The Code Reporter

The latest information on the California elevator safety code.





Tuesday, January 11, 2011

"FOR CAUSE” & “SPECIAL ORDERS"

Today we have a guest post from Dee Swerrie:

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“FOR CAUSE” & “SPECIAL ORDERS”
After reading Rich's Blog, I think a few words regarding, “for cause” could well be in order.  Also a few about “special orders” as “for cause” often generate them.  What I am about to say is based on my experience and is not necessarily how the current Elevator Principal Engineer, Debbie Tudor, may feel or mean by the same phrases.  Possibly, if she reads this and has the time, she will share how she interprets and applies them.
Keep in mind:
  1. Elevator conveyances are man made vertical transportation devices.  Man made devices, as all of us know, sometimes run into problems performing as they are intended to for various reasons.  Sometimes, even when they function as intended, it becomes obvious that there is a better and/or safer way to accomplish the same thing.  Following prolonged operation, wear and tear effects cause unintended problems.  Sometimes a device fails and needs to be replaced.  For a multitude of reasons some changes not covered by an existing order (section) may be necessary.
  2. Elevator codes, rules, regulations, and jurisdictional authority's, all came about years after the elevators, or “lifts”, became recognized and acceptable vertical transportation devices.  Why?  “For cause”!  Elevators and elevator enclosures were involved with people getting hurt!
   Remember, the purpose of taking jurisdiction and promulgating safety codes or orders is for an important reason.  That reason?  ̶“SAFETY” ̶  Elevator Inspectors do more than just inspect elevators for code compliance.  Actually that is the easier part of the job.  The real reason the inspector visits each elevator each year, or more frequently, is to determine if it is safe for the unit to remain in use.  ̶“SAFETY” ̶  I say this, not to minimize the codes and rules promulgated to which elevators must be be constructed and maintained.  Actually the codes, rules, or orders, do provide elevators that seldom need something unique, but it happens, thus  ̶“FOR CAUSE” ̶.
    An example or so: 
  1. An individual was observed opening a sliding hoistway door and falling into the pit on a quite old APB passenger elevator. A competent investigation determined the old interlocks were worn and faulty.  Also determined was the fact that the wooden door jamb was worn and sagging.  The AHJ ordered the owner to install new approved interlocks on all landings, and to have the door frames refurbished to ensure the doors were properly hung and operating.  “For cause!”  It did not need to state “for cause” on the order; the reason was quite obvious to every one concerned.
  2. An individual was observed holding the sliding doors of a relatively up to date elevator installation of a Selective-Collective passenger elevator from completely closing.  Then the individual slid the door open to step into the car but instead stepped  into a  void and fell.  A competent investigation determined that  there had previously been some problems with the elevator getting stalled.  The service mechanic had found a faulty door interlock contact and fixed it and since then elevator had functioned quite well.  The investigator delved deeper and determined the elevator was older than it appeared, having been installed in the late forties and since been modernized.  The mechanic when fixing the elevator following the call back had found a second set of contacts in the interlock, that solved his problem,  just change the conductors to the unused contacts and all was well.  The AHJ ordered that the elevator be provided with new, up to date, approved interlocks.  The AHJ allowed for a second option: remove all interlocks, remove all second sets of contacts, refurbish the interlocks leaving out the second set of contacts, prior to reinstalling the interlocks.  “For cause”
    Two similar occurrences, but for differing causes.  In the first case it was an older building with much wood construction and the interlock were old and obsolete.  The service company had to have replacement parts fabricated, and all in use had the contacts bent some varying amounts to make things work.  In the second case the building was in quite good condition being mostly concrete construction.  However the elevators installed had dual function interlocks.  Many younger elevator mechanics do not know, or forget, that the older car switch elevators that had an night time feature to allow automatic operation; that during the time the operator was running the elevator the interlock would make up at 4 inches, but under automatic operation the closed position for the elevator doors was less than ½ inch, therefore the double set of contacts in the interlock.  Of course with the closed position of car doors being two inches or less, no one was aware that the car could start prior to the hoistway doors being closed and locked.  The person holding the doors from closing held them within that 4 inch distance and as soon as the door contact made, the car left the landing, and the person could open the doors and step in.  Incidentally, in California the AHJ mandated all elevators under the control of elevator operators had to have a pawl arrangement fastened to the leading edge of the hoistway door near the bottom and a bracket fastened to the sill which would keep any one from pulling the doors open until after they were fully closed and locked to prevent what happened in the example given.    
    Another case comes to mind of a basement traction machine that was observed to be lifting itself off of the floor somewhat when the elevator started to run.  A valid reason for an order to correct? – For cause?  What say you?
    If you have a copy of Labor Code Section 7300 et seq., the chapter directly applicable to Elevators, you see in section 7318 that the division may prescribe and enforce special orders as well as general orders.  The history note indicates this order was enacted in 1937.  I rather think that that in itself is an indication that the need for special or “for cause” orders was recognized.  Probably soon following the commencement of inspecting and enforcement of the original elevator safety orders in 1920. 
   Browsing thru the Labor Code, note that LC Section 6309 authorizes the division to investigate, even on its own motion, if it hears of anything  indicating unsafe  conditions at a facility.  Normally such conditions come to the attention  of the division  through complaints but not always. LC Section 6313 is another interesting law that may be invoked by the division.  It pertains to the investigation of accidents.  LC Section 6430 is also interesting as it pertains to the falsely reporting of compliance with orders. 
    As with all laws, enforcement of every law that exists is not always the case, but if there is an accident, all the laws are available to the authority.
   A word about LC 7318.  I have no idea how or if Principal Elevator Engineer Debby Tudor intends to use it.  I do know that when I was Principal, I kept tight control on its use.  I also used some of the Labor code laws to good effect.  But with discretion.  There are times that a special order is necessary.  However indiscriminate use can cause problems and that is why I felt it best to maintain tight control. 

Dee Swerrie

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Thanks Dee.  Again, if for no other reason but to show that someone out there is reading this, please feel free to leave comments about this blog, past blogs, or anything that's on your mind regarding conveyances, codes, trends, etc.

Cheers,
Rich Blaska