Here in California, with the exception of Los Angeles and
federal installation, the authority having jurisdiction (AHJ) over commercial
elevators is DOSH-Elevator Unit. Well,
that’s the short name for the state governmental agency – go to their website
for the long version: http://www.dir.ca.gov/DOSH/Elevator.html. Even the short name is confusing because on
their web homepage, it’s titled, “Cal/OSHA – Elevator Unit.” But “DOSH-Elevator Unit HQS” is how Debra
Tudor, Principal Engineer, signs off on her letters.
Speaking of letters, this blog entry is about the latest DOSH-Elevator
Unit, Circular Letter. The term “circular
letter” does not refer to the circular/cylindrical receptacle off the corner of
your desk but to the intent that the letter “circulate” amongst members of our
industry in California. The presumed
official purpose of DOSH-Elevator Unit, Circular Letters is to clarify the Division’s
application and enforcement of the State’s laws regarding conveyances, the elevator
code, operating permits, letters of intent, etc. If my count is accurate, I believe around 119
have been issued since 1970. At least,
that’s what shows up on their web page dedicated to Circular Letters: http://www.dir.ca.gov/dosh/ertcrltr.html. The more recent ones are available as
downloads in PDF file format.
You might notice that there are a number of years where very
few Circular Letters were written, which was during the period that Al Tafazoli
was Principal Safety Engineer. He wrote what
I would say was a very good one on June 7, 2002, Circular Letter E-02-01.
It wisely informs the industry of a problem with a particular brand of electromechanical
relay and the requirement by the Division that these malfunctioning relays be
replaced. Al’s only other Circular
Letter was E-08-01, dated April 4, 2008 and it was
to announce the adoption of ASME A17.1-2004.
Shortly before he left his position, I had a conversation with him about
Circular Letters, specifically suggesting a few. He told me that he didn’t have the authority
to write Circular Letters as to do so was tantamount to writing code (words to
that effect). I countered that his predecessors
had done it rather consistently going back to the 70s. He said that that has changed and that the
State’s lawyers had told him he couldn’t do it anymore, except to announce code
adoptions, changes to the fees, etc.
Really?
Fortunately, Debra Tudor has resurrected the Circular Letter
– either in defiance of the State’s lawyers or more likely, simply in the
performance of her official duties. I had
a long lunch with Debbie at the 2009 NAEC United in Orlando elevator expo where
she made it clear to me it was a new day at the Division. I filled her ear with my observations and
opinions of what was amiss and needed her attention. I believe she is on the right track,
although, change is difficult. Circular
Letters began to flow, along with a number of commitments – for many of which
we are still waiting…
The most recent one is Circular Letter E-12-02 and has the subject: Disabling
of Conveyance Safety Devices. This
one is particularly interesting to me in that it doesn’t announce anything particularly
new, no new codes or regulations. It simply
informs the industry of a problem, actually a problem that, frankly, all of us
already know about. Maybe the newbie
sale representative hasn’t heard of the dangers of leaving a jumper on a safety
circuit. It’s the dirty little secret of
our industry – and a very dangerous one.
Clearly this Circular Letter was prompted by the fairly recent death in Manhattan
and possibly other incidents, as alluded to in the letter.
So, what’s the purpose of Circular Letter E-12-02?
It’s pure Debbie Tudor, taking a stand that there are laws on the books
and she’s going to enforce them – whatever it takes. Good for Debbie, good for California!
