LTC 200-2008 Enforcement of the Florida Elevator Safety Code (Abbott by the Sea Inquiry)
m MIAMIBEACH
OFFICE OF THE CITY MANAGER
NO. LTC # 200-2008
To: Mayor Matti H. Bower and Members of the City
FROM: Jorge M. Gonzalez, City Manager
DATE: August 5, 2008
SUBJECT: Enforcement of the Florida Elevator Safety
2008 AUG -6 AM II~ OZ
CITE' c~~~~:t's oF~ i~;i
R TO COMMISSION
mission
(Abbott by the Sea Inquiry)
This Letter to Commission is in response to recent inquiries regarding the City's
enforcement of the Florida Elevator Safety Code and to I, clarify the City's legal obligation
to the State of Florida in enforcing this code. This iss~e was originally brought to the
City's attention by the Abbot by the Sea Condomini m Association, which has an
elevator that needs to be brought into compliance. !,
In accordance with the Florida Building Code §3001.' elevator safety in the state is
based on standards by the American Society of Mech nical Engineers (ASME) A 17.1
(2000) and A 17.3 (1996) Codes. ASME A 17.1 sets a evator safety standards for new
buildings. Specifically, it requires that a permit applic nt submit a signed Affidavit of
Elevator Code Compliance with each application to att st that the work performed will
meet or exceed the current elevator safety standards. ASME A 17.3 standards apply to
the elevators which already operate in existing buildings.
Enforcement of the ASME A 17.1 and ASME A 17.3 standards is preempted to the
Bureau of Elevator Safety (henceforth the Bureau) of the Department of Business and
Professional Regulation by Florida Building Code §3001.1. In accordance with Florida
Statutes §399.061 and §399.13 municipalities are delegated the authority of enforcing
the Florida Elevator Safety Code by the state through the Bureau which enters into
contracts with municipalities. It should be noted that municipalities are delegated the
administrative authority which requires a municipality's interpretation of the Florida
Elevator Safety Code to be in accordance with that of the Bureau. The City of Miami
Beach has a contract with the Bureau and enforces the Elevator Safety Code on behalf
of the Bureau.
The Bureau issues Industry Bulletins where it interprets parts of the Florida Elevator
Safety Code. Over the last two years, the Bureau issued several bulletins clarifying the
meaning of the ASME A 17.1 and ASME A 17.3 standards. In the Industry Bulletin #
2006-01, the Bureau clarified its interpretation of Florida Statutes §399.03 (7) which
states that elevators "shall comply with the edition of the Florida Building Code or
Elevator Safety Code that was in effect at the time of the receipt for application for
construction permit for elevator" (attached). Although this section may have been
interpreted by some as allowing an overall exemption from compliance with the current
code requirements, the Industry Bulletin # 2006-01 states that "when a new edition of the
Florida Building Code requires retrofitting older elevators because aging equipment may
pose a threat to public safety, §399.03 (7) does not provide an exemption from that
requirement". Furthermore, the Bureau has "to follow the intent of Florida Statutes
§399.061 (3), which requires that, in the interest of public safety, the older and
potentially hazardous elevator be brought into compliance with the newer code". To
LTC #
Advise the Commission on enforcement of the Florida Elevator Safety Code
Page 2
ensure compliance the Bureau is mandated to "seal the elevator or order discontinued
use until the elevator has been satisfactorily repaired or replaced so that it may be
operated in a safe manner".
In Industry Bulletin # 2008-03 (attached), the Bureau clarified on the enforcement of the
ASME 17.1 and A 17.3 in response to owner and association inquiries:
"A 17.1-2000...A17.3-1996... provide a minimum standard for public safety.
These are the codes currently in effect and they will be enforced. In fact, the
more stringent of the codes in effect apply, unless specifically stated or
otherwise adopted by the Bureau of Elevator Safety, which is the Authority
Having Jurisdiction (AHJ). There are no exceptions. The elevator safety
code is not subject to individual interpretation. The codes collectively apply to
all elevators..."
This passage from the Industry Bulletin # 2008-03 indicates that municipalities are
bound to the interpretation by the Bureau and do not have the legal authority to deviate
from the state mandate. It also states that the enforcement of the ASME 17.1 and ASME
17.3 standards is mandatory and does not allow exceptions.
Although compliance with the ASME A 17.1 and ASME A 17.3 standards is required by
law, in the Industry Bulletin # 2006-04 (attached) and #2008-03 the Bureau
acknowledges that the considerable cost and time required to comply with certain
violations may prohibit some elevator owners from complying within the thirty (30) days
allowed by statute. For this reason, the Bureau allows elevator owners to submit a letter
of intent to comply within thirty (30) days of a notice of a violation followed by a submittal
of a Plan of Corrective Action- (PCA) within sixty (60) days of the date of the violation
notice. A PCA must be approved by the Bureau, or by the local jurisdiction if applicable,
or it will not be considered compliant with the statutory requirement. Thus through
bulletins, the Bureau has made it clear that, although property owners may be granted
an extension for complying with the elevator safety standards, complying with the ASME
A 17.1 and ASME A 17.3 codes is mandatory.
The City's enforcement of the Florida Elevator Safety Code has recently raised
questions from property owners. On May 29, 2008 the City received a complaint from
the Abbott by the Sea Condominium Association challenging the issued violation for not
meeting the ASME A 17.3 standard. An elevator safety inspector issued the property
owner a violation during the annual inspection process because the elevator does not
meet the required elevator recall standard. The standard requires that the elevator return
to the ground floor in the case of fire emergency and that the door open. This
requirement permits arriving firefighters to ensure by visual inspection, that no one is
trapped in the elevator, as well as to facilitate access to upper floors of high rise
buildings.
The attorney of the Abbott by the Sea Condominium Association challenged the violation
citing F.S. §399.03 (7) which states that elevators "shall comply with the edition of the
Florida Building Code or Elevator Safety Code that was in effect at the time of the receipt
for application for the construction permit for elevator". He argued that inasmuch as the
elevator was put in service in 1981, it should be required to comply not with the ASME A
17.3 (which was adopted in 1996), but with a pertinent regulation prior to 1981.
LTC #
Advise the Commission on enforcement of the Florida Elevator Safety Code
Page 3
After considering the complaint by the attorney of the Abbott by the Sea Condominium
Association, the City Attorney's Office, in conjunction with the Miami Beach Chief
Elevator Inspector, who is the regulatory Authority Having Jurisdiction, concluded that
when issuing the violation to the Association, the City's interpretation of the Florida
Elevator Safety Code was in agreement with that of the state. The City Attorney's Office
notified the attorney of the Abbott by the Sea Condominium Association that, although
the association could not be exempted from the requirement to comply with the elevator
safety requirements envisioned in ASME A 17.3, it could be granted an extension for
corrective action contingent upon the approval by the Elevator Safety Section within the
Building Department. The Abbott by the Sea Condominium Association has
subsequently requested a PCA which is currently being considered by the City's
Elevator Safety Section. The correspondence on this exchange is also attached.
The elevators in City Hall are compliant with the Florida Elevator Safety Code. The two
"glass" elevators in the front lobby meet the recall standard and are fully compliant with
the ASME A 17.3 requirements. The cargo elevator and the elevator for staff (located by
the Public Works and City Manager's Office) are under an active PCA and are
scheduled to be fully compliant within the next two years. The Building Department
treats the City's properties consistent with private sector properties.
As always, please let me know if there is any additional information that staff and I can
provide.
JMG/'FW/VJ
Attachments
C: Jose Smith, City Attorney
Jorge Gomez, Planning Director
Richard McConachie, Building Official
Grace Escalante, Assistant Building Director
John Antona, Chief Elevator Inspector
1,
'~ {NE -
,~ ~ a INDUSTRY BULLETIN s ~~~
u ~ for Florida's Elevator Industry ~,,~ ~-~~~`
SUBJECT: Elevator Inspection Standards Number: 2006-01 Date: 2006/04/01
This bulletin is provided to aid in compliance with Florida law, and is not intended as legal advice. While care has been
taken to ensure its accuracy, in the event of any conflict the actual statute or administrative rule will control.
NEW BUILDING CODE ADOPTED
The Department of Community Affairs Florida Building Commission has adopted the American Society of
Mechanical Engineers (ASME) A17.1 (2000) Code, replacing the 1996 edition. Effective October 1, 2005, all new
conveyances must meet ASME A17:1 (2000) standards. A signed Affidavit of Elevator Code Compliance must be
submitted with each permit application to attest that the work performed will meet or exceed the current code as
adopted in Chapter 30 of the Florida Building Code. Beginning October 1, 2005, elevator owners, certified elevator
inspectors, and all other regulated elevator professionals are expected to ensure conveyances comply with the
currently adopted code. This expectation includes citing violations during inspections and correction by owners of
the cited violations.
This newly adopted code contains safety provisions for single wall hydraulic cylinders. The ASME considered these
provisions so important to life safety that corrective action is required in all existing single wall hydraulic cylinder
elevators. This issue will be discussed further in future bulletins.
STATUTORY REQUIREMENTS FOR RETROFITTING AND CODE COMPLIANCE
Florida Statutes are in agreement with ASME A17.1 (2000) and A17.3 (1996) regarding life safety issues. In
section 399.001, Florida Statutes (F.S.), the Florida Legislature stated the purpose of Chapter 399, the Elevator
Safety Act," is to provide for the safety of life and limb and to promote public safety awareness". Considerable
debate has centered on Section 399.03(7), F.S., which states that elevators "shall comply with the edition of the
Florida Building Code or Elevator Safety Code that was in effect at the time of the receipt for application for the
construction permit for the elevator". This section may have been interpreted as allowing an overall exemption from
compliance with current code requirements.
However, when a new edition of the Florida Building Code requires retrofitting older elevators because aging
equipment may pose a threat to public safety, section 399.03(7), F.S., does not provide an exemption from that
requirement. Instead, the Division is compelled to follow the intent and letter of section 399.061(3), F.S., which
requires that, in the interest of public safety, the older and potentially hazardous elevator be brought into
compliance with the newer code and the Division may seal the elevator or order discontinued use until the elevator
has been satisfactorily repaired or replaced so that it may be operated in a safe manner.
Because public safety is the paramount basis for the Department's legislatively delegated regulatory power, the
Division cannot interpret section 399.03(7), F.S., to provide an elevator owner with an exemption from any new
code provision essential to the safe operation of the elevator.
INSPECTION REQUIRED AS PROOF OF CORRECTION OF VIOLATIONS
Effective July 1, 2005, the Department no longer accepts letters from owners attesting to correction of previous
violations. Proof of compliance for correction of violations is evidenced through a completed inspection report
showing no outstanding violations.
TWO-LANDING ELEVATOR INSPECTION REQUIREMENTS
Two-landing elevators with an active service maintenance contract, as defined by section 399.01(10), F.S., and
pursuant to that section and/or ASME A17.1(2000) do not require inspections, as long as the service maintenance
contract remains in-force and prescribed tests and maintenance are performed.
Extensive information regarding inspections, licensing and a number of forms is available on our website at
www.MyFlorida.com/dbpr or by calling 850.487.1395.
FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION
Jeb Bush, Governor Division of Hotels and Restaurants Simone Marstiller, Secretary
www.MyFlorida.com/dbpr www.hospitalityeducation.oro
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Very truly
Michael J. Oliver
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