Alabama Elevator Inspections and the Maintenance Control Program

I was in Alabama last week doing some inspections on units at a fairly large nursing home and a hospital. I use the word “inspection” lightly here- mainly because Alabama state law only requires an inspection after the test. Inspectors do not  witness tests, rather, we witness test tags being present on controllers or in the machine room. Now, I’ve witnessed a few elevator tests with mechanics in my time, and assuming they know what periodic tests A17.1 2010 requires is a bit… generous. Not to say they don’t know what they are doing, but I am always hearing “What next?”; “We have to do that???”; “That’s dumb. Tests are dumb.”; “Pressure switch?” But hey, maybe they are differently trained here in Alabama. Maybe they read A17.2 bedtime stories and get QEI-certified and derive joy from doing annual tests and have an unlimited amount of time outside of their regular maintenance route. (Before I get yelled at, I know there are great mechanics out there who take tests seriously. This is just the pessimistic realist in me).

Anyway. Most of the time, elevator companies that do the tests don’t even accomplish the actual putting of the updated tag on the controller every year – the case at these particular locations. Also notable was the missing maintenance control program – a new staple of the machine room, starting in A17.1 2007. This beast of a code requirement brought many a question to the inspecting and maintenance world and if you think you’ll understand the requirement by the end of this blog post, I assure you one thing: sore disappointment.

A17.1 2007 requires a written maintenance control program which will act as a plan to keep the unit in compliance with all of 8.6 – the maintenance section of A17.1. It goes on to say that it will include, but not be limited to, the scheduled intervals at which tests, maintenance, and examinations are required. Then it lists what these intervals are to be based off of (design, usage, age, etc). Instructions for lubrication, testing, reporting corrective action necessary to the responsible party, and locating the actual maintenance control program are also required. You think it’s straight forward? There was an entire book just written on A17.1 – that ONE section – by John Koshak.

So first of all, it has to be written. Written is defined as a mark on a surface, right? So it can’t be in a computer somewhere. It doesn’t have to be in the machine room, but it does have to be kept at “a central location” and instructions on how to get to this “central location” must be on the controller. What is a “central location?” Is that different from a “left-ish location?” It must be accessible to elevator personel (hey, that’s me). I think it’s pretty vague.
-What if I, as the inspector, wanted to see the MCP and the directions to the location on the controller was actually a map and key to a storage unit place up the road 10 miles where I had to wade through the boxes of other unit’s MCPs just to find the one belonging to the unit at which I was looking? Better yet, what if it was kept at Otis world headquarters in Farmington, CT? I mean, that could be defined as a “central location” – central for them, at least.
– What if my maintenance control program was to contact an elevator maintenance company to do model-specific maintenance quarterly? Would posting a sheet of paper on the controller saying just that (along with lube the rails, contact the maintenance company to report necessary corrective action, etc) meet the requirement? Why not?
-Also, as the author of this maintenance control program, are you not basically guaranteeing the proper and safe operation of the equipment as long as your plan is followed and barring any vandalism-type interference?

I did run across this response to the MCP violation written up last year:

Obviously a satisfactory MCPOk, so maybe the largest elevator company in the world really is trying to tell me straight-faced that the MCP (or even Maintenance Records which is a whole ‘nother ballgame) for this particular elevator is on a server in Russia somewhere. They printed it off and left it next to the Soviet-era server, which meets the written requirements. They’d also let me into their Russian server room, so now it’s accessible to me. But I (always the pessimist) am thinking we just had a Chili’s lunch date we had to get to instead. That or the temp in the office forgot to order the MCP booklets. Either way, repeat violation.

P.S. Got a 94/100 on my NYC building director’s exam. Background investigation up next.

P.S.S. Oh yeah. RTR!

1 comment

  1. Elevator U Conference 2012 - Elevator Blog » Elevator Blog says:

    […] You also learn a lot about vertical transportation in a school campus setting (which is fairly important since about a third of our consulting work comes from universities). Students trying to bypass door locks so they can have a drunken car top ride, kicking in hoistway doors while roughhousing, and third party contractors jumping out door interlocks were a few topics this year. We also talked light bulbs, maintenance control programs, incidents, electronic door restrictors, and suspension ropes (which was surprisingly more interesting than one would imagine). I got to speak on a panel (a first for me) during the maintenance control programs talk and share my experiences as an inspector and software developer with the MCP and maintenance record data. More on that here. […]

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