manufacturer has carried out an appropriate conformity assessment of the door and has drawn up the technical documentation. The technical documentation is available to the Consumer Protection and Technical Regulatory Authority on request for ten years. The importer may demonstrate his ability to meet these requirements through a manufacturer's representation agreement or letter of mandate under Article R3 of Decision No 768/2008/EU.
The manufacturer must produce suitable hoists and carry out conformity assessment. In the conformity assessment, the manufacturer draws up the required technical documentation and issues a declaration of conformity. The manufacturer can then affix the CE conformity marking to the door and start marketing the product. The manufacturer does not necessarily have to carry out the conformity assessment itself.
The manufacturer is advised to follow the relevant standards, but in most cases, full compliance with the essential health and safety requirements of the Machinery Directive cannot be achieved in this way. For example, if a lift-up door is manufactured by the old standard EN 12453:2000, the following safety requirements of Annex I to the Machinery Directive 2006/42/EC, Annex I, points 1.1.2, 1.1.6, 1.2.1, 1.3.7, 184.108.40.206, 1.4.1, 1.4.3 and 1.5.14, do not need to be additionally ensured.
A manufacturer is any person who manufactures a lift-up door, or who has a lift-up door designed or manufactured, and who markets that product under his own name or trademark. Any person who modifies a product already placed on the market so that compliance with the applicable requirements may be affected shall also be considered a manufacturer.
For example, if an Estonian company buys a hoist manufactured in another EU Member State, which is produced as an open device (for manual lifting), and resells it or installs it or has it installed with a drive, then this Estonian company qualifies as a manufacturer of an automated lifting device because it has substantially modified the original product (both technically and legally – the requirements of the Machinery Directive are added to the Construction Products Regulation). Based on the business scheme used, the door's delivery to the end-user can be roughly divided into Types A to D. This means that the door has to be of the same type as the lift truck.
In the case in the example, the manufacturer in another EU Member State is operating legally. At the same time, the Estonian company that has automated the door may not even be aware that it has taken on the role of door manufacturer.
Last updated: 06.04.2021