comments overvie… · web viewcontributor’s contact person. initials. organization. submitted...

Preparation phase – Collection of comments from stakeholders for the period 06.12.2013-07.02.2014PCR Lifts (elevators) CPC 4354 V1.0 DRAFT FOR OPEN CONSULTATION

Contributor’s contact person Initials Organization Submitted via Submission

dateEtienne Lees-Per-asso ELP Bureau Veritas CODDE Moderator

PCR Online Platform 27.01.2014

Jan König VFA VFA-Interlift e.V. Moderator 05.02.2014

Sascha Iqbal IQC IQ Consult GmbH Moderator 05.02.2014

Urs Thumm Schind-ler Schindler Elevator Ltd. Moderator

PCR Online Platform 06.02.2014

Hanna Uusitalo ELA European Lift Association Moderator PCR Online Platform 06.02.2014

Hanna Uusitalo KONE KONE PCR Online Platform 06.02.2014

Karl-Michael Renz OSMA OSMA Aufzüge Albert Schenk GmbH & Co. KG Moderator PCR Online Platform 06.02.2014

Stefania Galletti IMQ IMQ S.p.A. PCR Online Platform 06.02.2014

Cornelia Stettler CS Carbotech AG Moderator 07.02.2014


№Comment provider (date)

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Comment Proposed change

1.ELP (27.01.14)

3.2 Table 3-4 ge The differences between the two approaches can be a problem as the results can be drastically different. The point in keeping two different methods for a same product is surprising as the PCR should harmonize the practices by reducing the modelling choices.Moreover, the approach A appears to reduce the environmental impacts of the products by not taking into consideration the load factors nor the operating days per year.

Keeping only the approach B when the standard is published.

1 Type of comment: ge = general te = technical ed = editorial



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2.ELP (27.01.14)

4 §2 ge "Content declaration does not apply to proprietary materials and sub-stances such as those covered by exclusive legal rights including patent and trademarks". How are those materials and substances taken into account for the material declaration? Should we create a category named e.g. "materials unspecified"?

Clarifying this point.

3.ELP (27.01.14)

8.4.1 Table 8-1 ge The ELCD database doesn't provide electronic components data. In order to avoid confusion we recommend to remove it from this category

4.ELP (27.01.14)

8.4.1 Table 8-1 ge We would like to add the Bureau Veritas CODDE's EIME database to the list of available generic data sources for the different categories. Indeed, it is a long existing major database, specialized in the EEE sector with data such as, electronic components, PWB, thermoplastics, composites, etc. Therefore we believe it would be an important addition to the performed EPDs.

Addition of the EIME database

5.ELP (27.01.14)

7.5 ed Secondary data, as defined in the GPI, i.e. available LCI database, have to be used at almost 100% for every steps, because the producer won't have much information on the extraction of materials or energy production LCI. A threshold at 10% is impossible to respect.The idea as I understand it is that we should use no more than 10% of generic collection data, i.e. unspecified physical information on the product (mass, composition...)

Modifying the vocabulary: "Generic collection data on physical information must not exceed 10% of the core process..."

6.ELP (27.01.14)

10.2 te In order to be compliant with the EN 15804, it is necessary to focus on the CML characterisation methods listed by the standard. Moreover, the ELCD does not give characterisation factors for the methods listed (it uses differ-ent methods).

Removing all references to ELCD characterisation meth-ods in this part.

7.VFA (05.02.14) 1 geographical

regionge The PCR is global orientated. Why is it referenced to a European Directive

(95/16/EC Lift Directive)? (See also 11.6)

8.VFA (05.02.14) 1 This PCR was

prepared byge Please note DIN EN ISO 14025, 6.5

Interested parties are not involved. SME Manufactures of components, lifts and operators of lifts are not provided.

9.VFA (05.02.14) 1 Open consulta-

tion periodge The period for the open consultation is too short, it is not possible to in -

volve the interested parties in such short time.Please note DIN EN ISO 14025, 6.5:… Reasonable efforts should be made and resources and time should be made available to achieve this. …

The period for the open consultation shall extend to 6 month.

10.VFA (05.02.14) 1 Open consulta-

tion periodge A transition period for the introduction is generally customary for compar-

able papers and should also be granted here.The transition period shall define to 1 year.

11.VFA (05.02.14) 2 Table 2–1 ge The table should respond to the differentiated components.

Drive Unitso Motor with gearboxo Gearless motoro Hydraulic aggregate Doors

Please differentiate the table and include the VDI 4707-2.



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…12.

VFA (05.02.14) 2 Table 2–1 ge There is a lack at the energetic analysis of the components. Please specify the table and include the VDI 4707-2.

13.VFA (05.02.14) 2 Table 2–1 ge The energetic analysis should be declared by examples. Please include examples.

14.VFA (05.02.14) 2.2 … scope of this

PCR …ge Considers the PCR only new lifts? The referenced Lift Directive 95/16/EC is

specified for this kind of lifts.Please declare.

15.VFA (05.02.14) 3.1 VDI 4707 / ISO

25745ge By alternative use of VDI 4707 and ISO 25745 the EPDs are not compar-

able.Please choice VDI 4707 or ISO 25745 in PCR.

16.VFA (05.02.14) 3.1 VDI 4707 / ISO

25745ge For the differentiated view on components, the VDI 4707-2 is necessary.

See also DIN EN ISO 14025, Figure B.1.Please consider the VDI 4707-2 (see also Comment 5+6).

17.VFA (05.02.14) 4 Table 4-1 ge To enable transparency and traceability is a breakdown at the component

level necessary.Please expand the table.

18.VFA (05.02.14) 11.4 - ge Please note DIN EN ISO 14025, 8.1.2

Is here a review panel required? How should it be composed, if necessary?Please define this item.

19.IQC (05.02.14) 10.2 - ge Considering the global scope of the PCR, we highly recommend to include

TRACI methodology & impact categories for LCIA calculations, in order to facilitate “recognition of the PCR in the North American market, since the American system of certifying buildings “LEED” (Leadership in Energy & Environmental Design) in its latest version v4 started to award credits for construction projects when products are used which are verified and certified by an EPD. Thus, additional proof of the impact indicators of the Life Cycle Assessment (LCA) is required, on the basis of the TRACI-factors, applied in the USA” Reference: PDF p.3 of http://goo.gl/Yzp0LO

We highly recommend including TRACI methodology & impact categories for LCIA calculations.

20.Schindler (06.02.14) ge Schindler agrees and supports the comments given by ELA (QSEE). The

comments below are additional comments based on the outcome from further internal analysis.

21.Schindler (06.02.14) Tables ed Page breaks in tables, even in rows are confusing Avoid Tables to break across different pages.

If not possible make sure that the table headings are present on all pages

22.Schindler (06.02.14) List of Abbre-

viationsp.4 ed List of Abbreviations

Pst5 and Pst30 description mixed upCorrect it

23.Schindler (06.02.14) General

Introductionp.52ndlast para-graph

ed Sentence states “…of the three life-cycle stages mentioned above…”The three stages referenced to are nowhere listed on this page

clarify and correct

24.Schindler (06.02.14) 1 p.6

last lineed Typing error “… could be find…” “… could be found…”

25.Schindler (06.02.14) 2.2 p.8

3rd paragraphte Different definitions for inclined lifts exist for inclination angle (EN81,

A17.1, Lift Directive).Lift Directive: more than 15° to the horizontal

Define angle of inclination included in scope of the PCR

http://goo.gl/Yzp0LO



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EN81: not more than 15° to the verticalA17.1: 70° or less from the horizontal

26.Schindler (06.02.14) 3.1 p.11

Table 3-2te Low rise 2a, values missing for UC and Standby time To be defined

27.Schindler (06.02.14) 3.1 p.11

Table 3-2te High rise, usage is in our opinion to low.

Acc. VDI UC3 gives ~95’000 trips/yr (15s av. trip time)Acc. ISO UC3 300 trips/d gives ~80’000 trips/yr

We propose to useAcc. VDI: > Usage category 5 (gives ~370’000 trips/yr)Acc. ISO: > Usage category 5 (gives ~390’000 trips/yr)

28.Schindler (06.02.14) 3.2 p.13

Table 3-4ed Approach A

Functional unit is “per ….” > formulas are wrong, they must be 1 divided by…

Change formulas to:

FURSL= 1sRSL×Q

and FUFloor = 1P×FL

Change unit [tkm] to [1tkm

]

29.Schindler (06.02.14) 3.2 p.13

Table 3-4ed Approach B

Why is this FUtkm divided by 1000 this formula should be similar to Ap-proach A?Functional unit is “per ….” > formulas are wrong, they must be 1 divided by…

Change formulas to:

FURSL= 1sRSL×%Q

and FUFloor = 1P×FL

Change unit [tkm] to [1tkm

]

30.Schindler (06.02.14) 3.2 p.13

Table 3-4ed Use same symbols for the FU in approach A and B (FURSL / FUtkm) Use FURSL in Approach A and Approach B

31.Schindler (06.02.14) 4 p.14

3rd bullette What is the definition of “a very high specific environmental burden”?

This can be judged differently depending on the individual opinions.A clear measurable criterion (limit) needs to be defined

32.Schindler (06.02.14) 5 p.16 ed Metric units are not common in North America We propose to allow imperial units as an alternative for

the North American market

33.Schindler (06.02.14) 7.3

8.3p.20p.21

te For allocation total amount of units produced has to be considered. A minimal time span is missing

Propose to define allocation based on a minimal total amount produced in a year > change phrase to “ , the total annual amount of the units produced at the produc-tion site shall be used.”

34.Schindler (06.02.14) 10.4 p.28 te Waste generated along the whole life cycle shall be reported per func-

tional unit:One problem will be, that these figures are not part of the LCA/LCI and have to be calculated additionally!

Intention to be defined before final release



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35.Schindler (06.02.14) 10.4 p.28 te Non-hazardous waste:

Legal regulations are active! Therefore no additional reporting need exists.Intention to be defined before final release

36.ELA (06.02.14) ge Consider to delay consultation period in order to share the PCR with inter-

national elevator manufacturers outside Europe. It is also preferable to have construction association involved in consultation period. Also con-sider to delay the process until ISO 25745-2 specifications are fixed (by Q2/2014).C.2.3. SEEK COOPERATION WITH OTHER PARTIESDeveloping PCR documents should always be done as a co-operative effort including as many interested parties as possible, e.g. representatives different companies and branch organizations to ensure a broad accep-tance and reproducibility of the calculation rules. In case of single compa-nies initiating the work to develop PCR, it is especially important to seek co-operation with other parties that may be interested to participate in the work. This work can be supported by the program operator.

This is the responsibility of the Programme Operator and the PCR moderator to contact other interest parties. Currently contributors have been from Europe. We need contribution from global stakeholders for example from Asia-Pacific and from Americas (ISO members for exam-ple).

Extend open consultation until end of May 2014 to ensure involvement from international elevator manufacturers, especially from America’s and from Asia-Pacific regions.

37.ELA (06.02.14) ge Include terminology into the document for example Generic data and

secondary data terms are not defined and are unclear.What is OPD substances, where is it defined in the list of abbreviations used?GHS should state issued by UN

Include terminology into the document for example Generic data and secondary data terms are not defined and are unclear. Also GPI of Environdec should be listed as reference. It is not clear and known reference for the potential future consultation within the industry.

38.ELA (06.02.14) General All ge In the text of the Draft PCR different wording is used for the same defini -

tion (e.g. elevator and lift)Use the same wording through the whole document (e.g. following ISO 4190), i.e. lift (instead of elevator), rated load, rated speed

39.ELA (06.02.14) General All ge Too many options are included what makes the document more confusing Clarify or eliminate options

40.ELA (06.02.14) ge It is astonishing that such a PCR is developed by a circle with very limited

participation of the industry concerned. A call for participation never took place and such a document cannot claim for a wide acceptance.All parties concerned shall have the possibility to comment on such a document within a reasonable time frame to ensure a document of high quality and acceptance.The enquiry period of 2 months less the Christmas Period is not a means to full fill the above requirement.Should the present moderator not be willing to go into that direction, industry should think about taking over the leadership (e.g. within ELA) and bring the work to a better end

41.ELA (06.02.14) ge The document shall be written in such a way that it will also be possible

for SMEs to work out an environment declaration. There seems to be parts in the PCR, especially the content declarations, that have a low influence on the final result and are very difficult to assess. For such and similar items it should be possible to work with default values.



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42.ELA (06.02.14) General ge Based on the experience that several stake holder complain about the

short time schedule one has to discuss a re-schedule for the full task.ELA to take over moderator role? Is ELA in the position to take over this role (resources, budget)?The advantage is clear: ELA could define the schedule better and could better involve all member associations and members.

43.ELA (06.02.14) General ge PCR development procedure. The relevant document which defines the

PCR development procedure is the General Programme Instructions V2 from Environdec.In chapter 2.1.5 THE SECRETARIAT one of the “orders” is: to establish an accepted open consultation procedure for the programme structure and the Product Category Rules, PCRs,Many of the now participating organization have not been involved from the beginning of the PCR development; they even joined the task AFTER the start of open consultation.For these organizations it was and is not feasible to participate in a seri -ous and fair way. This conflicts with the self- defined order in the GPI.

The PCR development procedure has to be adopted to ensure an accepted open consultation procedure.(This does not concern the ISO vs. VDI discussion)

44.ELA (06.02.14) General ge In the list of consolidated comments 6.12.13 are several comments in the

state “TBD”. “TBD’s” shall be assigned to an actor and a deadline

45.ELA (06.02.14) ge At the end the PCR shall be lean and easy to handle. The relation between

the costs for the production of an environmental declaration and the costs for a lift shall have a reasonable ratio.

46.ELA (06.02.14) General ge In the list of consolidated comments 6.12.13 are several comments in the

state “Considered”.But is not evident how they have been reflected in the draft PCR for con-sultation (V1 6.12.13

“Considered” comments shall be assigned to an actor and a deadline

47.ELA (06.02.14) ge The use of the word "lift" followed by the use of "(elevator)" is unclear. It

should be clarified if this term "elevator" corresponds to the American word for lift in English (according to Lifts Directive) or if it corresponds to lifting appliance under Machinery Directive. It shall be clarified due to the fact that PCR document refers in its title to Escalators and travolators which are under Machinery Directive.

Clause 2.2. Specification of the product. Please use Lifts (elevators) termi-nology.

Clarify if this term "elevator" corresponds to the Ameri-can word for lift in English (according to Lifts Directive) or if it corresponds to lifting appliance under Machinery Directive. It shall be clarified due to the fact that PCR document refers in its title to Escalators and travolators which are under Machinery Directive.

Clarify and correct terminology throughout the document concerning Lifts (elevators).

48.ELA (06.02.14) 1 Geogra-phical

regionge The PCR is global orientated. Why is it referenced to a European Directive

(95/16/EC Lift Directive)? (See also 11.6)

49.ELA (06.02.14) 1 This PCR was

prepared byge Please note DIN EN ISO 14025, 6.5

Interested parties are not involved. SME Manufactures of components ,



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lifts and operators of lifts are not provided.

50.ELA (06.02.14) 1 Open consulta-

tion periodge The period for the open consultation is too short, it is not possible to in -

volve the interested parties in such short time.Please note DIN EN ISO 14025, 6.5:… Reasonable efforts should be made and resources and time should be made available to achieve this. …

51.ELA (06.02.14) 1 Open consulta-

tion periodge A transition period for the introduction is Generally customary for compa-

rable papers and should also be granted here.

52.ELA (06.02.14) 1.1 Footnote ge The definition of “the company” is taken from the Lift Directive 95/16/EC

Article a, point 4. If such definition is included in the PCR, the reference to the Lift Directive is not needed

Eliminate the reference to regional regulations and instead copy the definition in the PCR

53.ELA (06.02.14) 2 Table 2–1 ge The table should respond to the differentiated components.

54.ELA (06.02.14) Table 2–1 ge There is a lack at the energetic analysis of the components.

55.ELA (06.02.14) 2 Table 2–1 ge The energetic analysis should be declared by examples.

56.ELA (06.02.14) 2.1 ge The name and address of suppliers is confidential information requested

to be included in the EPD.This can be included in the LCA report but not disclosed in the EPD.

Eliminate this request and modify the text as follows:Information about the company issuing the EPD® shall be specified in the EPD®, including a description of the company, and a description of its overall environmental work.Mandatory information:• Name and address of company• The site(s), company or group of companies or those representing them for whom the EPD® is representa-tive, i.e. list of all in-house manufacturing locations• Name and address of supplier / manufacturers and designation of main component supplied by them• Issuer and contacts

57.ELA (06.02.14) 2.2 … scope of this

PCR …ge Considers the PCR only new lifts? The referenced Lift Directive 95/16/EC is

specified for this kind of lifts.



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58.ELA (06.02.14) 3.1 VDI 4707 / ISO

25745ge By alternative use of VDI 4707 and ISO 25745 the EPDs are not compara-

ble.

59.ELA (06.02.14) 3.1 VDI 4707 / ISO

25745ge For the differentiated view on components, the VDI 4707-2 is necessary.

See also DIN EN ISO 14025, Figure B.1.

60.ELA (06.02.14) 4 Table 4-1 ge To enable transparency and traceability is a breakdown at the component

level necessary.

61.ELA (06.02.14) 6.1 General

cut off rulesfirst sentence ge Difficult or impossible to apply, because you know the total environmental

impact of materials after LCA is done but not before that This cut off rule should be changed

62.ELA (06.02.14) 6.2, 6.3, 6.4, ge Concept for "Processes" and "Modules" unclear. See 2) below. We propose to integrate the process definitions in the

module chapters (As long there is no concept documen-tation available which shows any value added).PCR for CPC 43 does not use the process chapter either!

63.ELA (06.02.14) 7.1.1 Auxiliary ma-

terialsge too detailed, e.g. weight of screws in elevator is really a minor portion of

weightonly significant auxiliary materials should be included

64.ELA (06.02.14) 10.2 Impacts shall

be calculated using charac-terisation factors (CFs) recommended in regionally accepted impact assess-ment methods.

ge Regionally accepted impact assessment methods what does this mean in practice Define more clearly what are regionally accepted impact

assessment methods

65.ELA (06.02.14) 10.4 ge Waste is titled with very different ways in secondary databases and big-

gest amounts of waste is produced in the early upstream processes e.g. mining of minerals for metals

Requirement of waste Generated along the whole life cycle should be defined more clearly or changed

66.ELA (06.02.14) 11.2.1 Spec.

of Production Company

11.2.1 ge & te

Companies normally do not deploy any company internal information (e.g. in-house manufacturing locations, 3rd party suppliers, issuer etc.) and normally do not tell any product internal details (e.g. designation of main components).In addition companies may have very different sourcing and manufactur-ing concepts.A compare of such concepts is not the task of the LCA/EPD. But the results are documented in the core module.

Delete “ list of all in-house manufacturing locations”

Delete “Name and address of supplier / manufacturers and designation of main component supplied by them “

Delete “Issuer and contacts”

67.ELA (06.02.14) 11.3.4

EPD Contentge Warning flag: Due to individual solution in different regions and even

countries.For the EPD a representative disposal scenario per zone/region shall be defined and applied.

(Idea: The industry (under the lead of ELA) could build up a specific data base containing the information about the individual disposal scenarios for information purpose



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of the customers)

68.ELA (06.02.14) 11.3.5 see

10.5ge The lifetime of spare parts may be declared (years). Does this mean the

availability of spare parts? If not spare parts have the same lifetime as the original parts. Does this information represent any value added for the customer/owner of a lift? (maybe a little)

Delete/clarify

69.ELA (06.02.14) 11.4 ge Please note DIN EN ISO 14025, 8.1.2

Is here a review panel required? How should it be composed, if necessary?

70.ELA (06.02.14) Optional

(mandatory after 2016) Non alloyed steelLow-alloyed steelHigh-alloyed (stainless) steelGalvanized steel

Table 4-1 te Special steel grade should be mentioned to be able to use adequate LCI-data from databanks or General data from manufacturers (World Steel, World Stainless Steel, EAA)

Different sources have their own type to specify metal grades which PCR-rules should follow .

71.ELA (06.02.14)

EEE (electrical & electronic equipment) and PWBs (printed wiring boards) (mandatory)-EEE- PWBs

Table 4-1 te Define more clearly what is included in EEE and PWBs define what EEE means e.g. battery, cables and so on.define what is meant by PWBs: is it only circuit boards

72.ELA (06.02.14) page 17 Figure 6-1 te “cradle- to- job” term is not used in LCA Cradle- to- job term should be clarified or changed

73.ELA (06.02.14) Content

Declaration4Table 4-1

te Use of the CAS No: The proposal to add the CAS No for all substances and materials used was based on experienced customer requests. Even CAS No’s are available for all substances and mixtures, for many articles no CAS No is available. Examples are:o Alloyed steelso Many plasticso Etc.

The CAS No should be used only for the declaration of hazardous substances.For other materials the CAS No. should be only optional.



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74.ELA (06.02.14) EPD content te Due to very different definitions of the representative configurations for

the different zones EPD’s of different zones cannot be compared.The EPD should refer to the specific region/zone.

75.ELA (06.02.14) 2.2 te Home elevators are excluded from the scope of application of the PCR.

The definition of home elevators is not clear. We suggest eliminating this reference from the text

Eliminate the reference to home elevators and modify the text as follows:The PCR cannot be used for other type of products (e.g. skip hoists, home elevators, escalators or moving walk-ways) classified under the same UN CPC 4354.

76.ELA (06.02.14) 3.1 te Two scenarios for the calculation of the use phase are proposed: approach

A (VDI 4707-1) or approach B (ISO/DIS 25745-2). In the EPD® it shall be clearly stated which approach is chosen.ISO/DIS 25745-2 as a draft is incomplete and subject to changes. An EPD based on it only would bring confusion to the lift industry and to the cos-tumers

Delete all references to ISO/DIS ISO 25745-2. Approved EPD should not be based on ISO/DIS 25745-2

77.ELA (06.02.14) 3.1 te In the definition of the representative configuration, a reference is in-

cluded to a “additional category covering East Asia specifics”The representative configuration for East Asia is not identified in Table 3-2. This comment is not clear.Additional categories can be included for other Geographical areas

Eliminate this reference from the text and modify the text as follows:… a set of predetermined parameters or parameter ranges (Table 3–2), including additional category cover-ing East Asia specifics

78.ELA (06.02.14) 3.1 Table 3-2 te High Speed / High Rise elevator configurations are particular for every

customer. A representative configuration cannot be defined for themThe representative configurations collected in Table 3-2 show typical elevator configurations in Europe but they are not applicable outside EuropeThe same elevator can be used in different usage categories. All options should be included in the same EPD

Include the text: For those elevators which are not represented by the representative configurations de-fined in Table 3-2, the EPD will be developed for the particular elevator configuration. For these elevators, the comparison shall be done for the particular elevator configuration (e.g. High Rise/High Speed elevator whose configuration is defined by the customer)Extend Table 3-2 including additional representative configurations for other Geographical areas (North & South America, Europe and Asia)Revise the representative parameters in Table 3-2 and adapt them to all typical elevator configurations in EuropeEliminate the e usage category from the definition of the usage category

79.ELA (06.02.14) 3.1 te The following text is included: “Comparison of results between different

use categories is not possible and shall be avoided.”If the representative configuration is used, comparison is possible only for elevators from the same representative configuration

Change the reference from the use category to the representative configuration as follows: Comparison of results between different use categories representative configurations is not possible and shall be avoided.

80.ELA (06.02.14) 3.2 te The functional unit 'per floor' is not clear. What is the benefit of allowing

an additional functional unit? This FU would not take into consideration the traffic of the lift which in the FURSL is reflected by the km. Furthermore why is the number of passenger taken instead of the rated load in the other FU?

Delete functional unit 'per floor'.



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81.ELA (06.02.14) 3.1 and 3.2

table 3.3te Clause 3.1. and 3.2 are unclear, product specific range need to be further

defined, and product specific information needs to be stated that it refers to applicable range within that elevator platform.Unclear and non understandable.3.2. ISO categorization should be used, or what is the source in page 13 ISO table.

Clearly define that elevator platform range for represen-tative units means a range of values as defined in table 2-2 in nominal loads, nominal speed, travel length, # of stops, counterweight balancing, car dimensions, door dimensions, and number of doorsTherefore change example at table 3-3 to follow mini-mum requirement listed in paragraph 2.2 that elevator platform range for representative units will result to use range of values as defined in table 2-2 in nominal loads, nominal speed, travel length, # of stops, counterweight balancing, car dimensions, door dimensions, and num-ber of doors

82.ELA (06.02.14) 3, 3.1, 3.2 3, 3.1, 3.2

and 9.1te ISO 25745-2 vs. VDI 4707:

For optimal comparability of the results only one energy calcu-lation rule shall be in use. For the LCA a well-defined, applicable and available procedure how to measure and calculate the annual energy demand is needed. The classification is not a mandatory information for an EPD, but it will be used due to its good visibility of the results To ensure comparability the following prerequisites are manda-tory:o The definition of the usage category of the analysed lifto A representative configuration depending on the different zones (China, India, Europe, North America, South America, Russia etc.) related to the usage categoryo The functional unit

Use the same solution as Denmark in regulation BR10: The minimal energy efficiency ist defined as Class

B according VDI 4707 Part.1 As soon the ISO 25745 standard is available, it can

be regarded for a revision of the regulation(See comments No 51 to 63 in moderator’s consolidated list of comments 6.12.13)

83.ELA (06.02.14) 4 te It’s very difficult to Get detailed bill of materials of PWBs.

Precious materials are typically included in PWBs. And the percentage of the weight of the precious metals is insignificant when comparing it with elevator material weight.Delete OBD substances.

Delete the sentence. Any materials with a very high specific environmental burden per kg of extracted and processed raw materials (such as e.g. precious metals incorporated into electrical and electronic equipment).Delete OBD substances.

84.ELA (06.02.14) 4 te Change wording, delete including substances listed in the candi-

date list for authorization of SVHC.Change wording, delete including substances listed in the candidate list for authorization of SVHC.

85.ELA (06.02.14) 4 p.15 te EC 1272/2008 listed. From our point of view this regulation does not de-

fine any requirement for lifts? It is related to the classification, labelling and packaging of substances and mixtures, and not to articles, materials or products.Our comment has been rejected. It should be discussed in consultation phase again

Delete



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86.ELA (06.02.14) 4 Table 4-1 te The steel type is relevant for the LCA. Add examples for the adequate choice of LCI on steel

products (maybe in an appendix)

87.ELA (06.02.14) 6 Figure 6-1,

p.17te The definition of the core module is very much factory focused. This

seems too narrow for the elevator industry consideration.Looking at EN 15804 Table 1 (§6.3.6 p.26) the core module is basically defined as “Processes the manufacturer has influence over”

Propose to extend the core module to include A3’, A4 and A5 as well, as this is the part elevator system suppli-ers have control over.See also comments from earlier

88.ELA (06.02.14) 6.1 Cut-off

rules6.1 te What is 100%?

This definition is several times reused in this PCR.The hint not to misuse the Cut-off-Rules to hide anything (bad) is very good and shall be kept in the PCR.

A more detailed definition covering all aspects should be used (see the definition in PCR CPC 43)

89.ELA (06.02.14) 6.1 te We cannot agree before we have clear calculation rules for example how

100% and 95% is defined. If this material is in GPI it is not potentially known information for the lift industry.A minimum of 95 % for any impact category as defined in chapter 10.2 below of total environmental impact of materials and activities of modules assessed shall be included. Flows not included in the LCA shall be docu-mented in the EPD. Cut-off rules should not be used to hide results.

We cannot agree before we have clear calculation rules for example how 100% and 95% are defined. If this material is in GPI, it is not potentially known information for the lift industry.Clarify how the percentages are defined and agree calculation rules.

90.ELA (06.02.14) 6.3 (6.3) te For the calculation of the environmental impacts the transport distances

are a relevant parameter.Therefore a definition how to include the transport in the LCA has to be done.

Due to low impact in the overall LCA and the very differ-ent sourcing/manufacturing concepts the environmental impact for the transport shall be defined by a predefined value (e.g. 750 km)

91.ELA (06.02.14) 7.1.1 first bullet te The data of the reliable amount of water consumed is difficult to Get

(consumed water amount which is used in calculating water footprint is different than used water amount)

The amount of water consumed is relevant for PWBs manufacturers specifically

92.ELA (06.02.14) 7.1.1 A minimum of

95 % of the total weight of the declared product includ-ing packaging shall be in-cluded

te Packaging is optional why included here take away packaging from the sentence

93.ELA (06.02.14) 7.5 te Secondary data used must not exceed 10% of the core process life cycle

inventory.Please clarify secondary data usage of what. For example like in chapter 8.5. Sentence is missing relevance to be in line with Generic data de-scribed in the requirement 8.5.

Please clarify the 7.5 paragraph to be in line with clause 8.5. For example: Secondary data used must not exceed 10% of the core process life cycle inventories of the overall environmental impact from the product system.

94.ELA (06.02.14) 8.4.1 Table 8-1 te Generic data sources what does that mean? is Generic data source the

same as secondary data source? Use only terms: primary data source and secondary data source



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95.ELA (06.02.14) 9.3 te Take back programs need to be defines optional, not mandatory. Change wording, Take back programs need to be de-

fines optional, not mandatory.

96.ELA (06.02.14) 10.1 te optional indicators mentioned are difficult to define reliably from the data

of databanks Optional indicators should be taken off or changed

97.ELA (06.02.14) 10.2 ADP-elements

for non-fossil resources (includes all non-renewable, abiotic material resources (i.e. excepting fossil resources) in kg Antimony (Sb) equiva-lents

te ADP-elements are fossil why non-fossil resources is mentioned ADP-elements for fossil resources in kg Antimony (Sb) equivalents

98.ELA (06.02.14) 10.5 Specific pre-

and post-con-sumer recycled content of main compo-nents as de-fined in ISO 14021 includ-ing origin of information. For practical reasons a cut-off between 60% and 80% of total system mass as in-stalled is suffi-cient.

te This clause is unclear what does it mean in practice Define the clause more detailed

99.ELA (06.02.14) 11.3.2 see

10.1te Emission of ozone-depleting gases Based on feedback from LCA-experts

this is not a significant environmental impact for a lift delete

100.ELA (06.02.14) 11.3.2 see

10.1te Cumulative Energy Demand is missing.

This is an often requested information and the EPD is the right document To be added



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to deliver it101.

ELA (06.02.14) 11.4 te Verification should be optional.

This is business to business industry and mandatory verification is not necessary. PCR for lifts is clear enough guide for comparison.

Include to the paragraph 11.4. following sentence: The verification is optional.

102.ELA (06.02.14) 12 te Due to the nature of the industry, we do not drastically change our prod-

uct range (product design) in 5 year period. In practise changes made to product are minimal less that +/- 10%. Please describe by +/- 10% to which kind of analysis to use. We need easy and simple rules like +/- 10% of the typical weight of the elevator platform.Delete the paragraph 12.

Delete the paragraph 12 “If changes in any of the declared parameters of the EPD leading to a sig-nificant change of the product’s environmental performance are larger than +- 10% the EPD shall be adjusted. Regardless, the EPD shall be re-viewed every five years”.Or change the validity of the EPD is set at ten years.

103.ELA (06.02.14) 1 ed In the Draft PCR the following text is included:

“Preparing a PCR for lifts (elevators) will help avoiding inconsistencies between companies when reporting LCA results and increases trans-parency in Europe.”The PCR shall be worldwide applicable. No reference to its application in Europe must be included

Eliminate the reference to Europe and modify the text as follows:“Preparing a PCR for lifts (elevators) will help avoiding inconsistencies between companies when reporting LCA results and increases transparency in Europe.”

104.ELA (06.02.14) 2.2 Specific-

ation of the product

Table 2-2 ed "Usage Category" should be part of the product description too Add "Usage Category" add in column Example "1, 2, 3, 4 or 5" (based on VDI 4707 Part 1) Alternatively only the brand of the product and the

main application purpose shall be defined in this table and the individual definition of the product shall be done in chapter 3.1 Representative Config-uration…

105.ELA (06.02.14) 3.1 ed Table 3-1 is mentioned as a reference for the predetermined parameters

and parameter ranges. This reference is incorrect. Such information is shown in Table 3-2

Modify the reference to Table 3-2 as follows:… set of predetermined parameters or parameter ranges (Table 3–2)...

106.ELA (06.02.14) 3.1 Table 3-3 ed Load and area in the example don't fit together. Modify car area to 1100 x 1400

107.ELA (06.02.14) 3.2 Table 3-4 ed There is a mistake in the formula for the calculation of the FU Modify the formula as follows: FURSL=sRSL x Q / 1000

108.ELA (06.02.14) 4 Content

DeclarationTable 4-1 ed It states “…including maintenance & repair material (spare parts)”.

Experience shows that sufficient data about repair material due to failure is very difficult to collect.Furthermore this repair material will not be significant for the LCA.Comment has been rejected by moderator. Should be included in the consultation phase

Propose to include material (spare parts) used for pre-ventive maintenance over entire RSL only.

109.ELA (06.02.14) ed in the text words lift and elevator are used both, randomly in the text use only word lift or elevator



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110.ELA (06.02.14) 4 From the text, it is not clear if the disclosure of hazardous substances is

optional or mandatory . Keep the disclosure of hazardous substances optional.Include a reference to US optional hazardous substances disclosures: 'Health Product Declaration'

111.ELA (06.02.14) 6.2,

6.3p. 20, Row 24,Row 37

change

Production of operating and auxiliary material used is to be considered mandatory.Experience shows that the relevance of these material is not of relevance compared to energy and is difficult to collectOur comment has been considered to be defined with other contributors. There is no evidence that this has happen.

Propose to consider this by option (same as packaging material)

112.ELA (06.02.14) 8.5. ge Secondary data used must not exceed 10% of the core process life cycle

inventory.Please clarify secondary data usage to be in line with material proposals in 4.1, mandatory and optional requirements.

Please consider proposal for table 4.1. Clause 8.5. will need to be changed to be in line with proposal alteration of the table 4.1. ie, for the first two years level of detail in material reporting should be optional and after that mandatory.

113.ELA (06.02.14) 9.3 ge Recycled content needs to be optional Recycled content needs to be optional

114.ELA (06.02.14) 10.3. te Use of ReCiPe methodology should be the norm for calculation as defined

by the EUChange methodology for impact categories indicated to follow ReCiPe methodology.Methodologies defines in www.eebguide.euClarify 10.2.-10.3

115.ELA (06.02.14) 10.5 ge The Draft PCR request to include in the EPD qualitative terms information

about recommendations for energy saving measures related shaft thermal energy losses in the responsibility of the building owner (loss of heat in cold climates and heated buildings; loss of cold air in hot climates and air conditioned buildings) such as e.g. automatic ventilation dampers or heat exchangers.

Shaft thermal energy loses are of the responsibility of the elevator manufacturer. Eliminate this request from the PCR.

116.ELA (06.02.14) Table 3-2 ge Fixing the service life of the elevator to 20 years can be a disadvantage

for those elevators designed for a longer service life.The service life depends on the use of the elevator (more use, shorter service life)

Eliminate the reference service life from the definition of the representative configuration. This shall be defined by the manufacturer

117.KONE (06.02.14) - - ge KONE agrees and supports the comments given by ELA (QSEE) in letter

format and table format:1. European Lift Association Letter to Mr. Jense and to Mr. Minkov high-lighting ELA comments and proposals for the development of the PCR for Lifts2. European Lift Association comments to open consultation (table format, 81 comments)

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118.OSMA (06.02.14)

1 ge This PCR will receive the highest attention. Due to the high relevance of PCR and their impact on the overall environment of the elevators a broad discussion by all concerned institutions, companies and social groups is necessary. The establishment of the working group, who prepared this PCR, could not be perceived by the public. Normally nobody is looking in

The working group, who prepared this PCR, should be expanded so that all relevant groups are represented. We suggest to involve representatives of the associ-ations (VDMA, ELA), of component suppliers, of midsize l lift installations companies, of testing organizations and

http://www.eebguide.eu/



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this internet forum, and no one has tried to contact these groups. planners of elevators.119.

OSMA (06.02.14)

1 ge Time is too short to involve all stakeholders and institutions. (See above). Open consultation period: 2013-12.06 until 2015-02-06

120.OSMA (06.02.14)

Table 2-2 te The parameters in the table are not enough to describe a lift clear. The table should be revised completely in the extended discussion period.

121.OSMA (06.02.14)

Table 2-2 ge What's with elevators, which are specifically designed for a building? These elevators have no name and no sales catalogue.

The table should be revised completely in the extended discussion period.

122.OSMA (06.02.14)

3 ge What's with functional unit of elevators, which are specifically designed for a building? Neither VDI 4707 Part 1 nor ISO 25745 Part 2 has a solution for determining the energy consumption before the construction of an elev-ator.

This problem should be discussed and solved in the extended discussion period. Perhaps VDI 4707 Part 2 could be used.

123.OSMA (06.02.14)

3 ge The life time of elevators is very different. Therefore, a comparison of such EPDs when selecting the right elevator is not possible.

This problem should be discussed and solved in the extended discussion period. Various approaches should be discussed: a) scaling all the key figures at 1 year, by dividing the characteristic values through the number of lifetime years, or b) identification of any characteristics for different lifetimes, or ...

124.OSMA (06.02.14)

6, 7 ge Between the order of an elevator and the installation of an elevator often takes more than two years. During this time suppliers may change, the rules for the elevators may change, … . When have the EPS to be done? When have they to be changed? How much generic data may be used for air, road, rail, water?

This problem should be discussed in the extended dis-cussion period.

125.OSMA (06.02.14)

ANNEX More generic data are necessary.

126.IMQ (06.02.14)

Table 3-3 ge 20 yrs as reference service life can be relatively short, especially for resid-ential lifts of countries like Italy. No motivation of this choice was found in the PCR text.

Reference Service Life = 25 years (quite typical for new lifts).

127.IMQ (06.02.14)

Table 3-1 ge The ranges provided by the standards for the average travel either time (hrs) or the number of trips per day, can heavily affect calculations.

The PCR should clearly state that the typical values indicated (not the ranges) shall be taken for the energy consumption calculations.

128.CS(07.02.14)

- - ge I did not repeat my comments from the first phase in the open discussion. I hope main points will be discussed though in the final phase:• calculations of the energy demand (clear conditions for the calculation, only one method)• standard choice of parameters for the analysis of a representatives systems• choice of indicators for the evaluations (ozone depletion not relevant)

The open discussion shows the demand for simple stan-dard evaluations. Considering the relevance of life cycle phases, except for the energy calculation and the mate-rial contribution simple procedures for the evaluation should be tolerated.

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