Elevator Rulemaking - Revision of Elevator Safety Orders

The Division of Occupational Safety & Health - Elevator Unit (Division) is proposing new language consisting of revisions to Group I and the addition of a new Group V to the Elevator Safety Orders, for commercial elevators in the state of California.  The Division, including Debra Tutor, Principal Engineer and Dan Barker, Senior Engineer, will be hosting an Advisory Committee Meeting on Tuesday, April 22nd, 2014, 10 AM to 3:30 PM at the Elihu Harris State Building, 1515 Clay Street, 1st floor Auditorium, Oakland California.

More information is available on the Division's website page:  http://www.dir.ca.gov/dosh/elevator_rulemaking.html.  The Proposed Draft Language, Meeting Notice and Agenda can be downloaded at that site.  If you are not already on it, you might want to consider getting on the Division's email list so you will receive notices, such as these, directly from them.  To get on the list, email
Melissa Lockett at mlockett@dir.ca.gov.

The proposed new language will have far reaching consequences for the industry.  The changes to Group I of Elevator Safety Orders includes the implementation of the long awaited (long dreaded by some) Plan Review process as a required part of obtaining a permit for new installations and alterations.  The language includes very specific requirements for the submittal process, which will include job specific, scaled and dimensioned drawings.  There are drawing requirement beyond what I typically provide in my service at RCB Elevator Consulting, LLC.

The greatest change will be the addition of a Group V to the Elevator Safety Orders, which reference the ASME A17.1-2013/CSA B44-13 Safety Code for Elevators and Escalators.  Those of us that are finally comfortable working with the A17.1-2004 code will be in for a workout to get our arms around this new code.  It incorporates requirements for MRLs and other new technologies throughout, making the code vastly more complicated.  It commonly cross references section-to-section, making sorting things out a lot more difficult.  It will be a leap for us considering there have been previous upgrades to A17.1 including 2007 and 2010.  As I'm sure you know, the ASME codes must be purchased and are available from Elevator World, Techstreet (http://www.techstreet.com/products/1865958), and directly from ASME (https://www.asme.org).

Now, to add a level of complication geometrical to comprehending the A17.1-2013 code, the Division is proposing approximately 35 pages of Group V language that supersedes A17.1-2013.  Whole sections are "not adopted" and other sections are completely rewritten.  To help me get through attempting to reconcile the two documents, I completely red-lined a copy of A17.1-2013, lining-out the "not adopted" sections and word strike-outs.  I wrote in in red the new Division language, where there was sufficient room.  Otherwise, I added references back to the CCR Title 8 document.  There's a lot to comprehend!

The proposed Division changes to A17.1-2013 covers a lot of issues and I won't go into them all in this article.  I'll mention a few:

• The Performance Based Code A17.7-2007 is not adopted.
• Vast changes to MRL elevators regarding access to equipment.
• Controllers are not allowed in the hoistway, overhead, pit or entrance frames.  They must be in a dedicated machine or control room.
• Work platforms, stationary or retractable, are not allowed to service equipment in the overhead.
• If the drive machine or emergency brake are to be serviced from the car top, the cat top must be level with the access landing and locked at that location (how's that going to work?).  

Certainly don't rely upon my opinion - get a copy and work through it on your own.  I would recommend attending the Advisory Committee Meeting on Tuesday, April 22nd.  Unfortunately, I have to be in Denver on that day, attending the International Association of Elevator Consultants (IAEC) Annual Forum, as I serve on the Board.  My wife, Margaret will be there, taking notes, as well as a number of my spies.  It will be an interesting one...

Your Code Reporter,

Rich Blaska

D. A. Swerrie

It is with great sorrow that I report the passing of a true giant of the elevator industry, D. A. Swerrie.  In his 21 years of service at the State of California, DOSH-Elevator Unit, culminating with its highest position, Principal Safety Engineer, Dee was known and respected for his thorough knowledge of elevators and codes.  Moreover, Dee was appreciated for his fairness and understanding in the application of those codes, especially when dealing with the more gray areas in the ultimate balance between the letter of the code and the intent for assuring the safety of workers and the general public.  His example set the standard for all that followed him in this position.

Dee was an educator throughout his life.  Mentoring younger workers at Otis, helping fellow safety engineers, informing those at elevator companies as to the meaning of the code, his brilliant lectures, his ASME Code Seminars, his authoritative book Defensive Elevatoring (click here to purchase), and more recently his monthly quizzes he provided at our NCEIG meetings (I loved those).

I got to know and respect Dee through our time together at NCEIG, where he encouraged me in my work and to become active in the industry.  I can think of no one who I've met in our industry who has inspired me more than my friend, Dee Swerrie.  We will miss him...


Please read below Dee's obituary as provided by his family, the information provided by Dee himself:

 DEE ALLEN ERIKSEN SWERRIE

1925 - 2014

Commonly known as D. A. Swerrie by acquaintances and Dee by good friends and family, he left us on the next step of his journey quite peaceably on January 9, 2014.  He came to us as the son of Alexander Eriksen Swerrie (Sverre Aleksander Eriksen his name at birth in Norway) and his wife Olive Agnes Swerrie nee Westrom (of the Spencer family, Minnesota).  Dee was born March 21, 1925 in San Francisco. 

Following Dee's graduation from Balboa High School in the fall of 1942, and when he turned 18, he became a member of the Army and participated in the European Theater of WW II.  His anti-aircraft unit was attached to the 10^th Armored Division, in the 3^rd army under General Patton after securing the landing when Patton was ordered to Normandy.  From the invasion at Normandy, in the hedgerow area on the cliffs above the beaches, which was so difficult to cross, under Patton’s leadership they proceeded to re-take France, the Battle of the Bulge, the Siege of Bastogne, and the taking of Treir.  Crossing the Rhine River, they led the way across Germany to Bamberg, Dachau and Munich.  The war ended, and then, as a 2^nd Lieutenant in the Infantry he was rotated back to America and was relieved from active duty for his 21^st birthday. 

While working at numerous endeavors, Dee attended UC Berkeley and was awarded his BS in 1950.  On June 27, 1953, Dee was married to Martha Elizabeth Lee and began their family together. Having moved to Novato, California, in 1965, Dee and Martha were charter members of All Saints Lutheran Church, where Dee worked hard with other church members making the new church building all they envisioned.

After college Dee went to work in the elevator trade with Otis Elevator Company.  Leaving Otis in 1965 he became a California State Elevator Inspector.  Then he went on to be a Senior Safety Engineer and ultimately Principal Safety Engineer, at the same time achieving California State PE registration as a Safety Engineer. 

Retiring from the State in 1986, Dee was self-employed as a consultant specializing in Elevators, Ski-lifts, and Carnival Amusement Rides.  He quit field activity in 1999, although he remained active in the industry instructing for ASME and supporting the Northern California Elevator Industry Group.  While in the Elevator Industry, he wrote many articles published by Elevator World magazine and a book titled Defensive Elevatoring.  He attended seminars around the United States, in France, Germany, Japan and Taiwan.  During this time, Dee also became well known working with AARP   teaching Driver Safety courses for aging drivers.  Dee always said, “It is not work when you like what you are doing.  While others look forward to the weekend, I look forward to Mondays.”

He leaves behind his wife of 60 years, Martha, and his three children and their families: Daughter Christina and Edgar Shippey and their son Adam; Son Erik and his three children, Ben, Kyra and David; and Son Lee and Laurie and their two children, Allison and Jonathon.  Also surviving are his sister, Allyne Swerrie; Nephews, Mark Figley, Steve Lee and Don Lee; and nieces Lyndy Bullock, Clare Jenet, Jhun Holloway, Robin Orsua, and Laurie Dominguez, and their families.

When asked what he considered his greatest achievement, Dee would say, “Marrying my wife Martha and raising our three children Tina, Erik, and Lee.” 

A celebration of Dee's life will be held Saturday, January 18^th @ 11 am at All Saints' Lutheran Church, 2 San Marin Drive, Novato.  In lieu of flowers a donation to the All Saint's Lutheran Church Secret Santa Program or your favorite charity. 

EMPLOYEE SAFETY, by Dee A. Swerrie

Here begins a series of posts from one of the true greats of our industry, Dee A. Swerrie:

EMPLOYEE SAFETY

A question was asked during the luncheon meeting on January 9, 2013 and it occurs to me that I may be the last person with the ability to provide an answer; I have been told that following my tenure as Principal Engineer of the Elevator Unit of Cal-OSHA, two Cal-OSHA Seniors consecutively were assigned as the Principal.  One of them, again, as I have been told, purged all the old records which existed prior to the advent of Cal-OSHA.

The question:  Paraphrased:  How come California doesn't permit the installation of Drop-keys, hidden chains, or any other means of gaining access to hoistways if an elevator stalls away from a landing and a rescue must be initiated? 

Frequently this is done by other than adequately trained elevator mechanics, much to their frustration.  It also causes elevator mechanics, trained in other than California, similar frustration.

To understand the answer one must keep in mind that the first ASME/ANSI, or whatever name it went by at the time, A 17.1 Elevator, etc. “code” was made available was in 1921.  The word code is in quotes as we know it is not a national code nor is it even a code.  Until some AHJ (Authority Having Jurisdiction) legally adopts it, and makes it the code that that jurisdiction intends to enforce.  However, that AHJ always retains the ability to modify A17.1 to suit their needs.  Then it becomes a code – but, only for that jurisdiction.  I think of A17.1 as a standard rather than a code, a standard written in what the A 17 Committee suggests as code language.

Keeping the above in mind, let us now go back to the year 1914.  In 1914 the California Industrial Accident Commission had its origin, and within it was the Industrial Accident Prevention Bureau, (IAPB).  The IAPB had the responsibility of supervising places of employment to insure employee safety.  In San Francisco there were many, many big buildings containing elevators.  Recall some of the pictures you've seen relating to the 1905 earthquake.  At that time most high speed high rise elevators were hydraulic elevators. 

An Otis publication in 1900 indicated that the elevator industry was of the opinion that the future of high speed, high rise elevator cars would be suspended by ropes (steel cables) but the machine would be hydraulic.  Picture if you can the cylinder containing the plunger lying on and securely fastened to the basement floor of a building.  As the plunger moves out of the cylinder the car will move up in the hoistway.  The ropes (steel cables) are connected to the car with a very sophisticated roping arrangement passing over multiple pulleys which controlled elevator car acceleration and speed. Such machines always had a bit of leakage and needed ongoing maintenance.  There were many cases of elevator cars moving away from the landing to one degree or another.  There were cases of employees falling into cars and even down the shaft.  In addition to what took place with the elevator cars, think about maintaining the basement arrangement of the multitude of moving ropes and turning pulleys.  And further complicating the system, each elevator had to be suspended with 3 or more ropes.  There were certain to have been many injuries.  In the Flood Building in San Francisco there were at least 10 elevators all with such a system in the basement.

All the above problems with elevators were well known in 1914 when the Industrial Accident Commission had it origin; in fact elevator problems may have been a contributing factor to hold the meeting.  At that time the IAPB had the authority to:

·         Investigate work places and the work process itself for safety;

·         Investigate industrial injuries, especially disabling or fatal ones;

·         Enforce all laws and lawful orders requiring work and work places to be safe;

·         Prepare standards of industrial safety (Safety Orders), which if approved by the     Industrial Safety Board would have the effect of law;

·         Establish special orders, or rules and regulations to cover a specific individual place of employment and process of work.

It was during the meetings held in 1914, 15, and 16, that the original California Elevator Safety Orders were written.  Of course it took some time for the Industrial Safety Board (ISB) to approve the Safety Orders, to arrange suitable funding, and to create the agency that would enforce the orders. However, by 1920 all was ready to commence enforcement of the Elevator Safety Orders.  I no longer remember the name of the first chief (now principal); I do recall the last name of the first Certified Insurance Company Inspector.  His name was Moon.  I recall the name as his son Roy Moon was working as a State Elevator Inspector when I became such.   The Insurance Company Elevator Inspector program apparently was developed at the same time as the Elevator Safety Orders were.  The certification process came along later and appeared in the Elevator Safety Orders in 1951.  However for many years the insurance inspectors did the bulk of the inspection work.  After 1951 all insurance company elevator inspectors had to be tested and “certified as competent” if the insurance company wanted their inspectors report of inspection to be acceptable by the elevator inspection agency for permit purposes. 

Also, those first safety orders did establish retro-activity; from the very beginning.  Every elevator in all places of employment had to comply with all the retro-active orders.  Of interest is the fact that the first state employed Elevator Inspectors were issued side arms to assist them in enforcing compliance.  In my research of the history of the unit I found no mention that any State Elevator Inspector had to make use of his side arm to carry out his duties.

It was the decision of the IAPB, and the ISB that the Elevator Safety Orders would prohibit any means of opening the hoistway doors from the landing side.  That for safety in places of employment,  provisions made to permit the hoistway doors to be opened from the landing side if the car was away from the landing could lead to a very dangerous condition.  Therefore - No exceptions.  During my research, I found no other jurisdiction taking such a position.

Aside:  As representatives from the Elevator Industry were present during the meetings in 1914, 15 and 16, when the Elevator Safety Orders were under consideration, I can't help but wonder if the position California was taking didn't stimulate some action on the industry's part to come out with their first “Elevator Code” in 1921.

That is the response to the question asked during the January 9^th 2013 meeting.  It is going to take another BLOG or so to clarify how, “from applicable to places of employment” grew to what it was during my tenure as Principal.

Dee A. Swerrie

Circular Letter E-11-01 - Certification Requirements – Withdrawn

Revisiting the theme of my last Blog Report from May regarding DOSH-Elevator Unit - Circular Letters, many of you may be aware the Division has “Withdrawn” their Circular Letter E-11-01 - Certification Requirements, issued November 16, 2011 (http://www.dir.ca.gov/dosh/ertcrltr.html).

Rumors abound as to what was the impetus for the Division to withdraw this Circular Letter (CL).  Some say one or more of the majors was threatening to sue the State regarding the statement in the CL clarifying the requirement, “monthly fire phase one and two testing must be performed by a certified competent conveyance mechanic.”  The speculation is that these majors, and possibly minors as well, take issue with two aspects of this requirement:  One, that this testing must be performed by their CCCM mechanics; and two, that it must be performed “monthly.”  On the first, the companies would have to raise their service rates to cover the additional labor time to perform this testing.  On the second, the companies’ mechanic would actually have to visit the job every month. 

It’s been many years, decades likely, since the standard full service maintenance contracts by the majors (and many of the minors as well) used the word “monthly” with reference to frequency of maintenance.  It has been universally replaced with the word “periodic” or “as required…” – or some similar, undefined term.  Many tout their somewhat inscrutable, off-site elevator monitoring services as an effective substitution for more frequent physical visits to the equipment.  Their HQ computer will tell them when the units need servicing...  It’s curious to me that I’ve never seen dirtier pits and car tops since the advent of these systems.  It’s all about competition – or is it about profits? 

Back to the first issue, the question of whether the code requires elevator Fire Service Phase I & II be tested by a CCCM.  As the original CL references, the governing authority derives from the California Labor Code, Sections 7300-7324.2.  You can find this code language at:  http://www.leginfo.ca.gov/cgi-bin/displaycode?section=lab&group=07001-08000&file=7300-7324.2.  My re-reading of this code failed to find anything specific to fire service testing.  The closest the language comes to making this a requirement is section 7311.2 with the wording, “…any person who, without supervision, erects, constructs, installs, alters, tests, maintains, services or repairs, removes, or dismantles any conveyance covered by this chapter, shall be certified as a certified competent conveyance mechanic by the division.”  The operative word in that language is “tests.” 

This raises my point of my previous blog article, does the writing of Circular Letters by the Division constitute “writing code” as my old friend Al Tafazoli contented (and therefore avoided their use)?  Or, is the function of CLs to help clarify the code as written – which is my understanding.  Where it gets sticky is when the code is insufficiently specific, such as whether the word “tests” in the Labor Code extends to the monthly testing of fire service.  Admittedly, my study of the code on this point has not been exhaustive but my current interpretation would be that it would apply and that the CL was accurate.  Possibly someone out there can convince me otherwise…

In addition to the fire service testing, this CL speaks to an array of other issues concerning who can legally work on elevators.  It made clear that non-CCCM tradespersons could not perform cab alterations, which had been a common and potentially dangerous occurrence.  Examples of hazards to these non-certified personnel could include electrocution from drilling holes through the cab walls or canopy into unseen electrical devices.  A clear danger to the riding public has been the frequent use of non-fire & smoke rated materials, un-rated glass and improperly secured materials in elevator cab interiors.  A very serious problem has been system unbalancing and overloading of elevator cars with the use of excessively heavy materials in cab installations and upgrades.  I’ve seen a number of elevators with a negative over-balance, causing excessive drive sheave and rope wear from traction loss due to this error.  The intent of only allowing this work to be performed by CCCMs is that they are professionally trained & certified and understand the codes and dynamics of elevators.  

In summary, I disagree with the withdrawal of DOSH Circular Letter E-11-01.  This CL served a very useful and correct purpose and, I would argue, was needed to clarify vagueness in the code language.  Note that the withdrawal of this CL did not change or alter the underlying code.  The Labor Code and Elevator Safety Orders remain as written.  It didn’t make it legal for non-CCCM millwrights to install elevator cab interiors or demolition crews to remove old elevators.  What the withdrawal of this CL did, in my opinion, was to put back in place the uncertainty that existed previously, that the CL had intended – and succeeded briefly – in removing. Even worse, some believe it vindicated the wrong practices of the past. 

If indeed there was a specific problem with some of the language in this Circular Letter, then the better solution would be to amend it to make it right.  I’ll be the first to admit that I don’t know the whole story behind this controversy.  I welcome anyone out there to post a comment, or if they prefer, call me privately if you have more information on this subject.

Cheers,

Your Code Reporter
Rich Blaska

DOSH-Elevator Unit - Circular Letters

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!

NCEIG Christmas Dinner Party and Old Timers Reunion

Hello Elevator People!

Yes, the Annual NCEIG Christmas Dinner Party and Old Timers Reunion is just around the corner so make your plans now! In the past we have always asked our members to do a bit of outreach to our retired industry colleagues with some success. This year let’s try to get as many retirees as possible! Remember, our industry retirees and their spouses can attend this party without charge, they are our honored guests after all.

We would also like to ask everyone that is planning to attend to RSVP by no later than Friday, December 2^nd, 2011 by sending an E-mail to: ebleyle@bleyleelevator.com.

And our President, Erik Bleyle, has also requested that, if possible, our members (suppliers and otherwise) bring some items to donate for the Christmas party raffle.

So, get out your Roladex (old timers know what those are) and dial-up (wait, phones don't have "dials" anymore) all of the guys (were there any gals then?) who used to run you around when you were a 50%'r.  Know any old branch managers, construction/service managers, salesmen, drill rig operators, state inspectors, etc.  Get them all and their significant others to the Christmas party.  Truly the best event of the year for NCEIG is hearing the tall tales of these living legends - said by someone who's loosing his hair and is not so young anymore himself.  It's always great fun and the food & drinks are great too. 

See you at Sinbad's!

Cheers,
Your Code Reporter
Rich Blaska 

Changes to California Shunt-Trip Rules

I've been informed by my good friend, Bill Mitchell, Schindler Elevator Corp., of a major change in the requirement for shunt-trip power disconnection in California.  The Office of the State Fire Marshal (SFM) has made changes to the 2010 edition of the California Building Code (CBC), based on the 2009 International Building Code (IBC).  The entire text of the changes is available online at: 

http://osfm.fire.ca.gov/codedevelopment/pdf/2010interimcodeadoption/Interim%20Code%20Adoption%20Timeline/Part-2_ET_20110701.pdf

You might note that the title of this document reads:

FINAL EXPRESS TERMS FOR PROPOSED BUILDING STANDARDS OF THE OFFICE OF THE STATE FIRE MARSHAL REGARDING THE 2010 CALIFORNIA BUILDING CODE CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 2 2010 INTERIM RULEMAKING CYCLE

However, a representative of the SFM indicated that these changes to the regulations have formally been adopted by the California Building Standard Committee.  You may wish to verify this on your own but I am assured that this is now a part of the new California Fire Code. 

I’ve copied and pasted below the specific section of the referenced document:

CHAPTER 30 - ELEVATORS AND CONVEYING SYSTEMS

3006.4.1 Automatic sprinkler system. Automatic sprinklers shall not be required to be installed in the elevator hoistway, elevator machine room, elevator machinery space, elevator control space, or elevator control room where all the following are met:

1.  Approved smoke detectors shall be installed in the elevator hoistway, elevator machine room, elevator machinery spaces, elevator control spaces, or elevator control rooms and connected to the building fire alarm system in accordance with Section 907. 

2.  Activation of any smoke detector located in the elevator hoistway, elevator machine room, elevator machinery space, elevator control space, or elevator control room shall cause the actuation of the building fire alarm notification appliances in accordance with 907.

3.  Activation of any smoke detector located in the elevator hoistway, elevator machine room, elevator machinery space, elevator control space, or elevator control room shall cause all elevators having any equipment located in that elevator hoistway, elevator machine room, elevator machinery space, elevator control space, or elevator control room to recall nonstop to the appropriate designated floor in accordance with CCR Title 8, Division 1, Chapter 4, Subchapter 6, Elevator Safety Orders.

4. The elevator machine room, elevator machinery space, elevator control space, or elevator control room shall be enclosed with fire barriers constructed in accordance with Section 707 or horizontal assemblies constructed in accordance with Section 712, or both. The fire-resistance rating shall not be less than the required rating of the hoistway enclosure served by the machinery. Openings in the fire barriers shall be protected with assemblies having a fire protection rating not less than that required for the hoistway enclosure doors.  The exceptions to Section 3006.4 shall not apply.

5.  The building fire alarm system shall be monitored by an approved supervising station in accordance with 907.

6.  An approved sign shall be permanently displayed in the elevator machine room, elevator machinery space, elevator control space, or elevator control room in a conspicuous location with a minimum of 1½ inch letters on a contrasting background, stating: NO COMBUSTIBLE STORAGE PERMITTED IN THIS ROOM  By Order of the Fire Marshal [or name of fire authority]

This is great news as most in our industry have long argued against having machine rooms, control rooms and hoistways sprinkled and the power shunt-tripped.  I’m proceeding with the engineering of a number of elevator major alterations where we are verifying or correcting the fire-resistive nature of the elevator spaces and removing all of the sprinklers. 

As always, I must qualify that you should independently verify all code questions with the proper authorities having jurisdiction. 

Cheers,
Your Code Reporter
Rich Blaska

Rope Brakes, Platform Guards & Shallow Pits

I always knew them as toe guards.  Like many things in elevators, the codes and AHJs have different names for things than I had known them to be.  Spreader brackets are actually called “tie brackets.”  Sump pumps are called “water removal systems.”  We won't even go into what I learned as the name for hoistway door unlocking devices - which are disallowed in California anyway.  

Toe guards are called "Platform Guards (Aprons)" in ASME A17.1, section 2.15.9 as well as in CCR Title 8, Rule 3033(i).  I guess calling them toe guards comes from the perspective of an elevator person who might run cars up and down on hoistway access and without the toe guard, it would seem a lot easier to run the platform down on your toe if your were absent minded enough to stick your foot over the edge of the hoistway sill.  There was probably even a point early in my career were I actually thought this was the purpose of a platform guard – which is what I will call it that for the rest of this blog. 

As I'm sure all of you know, the real purpose of a platform guard is to prevent elevator passengers from going down the hoistway in the event they become entrapped in an immobilized elevator.  In brief, what happens is that an elevator malfunctions and comes to rest above a floor.  The passenger attempts to exit the car by forcing open the doors and climbing out to the floor below.  For example, say the car is 4 feet above the landing and it is an older car not equipped with a door restrictor device.  Depending on the door operator, it may be fairly easy to palm the car door open.  It wouldn't take too much trial and error to figure out how to open the hoistway door for most systems; usually it's a matter of pulling on the pickup rollers or pushing on the roller lever to release the swing door interlock. 

Then what happens is the passenger attempts to let themselves down to the  floor below by hanging onto the car sill and hoisting themselves down.  This is the rub.  If you’ve ever suspended yourself by your hands you know what happens.  Your body will rotate forward toward the car platform due to the natural location of your body’s center of gravity.  And where would that leave you – under the platform well within the hoistway.  The plan was to lower oneself down to the floor but instead the hapless passenger finds themselves inside the hoistway sill and down they go…  This is, I believe, the most common cause of death or major injury in elevator accidents.

Thus, the platform guard!  I haven’t done the research to be able to tell you when this essential safety feature was added to the code (Dee, do you know?).  I see early 20^th century elevators all the time with no platform guard, running, perfectly legally as this device was never made a retroactive requirement.   The code had been consistent for probably half a century requiring a platform guard with a height of “not less than the depth of the leveling or the truck zone, plus 3 inches.”  The problem is that with a 7 foot typical entrance, that would leave ample room for one to get out of a car and still go under the platform guard and down the hoistway.

As no doubt all of you know, starting with the ASME A17.1-2000 code the ascending car overspeed and unintended car movement (ACO-UCM) protection has been a requirement.  The platform guard section, 2.15.9, was modified to take into account the new ACO-UCM provision with the added requirement for a 48 inch platform guard.  The logic here is that 48 inches is the maximum allowed car travel upon activation of ACO-UCM.  The affect of this new code is that essentially all new traction elevators will have 48 inch platform aprons and pit deep enough to accommodate them.

All right, here’s the original reason I started this blog.  How does all of this play out when altering an existing elevator to add ACO-UCM?  There are five (5) alteration events that trigger the requirement to add ACO-UCM (Can you name these?  If you give up, go to my website articles to find the answer).   It is widely believed that when altering an existing elevator and ACO-UCM is added that a 48 inch platform apron is also required.  Not true. 

This gets to a very common error in reading the elevator code.  When altering an existing elevator, people will often automatically reference the full body of the current elevator code, A17.1, Part 2 or 3.  Wrong.  When altering an existing elevator one first must go to what local or state codes that applies.  In California, one must start with CCR Title 8 which in turn currently references ASME A17.1-2004, Alterations, Section 8.7.  This section will send you wherever you will need to go for any work performed, based on what is being altered.

In our discussion here, for instance, say the work is the classic new fixtures, door equipment and controls.  The existing elevator is a Ward-Lenard system with a motor-generator and a DC motor on a geared machine.  The alteration includes replacing the M-G with a Vector AC system and installing a new AC motor on the machine.  One of the sections you will have to go to is 8.7.2.27.5 Change in Type of Motion Control.  To confirm this go to A17.1, Part 1, Section 1.3 Definitions, “control, motion” which lists and defines all of the different types of motion control.  The elevator will be modified from a “control, generator field” to a “control, variable voltage, variable frequency (VVVF).”

Note section 8.7.2.27.5(e) sends you to section 2.19 ACO-UCM.  This is the most common trigger that requires the addition of an emergency brake, which if most often met when the machine is being retained by adding a rope brake.  Further note that nowhere in section 2.19 does it send you to section 2.15.9, the requirement for a 48 inch platform guard.  Nor does any other part of section 8.7 send you there for the scope of work described.  The authors of the code were very clever in how they constructed these code revisions so as not to create a trap whereby one would be required to deepen a pit simply because one wants to install new controls and motor on an existing elevator. 

There are a number of alteration sections in 8.7 that do send you to 2.15.9, such as 8.7.2.15.2 and 8.7.2.16.4.  These clarify the requirement that one “shall conform to 2.15.9 only to the extent the existing pit shall permit…”  Section 8.7.2.27.5 probably should include this same language but it doesn’t.  I make it a practice to do it anyway – install a new platform guard of the maximum length up to 48 inches, to the extent the existing pit depth will allow.   

Another place this language should be included, but it isn’t, is section 8.7.2.15.1 Alterations to Car Frames and Platforms.  That section simply sends you to 2.15 (which obviously includes 2.15.9).  So, what does that mean?  If one alters a platform, say cuts off 6 inches of the leading edge so as to install power-operated doors, does that then require you to deepen the pit so as to install a 48 inch platform guard?  Also, what if you install a complete new platform on an existing elevator?  Curiously, there is no language in 8.7 that specifically address a new platform, only alterations to car frames and platforms.  I assume that section 8.7.2.15.1 includes replacing the platform as well as altering one.  I recommend getting a clarification from your AHJ for this code omission.  The times I’ve done that the inspector rightly uses the logic clearly set out elsewhere in the alteration section and accepts that a platform apron of the maximum length be installed.

My business, Smart Elevator Tech, LLC, manufactures and supplies unique elevator products that I have invented, such as the Retracta Ladder®, Low-Profile Fishplate™ and a Deflector Sheave Isolator™.  I’m beginning to get a number of requests to invent a viable retractable platform apron.  I’ve given it some thought and, at least for the moment, have decided to pass.  First, why would anyone need one as they would not be needed in an alteration – as I’ve just shown.  For new construction, all companies would have the same requirement and should be able to specify the necessary pit depth that will be built.  Finally, there are many complications to designing a rise and fall or hinged platform apron that would be viable.  It would have to be activated with each run to the lowest landing, which is more often the lobby – the highest traffic landing.  There would be huge wear factors.  It would have to be failsafe, probably switched so the elevator couldn’t run if the device failed (or simply wore out).  And that’s just the beginning of the problems with such a device.

Cheers,
Your Code Reporter
Rich Blaska

Rope Grippers and the State

The issue of the requirement to provide Ascending Car Overspeed and Unintended Car Movement Protection - Section 2.19 on alterations has always been a little confusing and somewhat controversial.  I had written an article about this on my website some years ago, which I’ve just updated:  http://www.blaska.com/rope_brake.htm.   

With the time that had passed since California has adopted (by reference) the ASME A17.1-2004 code, most of us are now up to speed on what triggers this requirement when altering an elevator.  Probably the only remaining questions are:

·         what product to use

·         how to mount it

·         does it require engineering

As to what product to use, unless you are installing a new gearless machine, probably the best solution is to install a rope brake.  Some of the rope brakes currently available are the Hollister-Whitney Rope Gripper™, the BODE Rope Brake or the Draka Sure Stop™.  The new PMAC gearless machines now all have the emergency brake built in, an ideal solution.  Hollister-Whitney has begun to offer some of their traditional geared machines with integral factory mounts for their Rope Gripper™.  But if you are retaining the machine, this will usually mean mounting a rope brake of some type in some place.

How to mount a rope brake can be quite simple or very involved.  I wrote about this in some detail in my article, http://www.blaska.com/rope_brake.htm, so I won’t repeat it here. 

Does mounting a rope brake require engineering?  At least in California, I thought the answer was no or not necessarily.  It was my understanding from the principal engineer, back when A17.1-2004 was adopted, that full engineering submission was not required.  However, if the inspector suspects the installation and requests engineering, then it must be supplied.  This may have changed.  Currently we are seeing, as far as we can tell, that all Southern California Cal/OSHA - Elevator Unit offices are requiring specific installation engineering, wet signed by a California licensed professional engineer.  This must be supplied at the time of the final inspection if not submitted earlier. 

Based on an email thread I’ve seen, it appears Cal/OSHA - Elevator Unit offices throughout the state may now or will soon be requiring full engineering of non-factory installed rope brake installations.  On alterations, this engineering apparently is to include calcs on not just the mounting brackets or framework but also that to which it is attached.  For instance, if the rope brake is mounted on channels that are then through-bolted to the existing machine beams, those machine beams must be certified for the rope brake loading.  (Actually, the machine beams will never see loads from a rope brake that are greater than exerted by the base elevator system – but this appears to be the requirement.)  As to the criteria, for example if a Group II elevator is altered to include the addition of a rope brake, then the alteration must comply with Group IV criteria – meaning A17.1-2004.  This means that all that is altered must comply with the criteria of Group IV / A17.1-2004 including the loading and strength standards. 

You might want to check with your local Cal/OSHA - Elevator Unit office as to what they will require for your alteration, including whether formal engineering is required.  If it is, find out whether it should be submitted in advance or simply available to the inspector at the time of the final inspection. 

Some would argue that engineering is a good idea even if the state doesn’t mandate it.  The rope brake loading varies from 4,000 lbs. to 16,000 lbs. – not an inconsiderable amount. 

If anyone out there has any additional information on this topic, I would be grateful to hear it.  Feel free to call me (415) 819-5744 or email me at rich@blaska.com.  Let me know if you prefer the information to be added to this blog or kept in confidence.  Also, feel free to write a comment by clicking the link below (it would let me know someone is reading these…). 

Cheers,

Rich Blaska

"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

The Code Reporter – Elevator Pit Ladder Craziness

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).  I had said that unless an alteration was performed where the pit itself was altered, e.g. deepened, reconstructed, etc., that there was no code requirement to add a ladder.  This is apparently wrong as I just found out during an inspection of a winding drum conversation alteration.  The old winding drum elevator had a 38 inch pit depth and never had a pit ladder.  The alteration did not involve deepening or reconstructing the pit per se, but did include new buffer springs, pit lighting & outlet – the typical work of a major alteration.

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