Ylva Johansson Minister for Employment The Government Offices SE-103 33

22 February 2019

Dear Minister,

We would like to share our concerns regarding the interpretation by the Swedish Work Environment Authority of the EU Machinery Directive (2006/42/EC). This interpretation already has major detrimental effects on the wind industry. And it blunts the momentum of wind energy in Sweden which would otherwise double its output to 35 TWh over the next 4 years.

Our industry’s main concern and responsibility lies with the health and safety of our workforce. We therefore uphold the highest safety standards starting with the design of turbines.

We recognise the important role of the Swedish Work Environment Authority in carrying out Health and Safety conformity assessment in line with EU legislation. However, as stated in the Machinery Directive, Health and Safety requirements need to be applied with discernment to factor in the state of the art and economic considerations. In our view, the approach of the Swedish Work Environment Authority applies neither of these principles.

The conformity assessments and recommendation of the Authority apply a one-size-fits-all approach that is ill suited to a dynamic, competitive and innovative sector like wind energy. It is already resulting in the suspension of the sale of certain turbine models. It may also involve manufacturers proceeding with cumbersome retrofits.

More importantly, many of the Authority’s recommendations make turbines less safe to operate. Each decision in the design of safety features comes with tradeoffs. For instance, adding a guard rail around an escape hatch as recommended by the Authority will result in more manual handling and therefore more hazardous operations. The industry has been diligent in conducting risk assessment as part of the implementation of the Machinery Directive. The Authority has unfortunately largely ignored the important role of these risk assessments.

We therefore appeal to you as National Governments are mandated with ensuring the appropriate implementation of the EU Machinery Directive.

Rue d’Arlon 80, 1040 Brussels, Belgium · T +32 2 213 18 11 · F +32 2 213 18 90 · windeurope.org

We are confident that a technical dialogue between representatives of the Swedish Work Environment Authority and of the turbine manufacturers would help identify common ground in implementing the Machinery Directive while ensuring the safety of our workforce in charge of Operations and Maintenance.

This dialogue may also become a model helping uphold high Health and Safety standards while enhancing trade within the EU of the products that are delivering a cost-effective energy transition.

We would be grateful for an opportunity to meet with you, along with a delegation of manufacturers, to exchange on the best way forward.

Kind regards,

Giles Dickson Charlotte Unger Larson Chief Executive Officer Chief Executive Officer WindEurope Swedish Wind Energy Association

CC:

Ibrahim Baylan Minister for Enterprise The Government Offices SE-103 33 Stockholm Sweden

Anders Ygeman Minister for Energy The Government Offices SE-103 33 Stockholm Sweden