BOMA | Building Owners and Managers Association of San Francisco
Advocate: An Update on Legislative, Regulatory, and Political Issues Affecting Commercial Real Estate
August 31, 2015
Volume 21, Issue 8
UPDATE: California Proposes New Elevator Maintenance Rules
Costs May Increase for Elevator Maintenance
Your feedback is requested

To represent our members' interests, BOMA San Francisco's Codes and Regulations Committee representatives had a rare opportunity to discuss the proposed elevator code changes with the California Department of Industrial Relations, Occupational Safety and Health Division, Elevator Unit (Cal/OSHA) chief, Dan Barker recently. The purpose of the gathering was to help the Department understand any negative impacts, e.g., cost, availability, safety issues, et cetera, that may result from these changes. 

Also, National Elevator Industry, Inc. (NEII) is making building owners aware of the efforts underway by the Cal/OSHA to develop theGroup V elevator codes.  Cal/OSHA has proposed over 60 pages of changes - more than 125 specific modifications - to the ASME A.17.1 (2013) /CSA B44-13 Safety Code for Elevators and Escalators.  

The draft amendments to the ASME Code under discussion are so significant and controversial that, if enacted through formal rule making, they will drastically alter current elevator designs for all of the major elevator companies and impose significant new costs and construction delays on California building owners.

Key areas of concern in Cal/OSHA's pre-rule making draft and initial estimates of potential costs are set forth below.

KEY AREAS OF CONCERN:
  • Prohibits certain machine-room-less (MRL) designs in California.
  • Adds new restrictions for other MRL designs.
  • Prohibits elevator controls from being located in the building hoistway, requiring control rooms to be constructed.
  • Significant cost increases and delays for new construction.
  • Significant cost increases for elevator maintenance on existing buildings.
  • No demonstrable safety benefit; in fact, creates new workplace safety issues.
  • Lack of empirical data to support changes.
  • Disproportionate impact on low to mid-rise buildings.
  • Stunts technological innovation and eco-efficient building designs.
  • Moves California building transportation backwards 20 years.
SIGNIFICANT NEW COSTS:
  • Elevators unique for California
    • $100K-$200K per elevator
  • Larger cars, larger hoistways, less space to rent
    • $25M annually
  • No Hydraulic machine room-less elevators
    • $25M annually
  • Control rooms must be outside of hoistway
    • $100M annually
  • Licensed mechanics required to perform new tasks
    • $33.6M annually
The draft proposed rules are currently under review internally at Cal/OSHA. Formal rule making has not commenced, but we expect the rule making package to be completed and ready to file by late summer. 
 
If you have any feedback, please send it to mhargrove@cbpa.com.
--------------------

UPDATE - May 29, 2014

BOMA San Francisco's Codes and Regulations Committee members reviewed a letter that the National Elevator Industry Association wrote to the head of the California Department of Industrial Relations. Click here for a presentation related to the missive and here for an attachment to the letter.

The communication states that the 60 pages of amendments that the Department is considering adopting would make California unique as having the strictest and most expensive elevator requirements in the country.

Please be aware of these proposed changes for elevator maintenance if they are permanently adopted. 

If you have any feedback, please send it to mhargrove@cbpa.com

--------------------

UPDATE - April 28, 2014

Since 2012, members of BOMA San Francisco's Codes and Regulations Committee have been working with BOMA California and the California Division of Occupational Safety and Health on changes to statewide elevator maintenance rules.  Our members' feedback was detailed in a BOMA amended 2012 Division Circular Letter.

On April 22, 2014, the Division held a meeting to review a draft of new elevator regulations regarding:

  • Elevator maintenance;
  • The qualifications for elevator inspectors and/or mechanics;
  • And, requirements for other conveyances.

BOMA California members continue to maintain their feelings that routine upkeep of elevators - specifically those that do not affect the safe operation of the system - may eventually require Division mandated oversight by a certified elevator mechanic.  Any proposed changes along those lines would increase the time and cost for the maintenance of elevators and add a modicum of value to the safety of the elevator system.

BOMA San Francisco Board Member Kevin FitzPatirck kindly attended the April 22, 2014 meeting for BOMA members and relayed their comments.

If you have any questions or feedback regarding the draft proposal of new elevator regulations, please contact kenc@boma.com.

-------------------

Original Post - October 12, 2012

Elevator Categories of Work Circular Letter Withdrawn

BOMA California representatives are pleased to report that the California Division of Occupational Safety and Health has given notice that it has formally withdrawn Circular Letter 11-01 in its entirety, effective immediately.   Prior to this retraction, BOMA San Francisco's Codes and Regulations Committee members suggested edits to the Circular Letter which was sent to the Division on May 12, 2012.

According to the Division, the Circular Letter was initially published because they had received inquiries regarding if certain work on conveyances were covered by state law. After receiving more information from the elevator industry the Division has decided that clarifications are more appropriately addressed through a formal rule making process. BOMA California members agree and applaud the Division for this decision.  BOMA thanks our colleagues in the elevator industry for their diligence.

There will be future efforts by the Division regarding rule making so this issue is likely to be revisited by year end.

 
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In This Issue
Government Affairs Meeting on September 2nd - Mandatory Disability Access Improvements
•  Legislation Introduced by Supervisor Katy Tang
UPDATE: BOMA SF-PAC Slate Card for the November 3, 2015 San Francisco Municipal Election
•  Endorsed Candidates and Positions on Propositions
BOMA International's Political Action Committee (BOMAPAC) Needs Your Support
•  Jim Collins with Shorenstein is leading the effort for BOMA San Francisco
San Francisco's Transportation Sustainability Program and Transportation Sustainability Fee
•  Including an Update to the Transportation Impact Development Fee Structure
A Message from SFFD Chief Joanne Hayes-White
•  New Assistant Deputy Chief, Division of Fire Prevention and Investigation
BOMA California Advocacy Update
•  AB 1103 Re-Write, ADA Bill Advances,Water Fixture Replacement Mandate
BOMA Protects the Commercial Real Estate Industry - Proposition 13/Split Roll Property Tax
•  California Senate Constitutional Amendment 5
UPDATE: California Proposes New Elevator Maintenance Rules
•  Costs May Increase for Elevator Maintenance
BOMA San Francisco's Drought Coverage
•  San Francisco Public Utilities Commission Ordered Mandatory Water Reduction on July 1, 2015
BART Service Transbay Tube Shutdown
•  September 5-7th
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ADVOCACY EVENTS
•  Energy and Environment Committee Meeting
September 1, 2015
Ferry Building, Port Commission Hearing Room
Please click here for more information.
•  Government Affairs Policy Advisory Committee (GAPAC) Meeting
September 2, 2015
235 Montgomery Street (Russ Building), 7th Floor 
Please click here for more information.
• 
Emergency Preparedness Committee Meeting
September 8, 2015
Location 225 Bush Street, Montgomery Burns Boardroom
Please click here for more information.
• 
Codes and Regulations Committee 
September 23, 2015
650 California Street, Basement Conference Center
Please click here for more information.
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