DIRECTIVE NO D-L4 101125 4 - Technical Safety BC · (a) all maintenance, repairs and replacements...

DIRECTIVE NO: D-L4 101125 4 of 4

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FRM-1126-01 (2009/04/06)

DIRECTIVE NO: D-L4 101125 4

MANDATORY MAINTENANCE This Directive is being issued by a provincial safety manager pursuant to section 30 of the Safety Standards Act. Date of Issue: November 25, 2010 General Details This directive is issued to all elevating contractors and owners/property managers to clarify mandatory

maintenance requirements and intervals for elevators, material lifts, dumbwaiters, LULAs, escalators

and moving walks. This mandatory maintenance requirement has been a regulatory requirement since

1995. All maintenance contracts between an owner and licensed elevator contractor required under

section 21(2) of the Elevating Devices Safety Regulation (“EDSR”) must comply with this directive.

Specific Details Part 1: Maintenance Requirements:

Pursuant to the EDSR, Mandatory maintenance at a minimum must include:

(a) all maintenance, repairs and replacements specified by ASME 17.1 2007/CSA B44-07

Safety Code for Elevators and Escalators Part 8 Section 8.6.12.

(b) all examination and tests specified by CSA B44.2-07 Maintenance Requirements and

Intervals for Elevators, Dumbwaiters, Escalators and Moving Walks (formerly CSA B44-

04 Appendix J)

(for reference see attached code documents)

Part 2: Maintenance Intervals:

a) Maintenance Intervals

Maintenance intervals are determined by age, quality, usage, and the original manufacturer’s

recommendations or a professional engineer’s recommendation. If the original manufacturer’s

recommendations or professional engineer’s recommendations are not available (i.e. you are



FRM-1126-01 (2009/04/06)

not the original manufacturer or you do not have legal access to the recommendations) then

the maintenance intervals specified by CSA B44.2-07 must be followed.

Maintenance intervals for all mandatory examinations and tests required under Part 1(b) are

specified in CSA B44.2-07. For elevators, material lifts, dumbwaiters, LULAs, escalators, and

moving walks the minimum interval is once per month.

b) Changing of Maintenance Intervals

Maintenance intervals are established from the original manufacturer’s recommendations at

the time the unit was originally released into service and cannot be arbitrarily reduced on

existing units except in compliance with this Directive and ASME A17.1 2007/CSA B44-07

8.6.12.2.2.

If the maintenance interval of an existing elevator was established from the original time of

installation as a monthly frequency, the interval frequency cannot be reduced unless the level

of safety has significantly improved through an alteration or an upgrade. In this case the

reduction in maintenance frequency would be limited to the component(s) that were altered or

upgraded and determined by the manufacturer’s or professional engineer’s recommendation

for the new components.

A variance must be submitted to change the maintenance interval. The application for a

variance must be per unit and agreed to by the Owner, Contractor, and the BCSA. Please see

attachment for variance requirements.

Part 3: Maintenance Logbooks

A log pertaining to all maintenance activities specified in 8.6.12 and B44.2 must be maintained on site

at all times by the maintenance contractor and it must be easily accessible, legible and signed by

person(s) completing the task. The log must contain, as a minimum, but not be limited to, detailed

records of all tests, inspections, and other maintenance duties referred to in this Section that have

been performed in the previous five years (see 8.6.12.4.1.1). The maintenance frequency of each

component must also be clearly indicated. For records kept in an electronic format, a hard copy must

be placed in the job site log within a maximum of three months of the initial recording and the electronic

format will be kept up to date and made available to the Owner and the BCSA immediately upon

request.



FRM-1126-01 (2009/04/06)

Part 4: Wiring Diagrams

Each elevating device must have an up to date legible electrical wiring diagram, detailing electrical

protective circuits and primary directional circuits. The diagrams must be available in the machine or

control room at all times.

Relevant Legislation:

EDSR

"mandatory maintenance" means the maintenance of an elevating device that is provided by a

licensed contractor under contract to an owner and includes periodic examination and

maintenance services such as cleaning and lubrication, all safety-related tests required by the

ministry, and immediate treatment of any safety-related deficiency including the adjustment,

repair or replacement of any defective equipment or components as required by the adopted

codes or manufacturer's specifications, but does not include an alteration as specified by a

provincial safety manager or an alteration as defined by the adopted code;

Owner's operational and maintenance duties

21 (1) An owner must ensure that all new and existing elevating devices are operated in

accordance with this regulation and the manufacturer's specifications.

(2) An owner must engage a licensed elevating device contractor to maintain a

program of mandatory maintenance for the elevating device to ensure its safe working

condition.

(3) Subsection (2) does not apply if the owner is also a licensed elevating device

contractor and performs its own mandatory maintenance.

(4) The frequency of mandatory maintenance for an elevating device is at least

quarterly, unless otherwise provided under an applicable code.



FRM-1126-01 (2009/04/06)

(5) When any unsafe or potentially unsafe condition exists, an owner must close an

elevating device from the carriage of passengers until a provincial safety officer

permits the elevating device to operate. Provincial Safety Manager – Elevating Technology References: Bill 19 – 2003 Safety Standards Act B.C. Reg. 101/2004 Elevating Devices Safety Regulation

For more information on the British Columbia Safety Authority, please visit our web site at: www.safetyauthority.ca

Date: November 25, 2010

Mandatory Maintenance Directive Q & A

1. Q: Who is responsible to ensure mandatory maintenance is completed and all required

maintenance tasks and tests are being done at the required intervals?

A: It is a shared responsibility between the owner and the contractor. As an owner, it’s your responsibility to make sure that the unit is maintained & tested according to Code requirements. Therefore a maintenance contract with a BCSA licensed contractor has to be in place. The owner has to coordinate with the licensed contractor to make sure that all code required tasks and non-compliances are completed.

As a licensed contractor, it is your responsibility to ensure the safe operation of the elevating device through performing maintenance tasks & testing as per Code requirements. It is also the responsibility of the contractor to inform the owner of non-compliances, changes or alterations. The contractor & owner are both responsible for shutting down an elevating device in unsafe operating condition and notifying BCSA immediately.

2. Q: How do I know if my maintenance contract is Code compliant? A: Contracts vary considerably and may include or exclude certain tasks. Regardless of the contract coverage, as the owner you are still responsible to have the work completed by a BCSA licensed contractor as per Code requirements. It is the responsibility of the contractor to inform the owner of what is not included in the contract.

3. Q: How can we be sure that our contractor is in compliance with the requirements?

A: Mandatory maintenance tasks and intervals must be clearly noted in a logbook stored in the machine room. Contractors are required to have the mechanic sign off on all tasks, indicating when the work was completed. As the owner, the logbook records are your means to validate that work is being performed. A logbook is a record of all work and safety related tests performed on the equipment and must have as a minimum 5 years of data.

4. Q: Is there a specific Logbook that must be used in the machine room? A: Logbook is a generic term for the recording of maintenance, examinations, repairs, replacement & testing on site. The logbook must contain at a minimum, detailed records of all tests, inspections and other maintenance duties referred to in section 8.6.12 of the B44-07 Code and as per B44.2-07.

5. Q: What if certain mandatory tests are not included in the maintenance contract and the owner refuses to pay to have them done? A: The owner must have the work completed, whether or not the cost for this work is included within the maintenance contract or billed separately. Contractors must report to BCSA if mandatory tests are not completed.

6. Q: My elevator has been maintained by the original manufacturer at their recommended

frequency which has been quarterly. Can my maintenance frequency remain at quarterly if I switch to another contractor? A: As the new contractor is not the original manufacturer and does not have legal access to the recommendations, the maintenance frequency must be monthly as specified by B44.2-2007. Any changes will require a Variance, see Question 7.

7. Q: What if the owner or a contractor wants to change the maintenance intervals?

A: First, both the owner and contractor must agree on the change. Then, the contractor & owner must submit to the BCSA a request for a variance. Terms and conditions must be met to obtain approval. A professional engineer’s review and approval will be required. The variance will be evaluated on case by case basis & subject to all applicable terms and conditions. Duration of the variance will be defined accordingly. Termination of the variance is automatic on either the change of the maintenance contract or the building ownership. (See attachment for variance requirements)

8. Q: Where the frequency of maintenance was arbitrarily reduced other than through the variance process, is it required to revert back to the original frequency?

A: If the maintenance frequency was reduced from the original manufacturer’s recommendations at the time of installation, then it has to go back immediately to the originally recommended frequency. A variance must then be submitted to BCSA and approved before the frequency of maintenance can be reduced.

9. Q: What are the consequences for not performing the mandatory maintenance and not following the directives? Who would the consequences be directed to? A: Failure to perform mandatory maintenance could create an unsafe operating condition and the potential for serious injury or fatal incident. Enforcement by BCSA will be initiated as per applicable Acts and Regulations. This may include issuance of a compliance order or monetary penalty and shutdown of the unit. Enforcement can be directed at either owners or contractors depending on the circumstance.

10. Q: What will BCSA do in regard to site equipment inspections and can the BCSA’s services be called upon? A: Elevating Devices Safety Officers can be contacted for questions, queries, code clarifications and onsite inspections for safety issues where required.

11. Q: Who is responsible for ensuring wiring diagrams are up to date and in the machine or control room?

A: The contractor is responsible for ensuring the wiring diagrams are up to date. Should the wiring diagrams not be readily available to the contractor, the owner is ultimately responsible for ensuring that the necessary information is available.

Date: November 25, 2010

Subject: Variance on Maintenance Intervals Requirements

A variance application for reduced maintenance intervals, as required by the mandatory maintenance directive No: D-L4 101125 4, must include but not be limited to the following information:

Relevant Code clause(s) Variance application must be submitted per unit and each approved by the Owner and Contractor Frequency, type of use and history of use on the unit. Age and inherent quality of the equipment, expected life span. Incident data on the unit. Confirmation of up-to-date maintenance examinations & testing. Confirmation that no outstanding non-compliances exist. Complete copies of the log book, e-log book or contractor’s maintenance records. Professional engineer’s recommendations and risk assessment analysis. Elevating Devices Safety Officer special inspection report (COI).

A reduced maintenance frequency variance, once approved, will be subject to a duration limit. Termination of the variance is automatic on either the change of the maintenance contract or the building ownership. All variances are subject to termination should any risk to persons or property be identified. A copy of the variance must be attached to the logbook detailing the approved changes in maintenance frequency.

Additional information or documents may be required for particular variance applications.

DIRECTIVE NO D-L4 101125 4 - Technical Safety BC · (a) all maintenance, repairs and replacements...

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