Machine room guarding is a complicated an often misunderstood topic. There are multiple pieces of overlapping and seemingly conflicting pieces of legislation regarding elevator machine room guarding. The enforcement and interpretation of this legislation also falls under different jurisdictions. Machine room guarding is intended to protect the workers, who do work in the elevator machine rooms, from the hazards which can exist there.
Historically, the elevator machine room door was considered the guard for the elevator machine room equipment. Only authorized (and therefore trained) personnel are permitted in elevator machine rooms. Others, who need to work in elevator machine rooms, needed to do their work under the supervision of a trained elevator mechanic. Trained elevator professionals such as elevator mechanics and elevator inspectors have always been well aware of the many hazards in elevator machine rooms. The elevator industry has developed many best work practices to minimize and mitigate the risks to the workers in the machine rooms. In recent years, the Ontario Ministry of Labour (MOL) has started focusing on certain types of industries which had higher than average worker injuries. One of the first industries targeted in this way around 2004, was the Hotel industry. The elevator machine rooms in these facilities got caught up in a heightened application of “the green book” (MOL’s Occupational Health and Safety Act). The main legislation for this equipment guarding comes from Sections 24, 25, 75 and 76 of the Regulations for Industrial Establishments, Ontario Regulation 851 (O. Reg. 851) made under the OHSA.
There is a wealth of good information on elevator machine room guarding. I have reviewed quite a number of articles and provided links and a brief description of many of the better ones below. Instead of rewriting much of this excellent information, I am providing a number of points and highlights to help provide a better understanding of the topic of elevator machine room guarding. The various articles can help fill in many of the gaps.
- The MOL guarding requirements have been in place for almost 20 years, so there is often no grace period for a building owner to achieve compliance.
- No one can provide a machine room guarding solution which is guaranteed to be in compliance. The MOL will not pre-approve any design. Even after a guarding system is installed, the MOL inspector may deem a guarding order to be in compliance, but then at a subsequent MOL inspection, the exact same guarding system could be written up as non-compliant.
- Machine room guarding adds time and complexity (and ultimately cost) to the performance of elevator maintenance and trouble shooting.
- The MOL is the highest authority with respect to the need for having machine room guarding. The MOL’s guarding requirements are more stringent than those in the building code and those in the Elevator Safety Code.
- TSSA will not write directions requiring the installation of machine room guarding. The MOL writes the directions to install guarding and then later inspects the guarding to ensure conformance to the “green book”. TSSA will only ensure that the installation is done with licensed elevator personnel and that it does not adversely affect the safety of the elevator. This safety conformance is achieved by requiring that a professional engineer submit the appropriate “Minor A Alteration” documentation to TSSA. A TSSA inspector will then visit the elevator to verify that the installation conforms to the engineer’s design. The TSSA inspector also checks that the guarding does not infringe on any required clearances around the elevator equipment.
- The machine rooms for hydraulic elevators and handicapped lifts typically do not need guarding. Guarding is primarily required for traction elevators.
Links to more detailed information
Skyline Guarding Article – A short article with good information from a quality elevator contractor from London Ontario.
Working Safely with Elevators – An excellent article from another quality elevator contractor from Kitchener Ontario with a good section discussing the safety trade-offs in installing guarding in machine rooms.