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Technische Universiät Berlin stammhaus Osnabrück

Institut für Technischen Umweltschutz Bearbeitet durch:Karl-Michael Renz

Attn: Mr. Nikolay Minkov Telefon:o54i/5346-153Telefax: 0541 / 58 46- 155

Straße des 17. Juni 135 E-Mail: renzeosma-aufzuege.de

10623 Berlin Osnabrück, den 03. Februar 2014

UN CRC 4354 LIFTS (ELEVATORS)

Dear Mr. Minkov,

In the context of the public consultation of the UN CRC 4354 we would like to send you in the annex to thisletter our comments and suggestions.

This PCR is the very first milestone for the unification of environmental declarations of elevators. Therefore, weexpect that this PCR will receive the highest attention. Due to the high relevance of PCR and their impact on theoverall environment of the elevators a broad discussion by all concerned institutions, companies and socialgroups is necessary. For this discussion, more time is needed. Therefore we would like to ask you first of all, toextend the consultation period for at least 6 to 12 months. This time is especially needed to make the PCRmanageable for a larger area of the elevator industry. The elevator industry comprises alone in Germany morethan 800 companies. Most of them are small and midsize lift installations companies, but also many suppliers ofelevator components, planners and testing organizations. They all have to play their part in the application of thePCR. The time should be used to "bring them all into the boat". This task could be most easily solved by the helpof the associations VDMA and ELA.

With the current Version of the UN CPC 4354 environmental declarations can be created for far less than 50 %of all elevators. The environmental declarations are needed before an elevator is ordered by a dient. In order tocreate better conditions for more environmental declarations it is necessary to adapt the PCR better to thepossibilities of the suppliers of elevator components. Builders and planners of buildings can reliably detect, whichelevator will have the best environmental performance, because the declarations may be based on differentassumptions. The rules in the PCR should be more clearly. Our comments and suggestions aimed atimprovement in this direction. Due to the shortness of the time available, they are unfortunately still somewhatincomplete.

This letter and its annex will be sent to you electronically via email only in order to reach the intended timeline. Incase you have any further questions, please do not hesitate to contact us.

Best regards.

i.V.

Technisches Büro Mechanik / Entwicklung

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Template of the Comments and Proposed Changes for PCR DRAFTFOR LIFTS byOSMA Aufzüge

Date: 2014-02-05Document: PCR ElevatorVersion 1.0 DRAFT FOR OPEN

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This PCR will receive the highestattention. Due to the high relevanceof PCR and their impact on the overallenvironment of the elevators a broaddiscussion by all concernedinstitutions, companies and socialgroups is necessary. The establishmentof the working group, who preparedthis PCR, could not be perceived bythe public. Normally nobody is lookingin this internet forum, and no one hastried to contact these groups.

Time is too short to involve allstakeholders and institutions. (Seeabove).

The parameters in the table are notenough to describe a lift clear.

What's with elevators, which arespecifically designed for a building?These elevators have no name and nosales catalogue.

Proposed change

The working group, who preparedthis PCR, should be expanded sothat all relevant groups arerepresented. We suggest to involverepresentatives of the associations(VDMA, ELA), of componentsuppliers, of midsize l lift installationscompanies, of testing organizationsand planners of elevators.

Open consultation period: 2013-12. 06 until 201 5-02-06

The table should be revisedcompletely in the extendeddiscussion period.

The table should be revisedcompletely in the extendeddiscussion period.

Observations ofthe secretariat

Type of comment: ge = general te = technical ed = editorialpage! of 2

Template of the Comments and Proposed Changes for PCR DRAFTFOR LIFTS byOSMA Aufzüge

Date: 2014-02-05Document: PCR Elevator

Version 1.0 DRAFT FOR OPEN

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What's with functional unit ofelevators, which are specificallydesigned for a building? Neither VDI4707 Part 1 nor ISO 25745 Part 2 hasa solution for determining the energyconsumption before the constructionof an elevator.

The life time of elevators is verydifferent. Therefore, a comparison ofsuch EPDs when selecting the rightelevator is not possible.

Between the order of an elevator andthe installation of an elevator oftentakes more than two years. During thistime suppliers may change, the rulesfor the elevators may change, ... .When have the EPS to be done? Whenhave they to be changed? How muchgeneric data may be used for air, road,rail, water?

More generic data are necessary.

Proposed change

This problem should be discussedand solved in the extendeddiscussion period. Perhaps VDI 4707Part 2 could be used.

This problem should be discussedand solved in the extendeddiscussion period. Variousapproaches should be discussed: a)scaling all the key figures at 1 year,by dividing the characteristic valuesthrough the number of lifetimeyears, or b) Identification of anycharacteristics for different lifetimes,or ...

This problem should be discussed inthe extended discussion period.

Observations ofthe secretariat

Type of comment: ge = general te = technical ed = editorialpage2 of 2