European Federation of Hard of Hearing People
EFHOH
EFHOH’s vision is a Europe where people with hearing loss can live without barriers, and have opportunities to participate at all levels in society.
ID: 209304118333-41
Lobbying Activity
Response to Evaluation of the EU Lifts Directive
13 Feb 2025
European Federation of Hard of Hearing People (EFHOH) feedback to European Commissions evaluation of the Lifts Safety Directive (2014/33/EU) As stressed in Article 9 of the CRPD, accessibility is a human right and a pre-condition for the full and effective participation of persons with disabilities in society. Lifts improve access to the built environment allowing persons with disabilities to leave home, go to work, use public transport and enjoy leisure time. However, lifts, do not guarantee accessibility and especially safety in case of emergencies per see. They need to be designed in a specific way to make sure that the people who are the main target group, persons with disabilities. This includes blind and partially sighted, deaf and hard of hearing, persons with mobility impairments as well as persons with intellectual and cognitive disabilities. Assessment of the Safety Directive The EU and its Member States are parties to the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). This Convention seats clear obligations to its signatories, including the adoption of legislation that advances accessibility (Article 9). The text of the Lifts Safety Directive makes no mention of accessibility, which is left implied in the health or safety aspects of the lifts. This is particularly the case in Annex I where the requirements for people with disabilities are laid down. While the EAA has well developed Annexes explain the functional requirements that ensure accessibility, the lifts Directive sets general requirements that are further developed by a Harmonized European Standard (EN 81-70). Relation to EN 81-70 (2022 version) EN 81-70 is key to support the implementation of the directive as it explains how to achieve accessibility technically. However, if the standard does not consider the requirements for people with disabilities, lifts will remain inaccessible. Although EN 81-70 was revised in 2022, there are still many elements that exclude people with disabilities: Accessible communication systems (5.4.2.5.3 5.4.2.4) current standard does not contain any technical mean to guarantee communication for deaf, hard of hearing, deafblind people and people with speech impairments in the event of an emergency, according to the multiple-sense principle. For example, the use of an induction loop is a voluntary requirement. Hearing loops enable those who use assistive hearing technologies to communicate, without distracting background noise or reverberations. For many deafblind people direct hearing access via hearing loop is essential to communicate with the emergency services. Key accessibility features are only a recommendation (Annex D). Some elements that are essential to guarantee equal access to emergency such as an induction loop according to EN 60118-4:2015 should be provided as hearing assistance for alarm systems. Conclusion To ensure accessibility of lifts for persons who are deafened, deaf or hard of hearing we need legislation with clear accessibility requirements and supported by standards that meet the expectations of their main intended users. In order to communicate with external services, people with hearing loss need alternative ways of communicating with emergency services. Both methods of text-based communication and hearing loops are required. For the reasons explained in this paper, neither the Directive (with no reference to accessibility at all and general requirements) nor the harmonised standard (with important gaps) adopted to support its implementation achieve this goal. EFHOH urges adding essential accessibility requirements to ensure safety of lifts to people with hearing loss. Lidia Best, President I lidia.best@efhoh.org
Read full responseMeeting with Jarosław Duda-Latoszewski (Member of the European Parliament)
30 Nov 2023 · World Hearing Day