Section 8.6 Explained: The Most Important Part of Pennsylvania’s New Elevator Code for Building Owners
As Pennsylvania transitions from the ASME A17.1-2000 Code with the 2002 Addenda to ASME A17.1-2016, many building owners are asking:
“How does this actually affect my building?”
The answer is surprisingly simple.
While much of the 2016 Code focuses on new installations, new technology, and modernization projects, Section 8.6 is different.
Section 8.6 governs Maintenance, Repair, Replacement, Testing, and Documentation for existing equipment.
In other words…
It affects virtually every elevator, escalator, dumbwaiter, material lift, wheelchair lift, and other regulated lifting device that remains in service.
If you own vertical transportation equipment in Pennsylvania, this is the section of the new code you should understand first.
Section 8.6 Changes the Philosophy of Elevator Ownership
Under Pennsylvania’s previous code environment, many owners viewed elevator compliance like this:
- Hire a maintenance company.
- Schedule the annual inspection.
- Fix violations if they occur.
- Repeat next year.
Section 8.6 changes that mindset.
Instead of focusing only on inspections, the Code emphasizes an ongoing program of:
- Preventive maintenance
- Scheduled testing
- Equipment documentation
- Recordkeeping
- Continuous compliance
The goal is not simply to pass inspection.
The goal is to demonstrate that the equipment is being properly maintained throughout the entire year.
The Biggest Change: Annual Category 1 Testing
Without question, the most significant operational change for most Pennsylvania building owners is the implementation of annual Category 1 (CAT1) testing and reporting for regulated lifting devices. Pennsylvania’s proposed and final rule-making specifically identifies annual Category 1 testing as a new recurring compliance obligation for existing equipment.
Many owners mistakenly believe this is simply another inspection.
It isn’t.
Category 1 testing is a prescribed annual test of critical safety systems that must be documented on approved forms.
Depending on the equipment, testing may include:
- Brakes
- Governors
- Car Safety
- Pressure Testing
- Door protective devices
- Door locking systems
- Firefighters’ Emergency Operation
- Emergency communications
- Electrical protective devices
- Other code-required safety functions
The testing is designed to verify that these systems actually perform as intended—not merely that the elevator runs.
Category 1 Testing Applies to More Than Passenger Elevators
Another common misconception is that these requirements affect only passenger elevators.
Pennsylvania’s regulations apply to a broad range of lifting devices.
Depending on your building, this may include:
- Passenger elevators
- Freight elevators
- Escalators
- Moving walks
- Dumbwaiters
- Material lifts
- Platform lifts
- Other regulated conveyances
Many owners don’t realize how much equipment they are responsible for until they inventory their buildings.
The Maintenance Control Program (MCP): The Foundation of Section 8.6
If Category 1 testing is the most visible change…
The Maintenance Control Program (MCP) may be the most important long-term change.
Section 8.6 requires each unit to have a written Maintenance Control Program that establishes the examinations, tests, cleaning, lubrication, adjustments, and maintenance intervals necessary to keep that specific unit in compliance. The MCP must be available to elevator personnel, and maintenance activities are expected to follow it.
Think of the MCP as:
The maintenance roadmap for your elevator.
It is no longer sufficient to simply perform maintenance.
Maintenance should be performed according to a documented program.
Documentation Is No Longer Optional
One of the biggest shifts in Section 8.6 is the emphasis on documentation.
Owners should maintain organized records of:
- Maintenance activities
- Repairs
- Component replacements
- Category 1 testing
- Category 5 testing
- Inspection reports
- Maintenance Control Program revisions
These records serve several purposes.
They demonstrate compliance.
They help identify recurring problems.
They support insurance claims.
They provide valuable evidence if litigation ever occurs.
Good documentation is no longer just good business practice.
It is part of code compliance.
Maintenance Becomes Measurable
Perhaps the most significant philosophical change is this:
Instead of asking,
“Did someone come to the building this month?”
Owners should begin asking,
“What maintenance was actually performed?”
Section 8.6 shifts the discussion from technician visits to documented maintenance activities.
That benefits everyone.
Owners gain greater transparency.
Contractors have clearer expectations.
Inspectors have better documentation.
Most importantly, elevators receive more consistent maintenance.
Building Owners Have Greater Responsibility Than They Realize
Many owners believe compliance is entirely the responsibility of their elevator contractor.
It isn’t.
The maintenance contractor performs the work.
The inspector verifies compliance.
But the building owner remains responsible for ensuring the equipment complies with Pennsylvania’s requirements and that required maintenance, testing, and documentation are completed.
That’s why understanding Section 8.6 is so important.
What Building Owners Should Do Right Now
You don’t need to become an elevator expert.
But you should begin asking better questions.
Ask Your Elevator Contractor:
- Do all of our elevators have a current Maintenance Control Program?
- Is the MCP specific to each unit?
- Is Category 1 testing included in our maintenance agreement?
- Who schedules the testing?
- Who completes the required reports?
- Who submits the reports when required?
- Where are our maintenance records maintained?
- Are we prepared for the next inspection cycle?
If you don’t know the answers, now is the time to find out.
Turn Compliance Into Asset Management
Here’s where I think owners have the biggest opportunity.
Don’t think of Section 8.6 as another regulation.
Think of it as a management tool.
Annual testing and consistent documentation create a history.
That history allows owners to:
- Identify recurring failures.
- Measure reliability.
- Plan modernization.
- Improve budgeting.
- Reduce emergency repairs.
- Protect property value.
That’s a significant step forward from simply reacting when an elevator breaks down.
How an Independent Elevator Consultant Can Help
An independent consultant can help owners:
- Review Maintenance Control Programs.
- Audit maintenance records.
- Verify Category 1 testing compliance.
- Develop annual compliance calendars.
- Evaluate recurring deficiencies.
- Prioritize repairs.
- Plan modernization before emergencies occur.
The objective isn’t simply to pass an inspection.
It’s to build a long-term strategy for safe, reliable, and cost-effective elevator ownership.
The Bottom Line
Pennsylvania’s adoption of ASME A17.1-2016 is about more than updating an elevator code.
Section 8.6 fundamentally changes how existing elevators should be maintained, tested, documented, and managed.
The owners who benefit the most won’t be those who simply comply.
They’ll be the owners who use these new requirements to better understand their equipment, reduce long-term costs, and make smarter decisions about one of their building’s most valuable assets.
Need Help Preparing for Pennsylvania’s New Elevator Code?
KDA Elevator Consultants helps building owners, property managers, healthcare facilities, schools, HOAs, and commercial real estate owners understand Pennsylvania’s evolving elevator requirements through independent inspections, compliance audits, Maintenance Control Program reviews, Category 1 testing oversight, and long-term capital planning.
📞 484-995-3642
📧 john@kdaelevatorconsultants.com