An Overview of the Elevators' Periodic Control Regulation
The Elevator Operation, Maintenance and Periodic Control Regulation was announced in the Official Gazette dated 24.06.2015 and numbered 29396, and the old Regulation dated 18.11.2008 and numbered 27058 was abolished. Elevator Operation, Maintenance and Periodic Control Regulation was changed due to some problems about its scope of authority, and a new study was carried out by the Ministry of Science, Industry and Technology, as it was named in those years, by taking EMO's legal reclamations. At the end of these studies, the Regulation issued in the Official Gazette dated 4 May 2018 and numbered 30411 was divided into two groups and the Operation and Maintenance section was kept original and announced as the Elevator Periodic Control Regulation.
Even before the change in the regulation, the State Council 10th Chamber Merit No: 2016/777 and Decision No: 201/4318 decided to cancel the whole scope of authority of the Elevator Operation, Maintenance and Periodic Control Regulation. The Ministry, ignoring this decision and waiting for the justified decision made unanimously on 26.10.2017, effectuated the Elevator Periodic Control Regulation dated 4 May 2018 and numbered 30411, which legalized the studies conducted mostly by A-Type inspection bodies, which are still objects at issue.
Preparing legal regulations and meeting all shareholders' satisfaction with these regulations are not that easy. Since our country is busy with administrative structuring nowadays, such studies are becoming much more difficult. Despite its several articles with which I disagree, the Regulation laboringly prepared by ASTEK, the commission on which I have a membership, and despite the studies conducted by EMO, MMO, Sector, A-Type Inspection Bodies, Associations, Elevator Federation and other organisations for the problematic articles, a consensus could not be reached. I guess this Regulation will be the most popular issue of the IX. Elevator Symposium, which will be held on 18-20 October 2018 in İzmir.
In this article, I put my EMO identity aside and examined the Regulation by expressing that they were all my own opinions beforehand. First of all, it is important to note that Elevator Operation, Maintenance and Periodic Control Regulation issued at the Official Gazette dated 24.06.2015 and numbered 29396 is not actually valid. A new Regulation should be announced regarding the reasons declared void within the shortest time. The articles and their justifications which I find problematic are as in the followings.
Elevator Periodic Control Regulation dated 4 May 2018 and numbered 30411;
ARTICLE 6 – (2) The application includes the following information and documents:
f) Occupational and financial responsibility insurance policy including elevator periodic control activities which cost at least 1,000,000 TL.
When the cost is regarded as extending to years rather than a numeric data, it may cause problems in the future. Forming a contact with the related authority is in line with the values of the contract's period.
Periodic control period and the responsibility to perform it
ARTICLE 8 – (1) The periodic control of the elevator frequently used in a building/structure is performed once a year by the person authorized by the Ministry and by the A-Type inspection body that signed a protocol with the related authority.
I think the control must be performed two times a year for the elevators marked with a green tag before. This would be appropriate for encouragement and minimizing the work load of A-Type inspection bodies.
Periodic control principles
ARTICLE 9 – (10) The first periodic control before the registration is performed within expected load and speed before the elevator is put into service and the inspection and tests departments mentioned in the related harmonized standard or the equivalent harmonized Turkish standard. Speed that is used at this stage is provided by the elevator installation company. It is sufficient to perform these tests by an Authorised body.
Identifying the cost of periodic controls.
ARTICLE 10 – (3) The cost of Periodic controls is equal to the price defined by the related administrative share of the related administrative decision-making body, excluding VAT.
I think paying this price is not appropriate, and it causes an extra load for our people. Estate tax rates under the name of environmental cleaning tax are already higher in buildings with elevators. Would it be fair to get an extra cost here?
Assessment of periodic control results
ARTICLE 11 – (6) It is prohibited to use the elevator identified as unsafe and marked with red info tag by the building manager. It is expected for the building manager to make the elevator safe again within a maximum 60 days. At the end of this period, the follow-up audit is performed by the A-Type inspection body. The elevator identified as still unsafe as a result of the follow-up audit is prohibited to be in service, and is shut down by cutting its power through main feed system. The procedure for shutting down follows the App-2 format in 3 pages prepared by the related authority and distributed to the A-Type inspection body and the building manager, one for each.
(8) It is expected for the building manager to eliminate the nonconformities of the yellow-tagged elevator within a maximum 120 days. At the end of this period, the follow-up audit is performed by the A-Type inspection body. The elevator identified as still unsafe as a result of the follow-up audit is prohibited to be in service and shut down by cutting its power through its main feed system.
I believe that the right given to the related authority to cut the power (Municipal or provincial private authorities) mentioned in both articles is not legal and is under the responsibility of the marketing company, so this may cause a legal problem.
Responsibilities of Authorized A-Type Inspection Bodies
ARTICLE 15 (3) technical manager is to be graduated from one of the engineering/technology faculties of mechanical or electrical/electronic or electronic and communication or mechatronics fields, have a minimum 3 year-field experience in inspection or/and industry, and full-time employment.
(4) Inspection personnel are to be graduated from one of the engineering/technology faculties of mechanical or electrical or electrical-electronic or electronic and communication or mechatronics fields. The prospective inspection personnel must complete a minimum 100 elevator periodic control activities.
Technical Managers and Inspection Personnel must be authorized by related Chambers; the Chamber of Electrical Engineering (EMO) and the Chamber of Mechanical Engineering (MMO), because it is time for chambers to decide the suitable branches from different departments of universities for holding elevator activities. For instance, people who graduate from new engineering fields like Control and Automation Engineering, Power Engineering, Energy Systems Engineering, Software Engineering and Production Engineering must find a chance to work in this sector.
Principles regarding the Application
ARTICLE 16 – (1) periodic control of elevators frequently used in a building/structure is performed a minimum of once a year by an A-type inspection body.
(Biyearly for elevators marked with green tags)
(12) An A-type inspection body considers national construction regulations while performing periodic elevator controls.
Why are Municipality duties given to A-type inspection bodies? Wasn’t it necessary for structure inspection to control the Conformities with construction regulations before?
The number of controls
ARTICLE 18 – (1) Inspection personnel perform a maximum of five elevator periodic controls on a full day.
Isn’t it important here to focus on the number of stops? The buildings with more than 20 stops are increasing. This number must be revised for elevators with more than 10 stops, and 4- and more-story buildings.
(2) Inspection personnel perform a maximum 10 follow-up audits on a full day.
Buildings with more than 20 stops are increasing. This number must be revised for elevators with more than 10 stops and 8- and more-story buildings.
(3) Inspection Personnel perform a maximum two times more follow-up audits than the number of daily periodic controls he/she could not complete through the number mentioned in the first paragraph.
(4) Inspection Personnel perform their first periodic control before a maximum two elevator registrations on a full day. The said personnel cannot perform additional periodic control or follow-up audits. However, on a single work day, he can perform his first periodic control before a maximum three elevator registrations when the said elevators are all in the same district.
This number should be arranged as having competence of carrying out the periodic control of one elevator before registration for elevators with more than 20 stops.
ARTICLE 20 (7) The report is sent by A-Type inspection body to the related party via mail, e-mail, by hand or text message over its own website. All data is documented and kept for two years at least, to be proved by the Ministry.
(During the life cycle of elevator)
Receiving the cost of periodic control
ARTICLE 23 – (2) the cost of the first Periodic control is received by the A-Type inspection body three times more than the cost of periodic control before registration, including VAT.
After receiving the report of the approved institution, the periodic control cost of a maximum 10-story building can be two times more, while the cost of periodic controls in more-than-10-story building can be three times more.
(3) A minimum 10% of the price determined by the related authority between the highest and lowest price range mentioned in the App-1 is transferred by the A-Type inspection body to the related authority with which the protocol is signed, in case of the related authority demands or mentions in the protocol.
I believe that receiving this cost (a min 10% of periodic control cost) is not appropriate, and causes an extra cost for people.
ARTICLE 32 – (1) The A-Type inspection body defines the number of elevator addresses by scanning within the limits of the related authority with which it signs the protocol, and shares the data with the related authority.
(Other data received from institutions like the related Industrial Provincial Directorates, etc., in addition to the scanning A-type inspection bodies, is shared with A-type inspection bodies.)
ARTICLE 33 – (1) Tests that may be carried out by A-Type inspection bodies throughout periodic control stages may cause tensions to decrease elevator safety or excessive wear caused by repetitions.
(2) tests on elevator safety equipment and buffer are carried out within the related standard,s and while the carrier is empty and at lowest speed, by A-Type inspection bodies.
(3) first periodic control before registration is carried out at predicted load and speed in inspection and tests section by A-type inspection bodies only once before putting the elevator mentioned within the related harmonized standard or equivalent harmonized Turkish standard into service. However, within the scope of Elevator Regulation (2014/33/EU), if the last control of the elevator at issue is performed by the institution approved by one of the conformity assessment methods like unit verification or final inspection, first periodic control is carried out without load and at lowest speed before registration.
It is adequate to carry out these tests by approved institution. However; these tests should be carried out when any doubt is identified.