Question 1: An enforcing agency inspecting elevators is
referencing NFPA-70, 2002 Edition rather than the State mandated NFPA-70, 1999.
I understood that a more stringent code is acceptable, but I
also understand that the inspector or, in this case, the
contracted agency, had no right to pick the code arbitrarily
without an ordinance adopting the more stringent standard. Is this true?
Question 2: Broward County
Elevator Inspectors are giving elevator owners the choice of
removing sump pumps or buying and installing oil/water
separators.
a) A17.l Rule 106.1 clearly says elevators must
have a drain or a sump pump.
b) 61C-5.001(7)( e) clearly says elevators may have sump pumps.
Most owners will remove pumps rather than spend
10 to 30 thousand dollars for a separator. This leaves elevator
pits, which have had pumps removed, full of water, which is
extremely dangerous.
Is Broward County allowed to set environmental
issues above the elevator safety issues addressed by our code?
Or is there, perhaps, another agency which should worry about
oil/water separation? Chapter 61C-5 removed the requirement for
a pump because all elevators plainly do not need pumps. I'm
sure our legislators did not intend to place elevator repair
personnel, inspectors, and the riding public in jeopardy.
Broward County is inspecting to a less
stringent code standard by causing these pumps to be removed
and should cease doing so. Please respond as to whether Broward
County has the authority to require the removal of sump pumps
if separators are not installed.
Answer: The Division is researching this issue with
Broward County to make sure that there are no conflicts between
the statute or law, the rules, and practical policy. After our
research is complete, the Division will do whatever the Law
states and will communicate our findings to the Elevator
Association.
Question 3: ASME A17.1 Rule 211.3b was revised with the
1997 edition, changing the requirement for smoke detectors for
recall to "automatic fire initiating devices" and removed the
words "except at unenclosed landings". This rule requires such
devices to be installed in elevator spaces and at each elevator
floor "in compliance with NFPA-72" (National Fire Alarm Code).
An exception in NFPA-72 allows the use of heat detectors for
recall in unenclosed lobbies where smoke detectors are not
feasible.
As the local Fire Marshal is the enforcing
authority for NFPA-72, if they grant a variance or exception in
writing from NFPA-72 removing the requirement for automatic
fire initiating devices for elevator recall in open air
(unenclosed) lobbies, will the Bureau of Elevator Safety accept
the exception and allow these devices to be eliminated?
Answer: The State Fire Marshal’s office has been made
aware of this issue and is currently addressing the life safety
101 and the NFPA 72 harmonization.
Question 4: The State monitors are citing "Code Data
Plates" which are to state the Edition of the Code that was in
effect when the elevator was installed or altered. This rule
was first adopted by A17.1 with the 1996 Edition, but is being
cited on all existing units.
As the state has not enforced any retroactive
codes per Chapter 399.03(7) and 399.03(8), should this rule be
cited for elevators installed or altered prior to 10/04/00, the
effective date of the 1996 Edition of A17.1?
Answer: According to the ASME A17.1-1996 edition
(inquiry 01-07, subject Rule 1206.1I, Code Data Plate)
Question: Is it the intent of the A17.1 Code to require that
all existing elevators be provided with a Code Data Plat the
answer is yes. The A17 Committee approval date is June 27,
2001.
We are presently reviewing how this will be
implemented.
Question 5: I understand that an "alteration" inspection
will not count as an "inspection" so that if an alteration
inspection takes place when an inspection is due, two
inspection reports have to be filled out for the same
inspection, one for the alteration and one for the annual
inspection. Please clarify this procedure.
