If you’re connected with me and spend some time on LinkedIn, you will have seen that I talk about ride and device modifications a lot.
I make no apology for this.
In fact, the first Universal Verification webinar of 2026 will cover ride modifications. Also, our Q1 in-person training day in London in March focuses on ride modifications.
We consider incorrectly planned and / or implemented modifications to be a fundamental issue effecting the industry. We’ve seen numerous recent examples of industry incidents and accidents where a contributing factor has been a modification.
And yet, when we speak to Controllers and Operators, most of them do not list modifications or the change management process to be a concern or an issue at their attraction.
And this, in my humble opinion, is because most Controllers and Operators do not fully appreciate what a modification is. Or what it entails.
Most Controllers have not heard of EN 13814 and don’t have a copy of HS(G)175.
I say this without any blame, shame, guilt, or judgement on the Controllers.
I see this as an opportunity to educate. As consultants, I believe it to be our duty to work with our clients to raise and improve knowledge levels across the industry.
HS(G)175 doesn’t state what a modification is.
However, it defines a safety-critical modification as, “Any alteration to the hardware and/or software of a piece of equipment including the introduction of a safety critical component which results in a deviation from the original design specification.”
EN13814-2 talks about a major modification. This is, “Safety related alteration to the hardware or software of an amusement device including the introduction of a new safety related component or the substitution of a safety related component which results in a deviation from the current design specification.”
And what is a Safety related part or component? It’s a, “part or component of an amusement device on which the safety of the passengers is dependent as identified in the Design Risk Assessment and or the Operation and Use Risk Assessment.”
I know, I know… Don’t even get me started on the DRA and the OURA.
Components on which the safety of passengers is dependent. Ambiguous, isn’t it?
On one of our in-person training courses, I get the participants to list out the safety critical components for a typical ride at their attraction. The answers are often illuminating.
HS(G)175 (paragraph 203 if you’re interested) states that, “Any safety-critical modification should be subjected to a pre-use inspection. This should include (but not be limited to) changes to:
HS(G)175 goes on (paragraph 205) to state that, “If in doubt it should be assumed that every modification is safety-critical, and the advice of a competent person should be sought.”
As we know, the Pre-Use Inspection requires:
A pre-requisite of the In-service Annual inspection is for the inspection body to, “make all reasonable enquiries with the controller as to whether any modifications that may affect the safe operation of the device have been made since the previous DOC was issued and that the new design review, ACD and initial test, as required, have been documented in the operations manual.”
Is this performed robustly? Not in our experience.
So, how do we ensure that Controllers and Inspection Bodies are aware of this?
I believe that the associations (IAAPA, BALPPA, ADIPS etc) have a part to play.
If you’re a member of IAAPA EMEA, last year they produced a White Paper, ‘Change Management: Modification of Amusement Rides and Devices’.
The White Paper provides a great overview of a change management process, and details when a modification becomes safety critical, and the roles and responsibilities of key stakeholders such as owner/ operator/ controller, manufacturer, and inspection body.
It also covers the often forgotten or overlooked part of fully documenting and recording the modification.
For members of IAAPA, I would recommend grabbing a copy and following (or at least reviewing) the guidance contained within. It’s a great resource, and I’m proud that we helped on the task force.
However, in the UK, there approximately 6,000 rides that require a DOC (Declaration of Operational Compliance), basically, a permit to operate.
Of these, only a small percentage of rides are owned and operated by Controllers that are members of IAAPA. Therefore, the vast majority do not have access to the White Paper or other resources.
Also, let’s not forget the Inspection Bodies.
In the UK, there are 42 ADIPS registered Inspection Bodies with 140 registered inspectors. Again, of these, only a small percentage of Inspection Bodies are members of IAAPA.
And there are NO Inspection Bodies that are members of BALPPA.
So, how do we disseminate the information?
IAAPA/ BAPPA safety seminars?
These can be useful. However, the safety seminar attendees are not necessarily the most appropriate people to take and implement the safety information that’s shared. Also, the content is not relevant to maintenance and inspection of rides.
We need seminars dedicated to the maintenance and inspection of rides.
We need the attendees to be responsible for the maintenance and inspection of rides.
There’s a lot of work that needs to be done.
That’s why we have decided that our February webinar and March open training will focus on Ride Modifications.
This webinar will highlight industry best practice for the management of modifications.
We’ll explore examples where modifications have been planned and performed effectively, and we’ll look at examples where we can learn from mistakes in the modification process.
Here’s the link to the webinar: Modifications and Change Management | Meeting-Join | Microsoft Teams
It would be great to see you there.
Our training day in London (17th March) will go into more details and we’ll provide a hands on and practical training on using a simple 6-step change management process that the owner/ operator/ controller can follow.
We’ll look at:
For information and booking details, please contact enquiries@universal-verification.com
