Public comments for: Amendment of Rules regarding Elevator Work

Comments

Comment:
DOB should consider that any building that has a permit for the modernization of their elevators approved prior to the deadline to complete the Door Lock Monitoring should not receive a violation for not meeting the deadline. The building should be allowed to use the modernization to complete the door lock monitoring since they are already upgrading the safety of the elevators to an extent more than what the door lock monitoring requires. Due to the fact that to test door lock monitoring as it is installed requires the elevator to be placed on Fire Service, it places a burden on the building to place all the elevators on fire service in that particular elevator bank. Therefore most testing will be performed on overtime, the problem arises that the buildings can only do one elevator at a time and this will prolong the installation and testing of all the elevators. I request that the NYC DOB allows each elevator to be placed on Fire Service phase I individually from the machine room rather than having to initiate Fire Service from the lobby phase I key switch that places the whole bank of elevators on Fire Service and the resulting disturbance during normal business hours
Agency: DOB
Comment:
The requirement for Door lock monitoring is due by January 1, 2020. If this rule is passed it will lead to additional costs for building owners and since this new rule would be implemented during the middle of the year owner's have not budgeted for the extra costs associated with hiring a third party witness. This will lead to this work in many instances not being started until January of 2019 and leaves the majority of the elevators being tested in just one year. This may not be enough time to get all the work accomplished and I recommend that the due date be extended for one additional year, and due on January 1, 2021.
Agency: DOB