Licensing and Regulatory Affairs
In our continued, concentrated effort to clarify policy and bring consistency and compliance to the Elevator Division as well as the Elevator Industry in Michigan, below please find the latest topics we have received questions about.
Maintenance Control Programs
With the adoption of the 2010 edition of ASME A17.1 and the upcoming adoption of future editions, a Maintenance Control Program (MCP) has been and will continue to be required for all elevating devices per Code Section 188.8.131.52.1.
Excerpt from ASME 17.1-2010 184.108.40.206.1:
A written Maintenance Control Program shall be in place to maintain the equipment in compliance with the requirements of 8.6.
(a) The Maintenance Control Program shall consist of but not be limited to;
(1) examinations and maintenance of equipment at scheduled intervals in order to ensure that the installation conforms to the requirements of 8.6. The maintenance procedures and intervals shall be based on
(a) equipment age, condition, and accumulated wear
(b) design and inherent quality of the equipment
(d) environmental conditions
(e) improved technology
(f) the manufacturer’s recommendations for any SIL rated devices or circuits
(2) cleaning, lubricating, and adjusting applicable components at regular intervals and repairing or replacing all worn or defective components where necessary to maintain the installation in compliance with the requirements of 8.6.
(3) tests of equipment at scheduled intervals (220.127.116.11) in order to ensure that the installation conforms to the requirements of 8.6.
(4) all Code required written procedures (e.g., check out, inspection, testing, and maintenance).
(b) The instructions for locating the Maintenance Control Program shall be provided in or on the controller along with instructions on how to report any corrective action that might be necessary to the responsible party.
(c) The maintenance records required by 18.104.22.168 shall be kept at a central location.
(d) The Maintenance Control Program shall be accessible to the elevator personnel and shall document compliance with 8.6.
(e) Procedures for tests, periodic inspections, maintenance, replacements, adjustments, and repairs for all SIL rated E/E/PES electrical protective devices and circuits shall be incorporated into and made part of the Maintenance Control Program. See 22.214.171.124.2, 126.96.36.199.2(b), 188.8.131.52.1(b), and 184.108.40.206.1(b).
(f) Where unique or product-specific procedures or methods are required to inspect or test equipment, such procedures or methods shall be included in the Maintenance Control Program.
(g) Procedures for tests; periodic inspections; maintenance; replacements; adjustments; and repairs for traction-loss detection means, broken-suspension-member detection means, residual-strength detection means, and related circuits shall be incorporated into and made part of the Maintenance Control Program. [See 220.127.116.11, 18.104.22.168, 22.214.171.124, 126.96.36.199, 188.8.131.52.2(cc)(3)(c)(2), 184.108.40.206.2(ss), and 220.127.116.11.12.]
The MCP booklet, program, folder, etc. not only spells out what tasks need to be done, but more specifically, it must contain the procedures describing how the tasks are to be performed. Proper records are only one component of a proper MCP as described in the code section above. As current versions of code are adopted, the Division anticipates that the MCP will continue to mature and become even more specific. It is incumbent upon each Contractor to research, develop, obtain, or include an MCP that is suitable for their units.
MCP’s specific to the unit will be a requirement prior to the device being approved for use for the public per ASME 17.1 2013 and 2016 18.104.22.168 which means, when a newer version of code is adopted, the Inspector will have to see the MCP prior to issuing a compliant final.
22.214.171.124 Maintenance Control Program
The Maintenance Control Program complying with 126.96.36.199.1 shall be available at the time of inspection. On-site equipment documentation complying with 188.8.131.52.2 shall be available at the time of inspection.
As of August 1, 2019, the Elevator Division will be uniformly enforcing the requirement to have a robust MCP as described in ASME 17.1-2010 184.108.40.206.1. Failure to have an MCP available at the time of inspection will result in a violation being written. As the Division is beginning the process to adopt an updated version of the code, which will bring with it the requirements of a much more defined MCP, it is incumbent upon the Contractors, Journeypersons, and Inspectors to ensure compliance prior to adoption.
The email approval allowing work to begin on an emergency permit does not indicate the permit has been issued or paid for and does not negate the requirement for a final inspection prior to operation. The Division recognizes there is, at times, a business-need to return an elevator to service and will allow inspectors, at their discretion, to approve units to be put back into service prior to a final taking place but only once all below requirements have been met.
Please note, this does NOT remove the need for a final nor does it guarantee every Inspector will allow every emergency permit to be returned to service prior to a final.
If a Contracting company is found not to be complying with the above, the Department may disallow them from requesting elevators to be returned to service prior to a final.
Alterations leading to a New Install
There have been many questions concerning when alterations, or which alterations, will be considered to become a new unit requiring a new install permit. When an alteration of an elevator includes all three of the below items, the Elevator Division will consider this to be a replacement, and therefore, a new installation permit will be required to be obtained and the appropriate fees paid.
Alteration Permits Required
AMSE 17.1-2010 1.3, defines an alteration as:
Any change to equipment, including its parts, components, and/or subsystems, other than maintenance, repair, or replacement.
The operating rule of thumb for elevators has always been, if replacing “lik for like” and no adjustments or sub-system factors were involved, neither a permit nor inspection were needed. As of August 1, 2019, to ensure consistency, the Division’s policy is being clarified to state if a repair does not involve a manufacturer like for like part, or there is a requirement for adjustment or testing, or programing, it will be considered an alteration, and therefore, a permit shall be pulled and an inspection performed.
Some of the items requiring a permit as of August 1, 2019 will include but not be limited to;
Due to questions received regarding to the below section from the most recent Elevator Industry News, please note the following clarifications.
Effective immediately, non-circular elastomeric or polyurethane coated belts being replaced on existing Machine Room Less units should be fire rated at FT-1 or greater unless a letter is sent in by the Contractor, from the Local Fire Marshall or fire suppression AHJ, with the knowledge and acceptance of the hoistway construction without a sprinkler head in the top of the hoistway. Please note, the change in fire rating changes the form of the belt and is no longer a like for like replacement which means a permit, appropriate fees, and an inspection shall be required. Installation permits pulled on or after August 1, 2019, for Machine Room Less traction units utilizing non-circular elastomeric or polyurethane coated belts will be required to be an FT-1 or greater unless the Contractor provides with the permit, a letter from the Local Fire Marshall or fire suppression AHJ with the knowledge and acceptance of the hoistway construction without a sprinkler head in the top of the hoistway.
Hoistway Sprinkler Requirements
For the installation of Machine Room Less traction units that utilize non-circular elastomeric or polyurethane coated belts, NFPA 13 Sec. 220.127.116.11.1 requires there be a sprinkler head in the pit and overhead of the hoistway if the suspension belts fire rating is not an FT-1 or greater. It is not the intent of the Elevator Division to require a sprinkler head in the overhead understanding that shunt trips are not allowed in Michigan, as the introduction of water onto the car with the presence of high voltage presents the possibility of fatal results. In order to adhere to all applicable codes, the Division will require devices installed with these types of suspension means to either have the proper fire rating or a letter submitted with the permit, from the Local Fire Marshall or fire suppression AHJ with the knowledge and acceptance of the hoistway construction, without a sprinkler head in the top of the hoistway. As a reminder, if there is a sprinkler head in the pit, there shall also be the appropriate Fire Alarm Initiating Device (FAID). Heat sensors designed for the environment are preferable.
Escalator and Moving Walk Permits
As of August 1, 2019, the Division will be uniformly enforcing Michigan Elevator Rules 58a and 58b which label the replacement or change of any part of either an escalator or moving walk as an alteration and shall require a permit and inspection. Examples of items that will require a permit as of August 1, 2019 will include, but not be limited to; handrails, safety switches, and mother boards.
R 408.7058a Escalators; general requirements.
Rule 58a. Section 18.104.22.168.1 of the ASME A17.1 code is amended to read as follows:
22.214.171.124.1. A change in component parts that are interchangeable in form, fit, and function is an alteration and shall comply with the requirements in this section as described in section 126.96.36.199 of the ASME A17.1 code.
The addition of a component or a device that was not part of the original design is an alteration and shall conform to the requirements of section 188.8.131.52 of the ASME A17.1 code for that device or component.
The requirements of section 184.108.40.206.5 of the ASME A17.1 code do not apply to existing escalators that were not required to comply with this requirement at the time of the original installation.
R 408.7058b Moving walks; general requirements.
Rule 58b. Section 220.127.116.11.1 of the ASME A17.1 code is amended to read as follows:
18.104.22.168.1. A change in component parts that are interchangeable in form, fit, and function is an alteration and shall comply with the requirements in this section as described in section 22.214.171.124 of the ASME A17.1 code.
The addition of a component or a device that was not part of the original design is an alteration
and shall conform to the requirements of section 126.96.36.199 of the ASME A17.1 code for that device or component.
When multiple driving machines per moving walk are utilized, operating and safety devices
required by section 188.8.131.52 of the ASME A17.1 code shall simultaneously control all driving machines.
Thank you and as always, please contact the Elevator Division at firstname.lastname@example.org or 517-241-9337 with any questions.