Advisories on Elevators & Other Lifting Devices
Building Approval Information
Information on building plan approval must be provided on all permit applications for the new construction of any lifting device (see UCC-21 form
, Part L), wheelchair or stairchair lift (see UCC-23 form
, Part L) or escalator or moving walk (see UCC-25 form
, Part J).
Information on building plan approval must be provided on all permit applications for alteration of lifting devices (see UCC-22 form
, Part L) whenever the lifting device alterations also involve a change to the building and a building plan approval is required.
Note that a design professional must sign and seal the section where this information is provided on the respective Department applications.
If the work you are doing affects the structural or fire resistive properties of the building, you must have a building plan approval. One way to verify that a building plan approval is necessary is to check the references sections in § 8.7 of the ASME A 17.1 standard. If any of the references state “you must comply with the building code,” you should assume that a building approval is necessary.
Common Application Deficiencies
Every time an application is received with incorrect or incomplete information, our workload is unnecessarily expanded (sometimes, it takes the time we normally spend on two complete applications to review and process the incomplete application). We have to draft a deficiency letter, mail it, wait for a response, process the resubmission, and then re-review the corrected application. Each step of this process has to be logged for tracking purposes. Obviously, this is time consuming.
Please make sure that any correspondence is unit-specific (particularly, when the package includes a letter from a design professional, hoistway certification information and plans and specifications). Generic information is unacceptable, as is information pertaining to construction that only references an address.
Please be sure to provide all of the following identifiers that are available: the MD Number, the Drawing Number, permit numbers (those issued by both the Building Code Official and the Elevator Section), Elevator Section application number(s) and equipment numbers.
Citing Correct Code Sections:
If you are replacing components that are listed in section 8.6.3… you should be citing that section instead of 8.7.2 or 8.7.3. For example, if you are replacing hoist ropes of the same exact type and size, you should be using section 126.96.36.199.1 and not 188.8.131.52. Section 184.108.40.206.1 is to be used only if you are changing the type of rope that was there. This could be important to you, since citing sections in the alteration section vs. the replacement section may require you to comply with additional sections of the code.
Part L, “Drawing Number of Elevator Plans Used for Building Approval”:
The number requested here is the drawing number on the elevator company plans that were used by the design professional (architect or engineer) in drawing up plans for construction of the building in which the elevator or lifting device is located.
The number requested is not the number that the architect or engineer has put on their building drawings. If the wrong number is inserted here, this will be cause for returning the application package for correction.
It is up to elevator companies to review the documents for accuracy before they are submitted. If the drawing number the architect or engineer is referencing does not match the drawing number you are submitting to the Elevator Division, you must have him/her correct Part L. Since this is a sealed statement, only the design professional can make this change.
Part L, Altered Form:
If it is obvious that any part of the statement under Part L is not in the design professional’s handwriting and that he/she did not initial and date that item, we will return the form for corrections.
Part L, Alternative Statement by Design Professional:
Some design professionals are reluctant to sign Part L. If that is the case, we will work with the design professional to create an alternative statement that they can comfortably submit. This statement will have to clearly show that the specifications they used to design the building and obtain building plan approval match the specifications of the elevator or lift that is submitted for approval. This statement will likely include information such as the elevator’s capacity, gross weight, speed, travel, etc., or they can simply make reference to the elevator drawing number.
All Pages of Permit Application Must Be Submitted:
You must submit all three pages of our permit application. Even if Part L does not have to be completed, the applicant must sign the statement near the bottom of page 3.
Controller Change Alterations
In addition to listing the general section for a controller change (if electric elevator, see §220.127.116.11; if hydraulic elevators, see §18.104.22.168.5), permit applications must state if there is a change in motion (if electric elevators, see §22.214.171.124; if hydraulic elevator, see §126.96.36.199.6) or a change in operation (if electric elevator, see §188.8.131.52; if hydraulic elevator, see §184.108.40.206.6).
Check "control-motion" and "control-operation" in the definitions section (1.3) of the ASME standard for clarification on what constitute motion and operation changes. Per those definitions, list the type of controller being removed and the type being installed. Be sure to use the terms as they appear In the ASME A 17.1 2000 -2002 Addenda definitions.
If you are seeking an emergency permit, this must be clearly marked at the very top of the permit form in very large letters and highlighted, so that this will catch the attention of the person processing the application. You must specify the nature of the emergency. We get many requests for emergency permits, and this information will help us determine if a real emergency exists. Further, we often have to prioritize emergency permits.
The Elevator Division views an emergency situation as one where the elevator, with few exceptions, will be the only working elevator in the building. In order for us to prioritize emergency permit requests, applicants must provide the following information (if applicable):
- The elevator serves handicapped persons that reside, work or frequent the building.
- The building is a high-rise building housing the elderly.
- Other special conditions that exist in the building and that should cause us to view the situation as a dire emergency. (It is your responsibility to clearly explain why your permit should be given high priority; for example, the elevator is the only the only one that services operating rooms in a hospital.)
Excessive Car Top Clearance
When will platforms (or other permanent means for rope inspection) and rope Inspection procedures have to be provided in the hoistway?
As a general rule, if there is 11 feet of clearance or more above the crosshead, when the car is at the top landing, to the point where the cables go through the top of the hoistway, some permanent means for inspecting this portion of cable will have to be provided. It is the elevator company’s responsibility to show this on the hoistway drawing and to provide the Elevator Division with written documentation that clearly describes the method to be used that will safely and effectively allow for the rope inspection. If the method used involves construction of a platform/catwalk, it will require a building plan review and approval. The elevator plan must also state the capacity the platform was designed to handle, and that capacity must be posted on the platform/catwalk. Access to this platform or catwalk cannot be from the car top. It must be from outside the hoistway and comply with the access requirements of the code.
Note: If there is any equipment other than cables that require inspection, these same criteria will apply. The distance above the crosshead may vary, depending on the type of equipment.
Governors in the Hoistway
We have been getting more and more elevator permit applications showing the governors mounted in the hoistway. This is creating some concern because it is not always possible to do the entire test or to work on the governor without getting in the hoistway. Our concern is two-fold:
- Having to be in the hoistway to remove the governor rope (to establish the tripping speed of the governor) during the five-year safety test, and
- Having to work on the governor from the car top or in the pit with the governor being inoperative.
It has always been the policy of the Department of Labor & Industry that no one should be on or under the car with the governor inoperative.
As a result, if you are submitting a permit application for an elevator that has a hoistway-mounted governor:
- The drawings must show an access panel per the code.
- The permit application must include a copy of a written procedure that will be posted in a conspicuous place near the governor and the controller. The document must contain step-by-step procedures for testing or working on the governor. (If you must be in the hoistway to test or service the governor when the governor is disabled, this will require a variance.)
- The hoistway elevation drawing must show the location of the governor and the access door. If the governor and access door are located where a ladder or stair is needed to reach them, then the plan must show a permanent means of access per the code.
You will need a hoistway certification, if the new lift is going into an existing hoistway in an existing building, or if an alteration is being done to an existing lift and:
- Car capacity is increased or
- Car speed is increased or
- Different type buffers (car or counterweight) are installed or
- Gross Weight of the car is increased or
- Counterweight is increased or
- New car or counterweight rails are installed or
- An alteration is proposed that could potentially increase the impact loading on the building.
Hoistway certifications must be unit-specific. The language in the architect’s or engineer’s certification letter must make reference to your specific drawing number and the elevator to be installed or altered. Many applicants are providing a letter from an architect or engineer that merely references some project number. This is not acceptable. If we cannot match the project number to the plans being reviewed, we will have no alternative but to return the submission for correction.
Jack replacements require both a
hoistway drawing showing the hoistway clearances (bottom runby and top overtravel, car top and bottom clearance and top and bottom refuge space and buffer stroke), and a
jack drawing showing the plunger, cylinder, and construction of the cylinder (per sections 220.127.116.11, 18.104.22.168, 22.214.171.124, 126.96.36.199) and the method of protection.
This information is required so we can verify that no changes have been made to the travel or clearances since the time of the original approval or when an alteration was approved to change the travel or clearances. We have found changes that have been made without obtaining a permit, and that is why this information is requested.
Major Repair - Equipment Number
If the equipment number on the approved permit does not match the equipment number of the piece of equipment in the field, the elevator company will have to submit a revised permit with the correct number. A fee will be charged, since a second review will be required. It is imperative that the both the MD number and the equipment number of the lift be supplied. Without this information we may not be able to process your permit.
New Construction Vs. Alterations
We are often asked, “When is an alteration considered a new (replacement) elevator?" There is no single answer to this question, but the following guidelines will be helpful. If you still have questions, you should call the Elevator Division (dial 717-787-3806 and select option “2”), before you submit an application for a permit. This will help expedite the process for both of us.
Traction Elevators – If the only components you are keeping are the rails, sling, safeties, and door bucks, this will be considered a new (replacement) elevator. In this case, you must submit an application for a new construction permit and the elevator will have to comply with the ASME A17.1 2000 –2002 Elevator Code. If there are any components such as the door bucks that do not meet the code because they are not labeled, you will have to request a variance. Pit ladders will fall under the exception in the code for unavoidable obstructions, if they cannot meet the new standard.
Hydraulic Elevators - If the only components you are keeping are the rails, sling, and door bucks, this will be considered a new (replacement) elevator. . In this case, you must submit an application for a new construction permit and the elevator will have to comply with the ASME A17.1 2000 –2002 Elevator Code. If there are any components such as the door bucks that do not meet the code because they are not labeled, you will have to request a variance. Pit ladders will fall under the exception in the code for unavoidable obstructions, if they cannot meet the new standard.
New construction must meet the 7" x 16" rule. If the building was approved under the Fire and Panic Regulations, we can apply the exception (no variance request has to be filed) in the ASME code for 4 1/2 inches. Otherwise the 7" x 16" rule must be met. In order for the Elevator Section to make a determination on this, the architect’s letter must state very clearly what building code the work was approved under and the date of approval.
Proof of Contract
The Elevator Section will accept a design contract as justification for submitting a permit application to construct a lift under the pre-UCC code requirements. This contract must be signed and dated
prior to April 9, 2004 , and the elevator company must be party to this contract. There will be consideration (no variance request has to be made) for the pit ladder, if the elevator company can prove that the building received approval under the Fire and Panic regulations. This proof will consist of a letter from the design professional. Elevator companies should make sure that the design professional’s letter clearly states what code the building was approved under. If there are other issues because the construction of the building was done to meet the old code requirements, variances may be requested from the Industrial Board.
Temporary Construction Elevators
Permits Approved Per 34 Pa Code Chapter 7 (Old Elevator & Lifting Device Regulations)
Elevators that are approved under the old elevator regulations must follow these guidelines to obtain approval as a temporary construction elevator.
If an initial inspection is being done and the elevator fails, a failed invoice with deficiencies cited will be left with the elevator company. Before the elevator can be re-scheduled for a follow-up inspection, the deficiencies must be corrected and the inspector must receive notice from the Elevator Division that the failed inspection invoice has been paid. If the elevator company requests the elevator be turned over as a temporary construction elevator, the inspector may issue a temporary construction certificate. A copy of that certificate will be forwarded to the Elevator Division with the inspectors failed inspection report. Once the elevator has passed a final inspection, a permanent Certificate of Operation will be issued.
Permits Approved For New Permanent Elevators Under The UCC Regulations
An elevator approved under the ASME code for permanent new elevators may be approved as a temporary construction elevator after a failed initial inspection, if it meets all the requirements of Section 5.10. A failed invoice with deficiencies will be left with the elevator company. Before the elevator can be re-scheduled for a follow-up inspection, the deficiencies must be corrected and the inspector must receive notice from the Elevator Division that the failed inspection invoice has been paid. If the elevator company requests the elevator be turned over as a temporary construction elevator, the inspector may issue a temporary construction certificate. A copy of that certificate will be forwarded to the Elevator Division with the inspectors failed inspection report. Once the elevator has passed a final inspection, a permanent Certificate of Operation will be issued.
Temporary Construction Elevators – UCC Temporary Construction Car Permit
If the need for a temporary construction elevator is anticipated when the original permit is being submitted (or at any time prior to the elevator being ready for a final inspection), an alteration permit for a Temporary Construction Car may be applied for and submitted to the Elevator Division. Under Part H of the permit application you should state “Temporary Construction Elevator” and list section 5.10 as the code reference. Once the elevator is completed per section 5.10, you may call for the Temporary Construction Elevator inspection. Once the elevator is complete and you are ready to turn the car over for public use, you should then call for a final inspection. By taking out a Temporary Construction permit, you can eliminate the need to have a failed inspection first.
- It is acceptable to have a variance approved but not use it, as long as the installation meets the code. The variance does not have to be rescinded formally. We do request, however, that the applicant/owner send the Elevator Section a letter for our files stating the variance has not been implemented and that, if the approved variance is pursued at a later date, an application will be filed before the work commences.
- All variance requests regarding existing equipment must be submitted with reference to complying with the code that is currently in effect. If the new code requirements cannot be met, you must clearly justify why not. All variances must follow the instruction on the Elevator Safety Board petition form.
- All variance requests must go to the Elevator Safety Board. You should include a copy with your elevator permit application, so we know that a variance request has been requested, and so that we will continue to process your permit. Clearly mark the variance request "COPY.”
- If you are requesting a variance and the work associated with the variance requires a permit, a permit application must be submitted at the same time that you submit your variance request. If we do not have a permit application for the work, your variance request will be returned. If we have already approved a permit (even if the final inspection has not been completed), you cannot use that permit for the variance request that is being submitted. In order to change proposed work that has already been approved, you must submit a new alteration application (form UCC-22).
- All variance requests (under the current or an earlier code) must follow the instructions listed under "Request for Variance(s)" on the
LIIB-112 form (ELEVATOR SAFETY BOARD PETITION). If you do not justify why the letter of the code cannot be met, explain what compensatory features will be provided and explain how the approach you propose meets the same level of safety, we will recommend that the petition be returned without action.
Please note that if you are requesting a variance to perform an upgrade to an existing lift and that upgrade will be in compliance with the ASME code that is in effect, you do not need a variance. You should instead submit an application for an alteration permit. For example, if a shunt-trip device or a hoistway access switch is going to be installed on an existing elevator that was approved under the old PA 34 code you should simply submit an alteration permit to do this. In the past you did have to request a variance. However, since we have adopted the ASME code that covers these items, there is no need for a variance. In fact, if you submit a variance request for something that is covered by the ASME code,( i.e. hoistway access switches, shunt-trip, etc), we will recommend that the Board return the request and inform you to submit the alteration permit to do the work.
Generally, VRCs will not be able to use
combination mechanical locks and
electric contacts . Instead, they will have to use a device that is approved and labeled as an “interlock.”
There are two exceptions to this general rule. A VRC
with no more than two stops may use a combination mechanical lock and electric contact:
- If it already has a certificate of operation; or,
- If the equipment has been granted a variance by the Industrial Board.
Whenever UCC-certified inspectors discover a VRC (with more than two stops) that lacks interlocks, they will issue a written recommendation that labeled interlocks be installed on the VRC.
Effective March 14, 2005, application permits and plans for VRCs will only be approved if the Elevator Section has proof that the VRC is being installed to comply with the State’s building code (UCC) requirements. See the “BUILDING APPROVAL INFORMATION
” Advisory for additional information.
Both of these requirements are found in the ASME B20.1 standard that we have adopted under the UCC.
Wheelchair and Stairchair Lifts
We have been getting a number of wheelchair and stairchair permit applications that do not clarify whether the installations are for residential or commercial use.
The problem is compounded by the fact that some companies make a model that can be used in either setting. In talking to several major manufacturers, we have been told they don’t provide any information on their drawings that distinguish between residential and commercial lifts, unless specifically requested by the dealer when the order is placed.
Some companies have a “Public Package” or “Commercial Package” option that can be selected and put in the specifications. Either of these is acceptable. It is also acceptable for the manufacturer to include a statement on the plans to the effect that
“this lift was designed to meet the A18.1a –2001 code Chapters 2,3 or 4 for commercial applications”.
Any submission that does not clearly state that the lift can be used for a commercial use and that it complies with the code we use (A 18.1a-2001 Addenda to A18.1- 1999), will be returned.
Please also note the following:
If the lift has a certifying agency’s label that states
“for residential use,” the field inspector will not be able to issue a final approval. Before approving it, the lift manufacturer will have to have the certifying agency come to the site to put a label on the lift that states
“for commercial use.” A lift must have a label stating that it is designed for commercial use and that it meets the A18.1a –2001 Addenda, Chapters 2, 3 or 4. A statement solely to the effect that it meets the A18.1 standard is not acceptable, since this standard also covers “Residential” lifts under Chapters 5, 6 and 7.
Work/Equipment in the Machine Room
When work in the machine room involves replacing the controller, tanks, disconnects or anything else that could have an effect on clearances within the room, the entire machine room will be evaluated for clearances per the code.
All extraneous equipment will have to be removed or a variance obtained. To justify a variance allowing you to keep any extraneous equipment in the elevator machine room, compelling reasons must be provided as well as the alternate means of protection that will be provided to meet or exceed the protections provided in the code.
The intent of the code is to protect the elevator equipment from disturbances by unauthorized personnel and to protect the equipment from extraneous exposures.