A17.3 – Why not?
In my tenure as an AHJ, I noticed that many elevators in my jurisdiction were never in compliance with the code under which they were installed. Some were missing pit ladders, pit lighting, car top inspection stations, and other items that should have been installed at time of the original installation.
How were these items missed you ask? Simple; the AHJ was not paying attention to the code requirements of the time. And once you overlook required items and allow them to go unchecked for sometimes several decades, it is difficult to convince a building owner that these safety requirements are now of major importance. Of course the argument from the owner is that no one goes into that pit except the “elevator man”, and no one rides the car top except the “elevator man”. And of course, the everlasting saying, “and no one has ever been hurt!” The operative word here is, “yet”.
Most of us in the industry understand the hazards of working in elevator pits and on car tops, yet accidents and deaths have occurred nonetheless. Thus, it is important to provide safe working conditions to the extent possible for elevator technicians engaged in maintenance and repair of existing elevator equipment. So often, building owners seem to exclude elevator technicians from the realm of safety. While owners are not mean-spirited, they often forget that vendors on their property are afforded the right to a safe work place by OSHA. That means that owners certainly should have a vested interest in seeing that not only their employees have a safe work environment, but vendor’s employees also.
After having jumped down into 4-foot pits numerous times and in the dark no less; and after trying to service hoistway equipment with no car-top inspection station during my tenure as Chief for the State of Oregon, I decided that these items and others were too important and should not be allowed to continue. So how do you go back over several decades of ignored code items and try to bring the existing elevators into compliance?
The answer is ASME A17.3 - Safety Code for Existing Elevators and Escalators! ASME recognized the need for standardization for existing elevators and escalators to correct earlier code oversights, encompass better technology, or address design issues that later proved potentially unsafe; for example, shear angles on bi-parting doors.
ASME published the first edition of A17.3 in 1986 and it still exists today and is in its seventh edition of 2008. Of course A17.3 was not written just to allow AHJ’s to correct overlooked code items. Its main focus was to bring a consensus code to the foreground such that AHJ’s could utilize a nationally recognized standard as opposed to writing a local code. Local codes are well intended, but often overlook the issues that are broad-brushed within the industry. Generally AHJ’s do not have the resources to provide the depth of input that comes from a consensus-based standard.
Oregon made a vain attempt at some rules for existing elevators known affectionately as the “49-Rules” (later changed to the “47-Rules” as two of the original rules were dropped). Most of these rules were already covered in A17.3, but the home-grown rules were written in a vague script which allowed interpretations to pop up everywhere.
As Chief, I decided the best approach at solving this problem was not to go back and try to unravel all of the missed code requirements, but to adopt ASME A17.3 as a State standard that would allow enforcement and a method for owners to phase-in compliance over a reasonable time frame. Also, A17.3 would capture just about all of the overlooked code items making administration of the code requirements more focused.
As you might expect, there was push-back from some owners. There were those that just could not see the justification for the safety upgrades since they would not directly benefit from them and would not derive any additional revenue as a result of the upgrades. However, reluctant as some were, the concept of allowing owners to establish a plan of attack on A17.3 code requirements seemed to ease some of the financial pain. As a result many elevators were updated with car top inspection, pit ladders, pit lighting, machine room lighting, properly fused disconnects or circuit breakers, lockable machine room doors, safer roof access to machine rooms, and many other features; all designed to make the work place safer for elevator technicians and the end users.
But alas, political tides shift and often new management just wants to throw the baby out with the bath water since they do not like dealing with issues that are not fully understood by management or politicians. Well wake up and smell the coffee folks; being a regulator may not win many friends, but the goal it serves is essential. Without regulation, equipment would tend to degrade as owners try to tighten their outflow of expenses. Regulators must have the tools to keep the industry and owners responsible for the well-being of all who come in contact with a building and the equipment located therein. After all, when something serious does happen to a worker or member of the public, the outcry from the public is, “where was our government when this happened”; and my personal favorite, “there should be some kind of law against that”!
A17.3 is not really a monster in a regulator’s garb. It is an essential tool to deal with existing conditions that can be made safer. So let’s put in the pit ladders, install adequate pit lighting and add car-top inspection stations. For the owner this is normally a one-time cost per elevator. Otherwise, the ultimate cost for not having these safety items could be paid by the “elevator man”.
Reprinted with permission from NAESA International. For more information regarding this article or NAESA International please contact them directly. For commentary regarding this article from the Elevator Radio Show Podcast, listen to the show on March 30th, 2011, show 247.
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