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  • Regulation on Subcontracting of Elevator Maintenance
    • 담당부서 : 외투기업고충처리실(고상원)
    • 조회수 : 2,812
  • Organization : Ministry of Public Administration and Security
  • Regulation : administrative management
Grievance
Grievance
• Background: The Ministry of Security and Public Administration tried to impose a total ban on subcontracting in the elevator maintenance industry while revising the Enforcement Decree of the Elevator Safety Management Act without considering the situation of the industry.

• Main issue: When a ban on subcontracting for self inspection is implemented, manufactures need to end business with subcontracting firms and expand self-inspection staffs within a company. However, it is difficult to revise a company’s business model and will damage business efficiency.

‣And, when maintenance subcontracting firms stop business with manufacturers, they might exit from the market.

• Request: A request was made to reflect the stance o elevator maintenance industry regarding revision of the Enforcement Decree.

Resoultion and Results
Resolution and Results
•Resolution
‣ By holding a meeting, the Ombudsman listened to the stance of the elevator maintenance industry.

- Ban on subcontracting might intensify low-price competition among small cooperative firms with low technical skills, which undermines safety and convenience of users.

- Regulation on share of subcontracting needs to focus on work, not pricing.

- Regulation by pricing is difficult to be applied in reality because conducted work cannot be calculated into price and companies might not comply with safety rules to meet the required pricing.

•Meetings with relevant organizations
-(Sep. 6, 2012) Meeting with Director of Safety Improvement Division of the Ministry of Security and Public Administration was held.

-(Oct. 15, 2012) The Foreign Investment Ombudsman together with an elevator manufacturing company and maintenance subcontracting firms visited the Regulatory Reform Office to have discussion.

-(Nov. 30, 2012) The Foreign Investment Ombudsman had a meeting with Director General of the Regulatory Reform Office.

-(Dec. 7,2012). The Foreign Investment Ombudsman delivered the situation and opinions of foreign company to the Regulatory Reform Office.

Outcome:
• Results
‣As a ban on subcontracting was revised to 50 percent restriction from the total ban, part of industry’s opinions was reflected in revision. However, suggestions such as raising ratio of subcontracting or changing standard based on actual work, not price were not accepted.