The Real Estate Board of New York to The Department of Buildings on the Proposed Rules That Would Amend Certain Regulations Regarding Elevator Operations

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REBNY thanks the Department of Buildings (DOB) for the opportunity to comment on the proposed rules regarding elevator emergency operation and signaling devices, elevator capacity and loading and to add a new rule regarding maintenance and testing of electric elevators

The proposed rules would amend the regulations governing elevator operations to conform with ASME standard A17.1-2013 to address issues with load weighing devices on elevators as well as ensure the requirements are congruent with the updated 2022 Construction Code. REBNY appreciates updates to the safety standards surrounding building systems. It is imperative New Yorkers can live and work in the five boroughs knowing the built environment is safe. Moreover, it is important the City’s regulations conform with one another, which is why REBNY supports the proposed rules.

However, there are a few points in the draft rule that warrant some additional consideration or clarity from the DOB as it implements these changes. The draft rule would require an additional fire service periodic test to be completed during Category 5 testing. This would require building owners and managers to perform an additional fire service test during our Category 5 testing, which will require a 125% load and verification that the load-sensing device is bypassed up to this threshold. While REBNY understands this is meant to conform with the latest ASME standard, we would like to make the DOB aware that that this additional test during Category 5 testing will double the time it takes to test the fire service on each car. In some instances that would translate into an elevator bank being out of service for several hours, which could have significant impact on tenants. Owners and managers may opt instead for afterhours work to meet the proposed requirement. As the rule becomes effective, we ask the DOB to consider how these requirements will impact operations and work with the industry to help mitigate any disruption that compliance may cause.

In addition, we encourage the DOB to ensure that the weight of the individual performing the test be factored into the number of weights that are being added to the car. If the weight calculation is solely based on the actual test weights, this could lead to a severely overloaded car, which would compromise the safety of the individuals who are performing the test.

Finally, § 3610-05(a) states that all new and altered elevator devices must comply with the capacity and loading requirements outlined in the draft rule. We ask that the DOB clarify the definition of “altered elevator devices” to avoid ambiguity of which elevators would be subject to the requirements.

Thank you for the consideration of these points.