May 23, 2018

Elizabeth O. Rafferty

VA Board of Housing and Community Development

RE: Proposed Virginia Uniform Statewide Building Code, 13V AC5-51, 13VAC5-63

Dear Ms. Rafferty: 

The National Elevator Industry Inc. (NEII) appreciates the opportunity to provide comments regarding the proposed revisions to the Virginia Uniform Statewide Building Code.  Safety is a top priority for NEII and its member companies.  NEII members are actively involved in the development of all of the model codes that impact the building transportation industry.  The most effective way of ensuring the safety of the riding public, as well as elevator personnel, is by the adoption of the latest version of these model codes without deviation.  NEII supports the proposal to update the Virginia building code based on the 2015 IBC; however, we have concerns with some of the proposed amendments and possible correlation issues with the requirements in ASME A17.1/CSA B44 Safety Code for Elevators and Escalators which is referenced by the IBC. 

Specifically, the proposed addition of Section 3005.7, Items 1 and 3, address requirements that are already covered by ASME A17.1/CSA B44, NFPA 13 and NFPA 72.  The proposed requirements are not necessary since they are already addressed by the other model codes and adding them here would create a conflict with those codes.  We strongly recommend that this section be deleted from the proposal. 

Thank you for the opportunity to provide the elevator industry’s comments. NEII is committed to public and elevator personnel safety and is ready to support you in this process.  Representatives from NEII and our member companies operating in Virginia are available to discuss specific questions regarding these comments and provide additional technical input as needed. Please let us know if you would like to meet for a more in-depth dialogue.

For additional information, please contact:

Kevin L. Brinkman, PE

NEII VP, Codes & Safety

Eureka, IL 61530

Tel: 309-467-2379

Amy Blankenbiller

NEII VP, Government Affairs

Topeka, KS  66610

Tel:  785-286-7599

NEII  is the premier national trade association representing the interest of firms that install, maintain and/or manufacture elevators, escalators, moving walks and other building transportation products. The NEII  headquarters is located in Centreville, VA and our membership includes the top elevator companies in the United States, if not the world, and reports more than eighty percent of the work hours for the industry. Member companies include: Otis Elevator Company, Schindler Elevator Corp., ThyssenKrupp Elevator Corporation, KONE, Inc., and many other companies.  Safety for the riding public and industry personnel is a top priority for the industry and the NEII® member companies.

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