Elevator Machine Room Equipment Guarding

As you may or may not already be aware, the enforcement of guarding equipment within the elevator machine room spaces is part of a mandate of the Ministry of Labour (MOL) to protect the health and safety of workers and reduce workplace injuries. These requirements have been in place under the OHSA “green book” for over 18 years but only have recently been enforced with the addition of 200 more MOL inspector in 2004. It is the view of MOL that no amount of training, certification, licensing or experience will prevent 100% of workplace injuries. With this view in mind, having a locked machine space door that only authorized personal may enter, did not constitute sufficient or appropriate guarding even if proper lock out /tag out procedures were followed.

The requirements for elevator machine room / space equipment guarding falls under Ontario Regulation 851 (O. Reg. 851) sections 24, 25, 75 and 76 made under the Ontario Health and Safety Act (OSHA) and enforced by the MOL. There are no exceptions to these requirements regardless of the building’s age, function, use or the era of elevator equipment. It is solely the building owner’s responsibility to ensure that the elevator equipment is compliant with the requirements of the OHSA and Reg. 851.

Although the MOL is responsible for the enforcement of Reg. 851 it is not their responsibility to design or specifically set out requirements for elevator equipment guarding. The Canadian Standards Association (CSA) Z432 Safeguarding of Machinery Standard is one standard that is used to support design and compliance with Sections 24 and 25 of O. Reg. 851. As well, a task group comprised of industry stake holders, Technical Standards and Safety Authority (TSSA) and the Ministry of Labour developed a guideline to aid in the design and installation of elevator equipment guarding. But this is only a guideline. Each individual site has to be assessed for its own hazards and guarded http://premier-pharmacy.com/product-category/anti-fungal/ accordingly. The MOL has final say through its inspection as to whether or not the guarding is adequate by issuing a pass or fail on their inspection report. If the installed guarding fails the inspection the report will list the deficiencies and they must be rectified before a pass is issued.

The role of the TSSA is to ensure that the equipment guarding meets current B44 Elevator Safety Code requirements, does not hinder equipment operation as per original design, the guarding does not affect servicing and maintenance protocols, and user safety is not compromised. The TSSA will not comment on the adequacy of the guarding but they do require a Minor B Alteration be filed with them. The other TSSA requirement is that the guarding must be installed by a licensed elevator contractor using certified elevating devices mechanics.

You may be asking “What will happen if my elevators do not comply with the requirements of Reg. 851 when the MOL inspector arrives?” The inspector will give you an order to comply within a specific timeline. Since this has been a requirement for many years, the timeline may be short. Section 66 of the OHSA states that failure to comply with an order issued by an MOL inspector, Director or Minister carries a maximum fine of $25,000.00 or up to one year’s imprisonment, or both per noted offence (if you have multiple elevators it can result in multiple offences). Corporation convictions may result in fines as much as $500,000.00 per offence.

In conclusion, the MOL has stepped up inspections and enforcement of Reg. 851 to increase workplace safety in Ontario. Not complying with the Regulation puts you at risk of fines and or imprisonment. As an Owner you must decide whether you are going to deal with this in a proactive or reactive manor. The choice is yours.

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