Do evacuation chairs need servicing?
Estimated reading time: 78 minutes
Do evacuation chairs need servicing? It’s one of the most commonly asked questions that we hear when it comes to the myriad of different makes and models of evacuation chair that are on the market. While many people will see this requirement as “just a money making scheme” by the manufacturers, it’s actually a legal requirement. In this blog we look into this in detail and answer the question of why and how often servicing should take place.
TL:DR; Yes. At least annually and by a competent person (not your office caretaker).
Table of contents
What is an evacuation chair?
It makes sense to start at the beginning, so let’s do just that; exactly what is an evacuation chair? Put simply, an evacuation chair is a mechanical device that is used to help assist a person (the passenger) to transit to another area. Typically these chairs will be used to help move a person who has impaired mobility and needs assistance in transiting to another location.
Examples include:
1) someone who normally walks slowly with the assistance of crutches, but now needs to exit the premises swiftly, such as during a fire alarm activation.
2) someone who normally uses a wheelchair to get around, and as a result of the fire alarm activation, is not able to use the buildings elevators to get to the ground floor.
3) someone who is now intoxicated and needs to be assisted from the premises as they are unable to move by themselves.
Generally speaking, when a passenger needs to use an evacuation chair, they’re typically moving either horizontally through a building to another area, or downwards through a flight of stairs. In these instances mechanical chairs are typically the “go-to” product as they’re relatively cheap (£££), light-weight and can be operated by just one operator with the assistance of a second person.
Yes, operating a manual evacuation chair is most definitely a two person job, despite what manufacturers say in their sales brochures. This is especially the case when the passenger is more than around 14 stone (90kg) in weight, as the effort required to add additional braking force to the chair from behind can be considerable.
For passengers who are bigger than 14 stone, or that need to go up a flight of stairs, or even just a few steps, there are an increasing number of battery powered evacuation chairs available on the market. While they remove the manual handling aspect of using an evacuation chair, they are significantly more expensive than the traditional mechanical types (££££-£££££). As an alternative, many manufacturers of traditional mechanical evacuation chairs make versions of their mechanical chairs that feature additional handles, specifically so that they can be carried up steps by four people.
The law relating to evacuation chair maintenance
As you might imagine, there are laws in the UK that relate to pretty much everything. That’s also the case with evacuation equipment, whether its an evacuation chair, or an evacuation sledge (which are also known as ski sheets or evacuation mats).
For reference, the shortened term “evac chair” is generally used to denote a specific brand manufacturer, so we’ll stick to the longer “evacuation” in this blog.
In the 1990’s the UK rolled out it’s version of a tranche of EU legislation. The one that’s particularly relevant in this instance is The Provision and Use of Work Equipment Regulations 1998, commonly known as “PUWER” (pronounced “pew-er”).
Quite rightly, this law requires that anything that you bring to the workplace for use at work, or your employer provides for you to use at work, is fit for purpose. The Regulations provide various requirements for maintenance, the most generous being that servicing is carried out at a default period of every 12 months. However this comes with the caveat that the maintenance schedule is based on a risk assessment.
In practice this means that the more often you use your evacuation chair, the more worn it will become and therefore the more likely it is to need additional maintenance checks within each 12 month period.
Interestingly, the Lifting Operations and Lifting Equipment Regulations 1992 (LOLER) (pronounced “low-ler”) don’t apply to evacuation chairs as the main function of an evacuation chair is to carry/support a person, rather than to lift them. If these regulations did apply to evacuation chairs, then the default maximum maintenance period would be 6 months. This is the case for people elevators, care setting patient hoists and slings, etc.
At this point it’s worth looking at the Interpretation section of the The Provision and Use of Work Equipment Regulations 1998, in particular these points;
The key term for us to note in relation to “inspection” and “thorough examination” is that of “competent person”. In respect of “use”, it’s “maintaining, servicing and cleaning”. This leads us to the conclusion that whomever we engage to maintain our evacuation chairs or sledges must be competent.
But how do we demonstrate “competence”?
Typically this is done my having five things;
- Skills – having sufficient of such so that the person can undertake the task easily.
- Knowledge – of the task at hand and how to undertake the task safely.
- Attitude – a good work attitude so as to be able to undertake the task safely and with sufficient skill.
- Training – acquired through supervised on-the-job training or from a recognised course.
- Experience – sufficient to be able to know how to undertake the task and the common problems that can be found and how to resolve them.
The Medical Devices Directive
There is also another piece of legislation that we need to be aware of; the Medical Devices Directive. Or to give it it’s full title “Regulation (EU) 2017/745 of the European Parliament and of the Council of 5 April 2017 on medical devices, amending Directive 2001/83/EC, Regulation (EC) No 178/2002 and Regulation (EC) No 1223/2009 and repealing Council Directives 90/385/EEC and 93/42/EEC (Text with EEA relevance. )“
Fortunately there is a “plain English” version of this document; “MDCG 2021-24 Guidance on classification of medical devices.” (For reference, the previous version of this document was “Guidance document – Classification of Medical Devices – MEDDEV 2.4/1 rev.9G“)
Part one of the MDCG 2021-24 states that;
“The classification of medical devices in use by the EU medical device legislation is a risk-based system taking into account the vulnerability of the human body and the potential risks associated with the devices.”
It continues, stating that “These are referred to as the ‘classification rules’ and are set out in Annex VIII of Regulation (EU) 2017/745 on medical devices (MDR).“
The Directive gives us 22 Rules to follow, with Rules 1-4 being for non-invasive devices. Rule 1 states that the item must;
“Either do not touch patient of contact only intact skin”.
Looking at Rule 1 in more detail below, we can see that the Directive gives us examples of medical products that fall into this category.
The examples that we’re interested in are defined as;
- “Devices intended in general for external patient support (e.g. hospital beds, patient hoists, walking aids, wheelchairs, stretchers, dental patient chairs).
- “Wheelchairs pushed by hand.”
While this this is merely a list of examples, it would be reasonable to say that an evacuation chair would fall under this category, especially as the table above is a “plain English” version of Article 2 of Regulation – 2017/745 – EN – Medical Device Regulation – EUR-Lex, which states that;
“For the purposes of this Regulation, the following definitions apply:
- ‘medical device’ means any instrument, apparatus, appliance, software, implant, reagent, material or other article intended by the manufacturer to be used, alone or in combination, for human beings for one or more of the following specific medical purposes:
- diagnosis, prevention, monitoring, prediction, prognosis, treatment or alleviation of disease,
- diagnosis, monitoring, treatment, alleviation of, or compensation for, an injury or disability,
- investigation, replacement or modification of the anatomy or of a physiological or pathological process or state,
- providing information by means of in vitro examination of specimens derived from the human body, including organ, blood and tissue donations,
and which does not achieve its principal intended action by pharmacological, immunological or metabolic means, in or on the human body, but which may be assisted in its function by such means.
So we can see from the second bullet point above (highlighted in bold) evacuation chairs are definitely there to compensate for an injury or disability and are therefore Class 1 Medical Devices.
Article 2, Point 2 states that;
- ‘accessory for a medical device’ means an article which, whilst not being itself a medical device, is intended by its manufacturer to be used together with one or several particular medical device(s) to specifically enable the medical device(s) to be used in accordance with its/their intended purpose(s) or to specifically and directly assist the medical functionality of the medical device(s) in terms of its/their intended purpose(s)”
So, if you were to utilise a Comfy Seat on your Evac+Chair 300H, this would be deemed to be an “accessory for a medical device”.
Evacuation chair servicing requirements
Regulation 2017/745, Chapter II, Article 5 “Placing on the market and putting into service”, states that;
- “A device may be placed on the market or put into service only if it complies with this Regulation when duly supplied and properly installed, maintained and used in accordance with its intended purpose.”
Therefore, evacuation equipment needs to be properly installed (they generally come with wall hooks or you can get a free-standing frame to hold them up), and be maintained properly.
Looking at Regulation 2017/745, Annex I, General Safety and Performance Requirements, Chapter I, General Requirements, point 6 states;
- “The characteristics and performance of a device shall not be adversely affected to such a degree that the health or safety of the patient or the user and, where applicable, of other persons are compromised during the lifetime of the device, as indicated by the manufacturer, when the device is subjected to the stresses which can occur during normal conditions of use and has been properly maintained in accordance with the manufacturer’s instructions.”
So from this we can see that it it for the manufacturer to determine the maintenance schedule. The Regulations don’t specifically define “manufacturer’s instructions”, but Article 2, “Definitions” states that;
‘instructions for use’ means the information provided by the manufacturer to inform the user of a device’s intended purpose and proper use and of any precautions to be taken;
So while Regulation 2017/745 doesn’t state what the manufacturers maintenance schedule should be, we can take it that the instructions for use will include these maintenance requirements.
Evac+Chair, the manufacturers of what could be said to be the market leading evacuation chair, state that their chairs should be serviced every 12 months (the standard PUWER maintenance regime) with the belts/tracks being replaced every 3 years irrespective of use. Having seen some horrible examples of tracks that were unused but had cracked through UV degradation, this is entirely reasonable.
One thing to note is that when in use, the braking effect afforded by the belts passing through the braking mechanism causes wear on the belts, which generally leaves a rubber “crumb” or dust on the stairs. As such the belts’ life is shortened by the number of times the chair is used as well as UV degradation.
At this point it’s worth noting that the Government guidance document “Fire safety risk assessment: means of escape for disabled people” provides a recommended training diary for those who are designated operators of evacuation chairs and the evacuee (see below). This results in chairs being used on a regular/minimum 6 monthly basis, contributing to wear to the tracks, not to mention wear and potential damage to the tracks caused by sharp edges on metal stair nosings as the chair glides over them.
Conclusion
The main learning points from this are that:
- Evacuation chairs fall under the same Regulations as wheelchairs, etc, and are therefore classed as Class 1 Medical Devices under Regulation (EU) 2017/745.
- The Regulations don’t stipulate the maintenance regime, so this is left to the manufacturers of each chair to determine.
- Many manufacturers use PUWER as the default guidance for when chairs should be maintained, being every 12 months, but with the caveat of the risk assessment shortening this schedule.
- Whoever does undertake the maintenance of the chair needs to be competent to do so. For this we’d recommend that you engage the services of one of the many evacuation chair servicing companies, or the manufacturers themselves.
At Chris Garland Training we run a both Operator and Assistant courses and “Train the Trainer” courses, for both evacuation chairs and evacuation sledges. Courses run on a regular basis at our training centre in Cheshire with the option to hold private courses for your colleagues at your venues, nationwide.
If you’d like a quote for a private course, click on this link and fill in our quote request form and we’ll get back to you as soon as we can. We take great pride in the number of training companies who choose us to train their trainers as it shows that we remain market leaders in the field. We look forward to seeing you on a course soon.
2 thoughts on “Do evacuation chairs need servicing?”