Response to the Green Paper on safety of tourism - CEN

CEN Identification number in the EC register: 63623305522-13
Response to the Green Paper on safety
of tourism accommodation services
December 2014
CEN (European Committee for Standardization) is an officially recognised organisation (EU
Regulation 1025/20121) responsible for developing and defining standards at European level.
These standards set out specifications, requirements and recommendations in relation to a wide
range of products and services.
The members of CEN are the National Standards Bodies of 33 European countries including all of
the EU member states plus Iceland, Norway, Switzerland, Former Yugoslav Republic of Macedonia
and Turkey. CEN also works to promote the international harmonisation of standards in the
framework of a technical cooperation agreement with ISO (International Organization for
European Standards are developed through a process of collaboration among technical experts
nominated by business and industry, research institutes, public authorities, consumer and other
stakeholders. These standards are implemented throughout all of the 33 countries covered by
Q27- How would European safety standards help improve consumer
safety in tourism accommodation? What would be the main drawbacks?
Please elaborate your answer from both a national and a European
Standardization is a voluntary process based on the principles of transparency,
openness and consensus amongst the different interested parties in a specific
area (consumers, businesses, public authorities and other stakeholders committed to
participate). Stakeholder engagement and consensus building provided by a standard
that has been facilitated by an independent third-party organization and gone through a
public commenting phase, bring added value and can increase the confidence of
consumers. Standards are valuable tools for the promotion of best practice, increased
efficiency, quality and safety in relation to goods and services. This has been confirmed
Regulation 1025/2012 on European standardisation
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by the new Regulation on European standardization (1025/2012) which recognises the
role of the European Standardization Organizations in developing standards also in the
services area and provides legitimacy for the resulting standards to be used as a tool in
support of European legislation and public policy.
One of the biggest benefits of European Standards is their identical implementation
across Europe and the obligation of National Standardization Bodies to withdraw
any existing conflicting national standards. Although European Standards remain
voluntary in application for service providers, this contributes to creating a level playing
field and provides a common reference within the 33 countries member of CEN.
Nevertheless, as mentioned in the Green Paper the area of tourism accommodation is
regulated at national level in different Member States and there seem to be
important differences between the existing national legislations. Without a certain
level of harmonization of legislation at European level, reaching a consensus and
developing a European standard in such a context may be difficult. The standard
would either:
need to set a high level of requirements in line with the highest safety level
established by national legislation to avoid any conflicts with national regulation,
which could lead to businesses not using the standards, or,
if a minimum level of requirements are specified, to the non-application of the
standard in those countries where national legislation sets higher safety
Moreover, it should also be beard in mind that standardization is a market-driven
process and that the development of standards in this field would require the support
of both the consumer representatives and of the tourism accommodation sector.
Q 28 – If you have examples of national standards regarding tourism
accommodation safety, do you have evidence that they have helped
improve safety levels for consumers
In 2011, the consulting company Technopolis, at the request of CEN, carried out a study
on the impact of European service standards on service providers and users. The
conclusions of the study, confirm that the most widespread “major” benefits of using
service standards relates to the improvements to service quality. An improved ability to
meet health and safety requirements was also cited as a major benefit2. The study
did not focus on the area of tourism accommodation but it confirms that standards can
also play a role in helping companies to meet safety requirements in general.
At national and European level there are standards related to the safety products, which
support existing legislation and are relevant in relation to the safety of tourism
CEN reply- December 2014 Page 2 of 3
In the area of services, there are also national standards and other documents relevant
in relation to some safety aspects of services offered within tourism accommodation and
also in relation to accessibility of tourism and leisure facilities. Some examples include
the UNI (Italian Standardization Body) Public Available Specification on ‘Beach services –
Safety, quality, accessibility and sustainability requirements of services and amenities’ or
the Austrian standard ÖNORM B 1603:2013-10 ‘Accessible facilities for tourism and
leisure - Design principles’.
At European and international level, the standards developed by ISO/TC 228 ‘Tourism
and related services’ and CEN/TC 329 ‘Tourism services’ deal with safety aspects (e.g.
wellness spas, thalassotherapy, recreational diving services, adventure tourism…)
although the focus of the work of these technical committees has so far not been on
tourism accommodation.
Since most of the mentioned service standards are currently under development or have
been developed in the last two or three years, it is difficult to have information on their
specific impact.
Q 42 - Do you have any other comments or suggestions regarding
tourism accommodation safety?
The European Commission should consider a role for European standardization
within the context of future EU action on safety of tourism accommodation.
Nevertheless, as mentioned above, it should be highlighted that for the development of
(European) standards the support of the relevant stakeholders is essential.
Taking into account the existence of national regulations in this area some of the
national standardization bodies member of CEN have stressed that at this stage it may
only have a benefit to develop standards in this area in relation to the provision of
services to people with special needs. Finally, the green paper focuses on fire safety and
similar hazards although other aspects, e.g. hygienic aspects in catering facilities, may
also be relevant in relation to safety of tourism accommodation.
CEN reply- December 2014 Page 3 of 3