Extraordinary maintenance or substantial modification? The INAIL 2026 guide on fixed lifting equipment

What it is

In October 2026 INAIL — the Italian national institute for insurance against accidents at work, Department of technological innovation and safety of plants, products and human settlements — published in its Health and Safety series the document “Extraordinary maintenance interventions on fixed lifting equipment” (ISBN 979-12-5758-019-3), prepared together with the Ministry of Labour and ANIMA-AISEM.

The guide updates the long-standing ISPESL Circular no. 71/1997 in the light of Directive 2006/42/EC and, above all, of Regulation (EU) 2023/1230, whose art. 3(16) introduces for the first time in European law the definition of substantial modification. It is addressed to inspection bodies (INAIL, local health authorities, authorised bodies), enforcement authorities, employers, maintenance contractors and manufacturers.

Its scope is fixed lifting equipment: overhead travelling cranes, limited-structure cranes, gantry cranes and monorails.

Why the distinction matters

	Extraordinary maintenance	Substantial modification
Conformity	The original EC declaration remains valid	Whoever makes the modification is treated as the manufacturer: new conformity assessment, new technical file, new CE marking and declaration
Periodic inspections	The inspector records the intervention in the report on the basis of the documentation; the registration number is unchanged	The equipment is treated as new: fresh notification of placing in service and new INAIL registration number, with termination of service for the original one
Who decides	Classification is the responsibility of whoever carries out the intervention. The inspector does not judge its nature, but checks that the documentation is adequate to justify it: if it is missing, the periodic inspection may be suspended

The benchmark is always what the manufacturer originally envisaged in its risk assessment, as inferred from the instructions. The guide therefore recommends, wherever possible, consulting the manufacturer beforehand.

The four types of intervention under Italian Decree 81/2008

Type	Reference	Features
Maintenance	Art. 71(4), point 2	Work envisaged by the manufacturer in the instructions to preserve safety requirements over time; to be entered in the control register
Upgrading measures	Art. 71(4), point 3	Adaptations required by ministerial order to remedy hazardous situations: even if constructional, they are not substantial modifications
Modifications	Art. 71(5)	Improvements decided by the employer that do not affect the use and performance envisaged by the manufacturer
Substantial modifications	Art. 71(5) — Reg. 2023/1230, art. 3(16)	They alter use or performance, creating a new hazard or increasing a risk: they amount to a new placing on the market

Three examples the guide classes as substantial modification: motorising the originally manual movements of a jib crane; adding a hoisting unit not envisaged on an overhead or gantry crane, or changing capacity beyond the original limits; replacing free-rotation hook blocks with rotation-locked hook blocks.

The fifteen operational sheets

The core of the document is a table of fifteen recurring interventions. For each, it sets out the conditions under which the work remains extraordinary maintenance and the documentation to be produced, distinguishing work done by the manufacturer from work done by third parties.

Sheet	Intervention	Examples
1.01	Dimensional changes	Span, outreach, structure height, dead weights, counterweights
1.02	Installation of additional masses	Lamps, equipment for below-the-hook attachments
1.03	Change of functional parameters	Capacity, moments, speeds, dynamic effects
1.04	Changes in geometry, mass or reactions	Longer jib with reduced capacity, shorter column, wider span
1.05	Installation of safety components	Anti-collision, load limiters, limit switches, additional brakes, encoders
1.06	Replacement of safety components with different ones	Other make, model or technology (e.g. photocells → radar)
1.07	Work on the electrical installation	Phase monitoring, thermal and overcurrent protection, earthing
1.08	Installation of additional guards	Fixed or interlocked guards
1.09	Walkways, galleries, stairs and access	Access already envisaged by the manufacturer (e.g. an extra ladder)
1.10	Fall arrest for emergency work	Lifelines and anchor points
1.11	Control systems / electrical equipment	Replacement of devices, addition of an electrical axis
1.12	Drive system replaced with an equivalent one	Same functional parameters and protections
1.13	Drive system replaced with a different one	Requires stress and compatibility verification
1.14	Power supply for lifting attachments and their controls	Magnets, motorised spreader beams, vacuum lifters
1.15	Hook blocks with electric rotation	The block is partly completed machinery: it needs its own EC declaration

Three recurring conditions run through the sheets: no increase in stress beyond the limits set by the manufacturer; no change in geometry creating interference; no additional risk on the essential safety requirements concerned. For safety components and control systems, suitability to the state of the art, compatibility with the machine and a performance level at least equal to the original are added. One intervention may fall under several sheets: in that case all the conditions must be met.

The documentation and the role of the competent person

When the work is carried out by someone other than the manufacturer, the central document is the technical report signed by a competent person, whom the guide defines as someone with practical experience in the design, construction and maintenance of lifting equipment, including the applicable standards. The report must contain:

• the description and purpose of the intervention, with the information needed for its correct execution;
• the stress verification of the structures according to good engineering practice, certifying that the original limits of strength, stability and deflection are not exceeded;
• the extract of the risk assessment to UNI EN ISO 12100, for the risks the intervention may affect;
• the tests and checks to be carried out once the work is complete.

Supporting documents: the inspection or test report with the results; the declaration of correct installation or workmanlike execution, for which Appendix 2 provides a template; updated wiring diagrams where relevant; the documentation of the components installed; the entry in the control register with description, test results, date and signature. If the manufacturer carries out the work, the report is replaced by a declaration of suitability stating that the intervention does not invalidate the original EC declaration.

The employer remains responsible for selecting the parties involved and must verify their competence.

Relocating a permanently installed crane

Regulation 2023/1230 requires the EU declaration for permanently installed lifting machinery to state the place of installation. Relocation is not, however, in itself a substantial modification: if carried out according to the manufacturer's instructions, no new CE marking is required, and it is sufficient for the installer to state the new location in the declaration of extraordinary maintenance and correct installation/fitness for use.

Crane runways

Appendix 1 addresses an often-neglected subject. Runways may be part of the building, supported by or connected to an existing building, or self-supporting. Their adequacy must be re-verified whenever the configuration changes — a new crane on the same runway, an increased capacity — on three fronts: design strength (including seismic actions where applicable), geometry and alignment, state of preservation.

Four parties are involved: the crane manufacturer provides wheel loads and installation tolerances; the builder of the runway or building declares its limits of use; the installer verifies adequacy against the machine's specifications; the employer must provide evidence of the structural adequacy of the installation site. The Machinery Directive does not apply to runways unless they are an integral part of the machine (self-supporting structures); UNI EN 1090 and the DoP apply only where the runway is a structural element of the building.

What it means for companies

• Classify before intervening, using the sheets and, where possible, consulting the manufacturer: discovering afterwards that the work was a substantial modification means having to re-certify the machine;
• entrust the technical report to a competent person: it is the first document the inspector reads;
• do not underestimate “minor” work: adding lamps, a walkway or a lifeline also falls under the sheets and requires a report and a register entry;
• keep the control register up to date: it is the document that reconstructs the equipment's history and demonstrates compliance;
• document the adequacy of the runways, especially when installing a new crane or increasing its capacity.

How we support companies

Stefano Luise Engineering S.r.l. acts as a competent person under the guide: we prepare the technical report for the intervention with stress verification (including FEM analysis), the risk assessment extract, the test plan and the declaration of correct installation; we verify the adequacy of crane runways; we classify cases of substantial modification under Regulation 2023/1230; and we assist the employer during the periodic inspection of the equipment.

Regulatory references

INAIL, Extraordinary maintenance interventions on fixed lifting equipment, October 2026  •  Italian Legislative Decree 81/2008 (art. 71)  •  Regulation (EU) 2023/1230 (art. 3(16), Annex V)  •  Directive 2006/42/EC and its Guide  •  Presidential Decree 459/96 and ISPESL Circular 71/1997  •  Ministerial Decree 11/04/2011  •  UNI EN ISO 12100  •  Regulation (EU) 2024/3110

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