2025.12.08

Response to consultation: Proposal to amend the Swedish Maritime Administration's regulations (SJÖFS 2003:17) on passenger lifts, goods passenger lifts and small goods lifts on Swedish ships. Filing number: TSF 2020-172 

 The Swedish Maritime Administration's regulations and general advice on passenger lifts, goods passenger lifts and small goods lifts on Swedish ships (SJÖFS 2003:17) are repealed and replaced by the Swedish Transport Agency's collection of statutes (TSFS) with revised and updated rules and references. 

 References to standards 

However, we object to the fact that the statute contains mandatory requirements through direct references to the standard ISO 8383:1985. Our position is based partly on the fact that standards should generally not be mandatory, and partly on the fact that work is currently underway to replace this standard with ISO 8100-8. The statute therefore risks becoming outdated in the near future.