NYC Retroactive Code Items: Door Lock Monitoring

March 12, 2019

NYC has two retroactive requirements for all existing elevators: door lock monitoring by January 1, 2020, and single-plunger brakes by January 1, 2027. This document will provide information and guidance on the door lock monitoring requirement.

DOOR LOCK MONITORING CODE REQUIREMENT

The text of the requirement is in Appendix K3, Rule 3.10.12. In summary, the position of car doors must be monitored to prevent the following two issues:

• To prevent operation of the car if the car door is not closed, regardless of whether the car-door contact and interlock contact circuits are open or closed (excluding access switch operation and inspection operation).

• To prevent power closing of the doors if the door is open and the car door contact circuit is closed or bypassed, or if the interlock circuit is closed (excluding during Firefighters’ Service Phase II). Primarily, this determines if jumpers or other means of bypassing normal door operation are being used.

CODE HISTORY

1. The requirement was first introduced in ASME A17.1-1996. Therefore, most major equipment manufacturers would have started including this capability in their equipment around 1996-1997. However, NYC excluded this requirement in RS-18 when it adopted the 1996 code in 2003, so this was not required in new installations or modernizations in NYC at that time.

2. Upon adoption of the 2008 NYC Construction Code, NYC no longer excluded the relevant rule from the ASME code, making it a requirement on all new installations and controller modernizations in NYC. This code went into effect July 1, 2008, but was optional until permits filed after July 1, 2009.
   The 2008 Construction Code did not include an exception from A17.1-1996 rule 2.26.5(b)(2) for Firefighters’ Service Phase II operation, although NYC made it informally known that this was what they wanted. Some manufacturers were aware of this and incorporated this exception into the equipment installed in NYC at that time. All units installed after July 1, 2009 will need to be verified as to whether or not the Firefighter’s Service Phase II exception was implemented.

3. The 2014 NYC Construction Code included the same door lock monitoring requirement with the Firefighter’s Service Phase II exception noted in item 2 above. All units installed or having controller modifications after January 1, 2015 should be fully compliant with the requirement.

4. As of January 1, 2020, all existing elevators in NYC with automatic coupled doors, including those opposite a manual swing panel, must comply with the requirement.

CLIENT GUIDANCE

1. To address each existing elevator the owner/building manager should consider the following rough guidelines for the likely condition of the existing equipment related to this requirement. However, it ultimately needs to be verified in all cases by the elevator contractor that the equipment complies; just because it was required by code when the equipment was installed doesn’t mean it is operating at this time.

   1. Installed or modernized before July 1, 2009: will likely need a software update and possibly a hardware update.

   2. Controllers installed or modernized after July 1, 2009: may be compliant. This needs to be confirmed by the contractor, especially the Firefighter’s Service Phase II exception which may need a software update.

   3. Installed or modernized after January 1, 2015: should be fully compliant, but this should be confirmed by the contractor.

   4. Also note that modernization of controllers and door equipment going forward would be compliant, so this is a viable method of achieving compliance if it will be completed by January 1, 2020.

2. We are prepared to assist clients by evaluating the material and labor costs associated with contractor proposals. We can also work with controller manufacturers to determine what requirements are currently being met in units installed or modernized after July 1, 2009.

3. We can witness testing by the contractor that the completed work meets the code requirements and will incorporate witnessing of door monitoring testing into CAT1 testing, once the DOB makes this a code-mandated requirement.