Irish Lift and Escalator Association: Retrofitting modern lifts into existing buildings: How to avoid regulatory delays

Retrofitting lifts into Ireland’s historic buildings is vital for modern accessibility. SHAY GARLAND, General Secretary, Irish Lift & Escalator Association, writes that successful navigation of the mandatory Department of Enterprise, Tourism and Employment derogation process requires early consultation to prevent project delays, manage active sites and achieve sustainable compliance.
Retrofitting standard passenger lifts into Ireland’s existing and historic building stock is increasingly essential to meet modern accessibility goals. However, developers, architects and consulting engineers frequently run into structural and regulatory roadblocks around vertical transportation. Central to this challenge is harmonising strict European safety mandates—specifically EN 81-20 and its retrofit counterpart, EN 81-21 (governing vertical lifts), alongside EN 81-22 (governing inclined lifts)—with the physical reality of older infrastructure.
These standards strictly dictate permanent “safety cube” clearances in the lift headroom and pit to protect service technicians and include “refuge” spaces to prevent crushing. Where architectural limits, solid rock foundations or conservation restrictions make these clearances physically impossible, a formal derogation from the Department of Enterprise, Tourism and Employment (DETE) must be secured before installation can proceed.
DETE has published a guidance document ‘Derogation from the requirement to provide a permanent “refuge” space when installing lifts’, which outlines the procedure for requesting exemptions from standard lift safety requirements.

Irish Lift and Escalator Association
The Irish Lift and Escalator Association (ILEA) is the primary advisory body for compliance and safety in the Irish vertical transport industry. For building owners, design teams, engineers and contractors navigating the complex derogation process, ILEA offers critical practical advice.
Unoccupied sites vs occupied sites: Tackling the main retrofit challenges
Issues in relation to the retrofitting of passenger and goods/passenger lifts in existing buildings fall into two main categories:
– Where there is a new lift shaft being constructed and the lift shaft is to be constructed in compliance with the current lift standards EN 81-20/ EN-50 and building regulations, this is straight forward and once the information required is sought and discussed to ensure the correct type and capacity and meeting the end-user requirements, ILEA members will provide the information based on building usage and the capacity taking into the account safety, reliability and performance.
– For existing buildings, the issues that cause most concern start with whether a building is occupied and in use. There must be clear access to site storage capacity on site in the vicinity of the lift shaft to allow for ease of access to move heavy material into the lift shaft for installation. It is also vital to have safe and secure lockable hoardings on each landing entrance prior to the installation beginning on site. Finally, an Approved Form 2 (AF2) covering all of this must be completed and submitted to the Health and Safety Authority (HSA).

Vertical transportation standards
EN 81-20 and EN 81-50 are the primary European safety standards for vertical transportation design and testing. EN 81-20 dictates the manufacturing and construction requirements (what to build), while EN 81-50 specifies the corresponding design calculations, testing, and component verifications (how to prove it works).
EN 81-21:2022 is the European safety standard that specifies alternative rules for installing new passenger and goods lifts in existing buildings where strict compliance with standard lift dimensions—such as EN 81-20:2020 – is impossible due to structural building constraints.
The standard is used to address and resolve specific architectural limitations, including:
– Reduced Space – Alternative solutions for shafts with restricted headroom, pit depth, or machine/ pulley room dimensions
- Clearance Issues – Rules for tight spaces causing reduced distances between the lift car, counterweights, or balancing weights
– Access Restraints – Solutions for reduced landing door heights, trap door sizes, or limited car roof balustrade dimensions
– Perforated Wells & Separate Wells – Requirements for accommodating existing open/perforated lift well walls or counterweights situated in separate historical wells.
The retrofitting of vertical transport becomes an issue where the existing shaft or new shaft being constructed cannot meet the requirements of EN81- 20 /EN81-50, even with the introduction of EN81-21:2022.
Until recently, it was thought that the three standards were applicable in all cases in the Republic of Ireland, based on advice from DETE, which stated that once the standards were harmonised, a derogation was not required.
However, in October 2025, DETE stated that written pre-approval was required prior to “any installation work commencing”.
Therefore, an application for a derogation in the case of retrofitting vertical transportation elements in an existing building must be submitted by the building owner or lift designer/ installer as early as possible to avoid project delays.
Even with the harmonisation of EN81- 21:2022 and the vertical transportation meeting those requirements, there is no guarantee that a derogation will be granted. That is why full details must be submitted with the application for the derogation, which will require consultation with the full design team.
We must advise that there will be additional costs associated where a lift has to be installed in compliance with EN-21:2022, as there are a number of additional mechanical components and electrical enhancements to ensure the safety spaces can meet within EN81- 21:2022.
In addition, the lift has to be tested by the installer and then inspected and signed off by the installer’s notified body. These l costs are in addition to the lift cost.
Don’t wait for the quote: The hidden cost of late consultation
According to ILEA, the key issue that often arises is that the vertical transportation suppliers are not informed that an issue may prevail in an existing building until they are required to quote to supply. Then, when an issue arises, there is a substantial delay incurred, and the cost of this cannot be borne by the manufacturer.
This could be mitigated with earlier consultation with the relevant project team members, specifically the lift manufacturer.

Reducing your carbon footprint via smart modernisation
Where lifts are installed, and modernisation is being considered, there is a possibility of retaining many of the heavy steel components, saving costs and carbon emissions. ILEA members have a full elemental product range available, and can replace equipment and carry out works that include:
– Fitting of a new lift car into the existing lift car sling
––Supplying and fitting new equipment, controllers, lift car controls and indicators
– Car doors, landing doors, as well as retaining guides, where existing machines can be reused.
– Many modern lift packages can now provide energy efficiency options; traction lifts can offer potential energy savings of up to 30% on older hydraulic systems.
Some of the features available with traction lift systems would include the following:
– Gearless motors
– VVVF drives
– LED car lift shaft lighting
– Lifts will automatically go into standby mode when not in use
A traffic analysis can be carried out to determine if a regeneration drive can offer greater energy savings than the energy features detailed above.
ILEA advice
ILEA recommends that, prior to any decisions being made, a thorough survey should be conducted by an ILEA member on each lift in an existing building. This can help reduce a building’s carbon footprint and project costs, as well as ensure that all necessary information is available should a derogation be required.
Upgrading only the necessary equipment elements can also provide significant energy savings. Modern lift and escalator equipment can include regenerative lift control systems that can connect to the building energy systems.
ILEA emphasises the need for early communication and discussion with lift contactors to achieve the best possible outcome for developers and end users. ILEA members will provide all required technical and logistical support needed to deliver successful retrofit projects.

Irish Lift and Escalator Association
The Irish Lift and Escalator Association (ILEA) is the trade association and advisory body representing the vertical transport industry in Ireland. It is responsible for over 80% of lifts and escalators operating in Ireland, providing more than six million passenger journeys each day. Its chairperson is Giles Lord (Byrne Lifts); Declan McKenna (Fain Ireland) is its treasurer, and Niall Whitty (Orona Mid Western Lifts) is a director.
ILEA members include Accel Lifts Ltd, Ascension Lifts, Byrne Lifts, Fain Lifts, Infinity Lifts, Kone, Orona Mid Western Lifts, Schindler, and the Wittur Group.
To learn more about ILEA, email info@ilea.ie or phone 01 639 2994. To download the DETE guidance document, visit https://www.gov.ie/en/department-of-enterprise-tourism-and-employment/publications/application-to-install-a-lift-with-restricted-headroom-or-refuge-space/
How to applying for a vertical transportation clearance derogation
All applications for derogations from the requirement to provide permanent “refuge “ spaces for passenger lifts must be applied for directly through the Department of Enterprise, Tourism and Employment. Information on the process and contact details are available through the Department. If you require more information on derogations, email healthandsafetypolicy@enterprise.gov.ie
