GENERAL RATIONALE:

Recent changes to controller requirements have prompted a review of these requirements. While these alteration scopes are

somewhat interrelated, the objective of this proposal is to establish a logical progression of increasing safety requirements based on each alteration scope. In A17.1a-2005/CSA B44-04 update 1, significant additions where added to change in motion control scope – so much that there was virtually no distinction between a motion control change and an operation control change – and given the scope of what a motion control change involves, these new requirements in many ways are unnecessary. The progression of safety requirements in this proposal are dependant upon the potential hazards related to the alteration and the mitigations needed to adequately address the scope of the proposed work.

Regarding Change of Operation Control 8.7.2.27.6 and 8.7.3.31.7. This alteration scope is used to establish requirements when the mode of operation is altered from a form of continuous pressure operation to a form of automatic operation or vise versa, although the latter change may not be a common occurrence. The requirements primarily address hazards associated with an elevating device that was previously manually controlled by an operator but will now be permitted to travel through the hoistway automatically. This alteration scope includes the greatest number of alteration requirements that are necessary to ensure safety for the rider and

elevator personnel. As you will see in the proposal, changes to motion control will introduces lesser requirements and finally changes to controllers requiring even less (provided the method of motion and operation remain unchanged).

Regarding Change of Motion Control 8.7.2.27.5 and 8.7.3.31.6. The A17.1 definition for motion control means the portion of a control system that governs the acceleration, speed, retardation, and stopping of the elevator. If the method of motion control (the method that governs the acceleration, speed, retardation, and stopping of the elevator) is not identical to the original method of motion control then the scope of 8.7.2.27.5 applies. Examples of identical might be: SS AC to SS AC, or 2Spd AC to 2 Spd AC, or VVVF to VVVF, or VFAC to VFAC. A change from SSAC to VVVF, or MG to SCR is not an identical method of motion control.

Since a motion control alteration does not have the same extent of hazards that can be associated with a change in operation control (as outlined in 8.7.2.27.6 & 8.7.3.31.7), the proposed requirements associated with a Motion Control are less than those required for an alteration to Operation Control.

Regarding Change of Controller 8.7.2.27.4 and 8.7.3.31.5. This alteration scope requires the least amount of alteration requirements – as compared to Motion or Operation control change since this alteration scope requires that the method of motion control or operation control remain unchanged. As shown in A17 Nonmandatory Appendix A, controllers are primarily comprised of two main items, Motion and Operation Control. To effectively define the requirements within this alteration scope it is essential to discuss changes to these components individually as well as collectively. To properly address this, this proposed alteration scope is separated into 3 parts:

1) where only a motion controller is changed for same method,

2) where only an operation controller is changed for same method, and finally

3) where both Motion & Operation controllers are changed with same overall method. OPERATION CONTROL

PROPOSAL - OPERATION CONTROL – Electric elevators

8.7.2.27.6 Change in Type of Operation Control. Rationale

Where there is a change in the type of operation control, from continuous pressure, car switch, or other type of operation where the movement or stopping of the car is under the manual control of the

operator, to any form of automatic operation, or vise versa, the

installation shall conform to the following:

Operation control as currently defined in 1.3 covers a variety of

different operation control types. While a change from down collective to selective collective is a change to operation control, it is not

significant enough to require conformance to 8.7.2.27.6. For 8.7.2.27.6 to make sense from a safety standpoint, we need to concern ourselves with operation control changes where the starting and stopping of the elevating device was solely in the hands of the attendant/operator to a

PROPOSAL - OPERATION CONTROL – Electric elevators

8.7.2.27.6 Change in Type of Operation Control. Rationale

form of operation control where either or both the starting and stopping are no longer under full control of the attendant/operator.

This is the primary premise for a change in operation control, however it may also be possible to change from automatic to manual in which case the current level of safety should not be diminished and requirements should be stated even though the potential for such an alteration scope is slight.

(a)pits to 2.2, except; 2.2.2.1, 2.2.2.2, 2.2.2.5 add requirements for worker safety to ensure access, lighting, drainage,

& stop switches are provided, exclude requirements which are related to physical construction

(b) counterweight guarding to 2.3 add requirement for worker safety to address counterweight guarding,

since operation may now be automatic

(c) vertical clearances and runbys as required by 8.7.2.4 add requirement for user safety to ensure vertical clearances and refuge

space is addressed for mechanic safety

(d) horizontal car and counterweight clearances as required by

8.7.2.5 add requirement for user safety to ensure horizontal car and cwt clearances are adequate since operation may now be automatic and not

under attendant control

(e)2.7.2, 8.7.2.7.2, 2.7.5, 2.7.6, and 2.7.9 for the newly installed

equipment. Add requirements for path, clearance, working areas in the pit, locations of equipment related to inspection and tests and lighting as related to the

new control equipment, also add temperature and humidity requirements to ensure operation within specified limits

(f)all new and modified electrical equipment and wiring to 8.7.2.8 Add requirement for electrical equipment related to this alteration

(g)(a) The protection of the hoistway landing openings shall

conform to 2.11.1 through 2.11.13, 2.12, and 2.13.

(h)(b) Car enclosures and car doors or gates shall conform to 2.14,

except that where existing car enclosures and/or car doors or gates are retained, conformance with the following requirements is not required:

PROPOSAL - OPERATION CONTROL – Electric elevators

8.7.2.27.6 Change in Type of Operation Control. Rationale

the required running clearances referenced in 2.14.1.3 are

achieved, 2.14.1.5.1, and 2.14.1.8 require conformance to 2.14.1.3 as far as running clearances are concerned, to ensure clearance between the car and hoistway or

counterweight are maintained.

Require conformance to 2.14.1.5.1, top emergency exit to ensure means are provided to rescue passengers.

Existing glass is permitted to remain by exempting 2.14.1.8 (2) requirements 2.14.2.1, 2.14.2.3, and 2.14.2.4

(3) requirement 2.14.3 Require freight-car enclosures to meet these dimensional requirements

if openwork (perforated enclosures) are intended to be retained.

(3)(4) requirement 2.14.4.3 and 2.14.4.6 except that with the

specified force, the door or gate will not deflect beyond the line of the car sill

As the installation may now run automatically, qualify that the door or gate strength should be sufficient to not deflect beyond the car sill.

(i) Where conformance to 2.14.1.7.1 is not possible due to existing overhead conditions, an alternative solution, acceptable to the authority having jurisdiction, providing equivalency to 2.14.1.7.1 shall be permitted.

Recognize that a standard railing height may not be feasible, in which case an alternate solution of equivalency is permitted. The solution must be acceptable to the authority having jurisdiction. (Ref: see TN 10- 791)

(j)(c) The car safety, the counterweight safety (where provided), and

the governor shall conform to 2.17 and 2.18, except that the pitch diameter of speed governor sheaves and governor tension sheaves are not required to conform to 2.18.7.

(k)(d) The capacity and loading shall conform to 2.16.

(l) Ascending car overspeed and unintended car movement

protection shall conform to 2.19. Require conformance to 2.19.

(m)(e) The terminal stopping devices shall conform to 2.25.

(n)(f) The operating devices and control equipment shall conform to

2.26. The requirements of 2.26.4.2, 2.26.4.3, and 2.26.4.4 shall not apply to electrical equipment unchanged by the alteration.

(o)(g) Emergency operation and signaling devices shall be provided

and shall conform to 2.27.

PROPOSAL - OPERATION CONTROL – Electric elevators

8.7.2.27.6 Change in Type of Operation Control. Rationale