agenda a17 maintenance, repair, and replacement committee

AGENDA

A17 Maintenance, Repair, and Replacement Committee

Teleconference https://asme.zoom.us/j/92919498035?pwd=RldUMkVWTllwVXc3Njd1em1mTDBydz09

Meeting ID: 929 1949 8035 Passcode: 854179

Monday, December 13, 2021 | 10:00 A.M. – 1:00 P.M. EST

This document is subject to approval and is for Committee use only. This document is not to be duplicated or quoted for other than Committee business.

1 CALL TO ORDER The meeting is scheduled to begin at 10:00 a.m. on Monday, December 13, 2021.

2 RECORD OF ATTENDANCE

3 ANNOUNCEMENTS

Attendees are reminded that ASME Policy prohibits the taping of these proceedings. In addition, members are advised to please place the call on mute unless wishing to speak.

4 ADOPTION OF THE AGENDA

5 APPROVAL OF THE SEPTEMBER 14 , 2021 MINUTES

6 PERSONNEL

Te l 1.212.591.8500 fax 1 .212.591.8501 www.asme.org

Two Park Avenue New York, NY 10016-5990 U.S.A.

https://asme.zoom.us/j/92919498035?pwd=RldUMkVWTllwVXc3Njd1em1mTDBydz09

A17 Maintenance, Repair, & Replacement Committee – AGENDA December 13, 2021

The current roster may be found in Attachment 1. Members are requested to report any updates or corrections to the Secretary. The attendance record is shown in Attachment 2. It should be noted that if you are a full voting member, as per the A17 Committee Procedures, you must attend at least 50% of the Committee meetings.

7 A17.1-202X Public Review Comments September 2021: The Public Review comments shown in Attachment 15 were received regarding Record 08-1345. The Committee was asked to develop responses to the comments and a recommendation for further actions regarding this record. Please note that Record 08-1345 will not proceed further until the Public Review comments are addressed. The Committee developed a response to Mr. Hultstrom’s comment. It was moved, seconded, and voted to approved the response and send it to the A17 Standards Committee for approval. The Committee developed a response to Mr. Bazner’s comment. It was moved, seconded, and voted to approved the response and send it to the A17 Standards Committee for approval. The Committee recommends no change be made to Record 08-1345. (NOTE: After the meeting, the A17 Standards Committee Secretary advised that additional public review comments have been received. Therefore, the responses developed during the meeting will be held and reconsidered once all the comments have been compiled.) December 2021 Discussion: The additional Public Review comments shown in Attachment 3 were received regarding Record 08-1345. The Committee is asked to develop responses to the comments and a recommendation for further actions regarding this record. Please note that Records 08-1345 will not proceed further until the Public Review comments are addressed.

11 NEXT MEETING The next A17 Existing Installations Committee and Maintenance, Repair, and Replacement Committee meetings are scheduled for the following dates and locations:

A17 MRR: March 30, 2022 | 1:00 PM – 5:00 PM EDT | Teleconference

A17 EI: March 29, 2022 | 1:00 PM – 5:00 PM EDT | Teleconference

The next A17 Standards Committee meeting is scheduled for the following date and location:

Wednesday, January 12, 2022 | Teleconference

A17 Maintenance, Repair, & Replacement Committee – AGENDA December 13, 2021

12 ADJOURNMENT

The meeting is scheduled to adjourn at 1:00 p.m. on Monday, December 13, 2021. Submitted by,

Nicole Gomez S&C Project Engineer Tel: (212) 591-8720 E-mail: [email protected]

mailto:[email protected]

L01033800 A17 Maintenance, Repair, and Replacement Committee Date Printed: 11/29/2021

As of: 11/29/2021

Page 1 of 7

Douglas LaBrecque

Chair

Manager, Service Engineering

Otis Elevator Co

212 West Newberry Rd

Bloomfield, CT 06002-5305

1(860)286-4584Phone #

1(860)286-1657Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Paul Rosenberg

Vice Chair

President

Performance Elevator Consulting, LLC

PO Box 464

Mequon, WI 53092-0464

1(262)242-3077Phone #

[email protected]

Com. Exp. Date - 06/30/2023

Johnny W. Stockstill

Vice Chair

Engineer III,

TK Elevator

788 Circle 75 Parkway SE

Atlanta, GA 30339

1(901)409-1999Phone #

1(901)261-1660Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Nicole Gomez

Staff Secretary

S&C Engineer

ASME

MS: 6-2B

2 Park Ave

New York, NY 10016-5675

1(212)591-8720Phone #

[email protected]

Com. Exp. Date - 06/30/2049

Richard Baxter

Member

Baxter Residential Elevators, LLC

1314 W McDermott

S106/lB805

Allen, TX 75013-3021

1(469)446-2324Phone #

1(469)519-0319Fax #

[email protected]

Com. Exp. Date - 06/30/2026

Joseph M. Block

Member

Area General Manager

KONE Elevator

1642 Westgate Cir

Brentwood, TN 37027-8194

1(615)838-9165Phone #

1(240)876-8978Fax #

[email protected]

Com. Exp. Date - 06/30/2022

Christopher Duke

Member

Architectural Resources

505 Franklin St

Buffalo, NY 14202-1109

1(315)559-1937Phone #

1(315)425-1232Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Tray Edmonds, PE

Member

Compass Elevator Consulting Group LLC

417 Apollo Beach Blvd

Apollo Beach, FL 33572-2281

1(813)641-2515Phone #

1(813)200-3869Fax #

[email protected]

Com. Exp. Date - 06/30/2022

Attachment 1 Page 1 of 7


As of: 11/29/2021

Page 2 of 7

Michael Farinola

Member

President

MV Farinola Inc.

4023 Kennett Pike Ste 219

Wilmington, DE 19807-2018

1(610)388-1553Phone #

1(610)388-3753Fax #

[email protected]

Com. Exp. Date - 06/30/2025

James Filippone, PE

Member

Engineer

Vertical Transportation Consultant

75 Farms Road Circle

East Brunswick, NJ 08816

1(732)735-7128Phone #

1(732)254-1018Fax #

[email protected]

Com. Exp. Date - 06/30/2026

J. R. Freeman

Member

Owner

JRF Visions

1301 Cypress Cove Rd

Spring Branch, TX 78070-4999

1(512)426-9229Phone #

[email protected]

Com. Exp. Date - 06/30/2022

Stephen Greene

Member

Principal Consultant

Steve Greene & Associates

911 Lakeville St # 263

Petaluma, CA 94952-3329

1(707)769-7399Phone #

1(707)769-7799Fax #

[email protected]

Com. Exp. Date - 06/30/2023

Richard Gregory

Member

Consultant

Vertex Corp.

1040 W Albion Ave

Chicago, IL 60626-4612

1(773)338-7066Phone #

1(773)338-6387Fax #

[email protected]

Com. Exp. Date - 06/30/2023

Michael D. Janca

Member

Business Manager

IUEC Local 85

15694 S US 27

Lansing, MI 48906-1486

1(517)719-3616Phone #

1(517)882-1970Fax #

[email protected]

Com. Exp. Date - 06/30/2026

Thomas Jose

Member

The Port Authority of NY & NJ

Engineering 4th Floor

2 Montgomery Street

Jersey City, NJ 07302-3855

1(347)236-4758Phone #

[email protected]

Com. Exp. Date - 06/30/2023

Rob Kremer, PE

Member

Engineering Manager

Technical Standards and Safety Authority

345 Carlingview Drive

Toronto ON M9W 6N9

Canada

1 (416) 734-3344Phone #

1 (416) 231-7525Fax #

[email protected]

Com. Exp. Date - 06/30/2026



As of: 11/29/2021

Page 3 of 7

Quinton Matthews

Member

Alimak Group USA Inc

12552 Highway 3 Ste A160

STE A-160

Webster, TX 77598-5427

[email protected]

Com. Exp. Date - 06/30/2024

Brian McCue

Member

Inspector

VDA

237 Martin Ave

Staten Island, NY 10314-4327

1(718)392-4507Phone #

[email protected]

Com. Exp. Date - 06/30/2022

Patrick McPartland, PE

Member

Owner

Pm Engineering Pllc

10 Boulevard Ave Ste 101

Greenlawn, NY 11740-1402

1(631)757-8900Phone #

1(631)757-8905Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Michael J. Mellon Jr

Member

Staff Engineer

904 Acri Rd

Mechanicsburg, PA 17050-2248

1(717)574-9611Phone #

[email protected]

Com. Exp. Date - 06/30/2022

Nilesh R. Mistry

Member

20 Brighton Terrace

Parsippany, NJ 07054-2343

1(201)936-5895Phone #

[email protected]

Com. Exp. Date - 06/30/2024

Michael D. Morand

Member

Administrator

QEITF

7154 Columbia Gateway Drive

Columbia, MD 21046

1(410)701-2171Phone #

[email protected]

Com. Exp. Date - 06/30/2026

Kevin P. Morse

Member

Elev Prog Mgr Elev Tech Expert

NAVFAC EXWC

6506 Hampton Blvd

Norfolk, VA 23508-1212

1(757)322-4653Phone #

1(757)322-4715Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Nicolas Ortiz

Member

Manager/Chief Elevator Inspector

Miami-Dade County Internal Services Department

Facilities and Utilities Management Division

201 West Flagler Street

Miami, FL 33130-1510

1(305)375-3912Phone #

[email protected]

Com. Exp. Date - 06/30/2022



As of: 11/29/2021

Page 4 of 7

Robert Preston

Member

Director, International Technical Services

TK Elevator Corporation

621 S Royal Ln Ste 500

Coppell, TX 75019-3878

1(214)783-0919Phone #

[email protected]

Com. Exp. Date - 06/30/2023

John Rearick

Member

President

Rearick & Company Inc.

8096 Squirrel Corn Ln

Manlius, NY 13104-9794

1(832)239-2513Phone #

[email protected]

Com. Exp. Date - 06/30/2023

Philip Reid

Member

Premier Elevator / NAEC

230 Andrew Drive

Stockbridge, GA 30281

1(770)389-4951Phone #

1(770)389-1586Fax #

[email protected]

Com. Exp. Date - 06/30/2026

Vincent Robibero

Member

Chief Codes and Standards Officer

Robiberov Consultancy LLC

6219 Darby Way

Spring, TX 77389-5210

(832) 562-9232Phone #

(973) 1(973)397-6149Fax #

[email protected]

Com. Exp. Date - 06/30/2023

Robert T. Shanklin

Member

Vice President & Inspector

Just Elevator Inspection Co.

10540 Illinois Ct

Orland Park, IL 60467-8953

1(708)825-3964Phone #

[email protected]

Com. Exp. Date - 06/30/2024

Joseph Stabler

Member

President

Stabler Associates, Inc.

8572 St Charles Rock Rd

St Louis, MO 63114-4560

1(314)423-5171Phone #

1(314)428-3917Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Chris Strawn

Member

President

Elevator Safety and Technical Services

3102 Dunkeld Ct

Tallahassee, FL 32303-2664

1(850)222-3787Phone #

[email protected]

Com. Exp. Date - 06/30/2024

Lawrence M. Taylor

Member

Codes and Standards Officer

Schindler Elevator Corporation

504 McCarthur Dr

Leander, TX 78641-2083

1(512)619-3775Phone #

1(512)475-4870Fax #

[email protected]

Com. Exp. Date - 06/30/2025



As of: 11/29/2021

Page 5 of 7

Harold Thurmer

Member

Service Manager

KONE

718 Walsh Rd

Madison, WI 53714-1370

1(773)490-1697Phone #

[email protected]

Com. Exp. Date - 06/30/2022

Hiren (Harry) M. Vyas

Member

Senior Director of Compliance

vda® Thevda- Leader in Delivering Vertical Transportation Consulting Solutions

145 West 30th Street, 4th Fl

New York, NY 10001

1(212)868-9090Phone #

1(212)868-9099Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Thomas Waardenburg

Member

President

Elevator Consulting Services Inc.

10719 Versailles Blvd

Wellington, FL 33449-8090

1(561)789-0237Phone #

1(866)644-0130Fax #

[email protected]

Com. Exp. Date - 06/30/2022

Michael P. Walsh

Member

National Accounts Project Manager

Castlehale Consulting

751 Elmhurst Place

Glassboro, NJ 08028

1(856)723-6485Phone #

[email protected]

Com. Exp. Date - 06/30/2023

Gregory B. Cassini

Contributing Member

National Modernization Operations Manager

Fujitec America Inc.

7258 Innovation Way

Mason, OH 45040-9693

1(513)932-8000Phone #

1(513)933-5504Fax #

[email protected]

Com. Exp. Date - 06/30/2023

John J. De Lorenzi

Contributing Member

Senior Technical Consultant

De Loren Tech Inc.

62 Edgewood Rd

Bedminster, NJ 07921-1623

1(908)781-6787Phone #

[email protected]

Com. Exp. Date - 06/30/2024

James T. Herrity

Contributing Member

Engineering Technician VTE

Department of the Navy, Naval Facilities Command (NAVFAC)

2032 County Road 220 Lot 35

Fleming Island, FL 32003-7938

1(904)509-1861Phone #

[email protected]

Com. Exp. Date - 06/30/2024

Allan S. Hopkirk

Contributing Member

Trident Elevator Co. Ltd.

40 Production Dr.

Toronto ON M1H 2X8

Canada

1 (416) 724-2228Phone #

1 (416) 724-8988Fax #

[email protected]

Com. Exp. Date - 06/30/2026



As of: 11/29/2021

Page 6 of 7

Tao Jiang

Contributing Member

Senior Engineer

Shanghai Institute of Special Equipment Inspection and Technical Research (SSEI)

No. 915 Jinsha Jiang Road

Shanghai 200062

People's Republic of China

8602132584752Phone #

[email protected]

Com. Exp. Date - 06/30/2023

Joseph J. Knolmajer

Contributing Member

Director of Field Operation

America Testing and Inspection Services

77 Water St Fl 8

New York, NY 10005-4418

1(908)334-6651Phone #

[email protected]

Com. Exp. Date - 06/30/2022

John Koshak

Contributing Member

Consultant

Elevator Safety Solutions LLC

2308 Turpins Glen Dr

Germantown, TN 38138-5832

1(619)726-1419Phone #

1(901)414-0175Fax #

[email protected]

Com. Exp. Date - 06/30/2024

David McColl

Contributing Member

Director - Worldwide Codes Development

Otis Canada Inc.

408 Claremont Crescent

Oakville ON L6J 6K1

Canada

1(416)500-3919Phone #

1 (860) 660-9874Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Carl McDilda

Contributing Member

Owner/CEO

EEIS

208 W Depot St

Bedford, VA 24523-1936

1(540)551-5520Phone #

1(540)759-7921Fax #

[email protected]

Com. Exp. Date - 06/30/2025

James L. Meyer

Contributing Member

Area Vice President

National Elevator Inspection Services, a Bureau Veritas Company

PO Box 1449

Sutter Creek, CA 95685-1449

1(916)952-6933Phone #

[email protected]

Com. Exp. Date - 06/30/2022

Alan Clarke Jr.

Alternate

SEB Reliability Engineer, Escalator Products

KONE Inc,

110 Louise St

Charlotte, IA 52731-9685

1(563)650-7476Phone #

1(309)743-5355Fax #

[email protected]

Com. Exp. Date - 06/30/2022

Alternate to: Harold Thurmer

Phillip Hampton

Alternate

Chief Engineer

TK Elevator

US Manufacturing Headquarters

788 Circle 75 Parkway SE

Atlanta, GA 30339

1(901)210-9275Phone #

1(901)261-1660Fax #

[email protected]

Com. Exp. Date - 06/30/2024

Alternate to: Johnny W. Stockstill



As of: 11/29/2021

Page 7 of 7

Ricky Henderson

Alternate

National Trainer

TK Elevator

1111 San Juan Drive

Camano Island, WA 98292

1(425)864-3584Phone #

[email protected]

Com. Exp. Date - 06/30/2023

Alternate to: Robert Preston

Ronald D. Schloss

Alternate

Executive Director

SEEC, LLC

115 Leamour Court

Stroudsburg, PA 18360

1(908)256-3198Phone #

[email protected]

Com. Exp. Date - 06/30/2024

Alternate to: Joseph Stabler

Kevin P. Sullivan

Alternate

National Coordinator

Elevator Industry Work Preservation Fund

7 Village Grn

Norfolk, MA 02056-1008

1(508)528-8843Phone #

1(508)528-8266Fax #

[email protected]

Com. Exp. Date - 06/30/2026

Alternate to: Michael D. Morand

Harold F. Wagner Jr.

Alternate

FQE Territory Operations Manager

Schindler Elevator Co.

210 S Island View Ave

Long Beach, MS 39560-5816

1(504)210-9093Phone #

[email protected]

Com. Exp. Date - 06/30/2025

Alternate to: Lawrence M. Taylor

Total Number of Members: 52


Sept 2021 Apr 2021 Sept 2020 Apr 2020 Sept 2019 Apr 2019 Sept 2018

D. LaBrecque 100% 0 0 0 0 0 0 0

P. Rosenberg 100% 0 0 0 0 0 0 0

J. Stockstill

(Alt. Hampton)86% 0 0 0 0 0 0

R. Baxter 86% 0 0 0 0 0 REP

J. Block 14% 0

C. Duke 71% 0 0 0 0 0

T. Edmonds 86% 0 0 0 0 0 0

M. Farinola

(Alt. Carr)43% 0 0 0

J. Filippone 86% 0 0 0 0 0 0

J.R. Freeman 71% 0 0 0 0 0

S. Greene 100% 0 0 0 0 0 0 0

R. Gregory 100% 0 0 0 0 0 0 0

M. Janca 100% 0 n/a n/a n/a n/a n/a n/a

T. Jose 100% 0 0 0 0 0 0 n/a

R. Kremer 100% 0 0 0 0 0 0 0

Q. Matthews 25% 0 n/a n/a n/a

B. McCue 57% 0 0 0 0

P. McPartland 57% 0 0 0 0

M. Mellon 100% 0 0 0 0 0 0 0

N. Mistry 100% 0 0 0 0 n/a n/a n/a

M. Morand

(Alt. Sullivan)100% 0 0 0 0 0 0 0

K. Morse 67% 0 0 n/a n/a n/a n/a

N. Ortiz 100% 0 0 0 0 0 0 0

R. Preston

(Alt. Henderson)83% ALT ALT 0 0 0 n/a

J. Rearick 100% 0 0 0 0 0 0 0

P. Reid 100% 0 0 0 0 0 0 0

V. Robibero 43% 0 0 ALT

R. Shanklin 0%

J. Stabler

(Alt. Schloss)100% 0 0 0 0 0 n/a n/a

C. Strawn 100% 0 0 0 n/a n/a n/a n/a

L. Taylor

(Alt. Wagner)100% 0 0 n/a n/a n/a n/a n/a

H. Thurmer

(Alt. Clarke) 86% ALT 0 0 0 0 0

H. Vyas 57% 0 0 0 0

T. Waardenburg 86% 0 0 0 0 0 0M. Walsh 83% 0 0 0 0 0 n/a

G. Cassini

J. De Lorenzi

J. Herrity 0 0 0

A. Hopkirk 0

T. Jiang

J. Knolmajer 0 0 0 0 0

J. Koshak

D. McColl

C. McDilda

J. Meyer

0 = Present at Meeting

ALT = Alternate Present at Meeting

REP = Representative Present at Meeting

n/a = Not a Member

A17 Maintenance, Repair, & Replacement CommitteeMeeting Attendance Record

Member

Contributing

Member

Meeting% Attended


A17.1-202X/CSA B44-2X Public Review Comments A17 Maintenance, Repair, & Replacement Committee

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A17.1-202X Public Review Comments A17 Maintenance, Repair, & Replacement Committee

Commenter Record No. Comment Committee Response Lee Alley 08-1345 Record 08-1345

8.6.3.16.1 Replacement of the Complete Driving Machine The changes to this section should not be allowed. The changing of a complete driving machine should always be an alteration! To allow this exemption based on someone’s interpretation of a same for same type, form, fit, or function is opening a very dangerous gray area that can be used to diminish the overall Safety of a conveyance. 8.6.3.10 Replacement of Hydraulic Jack, Plunger, and Cylinder, Tanks, and Anti-creep Leveling Device I feel that this change should not be made. If a tank replacement is no longer considered an alteration then it will not have a mandatory inspection after this work is completed. THIS LOWERS THE MINIMUM SAFETY! When the tank is changed the plumbing and all other mechanical connections are manipulated, therefore this work should always be an alteration.

Kenneth Bazner 08-1345 8.6.3.10.4 Proposed 8.6.3.10.4 is misleading an will result in non compliance an lower A17.1 safety requirements. The proposed language to remove it is a alteration in fact is a alteration an has to comply to 8.7.3.29 removes a level of oversight that 8.7.3.29 triggers compliance with 8.10.2.3.1 which requires a inspection by AHJ. If approved will remove a layer os safety an result in self testing an self inspecting. 8.6.3.10.4 A tank replacement shall be classified as an alteration and shall comply with 8.7.3.29

Not accepted. The definition for a replacement is the substitution of a device or component and/or subsystems, in its entirety, with a unit that is basically the same as the original for the purpose of ensuring performance in accordance with applicable Code requirements. There are no test requirements for altered or replaced tanks in A17.1. Requirement 8.7.3.29 contains the same requirements as in the proposal.

Frank Belio 08-1345 Public Comment: any equipment not installed to the original manufacture specification is an alteration not a replacement. Miss classifying an alteration a repair can subject the



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equipment not meeting the original engineering specification thereby jeopardizing safety, I am not in support of this proposed change

Dustin Black 08-1345 I am a trained elevator mechanic. I have been trained to install, repair and service all elevators and escalators. Elevators and escalators can be very dangerous when proper steps are not followed. Elevator and escalators move the public vertically, and sometimes hundreds or thousands of feet. Being that I am trained and licensed to work on elevators and escalators, I have a few safety concerns about some of the proposed changes to A17.1. A few of the proposed changes put the public at risk of being injured or worse. Hydraulic Tanks, Jacks, Plungers, Cylinder, Anti-Creep Leveling Device, Valves, Pressure Piping, and Fittings Elevators are the largest form of transportation, moving more people per day than any other form of transportation. Without 3rd party verification, ANSI inspections, the public is possibly being put in a scenario of a serious accident. To let the proposed changes to A17.1.8.6.3.10 and A17.1.8.6.3.11 take effect, is putting the riding public in harm’s way. What is the price on safety? By removing A17.1.8.6.3.10. is misleading, this proposal lowers A17.1’s minimum standard. By removing the language that a tank replacement is an alteration and has to comply with 8.7.3.29 removes the level of oversight. 8.7.3.29 triggers compliance with 8.10.2.3.1 which at minimum requires an inspection of alterations. What is being proposed removes the oversight provided by an ANSI inspector and suggest self-testing. This may lead to non-compliance, unsafe equipment, possible risk of injury to the riding public. A17.1-2019,8.7.12 states “Where an alteration not specifically covered in section8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section1.2”. When a 3rd party inspection happens, there is compliance. This proposal removes this. All valves, oil line, fittings, and anti-creep valves are just as critical as the changing of a tank. Without an inspection the existing level of safety is lowered. When these items are tested, they are tested at a worst case scenario, and many times an additional 25%. Replacement of Complete Drive Machine



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Not all driving machines are equivalent, some are more involved than others. Others require precision alignment. If machines aren’t installed properly, they can vibrate. This vibration can lead to a broken worm shaft. If this happens the elevator can start to ascend upwards at an uncontrollable rate. This will result in injury and death. Again, by removing a 3rd party inspection results in a lowered level of safety. The public is at risk here. This is frightening that it is even being considered.

Scott Hultstrom 08-1345 8.6.3.10.4 Comments/Proposed Revision/Rationale: The proposed language in 8.6.3.10.4 is misleading and will result in non-compliance. Overall the proposal lowers A17.1’s minimum safety requirement. The language proposed to remove the fact it is an alteration and has to comply with 8.7.3.29 removes a level of oversight. 8.7.3.29 triggers compliance with 8.10.2.3.1 which at a minimum requires an inspection. Your proposal if approved removes that layer of safety and results in private companies “self-inspecting and self-testing” as they see fit which historically has led to non-compliance, unsafe equipment, and financial loss to equipment owners. The proposal appears to be driven monetarily so as to avoid permit fees since many jurisdictions would trigger that based on calling it an alteration. This is short sighted and that permitting is a further trigger that provides jurisdictional oversight via an inspection. The tank replacement is in fact an alteration as considered but not limited to A17.1-2019, 8.7.1.2 which reads: “Where an alteration not specifically covered in Section 8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section 1.3.” This when combined with the required inspection provides a level of scrutiny to ensure safety was in fact not diminished. Your proposal removes this opportunity. As an Elevator Constructor working in the field for over 26 years I would not replace a tank without at a minimum having it inspected since in addition to the tank being replaced other equipment is affected. Additionally the job site environment needs to be inspected for safety after an event such as this. The line should read: 8.6.3.10.4 A tank replacement shall be classified as an alteration and shall comply with 8.7.3.29.

Not accepted. The definition for a replacement is the substitution of a device or component and/or subsystems, in its entirety, with a unit that is basically the same as the original for the purpose of ensuring performance in accordance with applicable Code requirements. There are no test requirements for altered or replaced tanks in A17.1. Requirement 8.7.3.29 contains the same requirements as in the proposal.

Commented [NG1]: Additional comments were received after this response was developed. Please review entire comment and revise response as necessary.



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8.6.3.16

The proposal’s rationale fails to accurately indicate to readers what you have changed technically (i.e. removal of the inspection). Make no mistake, your proposal eliminated an inspection. The rationale technically does not match the resultant affect on communities using this code. If this process through exception is no longer an alteration it reduces or eliminates oversight, due diligence, proper engineering, incorrect sales proposals, and non-compliance with OSHA. Forgive me if I don’t add The Federal and Provincial Health and Safety Regulations for Canada. I know they are extensive and may bear with great effect to this topic, I am not competent in that language yet. I do recommend any bi-national effort reviews that language as ASME has entertained arguments and approved language in the past neglecting Canada’s safety regulations. This puts the decision making process solely in the hands of a manufacturer who is almost exclusively monetarily driven. Anyone arguing against that fact is either not competent in the area or is neglecting the safety needed to be observed. When reviewing this keep an open mind and don’t just try to think of why to say no to any public comment. Replacements although by definition not alterations still trigger alteration driven oversight. The existing language observes that safety and the proposal deletes safety in that area. Overall the proposal lowers A17.1’s minimum safety requirements. So if I am a manufacturer, company etc. I can just write a document or pay an engineer to state its equivalent to the original make and model and able to meet the original design criteria of the elevator system? That’s an easy out. This exception can be exploited. You should write language that protects against that. The current proposal does not fix this problem. ASME doesn’t address or mandate permitting but many elevator divisions fund themselves through permits at least in part. By allowing any alteration to not be an alteration you are hurting the public welfare of a community and putting life and limb at risk through de-funding the oversight. This leads to either no inspectors or third party inspectors who habitually do piece work and stack inspections at a fevering pace all the while not citing code violations for fear of not retaining clients. This proposal’s exception starts that snowball effect.



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Engineers are not code competent. Their discipline is engineering. Many times I have in my field experience consulted an elevator company engineer who failed to see what code required, and they directed field personnel to non-compliance. The complex scope of work and the materials involved spanning a myriad of codes to be complied with necessitate this to be an alteration and if anything expanding through referenced standards what need be complied with. Many alterations performed by manufacturers in the United States by design fail to comply with regulatory language and are running in violation creating imminent danger to affected persons. Revise the proposal to not remove the alteration criteria. This proposal as written, is unsafe. If the proper revision to make the proposal less dangerous than it is as written is not accomplished then withdraw any approval of this proposal. General: The proposal’s rationale fails to accurately indicate to readers what you have changed technically (i.e. removal of the inspection). Make no mistake, your proposal eliminated an inspection. The rationale technically does not match the resultant affect on communities using this code. If this process is no longer an alteration it won’t have a mandatory inspection which lowers safety by reducing oversight. Without an inspection an AHJ providing oversight would reduce/omit an inspector verifying code compliance. If after performing the due diligence of changing a tank it is virtually impossible this is not an alteration, the tank is always going to be different as well as variables that affect safety would trigger Section 8.7. Anyone arguing against that fact is either not competent in the area or is neglecting the safety needed to be observed. Replacements although by definition not alterations still trigger alteration driven oversight. The existing language observes that safety and the proposal deletes safety in that area. Overall the proposal lowers A17.1’s minimum safety requirements.



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Regarding the leveling device replacement it says it still has to be tested. Is the test by the installer with or without a witnessing by an inspector? Please provide a response to me as I want to see how far safety was lowered. Removing alteration from tank replacement opens up the door so that an inspector doesn’t just check period. A myriad of variable unfold ranging from skill level, company compliance, company safety priority etc. that make it mandatory to allow inspector oversight driven by the alteration language and is paramount to safety. Keep alteration in the requirement. Compliance helps everyone understand they have skin in the game driven by enforcement. Don’t use the proposal to tie a jurisdictions hands by taking that enforcement away. An inspector performing the mandatory alteration inspection can plainly catch that pressure relief was set etc., and you get the value of a qualified inspector who knows the code better than probably everyone else involved in this process as well as their unique point of view in enforcing safety. Many do not understand 8.6.1.1.2 and 8.7.1.1 which by requiring an alteration inspection and say replacing an older tank under an older code the inspector inspecting knows to determine what falls under the installation code and what has to comply with the current code. I do fear telling ASME any problem, discrepancy or incorrect proposal as I see that in the past that knowledge is then used by the dominant controlling interest group running ASME acting to change what was pointed out rather than the problem proposal. Conversely when a safety failure in an ASME standard was identified manufacturers verbally stated “Well we have to fix that”, but never acted on that claim. Please don’t allow that as it has continued to lessen the safety value of A17.1. During this public review process I have had many people state they fear publicly commenting because of a fear of retaliation by persons volunteering at ASME. This is a frightening fact that need be addressed. Revise the proposal to not remove the alteration criteria. This proposal as written, is unsafe. If the proper revision to make the proposal less dangerous than it is as written is not accomplished then withdraw any approval of this proposal.

Ken Michalik 08-1345 Requirement 8.6.3.10:



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The rationale fails to accurately indicate to readers what you have changed technically (i.e. removal of the inspection)

I feel that if it is no longer an alteration it won’t have a mandatory inspection. This lowers safety.

This could affect the level of safety by not having the AHJ providing oversight.

This change would reduce/omit an inspector verifying code compliance.

There is no way this is not an alteration, the tank is always going to be different.

Unless you update Appendix L and Section 8.7 a conflict will exist you created between replacement and alteration.

The proposed language in 8.6.3.10.4 is misleading and will result in non-compliance.

Overall the proposal lowers A17.1’s minimum safety requirement.

The 8.6.3.10.4 language proposed to remove the fact it is an alteration and has to comply with 8.7.3.29 removes a level of oversight. 8.7.3.29 triggers compliance with 8.10.2.3.1 which at a minimum requires an inspection. Your proposal if approved removes that layer of safety and results in private companies “self-inspecting and self-testing” as they see fit which historically has led to non-compliance, unsafe equipment, and financial loss to equipment owners.

The 8.6.3.10.4 proposal appears to be driven monetarily so as to avoid permit fees since many jurisdictions would trigger that based on calling it an alteration. This is short sighted and that permitting is a further trigger that provides jurisdictional oversight via an inspection.

The tank replacement is in fact an alteration as considered but not limited to A17.1-2019, 8.7.1.2 which reads: ”Where an alteration not specifically covered in Section 8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section 1.2.” This when combined with the required inspection provides a level of scrutiny to ensure safety was in fact not diminished. Your proposal removes this opportunity.

As an Elevator Constructor working in the field for over 26 years I would not replace a tank without at a minimum having it inspected since in addition to the tank being replaced other equipment is affected. Additionally the job site environment needs to be inspected for safety after an event such as this.

The line should read: o 8.6.3.10.4 A tank replacement shall be classified as an alteration and shall

comply with 8.7.3.29.


Overall the above proposals lower A17.1’s minimum safety requirement.



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The language proposed in 8.6.3.10.5 to remove the fact it is an alteration and has to comply with 8.7.3.31.3 removes a level of oversight. Despite the proposal indicating testing, it removes the 8.10.2.3.1 inspection requirement. 8.7.3.31.3 triggers compliance with 8.10.2.3.1 which at a minimum requires an inspection. Your proposal if approved removes that layer of safety and results in private companies “self-inspecting and self-testing” as they see fit which historically has led to non-compliance, unsafe equipment, and financial loss to equipment owners. Inspection and testing are performed by two different categories of people and your proposal removes one of those categories that would have made this scenario safer.

The proposal in 8.6.3.10.5 appears to be driven monetarily so as to avoid permit fees since many jurisdictions would trigger that based on calling it an alteration. This is short sighted and that permitting is a further trigger that provides jurisdictional oversight via an inspection.

Regarding the leveling device replacement it says it still has to be tested. Is the test by the installer with or without a witnessing by an inspector? Please provide a response to me.

An anti-creep leveling device replacement is in fact an alteration as considered but not limited to A17.1-2019, 8.7.1.2 which reads: ”Where an alteration not specifically covered in Section 8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section 1.2.” This when combined with the required inspection provides a level of scrutiny to ensure safety was in fact not diminished. Your proposal removes this opportunity.

Removing alteration from tank replacement opens up the door so that an inspector doesn’t just check period. Given the varied skill level of workers in a jurisdiction this inspector oversight is paramount to safety. Keep alteration in there. Important part of all this is the ownership of work completed to make everyone accountable both in a proactive way and afterward in the event an accident occurred.

When you replace a tank the required alteration inspection gives way to an inspector verifying that pressure relief was set etc., and you get the value that the inspector who knows the code better actually puts eyes on the job.

If replacing an older tank under an older code the inspector inspecting knows to decipher what falls under the grandfather code and what has to comply with new.

As an Elevator Constructor working in the field for over 26 years I would not replace an anti-creep leveling device without at a minimum having it inspected since in addition to the tank being replaced other equipment is affected as well as accessibility compliance. Additionally the job site environment needs to be inspected for safety after an event such as this.



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The line should read: 8.6.3.10.5 An anticreep leveling device replacement shall be classified as an alteration and shall comply with 8.7.3.31.3.

Requirement 8.6.3.16:

Even though it’s a replacement, the scope of work and the materials involved make it a larger job. After considering all the things involved in this work, this should be an alteration.

The allowance to have an engineer sign off that its equivalent is a slippery slope that may reduce safety. I see there is a grey area that could make something as large as a mod be minimized to a repair/replacement.

Work of this type could take days and combined with the scope of work this complex, it should be an alteration.

Although A17.1 does not address permits, this change could eliminate the need for a mod permit that can reduce funds a jurisdiction takes in which will hurt already struggling AHJs. This reduces the good welfare of a community by hurting the jurisdiction financially who provides oversight.

Jeff Parker 08-1345 I think that tank replacement should still be an alteration, because sometimes through the ordering process the wrong thing arrives at the job and the mechanics are told to make it work. An AHJ is in a different light than the mechanics to question whether or not it's the same part for replacement.

Dillon Scheitlin 08-1345 Hydraulic Tanks, Jacks, Plungers, Cylinder, Anti-Creep Leveling Device, Valves, Pressure Piping, and Fittings Elevators are the largest form of transportation, moving more people per day than any other form of transportation. Without 3rd party verification, ANSI inspections, the public is possibly being put in a scenario of a serious accident. To let the proposed changes to A17.1.8.6.3.10 and A17.1.8.6.3.11 take effect, is putting the riding public in harm’s way. What is the price on safety? By removing A17.1.8.6.3.10. is misleading, this proposal lowers A17.1’s minimum standard. By removing the language that a tank replacement is an alteration and has to comply with 8.7.3.29 removes the level of oversight. 8.7.3.29 triggers compliance with 8.10.2.3.1 which at minimum requires an inspection of alterations. What is being proposed removes the oversight provided by an ANSI inspector and suggest self-testing. This may lead to non-compliance, unsafe equipment, possible risk of injury to the riding public.



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A17.1-2019,8.7.12 states “Where an alteration not specifically covered in section8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section1.2”. When a 3rd party inspection happens, there is compliance. This proposal removes this. All valves, oil line, fittings, and anti-creep valves are just as critical as the changing of a tank. Without an inspection the existing level of safety is lowered. When these items are tested, they are tested at a worst case scenario, and many times an additional 25%. Replacement of Complete Drive Machine Not all driving machines are equivalent, some are more involved than others. Others require precision alignment. If machines aren’t installed properly, they can vibrate. This vibration can lead to a broken worm shaft. If this happens the elevator can start to ascend upwards at an uncontrollable rate. This will result in injury and death. Again, by removing a 3rd party inspection results in a lowered level of safety. The public is at risk here. This is frightening that it is even being considered.

Charles Sheriff 08-1345 I am a trained elevator mechanic. I have been trained to install, repair and service all elevators and escalators. Elevators and escalators can be very dangerous when proper steps are not followed. Elevator and escalators move the public vertically, and sometimes hundreds or thousands of feet. Being that I am trained and licensed to work on elevators and escalators, I have a few safety concerns about some of the proposed changes to A17.1. A few of the proposed changes put the public at risk of being injured or worse. Hydraulic Tanks, Jacks, Plungers, Cylinder, Anti-Creep Leveling Device, Valves, Pressure Piping, and Fittings Elevators are the largest form of transportation, moving more people per day than any other form of transportation. Without 3rd party verification, ANSI inspections, the public is possibly being put in a scenario of a serious accident. To let the proposed changes to A17.1.8.6.3.10 and A17.1.8.6.3.11 take effect, is putting the riding public in harm’s way. What is the price on safety? By removing A17.1.8.6.3.10. is misleading, this proposal lowers A17.1’s minimum standard. By removing the language that a tank replacement is an alteration and has to comply with 8.7.3.29 removes the level of oversight. 8.7.3.29 triggers compliance with 8.10.2.3.1 which at minimum requires an inspection of alterations. What is being



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proposed removes the oversight provided by an ANSI inspector and suggest self-testing. This may lead to non-compliance, unsafe equipment, possible risk of injury to the riding public. A17.1-2019,8.7.12 states “Where an alteration not specifically covered in section8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section1.2”. When a 3rd party inspection happens, there is compliance. This proposal removes this. All valves, oil line, fittings, and anti-creep valves are just as critical as the changing of a tank. Without an inspection the existing level of safety is lowered. When these items are tested, they are tested at a worst case scenario, and many times an additional 25%. Replacement of Complete Drive Machine Not all driving machines are equivalent, some are more involved than others. Others require precision alignment. If machines aren’t installed properly, they can vibrate. This vibration can lead to a broken worm shaft. If this happens the elevator can start to ascend upwards at an uncontrollable rate. This will result in injury and death. Again, by removing a 3rd party inspection results in a lowered level of safety. The public is at risk here. This is frightening that it is even being considered.

Dave Smith 08-1345 NOTE to Committee: Not all of these comments apply to Record 08-1345. Some of the comments are for the RIO proposal. However, the commenter only referenced 08-1345. I have only included the comments related to Record 08-1345. The A17 Electrical Committee will address the comments related to RIO.

1. Replacement of Hydraulic Jack, Plunger, and Cylinder, Tanks, and Anticreep

Leveling Device …

1. A tank replacement shall be classified as an alteration and shall comply with 8.7.3.29 3.24.

1. An anti-creep leveling device replacement shall be classified as an alteration and shall comply tested to determine conformance with 8.7.3.31.3 8.10.3.4.2(a).

Rationale:

To define tank replacement as a Replacement. Note: For an Alteration; 8.7.3.29 requires conformance to 3.24.



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To define anti-creep device replacement as a Replacement. Note: For an Alteration; 8.7.3.31.3 requires conformance to 3.26.3.1.

I believe that in the interest of safety 8.6.3.10.4 should read: 8.6.3.10.4 A tank replacement shall be classified as an alteration and shall comply with 8.7.3.29. and that 8.6.3.10.5 should read: 8.6.3.10.5 An anticreep leveling device replacement shall be classified as an alteration and shall comply with 8.7.3.31.3. That leaves no doubt an inspection is needed. 8.6.3.16.1 Replacement of the Complete Driving Machine. (a) Where an electric elevator driving machine (see Section 1.3) is replaced, it shall be considered an alteration and shall conform to 8.7.2.25.1 except, the replacement driving machine shall be permitted to conform to the code under which the original machine was installed, or altered if; (1) the driving machine is replaced with equipment approved by the original equipment elevator manufacturer as being equivalent to the original make and model or, (2) the replaced driving machine is certified by a licensed professional engineer as being equivalent to the original make and model and able to meet the original design criteria of the elevator system (b) Where an electric elevator driving machine is replaced in accordance with 8.6.3.16.1(a)(1) or 8.6.3.16.1(a)(2) it shall be inspected and tested in accordance with the requirements specified in 8.10.2.4.1(a). Rationale: To allow for direct replacement of machines and to provide inspection and testing requirements. The intention is to allow exception to the alteration requirement only when the same type machine with the same form, fit and function is used. This would leave a huge possibility of a Drive Machine running with safety violations. The Drive machine as shipped may meet the requirement of fit; however, the installer may need to use a different fitting when installing the replacement machine and codes may not be met. The Machine may not be placed in the original position and codes may not be met. 8.6.3.16.1 should read: 8.6.3.16.1 Replacement of the Complete Driving Machine.



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(a) Where an electric elevator driving machine (see Section 1.3) is replaced, it shall be considered an alteration and shall conform to 8.7.2.25.1. 8.6.3.16.2 Replacement of Controller

a. Where an elevator controller is replaced, with either; 1. a motion controller, 2. an operation controller, 3. a motion and operation controller, or 4. a door controller

it shall be considered an alteration and shall conform to 8.7.2.27.4 or 8.7.3.31.5 as applicable.

a. Where a controller specified in (a) is replaced with equipment equivalent to the original make and model, due to;

1. damage or loss, and 2. for the purpose of matching other equipment in the group

it shall be permitted to conform to the code under which the original controller was installed or last altered, and shall be inspected and tested in accordance with the requirements specified in 8.10.2.4.1(b) or 8.10.3.4.1(a) as applicable. Rationale: Allow for the direct replacement of a controller, with an identical and available controller, when the original controller has been damaged. (Example: Controller destroyed by fire or water). The controller will need to meet the Code to which it was originally installed or last altered. In 8.6.3.16.2 (b)(1) and (2) should be deleted. 8.10.2.4.1 (a) Where a driving machine is replaced (see 8.6.3.16.1), tests shall be performed as specified in 8.10.2.2.2(o), and (u) through (z), (cc)(1), (cc)(2), (cc)(3) [except (cc)(3)(-c), unless required as installed or last altered], (dd), and (kk); and 8.10.2.2.1(q). Tests as specified in requirements (b) Where a controller is replaced (see 8.6.3.16.2); tests shall be performed, if these features were present when the unit was installed or last altered, as specified in 8.10.2.2.1(c), (j), (l)(5), (q), and (t); 8.10.2.2.2(r), (s), (t), (v), (aa), (bb), (ff), (gg), (jj) and (kk); 8.10.2.2.6; and 8.10.2.2.3(o). All electric protective devices shall be tested for proper operation.



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Rationale: To provide inspection and testing requirements for the direct replacement of an Electric elevator controller with a spare due to a controller loss. (cc)(3) and (jj) are required if these features were present when the unit was installed or last altered. Rationale: To provide inspection and testing requirements for the direct replacement of an Electric elevator driving machine. Since replacing a drive machine may include repiping, brake(s) and sheave(s), in the interest of safety 8.10.2.4.1(a) should read: 8.10.2.4.1 (a) Where a driving machine is replaced (see 8.6.3.16.1), tests shall be performed as specified in 8.10.2.2.2(o)through (ff) and (jj) (b) Where a controller is replaced (see 8.6.3.16.2); tests shall be performed, if these features were present when the unit was installed or last altered, as specified in 8.10.2.2.1(c), (j), (l)(5), (q), and (t); 8.10.2.2.2(r), (s), (t), (v), (aa), (bb), (ff), (gg), (jj) and (kk); 8.10.2.2.6; and 8.10.2.2.3(o). All electric protective devices shall be tested for proper operation. Rationale: To provide inspection and testing requirements for the direct replacement of an Electric elevator controller with a spare due to a controller loss. Since electrical taps for doors and brakes,and drive motor can be in the controler, when replacing a controler 8.10.2.4.1(b) should read. (b) Where a controller is replaced (see 8.6.3.16.2); tests shall be performed, if these features were present when the unit was installed or last altered, as specified in 8.10.2.2.1(a) through (e), (h) through(j), (q),(s),(t),(u)(v),(aa),(bb),(ff),(gg),(jj),(kk),(oo) and (tt); 8.10.2.2.2(r), (s), (t), (v), (aa), (bb), (ff), (gg), (jj)(oo),(tt),and(kk) and 8.10.2.2.3(o). All electric protective devices shall be tested for proper operation.

Anthony Wunderlich 08-1345 I am a trained elevator mechanic. I have been trained to install, repair and service all elevators and escalators. Elevators and escalators can be very dangerous when proper steps are not followed. Elevator and escalators move the public vertically, and sometimes hundreds or thousands of feet. Being that I am trained and licensed to work on elevators and escalators, I have a few safety concerns about some of the proposed changes to A17.1. A few of the proposed changes put the public at risk of being injured or worse. Hydrolic Tanks, Jacks, Plungers, Cylinder, Anti-Creep Leveling Device, Valves, Pressure Piping, and Fittings



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Record 08-1345 Page 2 Elevators are the largest form of transportation, moving more people per day than any other form of transportation. Without 3rd party verification, ANSI inspections, the public is possibly being put in a scenario of a serious accident. To let the proposed changes to A17.1.8.6.3.10 and A17.1.8.6.3.11 take effect, is putting the riding public in harms way. What is the price on safety? By removing A17.1.8.6.3.10. is misleading, this proposal lowers A17.1’s minimum standard. By removing the language that a tank replacement is an alteration and has to comply with 8.7.3.29 removes the level of oversight. 8.7.3.29 triggers compliance with 8.10.2.3.1 which at minimum requires an inspection of alterations. What is being proposed removes the oversight provided by an ANSI inspector, and suggest self testing. This may lead to non compliance, unsafe equipment, possible risk of injury to the riding public. A17.1-2019,8.7.12 states “Where an alteration not specifically covered in section8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section1.2”. When a 3rd party inspection happens, there is compliance. This proposal removes this. All valves, oil line, fittings, and anti creep valves are just as critical as the changing of a tank. Without an inspection the existing level of safety is lowered. When these items are tested, they are tested at a worse case scenario, and many times an additional 25%. Replacement of Complete Drive Machine Record 08-1345 Page2-4 A17.1.8.10.4.1.2(m) Not all driving machines are equivalent, some are more involved than others. Others require precision alignment. If machines aren’t installed properly they can vibrate. This vibration can lead to a broken worm shaft. If this happens the elevator can start to ascend upwards at an uncontrollable rate. This will result in injury and death. Again by removing a 3rd party inspection results in a lowered level of safety. The public is at risk here. This is frightening that it is even being considered.



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Michael Vandervennet

08-1345 Requirement 8.6.3.10:

This could affect the level of safety by not having the AHJ providing oversight.

This change would reduce/omit an inspector verifying code compliance.

There is no way this is not an alteration, the tank is always going to be different.

Unless you update Appendix L and Section 8.7 a conflict will exist you created between replacement and alteration.


Overall the proposal lowers A17.1's minimum safety requirement.

The 8.6.3.10.4 language proposed to remove the fact it is an alteration and has to comply with 8.7.3.29 removes a level of oversight. 8.7.3.29 triggers compliance with 8.10.2.3.1 which at a minimum requires an inspection. Your proposal if approved removes that layer of safety and results in private companies "self-inspecting and self-testing" as they see fit which historically has led to non-compliance, unsafe equipment, and financial loss to equipment owners.

The 8.6.3.10.4 proposal appears to be driven monetarily so as to avoid permit fees since many jurisdictions would trigger that based on calling it an alteration. This is short sighted and that permitting is a further trigger that provides jurisdictional oversight via an inspection.

The tank replacement is in fact an alteration as considered but not limited to A17.1-2019, 8.7.1.2 which reads: "Where an alteration not specifically covered in Section 8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section 1.2." This when combined with the required inspection provides a level of scrutiny to ensure safety was in fact not diminished. Your proposal removes this opportunity.

As an Elevator Constructor working in the field for over 26 years I would not replace a tank without at a minimum having it inspected since in addition to the tank being replaced other equipment is affected. Additionally the job site environment needs to be inspected for safety after an event such as this.

The line should read: 8.6.3.10.4 A tank replacement shall be classified as an alteration and shall comply with 8.7.3.29.


Overall the above proposals lower A17.1's minimum safety requirement.

The language proposed in 8.6.3.10.5 to remove the fact it is an alteration and has to comply with 8.7.3.31.3 removes a level of oversight. Despite the proposal indicating testing, it removes the 8.10.2.3.1 inspection requirement. 8.7.3.31.3 triggers compliance with 8.10.2.3.1 which at a minimum requires an inspection. Your



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proposal if approved removes that layer of safety and results in private companies "self-inspecting and self-testing" as they see fit which historically has led to non-compliance, unsafe equipment, and financial loss to equipment owners. Inspection and testing are performed by two different categories of people and your proposal removes one of those categories that would have made this scenario safer.

The proposal in 8.6.3.10.5 appears to be driven monetarily so as to avoid permit fees since many jurisdictions would trigger that based on calling it an alteration. This is short sighted and that permitting is a further trigger that provides jurisdictional oversight via an inspection.

An anti-creep leveling device replacement is in fact an alteration as considered but not limited to A17.1-2019, 8.7.1.2 which reads: "Where an alteration not specifically covered in Section 8.7 is made, it shall not diminish the level of safety below that which existed prior to the alteration. See also Section 1.2." This when combined with the required inspection provides a level of scrutiny to ensure safety was in fact not diminished. Your proposal removes this opportunity.

As an Elevator Constructor working in the field for over 26 years I would not replace an anti-creep leveling device without at a minimum having it inspected since in addition to the tank being replaced other equipment is affected as well as accessibility compliance. Additionally the job site environment needs to be inspected for safety after an event such as this.

The line should read: 8.6.3.10.5 An anticreep leveling device replacement shall be classified as an alteration and shall comply with 8.7.3.31.3.

Requirement 8.6.3.16:

Even though it's a replacement, the scope of work and the materials involved make it a larger job. After considering all the things involved in this work, this should be an alteration.

The allowance to have an engineer sign off that its equivalent is a slippery slope that may reduce safety. I see there is a grey area that could make something as large as a mod be minimized to a repair/replacement.

Work of this type could take days and combined with the scope of work this complex, it should be an alteration.

Although A17.1 does not address permits, this change could eliminate the need for a mod permit that can reduce funds a jurisdiction takes in which will hurt already



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struggling AHJs. This reduces the good welfare of a community by hurting the jurisdiction financially who provides oversight.

Joe Williams 08-1345 The following comments on the proposed ASME A17.1-2019/ CSA B44-19 draft on proposals to revise, reaffirm or withdraw approval of existing ASME Standards on Elevator Safety Code for Elevators and Escalators are submitted to public comment by Joe Williams, 1207 Graylyn Rd, Wilmington, DE 19803. I have worked in the elevator industry since 1983. My experiences include time in construction, modernization, repair, and maintenance. I currently work as the Business Manager for Local 5 IUEC in Philadelphia, PA. The revisions recommended for 8.6.3.10.4 and 8.6.3.10.5 should not be approved as they remove the requirement for an inspection which would lower the factor of safety.


agenda a17 maintenance, repair, and replacement committee

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