UPDATE: California Proposes New Elevator Maintenance Rules

UPDATE - January 29, 2015

Elevators are a major part of the high-rise building environment. As such, it's incumbent upon BOMA members to participate in discussions regarding vertical conveyances. Thankfully, if you haven't had the time, your BOMA San Francisco Codes and Regulations Committee has been doing just that. It’s time to take reassess where the issue of elevator design and a maintenance stands.

California's position has been that some machine-room-less (MRL) elevators are not safe for maintenance personnel to service. Their examples are laid out in the this power point presentation. 

The Commercial Real Estate Industry says these are rare occurrences. Also, the State's proposed new Group V regulations will effectively prevent the future installation of MRL elevators or that the elevator cab designs will have to be customized for the California market, raising costs along the way.

Click here and here for two additional documents from the U.S. Navy and the U.S. Army Corps of Engineers regarding the installation and maintenance of future elevators. The State has submitted them as evidence to support their call for higher safety standards for all new Group V commercial elevators.

Additional resources:

• NEII Summary of Key Group V Proposals
• Draft Elevator Safety Orders, Group V: Briefing of Issues - Department of Industrial Relations, Division of Occupational Safety and Health (Cal/OSHA), August 26, 2015

If you have any feedback, please send it to mhargrove@cbpa.com.

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UPDATE - June 25, 2015

As detailed in our previous posts. the rules are most likely going to change for Group V elevator maintenance and inspections.

To represent our members' interests, BOMA San Francisco's Codes and Regulations Committee representatives had a rare opportunity to discuss the proposed changes with the California Department of Industrial Relations, Occupational Safety and Health Division, Elevator Unit (Cal/OSHA) chief, Dan Barker recently. The purpose of the gathering was to help the Department understand any negative impacts, e.g., cost, availability, safety issues, et cetera, that may result from these changes.

Also, the National Elevator Industry, Inc. (NEII) is making building owners aware of the efforts underway by the Cal/OSHA to develop the Group V elevator codes.  Cal/OSHA has proposed over 60 pages of changes - more than 125 specific modifications - to the ASME A.17.1 (2013) /CSA B44-13 Safety Code for Elevators and Escalators.  

The draft amendments to the ASME Code under discussion are so significant and controversial that, if enacted through formal rule making, they will drastically alter current elevator designs for all of the major elevator companies and impose significant new costs and construction delays on California building owners.

Key areas of concern in Cal/OSHA's pre-rule making draft and initial estimates of potential costs are set forth below.

KEY AREAS OF CONCERN:

• Prohibits certain machine-room-less (MRL) designs in California.
• Adds new restrictions for other MRL designs.
• Prohibits elevator controls from being located in the building hoistway, requiring control rooms to be constructed.
• Significant cost increases and delays for new construction.
• Significant cost increases for elevator maintenance on existing buildings.
• No demonstrable safety benefit; in fact, creates new workplace safety issues.
• Lack of empirical data to support changes.
• Disproportionate impact on low to mid-rise buildings.
• Stunts technological innovation and eco-efficient building designs.
• Moves California building transportation backwards 20 years.

SIGNIFICANT NEW COSTS:

• Elevators unique for California
• $100K-$200K per elevator
• Larger cars, larger hoistways, less space to rent
• $25M annually
• No Hydraulic machine room-less elevators
• $25M annually
• Control rooms must be outside of hoistway
• $100M annually
• Licensed mechanics required to perform new tasks
• $33.6M annually

The draft proposed rules are currently under review internally at Cal/OSHA. Formal rule making has not commenced, but we expect the rule making package to be completed and ready to file by late summer.

If you have any feedback, please send it to mhargrove@cbpa.com.

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UPDATE - May 29, 2015

BOMA San Francisco's Codes and Regulations Committee members reviewed a letter that the National Elevator Industry Association wrote to the head of the California Department of Industrial Relations. Click here for a presentation related to the missive and here for an attachment to the letter.

The communication states that the 60 pages of amendments that the Department is considering adopting would make California unique as having the strictest and most expensive elevator requirements in the country.

Please be aware of these proposed changes for elevator maintenance if they are permanently adopted.

If you have any feedback, please send it to mhargrove@cbpa.com.

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UPDATE - April 28, 2014

Since 2012, members of BOMA San Francisco's Codes and Regulations Committee have been working with BOMA California and the California Division of Occupational Safety and Health on changes to statewide elevator maintenance rules.  Our members' feedback was detailed in a BOMA amended 2012 Division Circular Letter.

On April 22, 2014, the Division held a meeting to review a draft of new elevator regulations regarding:

• Elevator maintenance;
• The qualifications for elevator inspectors and/or mechanics;
• And, requirements for other conveyances.

BOMA California members continue to maintain their feelings that routine upkeep of elevators - specifically those that do not affect the safe operation of the system - may eventually require Division mandated oversight by a certified elevator mechanic.  Any proposed changes along those lines would increase the time and cost for the maintenance of elevators and add a modicum of value to the safety of the elevator system.

BOMA San Francisco Board Member Kevin FitzPatirck kindly attended the April 22, 2014 meeting for BOMA members and relayed their comments.

If you have any questions or feedback regarding the draft proposal of new elevator regulations, please contact kenc@boma.com.

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Original Post - October 12, 2012

Elevator Categories of Work Circular Letter Withdrawn

BOMA California representatives are pleased to report that the California Division of Occupational Safety and Health has given notice that it has formally withdrawn Circular Letter 11-01 in its entirety, effective immediately.   Prior to this retraction, BOMA San Francisco's Codes and Regulations Committee members suggested edits to the Circular Letter which was sent to the Division on May 12, 2012.

According to the Division, the Circular Letter was initially published because they had received inquiries regarding if certain work on conveyances were covered by state law. After receiving more information from the elevator industry the Division has decided that clarifications are more appropriately addressed through a formal rule making process. BOMA California members agree and applaud the Division for this decision.  BOMA thanks our colleagues in the elevator industry for their diligence.

There will be future efforts by the Division regarding rule making so this issue is likely to be revisited by year end.