Recap of Meeting of April 15, 2008
The meeting was called to order by President Mike Shaw with about 120 attending. In view of the size of the group, the usual business session was omitted, as were self – introductions. We proceeded directly to the program, headed by Al Tafazoli, Principal Engineer for the Elevator unit of DOSH for the State of California. Additional representatives of the state code enforcing authorities on hand included Michael Boyle, Paul Puno, John Pevehouse, Steve Singleton, Daniel Barker and Al Swanson. The City of Los Angeles was represented by Chief Inspector Peter Callas, Barry Friesen and David Jennings.
All present were provided with copies of Circular letter E-08-01 form the State of California, DOSH, Elevator, Ride and Tramway Unit, which is the official notification of the new regulations which were the stimulus for our meeting. The letter can be seen here:
Mr. Tafazoli reminded us that the state’s elevator regulations are embodied in Title 8 of the California Code of Regulations, and that ASME A17.1-2004 only applies to the extent that it is incorporated in those regulations. Further, when reference is made to ASME A17.1-2004 (which we will refer to hereafter as A17), it means the original version thereof and does not include supplement 1S-2005 or addenda 1a-2005. Al emphasized that when consulting the regulations, it is important to begin with Title 8 and refer to A17 only where directed therein. Many items are addressed in the Title 8 regulations and not necessarily covered by A17. Some examples are static controls, vertical platform (Wheelchair) lifts, water removal systems and limited use, limited access systems (“LULA’s”).
Elevators covered by these revised regulations are classified as being in a new grouping, designated Group IV. Equipment covered by previously created Groups I, II and III continue to be covered by the regulations appropriate thereto and the new regulations incorporated into Group IV are not retroactive. Previously granted permanent variances continue to be valid.
The effective date of the new regulations is May 1, 2008. For contracts signed prior to May 1, a letter of intent should be sent to the Division to insure “grandfathering” as Group III. Contracts executed on and after May 1, 2008 will be covered by Group IV.
California has no regulations governing elevators and the like in single family residences. Section 3001((b)(5) states that elevators installed in a multiunit residential serving no more than two dwelling units, not accessible to the public, installed after September 28, 2001 are required to comply with applicable provisions of ASME A17.1-1996, part 5, or ASME A18.1-1999, sections 5, 6 and 7. Such installations require an “acceptance” inspection but are not subject to periodic inspections thereafter.
Device approval (“labeling”) is still required by the State for hoistway door locks, oil buffers, governors and safety devices. Plunger grippers are added to this list by the Group IV requirements. In response to a question, it was indicated that the auxiliary braking devices required by the new regulations do not require labeling.
Conveyances used for construction covered by A17 section 5.10 are required to comply with that section and additional requirements are listed in Section 3141.10 of Title 8.
Many questions were asked concerning what are commonly called “modernization’s” (called alterations in A17). The concern is when the Group IV regulations would apply in such cases. There is no short answer. Each Group has regulations which address the subject and one must consider what is being done, look in the appropriate section and make a determination. Generally, it may be said that components that are in no way altered would continue to be governed by the rules applying at time of original installation. As a specific example, any modernization of a hydraulic elevator that did not directly affect the jack unit, would not be cause to apply the Group IV rules to that jack. Where the jack unit is replaced as part of a modernization, (alteration) Group IV rules would apply to that jack, simply because those would be the rules in effect at time of installation insofar as the jack is concerned. Where a cylinder is installed, altered or sleeved as part of an alteration it would be required to conform to rule 3.18.3 of A17, which is the same requirement a new installation would have to satisfy.
Section 3141.6 states that periodic testing (generally not previously required) shall comply with the requirements of A17 section 8.11, establishes the frequency for such tests and requires that such testing be witnessed by a “Certified Competent Conveyance Inspector” (CCCI). A CCCI is defined as “Any person who has been determined by the Division to have the qualifications and ability of a competent conveyance inspector and is certified as a CCCI by the Division”. The methods to be used by the Division to determine such competency have yet to be developed. The CCCI witnessing such tests is required to report the details and results to the Division within 21 days of the date of the test, on a form to be provided by the Division or equivalent. All statements on the form are to be made under penalty of perjury.
In a separate conversation, Mr.Tafazoli indicated that the written Maintenance Control Program, as called for in 184.108.40.206.1 and the maintenance records called for in 220.127.116.11 of A17 will be required to be kept on the premises, readily available to his inspectors upon request.
Up to date wiring diagrams are required by 18.104.22.168.3 of A17 to be available in the machine room.
Another meeting is contemplated n the near future to discuss pending items and other developments. Thanks to all the participants for their cooperation and support!
Proceedings concluded with our regular raffle. We had a truly nice group of prizes. Unfortunately, I fear that in the rush due to the larger than usual attendance, the names of all the donors were not properly recorded. Those that were include: Allan Lloyd of DRAKA, Michael Shaw of LERCH BATES, John and Doris Brannon, Bill Adrian of REPUBLIC ELEVATOR, Stan Schultz and Scott Dutton of CED. Apologies to anyone left out.
And the winners were:
Orion Pepin, Mark Anderson (big time), Mike Shaw, Phillip Hampton, Dave Turner, Alan Taylor, Marilyn Look, Doris Brannon, Dave Turner, Jim Finley, Paul Puno, Steve Grainer, Joe Orrico, John Irelan, and last but certainly not least — the grand prize went to Teel Whittington.