Elevator Safety and Licensing Technical Memoranda

Below is an excerpt of the current language from ASME A17.1-2007:

8.11.1.6 Periodic Test Tags. A metal tag with the applicable code requirement(s) and date(s) performed, and the name of the person of firm performing the test, shall be installed in the machine room or machine space for all periodic tests.

In accordance with state law, the Department has interpreted the referenced code requirement as follows:
Effective immediately, the Department will no longer require test tags to include the "applicable code requirement(s)". A metal tag with the name of the person or firm performing the test(s) AND the date the test(s) were performed will suffice. NOTE: There is no prohibition from continuing to use these metal tags - anyone with tags already including that information may continue to use those tags.

In addition, if a contractor wants to use a material other than metal for a test tag, the Department will consider alternative materials IF the contractor will provide the Department with a physical sample of the test tag they propose to use for our evaluation. If the Department determines that the proposed test tag is acceptable, written authorization will be provided allowing that contractor to utilize that material for their test tags.

Rationale:
Texas is somewhat unique in that every test required by code is witnessed by an inspector. The inspector is already responsible for verifying to the Department (on a report form) that all of the tests were performed and whether or not they were satisfactory.

State law 754.014(g)(2) recognizes the authority of the Executive Director to waive compliance from an applicable code requirement if the Executive Director finds that "noncompliance will not constitute a significant threat to passenger safety". As the authority having jurisdiction, the Department has determined that this will not constitute a threat to passenger safety.

Thanks to the Advisory Board members, inspectors, and contractors who provided us with input on these matters.

Lawrence Taylor
Chief Elevator Inspector
Building and Mechanical Section
Compliance Division - TDLR