Used Solid-State Controller and an Outstanding TSSA Order
A mechanic employed by a TSSA-licensed elevating devices contractor is sent to a 1968 six-storey apartment building with a hydraulic passenger elevator rated 2,000 lb at 100 fpm. The building's handyman has already replaced the original relay controller with a used solid-state controller taken from another building, changed the motor starter, and reconnected the leveling circuit. The car now runs, but it stops about 30 mm above or below floor level, and the original door operator and car door reopening device remain. The pit ladder is loose at its top support. A TSSA inspector has issued an order to comply, and the owner asks the mechanic to sign the maintenance record for the month, keep the elevator running through the holiday weekend, and 'fix the little things later.' The contractor's office says the controller swap was just a repair. The mechanic must decide what to do before touching the car.
1. Is the controller replacement an alteration or routine maintenance under Ontario's elevating devices regime, and what must happen before the car carries passengers again? Explain your reasoning.
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Start with the definition, not with the label the office used. Maintenance restores a device to its original design condition; an alteration changes the design, operating characteristics, or type of a component. Replacing a relay controller with a used solid-state controller of a different type, and changing the motor starter, changes the control system and the car's operating characteristics. It is therefore an alteration, not a repair. Under the Technical Standards and Safety Act, 2000 and O. Reg. 209/01, alteration work must be done by a licensed elevating devices contractor using certified mechanics, with the required notice or approval to TSSA and inspection before the device is placed back in service. A used controller also needs documentation of suitability and approval for the application. Because a TSSA order to comply is outstanding, operation before clearance is both a code violation and an offence risk. The 30 mm leveling error is not a 'little thing': passenger elevator leveling is normally required within about plus or minus 13 mm (1/2 in), and the door reopening device and door operator must be verified after the control change. The car should remain out of service until the alteration is accepted and inspected.
2. How should the mechanic respond to the owner's request to sign the record and keep the car running? Identify the specific risks and the correct escalation.
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Refuse. A maintenance record is a statement that specified work was done; signing for work not performed is falsification, not a paperwork shortcut. It misleads the owner and TSSA, destroys the maintenance history the next mechanic relies on, and creates personal liability if a door or leveling fault injures someone. Under the TSSA Act, false statements and operation contrary to an order can lead to offences, and a mechanic's certificate can be suspended or revoked; the contractor's licence is also at risk. The correct response is to tell the supervisor and owner in writing that the car is under an order and cannot be signed off or operated, describe the deficiencies, and recommend a compliance path: approved alteration, inspection, then routine maintenance. If the owner insists, the mechanic should escalate to the contractor's responsible person and contact the TSSA inspector named on the order. 'Keep it running until after the holidays' is precisely the pressure the regulation is designed to resist.
3. Identify the additional code-related deficiencies visible in the setup and explain how each should be handled and documented.
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Beyond the controller: (1) Loose pit ladder - secure it and verify it meets access requirements (secure top and bottom, handrails, non-slip rungs); a loose ladder is a fall hazard during pit work. (2) Leveling - 30 mm is outside normal passenger tolerance; recalibrate and test at all floors, including with load. (3) Door operator and reopening device - with a new controller the door timing and reversing may have changed; test the reopening device and closing force. (4) Controller enclosure - used equipment must be suitable for the location, guarded, labelled, and properly grounded. (5) Wiring and identification - verify terminals, fuses, and disconnecting means; the alteration must be documented with as-built drawings. Document with photos, measurements, and a written deficiency list, give copies to the owner and contractor, and keep them in the maintenance record. Do not rely on verbal promises.