A number of people have asked me whether a pit ladder is required to be installed in an existing elevator pit on an old elevator where no ladder had ever been installed (California
The inspector indicated that a ladder must be installed based on California Code of Regulations (CCR), Title 8, Section 3016(d)(4) which reads:
(4) Access to pits over 3 ft (914mm) in depth below the sill of the pit access door shall be by means of a permanent ladder or stairway into the pit. The ladder or stairway shall be adequately guarded to prevent contact between a person on the ladder or stairway and any moving part of adjacent elevators or machinery. The ladder shall be located adjacent to the strike jamb of and accessible from the access door to the pit.
EXCEPTIONS to subsection 3016(d)(4);
1. Ladders or stairways are not required to be provided in pits of elevators installed before June 5, 1947 unless they have undergone a major alteration or have been required for cause.
2. Elevators installed between June 5, 1947 and December 1, 1988 are only required to have ladders or stairways if the pit is over 4 ft (1.22m) in depth.
Note that the first two sentences of 3016(d)(4) is italicized text which is defined in the opening paragraph of Group II:
Italicized paragraphs, sentences, or phrases apply to all existing elevators while non-italicized apply to elevators installed after 1970 or after the date the regulation was adopted.
So, how does the logic of the state inspector’s decision work? Well, first the pit is 38” in depth, which is greater than the 36” depth trigger indicating a ladder is required. However, the elevator was originally installed with the construction of the building following the 1906 earthquake and fire, almost 40 years before 1947. That would suggest the exception no. 1 would apply and a ladder would not be required. However, let’s look at the second half of exception no. 1, “unless they have undergone a major alteration or have been required for cause.” This effectively reverses the exception under two conditions: a “major alteration” or “required for cause.”
Since the adoption of ASME A17.1-1996 effective October 25, 1998 the state has followed the precedent that that which is altered must comply with the Alteration sections of A17.1 (with some exceptions), initially the 1996 code and after May 1, 2008, the 2004 code. Conversely, that which is not altered is not required to be brought up to these newer standards. I had thought that was the case with pit ladders as well. In this sense, CCR section 3016(d)(4) is one of the rare examples where, apparently, if a “major alteration” is performed on the elevator – no matter what that alteration entails – a pit ladder must be installed if the pit depth is over 3 ft. and the elevator was installed before June 5, 1947. Change the interlocks, put in a pit ladder…
The other exception to the exception is “required for cause.” I’m not quite sure what this means other than possibly if the state says they want a ladder in a pit; then you have to put a ladder in the pit. Possibly someone out there can shed more light on what this means – please write a comment.
Now let’s look at the exception no. 2. If the original elevator was installed between June 5, 1947 and December 1, 1988 and the pit depth was 4 ft. or less, then you would never have to add a ladder – even if the elevator underwent a major alteration. Note the major alteration exception to the exception only applies to elevators installed before 1947, per exception no. 1. Also, there is no “required for cause” exception in exception no. 2 – so apparently the state can’t require a ladder for cause on these elevators where they can on the older ones. It’s pretty clear that this entire section and especially the exception don’t make much sense.
You might ask, OK, when does the A17.1 code come into play? Apparently it is only triggered in an alteration when the pit itself is altered, say deepened or widened, etc. This is important because some of the rules change with the national code. Note section 3016(d)(4) finishes with the provision, “The ladder shall be located adjacent to the strike jamb of and accessible from the access door to the pit.” There is no requirement that the ladder be on the strike side of the entrance in A17.1-2004, section 2.2.4, which instead says, “located within reach of the access door.” It also says, “The nearest point of the ladder shall be within 1 000 mm (39”), measured horizontally from the means to unlock the egress door from the pit.” The A17.1 code makes more sense than the Title 8 language as center-parting elevator doors have no strike jambs. On some smaller, older elevators including winding drums no ladder – not even retractable ladders – will fit on the strike side whereas they will fit on the pass side. So, with the A17.1 code as long as the pick-up rollers are within 39” of the near side ladder upright, the ladder can be on the pass side of the entrance whereas this is not allowed in Title 8.
Another major difference between the two codes is the potential ladder width. CCR Title 8, section 3016(d)(5) references a separate state ladder code (I have a copy if you want to see it). This ladder code wasn’t written specifically for elevators but for general commercial applications. As such, it’s pretty rigid dimensionally, requiring a minimum 16” rung and riser I.D. width. The A17.1 section 2.2.4 allows a narrower ladder, referencing a 12” and even a 9” width if necessary due to existing obstructions. I ran into this situation on a major alteration of a 1920s 750 lbs capacity elevator with a 48” pit. The contractor wanted to add a 12” wide Retracta Ladder™ retractable pit ladder as a 16” wide ladder would not fit. The state senior engineer indicated that unless the pit itself was altered allowing the application of the A17.1-2004, section 2.2.4 rules, then the CCR Title 8 section 3016(d)(5) would apply, which requires a 16” ladder width. The project scope of work did not include altering the actual pit, therefore the only solutions were to either apply for a permanent variance to install a 12” wide ladder or not install a ladder. A permanent variance is a somewhat involved, time consuming and expensive process – gross overkill on a matter such as this. The unfortunate result was not to install a ladder and henceforth the service technician will have to fetch a step ladder or risk climbing in and out of a 4 ft. pit. This is one of the finest examples I’ve seen of where the application and enforcement of obsolete codes decreases or diminishes safety.
According to several insurance brokers I’ve spoken with who insure the elevator industry, they all tell me that injuries sustained involving accidents entering and existing elevator pits are among there most common and costly insurance claims. Many of these involve major injuries, permanent disabilities and even deaths. Some companies I know have a policy to install ladders in every existing elevator they take on service. The cost to install these ladders is negligible compared to the cost of lost work time, workers’ compensation, legal expenses, etc. California DOSH-Elevator Unit has recognized the benefit in installing pit ladders both in the CCR code language discussed above and the recent issuance of the Circular Letter #E-10-02 providing the criteria for installing retractable elevator pit ladders. Possibly another Circular Letter could be written to clean up the logic in CCR Title 8, section 3016(d)(4), making it clearer when a ladder is required in an alteration and preferably by simply referencing the A17.1-2004 code criteria for all ladder installations.
Comments are more than welcome – please write.
Your Code Reporter
Rich Blaska
