Modifications to an existing design registration

Lift upgrade or replacement

Like most other types of moving mechanical machinery, lifts reach a stage where they begin to develop performance issues and maintenance costs can become high. This is usually when the lift has reached or exceeded its design life. The owner of the lift may need to make a decision whether to upgrade or replace the lift, escalator or moving walkway.

In some instances the owner may be able to resolve the performance issues by a service or repair. In other instances where the problem becomes more severe, greater works, such as a full or partial upgrade may be necessary.

The owner of the lift should always consult with a competent person before making any decision on an alteration or replacement. A competent person is best placed to give guidance on the most appropriate solution to restore performance. They also ensure compliance with WHS legislation, the current codes of practice, technical standards, the original manufacturers’ instructions, and conduct a risk assessment.

A competent person in this case, may be a consultant with engineering experience, employee of a lift company, or an individual with industry experience. Whoever is engaged, they must meet the definition of a competent person as defined within the WHS Regulations 2011 (QLD).

When assessing the condition of a lift consideration should be given to:

• the operational history of the lift, such as frequency of break downs, trapped passengers, stoppages from out-of-alignment relative to building floor level, door malfunctions, or any general performance deemed below manufacturer specification
• the service history, including any testing and repairs made in accordance with the manufacturer’s instructions
• the ride quality, such as any noisy, bumpy, or harsh movements or any unusual vibrations that have developed while the lift is moving or stationary
• the availability and cost of replacement parts
• an industry history of poor performance that could identify potential hazards or risks to users
• better performance measures or safeguards offered by newer technologies
• compliance to current technical standards, Codes of Practice and WHS legislation.

Registering an alteration to a lift design

When a lift is first design registered, the design is based on certain criteria and specifications which have been verified by the design verifier. In many cases this relates back to the version of the technical standard used for the design and the design verification. If a registered plant design is altered and the altered design may affect health and safety, the altered design must be registered. An application for the alteration of design should be made in the state that the unmodified plant has design registration with.

The lift must not be placed back into service until registration is granted.

Examples of where the level of health and safety may be altered include:

• increase or decrease in speed
• change to the number of suspension ropes
• changes to the traction method or type, or mounting structure and hardware
• changes to the load capacity
• changes to the size of the car
• increase or decrease in the travel height
• changes to electrical, control or mechanical configuration of the lift system.

Any alterations, including replacement parts, must be compliant to the latest requirements. Repair and maintenance using like-for-like replacement parts is not considered an alteration, even if those parts are manufactured by a different company.

Replacement parts

Motor replacement

If a motor has malfunctioned, requires replacement, and is replaced with a like for like motor then this constitutes a repair and not an alteration. No alteration to a design application is required. Like for like may include a motor with the same specifications from a different manufacturer. This may happen if an identical motor is not available due to age.

If however, the replacement motor increases the speed, loading capacity, or alters the level of safety from the original design, then notification of the alteration is required. In most cases other related parts of the lift system would similarly require alteration.

Wire rope replacement

This is generally considered a repair and not an alteration. No alteration to a design application is required.

If however, the number or size of the wire rope was altered (and therefore the level of safety is altered) an application for design alteration must be lodged with Workplace Health and Safety Queensland (WHSQ).

Lift controller replacement

In most cases it is considered likely that, a new controller will incorporate additional safety features which are monitored or controlled in a different manner to the old controller. This could include the addition of a variable frequency drive. In instances where safety features have changed, an application for design alteration must be submitted to WHSQ.

Each controller replacement must be assessed individually and on a case by case basis. In addition, most new controllers will involve some additional alteration to the lift system.

When replacing a controller, you should consider if:

• there is an increased risk to safety due to the mode of control being used
• the safety inputs and outputs to the new controller have changed
• there are additional control measures being utilised to monitor the speed, loading and operation of the lift such as tachos, encoders and variable frequency drives
• the speed, loading, travel or height have been altered
• the control of the safety circuit has changed.

If the safety functions of the new controller have inputs and outputs identical with the old controller, then no notification is required. Like for like may include a controller with the same specifications from a different manufacturer. To be considered a like-for-like controller there will need to be documentation, from the controller manufacturer, that confirms the new controller is a direct replacement of the superseded controller and no other control circuit changes are required.  Where this is the case no application for an altered design registration is required.

Cosmetic changes that do not affect health and safety

Notification back to the issuing regulator is not required where the alteration is considered cosmetic and the level of health and safety is not affected. These include changes to the:

• car interior
• car operating panel
• car lighting and landing fixtures.

This guidance material about Lifts was developed by SafeWork SA and has been adapted and adopted by WHSQ.