ISO 8100 vs. A17.1: What’s at Stake for Elevator Codes in North America?

If implemented, ISO 8100 elevator code could have a major impact on the future of elevator standards and regulation in North America. But what exactly is being proposed, and what could it mean? In this livestream, I’ll be meeting with Don Gelestino, John Koshak, and David Guerin. We’ll be discussing ISO 8100 and A17.1, the differences between the two standards and the questions surrounding this potential change. We’ll discuss what could be at stake for elevator safety, manufacturers and companies, and other stakeholders, as well as concerns around maintenance, inspection, proprietary equipment, documentation, capacity and accountability. We’ll also look at whether changing the standards would actually address safety challenges and discuss alternative approaches to these issues. This discussion is intended to explore concerns surrounding elevator codes and what elevator professionals & companies, regulators, and building owners should know as the conversation develops. 

Article written by David Guerin & John Koshak about this proposed code change, published in Elevator World Magazine: https://elevatorworld.com/article/the-case-for-a-federal-elevator-safety-floor/ 

Transcript:

Matt Allred (00:00)
Hello, and we are live. Welcome to the Elevator Careers Podcast. Hopefully everyone’s hearing us. I’m Matt Alred, your host, and today we have three guests, Don Gelestino, John Koshak, and David Guerin. Gentlemen, welcome to the show.

Donald A Gelestino (00:18)
Thank you.

David Guerin (00:18)
Thank you.

John Koshak (00:18)
Thanks.

Matt Allred (00:20)
Yeah.

Yeah, I’m excited to to have this conversation. And you know, we’re we’re discussing a very interesting and unique topic. And honestly, I’ve only become aware of it in last few months. I know that John and David have both recently published an article in Elevator World. So I’ll invite all listeners to to check out the latest edition of Elevator World. I do wanna say up front that because this is such a big topic, we’re not gonna be able to address all that we’ve

prepared even or even all audience questions. we will do our best. And in that regard, we’re open to to doing, you know, some future conversations, live streams, episodes, whatever we need to do, to have some more of these. but we do invite

Donald A Gelestino (01:05)
Mm.

Matt Allred (01:05)
questions and look forward to to having listeners, you know, pose questions as they come up or or thoughts or comments, whatever you you feel. So

Let’s let’s go ahead and and dive in. And the first question I just want to start with is what is happening? You know, why now and why should elevator companies and suppliers pay attention? John, you want to start with that one?

John Koshak (01:33)
Sure. first off a little background. I’m on the A seventeen Standards Committee, currently a corresponding member on the ISO committee, but I was a a traveling member of that committee for several years during my Kis Tissencrupp days. And what’s not happening now is rather than coming up with a global consensus code, which was the original purpose of of the committee, we’ve now seen that

The European codes have been cut and pasted over into the ISO codes, which means in real terms, there’s a pr performance based code that is being proffered to the the world as a global code. And that is contra to a more prescriptive code that ASME A17 B44 is, and that has ramifications with regard to

product and safety in my in my view.

Matt Allred (02:34)
For sure. Can you help just just for our listeners define a little bit more about performance versus prescriptive? Because obviously there’s very specific meanings behind those words.

John Koshak (02:45)
Yeah, a prescriptive code would say a toe guard must be made of metal and it must be forty-eight inches long and a 70-degree kickback and must withstand 150 pounds of force.

Matt Allred (03:00)
Okay,

very precise.

John Koshak (03:01)
So it prescribes the materials, the strengths, and the performance required.

Or it assumes the performance required based on the prescriptions. A performance code says put something there that will resist somebody pushing it at 150 pounds or what other number you may use, and it could be made of anything in the judgment of whoever does a risk assessment and gains notified body approval.

Matt Allred (03:29)
Gotcha. Gotcha. Okay. So instead of instead of being very precise about here’s what it exactly what it needs to to do it or or be, it’s a it’s more like, Hey, if if it works, use it. Is that correct? Is that

John Koshak (03:44)
Yeah, it but it relies on two things that are key to the discussion. It relies on a risk assessment performed by the company, the manufacturer, and it relies on the junk the sound engineering judgment of the members of that design team. And so there’s no consensus with industry or owners or anybody. It’s simply the manufacturer. The manufacturer says

I I think this works. And if he gets a notified body to agree to it, it’s gonna be the product. So sound

Matt Allred (04:17)
Hm. So so

John Koshak (04:18)
judgment and risk assessment are key. Sorry.

Matt Allred (04:21)
Yeah, yeah. Yeah, but it’s but it’s the same group that’s designing it, selling it, and giving the sound judgment for it. Is that correct?

Fascinating. so I’m curious, and maybe David, you could speak to this. How how long has this been effort been been underway?

David Guerin (04:42)
I would say I’ve been thinking about it for a few years now. A

Matt Allred (04:47)
Mm-hmm.

David Guerin (04:48)
and if you know, if you’re talking of I don’t know about the the E N thing. I

Matt Allred (04:52)
Mm.

David Guerin (04:52)
mean how long that’s been in progression, but you know, it’s certainly like I what I wanna say initially is that ASME has the best codes and the best engineers to help produce the codes. The the problem I see is that we don’t have any

we don’t have any architecture for the codes. So there’s no there’s no baseline, there’s no floor for for the for the whole country. So that’s the problem that I’m in I run into and probably like John and other consultants that go around and you know there’s there’s the no compliance, you know, the the the they’re using outdated codes, you know, and then there’s no date

Matt Allred (05:38)
So you’re saying just to clarify,

you’re saying in in the US currently there’s there’s some some some Okay. Okay.

David Guerin (05:44)
There’s there’s jurisdictions that are that are way behind. You know,

way, way behind. And then they ha they might have they might have their own version of the code. They might adopt like a 2013 with addendums, you know, or they write their own they write their own code and then they they pull from ASME. But I guess what I want to say is that ASME has the best engineers, has a hundred years of like really good codes now.

And

you know, I I grew up in I grew up in Ireland with the just Jersey accent, trust me. And

Matt Allred (06:17)
Right.

David Guerin (06:17)
I go to Ireland every year and then I go to other countries and I I travel throughout Europe and you know it’s it’s just much different, you know, like the for a lot of different a lot of different reasons, you know, like life safety, fire service, you know,

Matt Allred (06:31)
For sure.

David Guerin (06:32)
maybe it’s required, maybe it’s not, you know, you know, ventilation, even ventilation in the camp. You know, I I was in Obiza Spain this year.

You know, we’re not a beautiful hotel resort. But you know, there’s there’s no there’s no exhaust van. It’s a hundred degrees outside. They

Matt Allred (06:47)
Wow. Yeah.

David Guerin (06:48)
got they got vents there’s no vents on the you know, like our elevators we have ventilation built into the camps. We have an exhaust van, you know, to pull and suck the air out, you know. Hopefully you don’t hopefully you don’t affixicate. But like if you were stuck in an elevator for a few hours in a bizain during the midday, I don’t know. You know, I mean there’s there’s just different

There’s just different you know, I mean, they just got different codes than we do. We’re very sp specific and you know, if we see something wrong, or inspector sees something wrong, he’ll he’ll he’ll write for clarification. You know, we have we have the only thing we don’t have is a federal fraud. We don’t have a federal fraud for our equipment, so our our the safety is based on the zip code that you live in. And it’s it’s

Matt Allred (07:39)
So so hence the the

there’s some inconsistency

David Guerin (07:40)
It’s unfortunate.

Matt Allred (07:42)
is what I’m hearing. In in the US. Okay. Yeah, yeah.

David Guerin (07:44)
Absolutely. Yeah, throughout the whole United States. I mean some

some jurisdictions are are sh are way above a floor and some jurisdictions they don’t even have a program or you know, not much of a program. So I’ll let I’ll let somebody else talk. So yeah.

Matt Allred (07:54)
Yeah, yeah. Yeah. Thank you. No, you’re good. Yeah. So Don, I wanna just

ask you, you know, from your perspective, what what concerns you most about the direction you feel like this this may be heading?

Donald A Gelestino (08:08)
So, you know, I come f you know, I’m more of a the field type person, running running men, running teams and and you know, elevator service companies. So a couple of different things. So for me, I’m I’m really for learning the best practices around around the world, you know. But codes, in my opinion, they don’t exist in a vacuum. They develop around culture, laws, buildings and emergency response systems.

And different countries have their own ecosystem, right? So, you know, we in the United States have, you know, like I and I really agree with Dave. I think the A seventeen and Anzi and the whole group over there are one of the best globally, and we’re very lucky in our time to have where we are at with some of those codes. And, you know, the thought of, you know.

changing or implementing to to me that sounds like if tomorrow, you know, somebody was gonna say, all right, everybody has to speak another language and we don’t know what that language is yet, but we’re gonna operate that way soon. very scary for for someone like me. And you know, I come down to a few different things. You know, I bid a lot of jobs and you know, everybody’s always looking to get the best price. And hypothetical

Right now, if we were to have adapted this kind of standard, just like John was saying, you know, a company can come, they could be the cook, the bottle washer, the judge, the jury, put this thing together. It could be the cheapest price product, so everybody’s gonna wanna buy it. And we’re gonna find ourselves in a different culture than what we know today as the United States. And I’ll tell you, I wrap my head around the concept,

That the United States has developed very specific expectations around accessibility. So if we move more towards a global standard, I just wonder, number one, how those requirements are actually protected. and, you know, just being more of a New York type of person. you know, I started in the business in New York in nineteen eighty six and I’ve been through Hurricane Sandy, Hurricane Irene, nine eleven, plenty of other crazy stuff.

And what I’ve what I feel is our first responders and our firefighters operate and train around systems developed here in the United States. And you know, they you know there’s a reason why our codes have adapted a thirty five hundred pound stretcher code because maybe first responders and through different different governing bodies

have they’ve already recognized that it’s not that easy to carry a stretcher up and down six or seven flights, God forbid more, right? So we’ve as a society already already went through all the motions to recognize and implement certain standards that we as a society, I feel we need just to function the way we do. You know, I’m I’m very

Sympathetic to, you know, I I talked to a gentleman that had like a brown stone and but it was multifamily, and they wanted to put a little elevator like a lula, but then they’re like, no, it can’t be a lula, it has to run without a key, and we all got to use it. I said, that’s not real. It’s like sounds real, but it’s not real. And there’s reasons why. So I’m

Matt Allred (11:48)
Sure.

Donald A Gelestino (11:49)
sympathetic to that concept, but also I am very sympathetic to the reality of where we’ve.

come from as a society. And, you know, that’s so that’s kind of my take on it from like an elevated guy’s perspective. You know, I’m I’m more about learning from the best safety practices around the world, and maybe learning from this concept of harmonization. But I don’t I don’t personally know if in my life we’ll actually see something like this happen. You know, I rem I I’ll just say one more thing that

kind of makes me laugh. I remember being in high school, which is I’m fifty-eight years old now, so that was a long time ago. And we were talking about the standard system and the metric system. And we were gonna all become the metric system. And I see now at fifty eight, it’s still not that way. So I don’t know if implementing things like that happened so fast, but I do think this needs everybody’s attention on it. And I think small elevator companies

mo mostly independents. I don’t even know if they understand the magnitude and the severity of what we’re talking about here. And that’s why podcasts like this are great. And people like Dave and John, way above my pay pay grade, their knowledge is so valuable that you know, I think this is a key podcast for our industry right now.

Matt Allred (13:21)
Yeah, thank you. Thank you. And appreciate that. So let’s let’s get a little more specific. John, which ISO eighty one hundred parts are actually in play and how how do they relate to you had mentioned the the European EN eighty one historically? And I I heard you say copy and paste. Maybe that’s so maybe that’s the answer to that part of it, but which which parts are actually in play? What are we talking about?

John Koshak (13:44)
So just to clarify, was EN eighty one dash one and two became EN eighty one twenty fifty, and then through the Vienna Agreement, which is a European construct, ISO copied eighty one EN eighty one twenty and fifty, and they became eighty one hundred part one and part two. And then there would have been some changes to eighty one hundreds part one and two, with

Adaptations and modifications to the EN81 20 and 50. And then for the differences in North America.

They created what’s called EN Eighty One Hundred Part Three. So the concept is they recognize that they don’t have maintenance, they don’t have our societal constraints and our building code requirements and our NFPA fire requirements. They just do things differently. So part three of eighty one hundred was supposed to detail how they handle that. And

What’s interesting to me is and and Don touched on it, the the cultural societal values. If you go to England, for instance, they don’t have fire recall. They have a fire brigade and people in the building have buckets and they answer fire calls first while they call the fire brigade to, you know, to come help. W and we don’t do that. We make the elevators perform so that the firefighters have a a

carriage.

Matt Allred (15:07)
So when you just to clarify,

you said people in the building, does that mean if I’m a a business owner, I’m in charge of fighting my own fire with with me and my secretary and and team with buckets and and then I okay. That

John Koshak (15:20)
Yeah.

Matt Allred (15:20)
is a little culturally different, right? I I wouldn’t ever

John Koshak (15:23)
Yeah.

Matt Allred (15:23)
have thought.

John Koshak (15:24)
I wouldn’t have thought it either until I was in England and they told me that’s how it works.

Matt Allred (15:29)
Ha ha.

John Koshak (15:31)
and it might have changed in twenty years because it’s been twenty years since I was on traveling with ISO. But nonetheless, they had twenty years to say, let’s add fire recall to eighty one hundred, and they didn’t. So to me, the cultural

things carry on. And and that’s important because the people who control modifying and changing and updating 8100 are gonna be the companies. It’s not like ASME where you have consensus from inspectors, consultants, manufacturers. It’s it’s all the major companies. And furthermore, ISO

Matt Allred (16:09)
So there’s not disparate

it’s not as as balanced as it sounds as as a group that’s gonna decide some of this. It’s more j just just the manufacturers that are approving their own designs and and kind of pushing it ahead.

John Koshak (16:21)
By virtue of the voting. So

on ISO you have P members,

Donald A Gelestino (16:24)
Yeah.

John Koshak (16:26)
voting members, and other members, but they’re essentially 13 voting members, and they’re all company people. So if I were to suggest a proposed change, it would have to go through 13 major company people to say, yeah, we’ll we’ll make that change, we’ll change the code.

And America is one vote of thirteen. So for us having a code that’s been around for a hundred and seven years, we we lose all control. And furthermore, we lose the consensus of the rest of the industry.

Matt Allred (17:04)
So so as a a nation, we we we kinda lose the ability to to self govern the elevator future. Is that kind of what you’re saying? We lose control. Is that

John Koshak (17:12)
Yeah, absolutely.

Matt Allred (17:16)
Okay. That’s a lot. so I’m just just wanted to make a a comment. We do have some, you know, live participants and I do want to encourage questions. there is I’m just gonna bring this up. I think it’s a little bit out of scope, but I’m just gonna one of our listeners is saying, Hey, ASME for the past five years or so has been working hard to implement A seventeen code into China, where existing G B code is a derivative of E N.

And he’s curious, again, I think it’s a little out of scope, but he’s saying does it follow the ASME has abandoned their pursuit in China? Or is it is I I don’t even know if you could s respond to that, but

John Koshak (17:56)
I’ll give you my impression. I have a little knowledge. So we did go to China and they do have their G B codes and ASME started a China International Committee. I went to the inaugural committee

Matt Allred (18:10)
Mm-hmm.

John Koshak (18:10)
of that group and EN and SEN, which would be C E N is the ASME equivalent, if you will, the managing body of that standard. They came over as well. They’re

part of the ISO team and China was sold on going to the EN 81, which included modifying some of the G B standards over there. And when China wanted to make some changes, they submitted them to Sen and Sen said, sorry, you’re not a member of the of the group, because this is only for European countries.

And China kind of got miffed and I thought ASME should jump on that and say, look, you know, you can be on our committees. We have started a committee. And China didn’t and went back to pretty much, we’re gonna go with our own codes. So that’s my understanding of it.

Matt Allred (19:06)
Interesting.

Interest. Okay. So but but because they were disallowed from and and I think it does relate a bit, even though it it’s obviously a different side of the world. because it it sounds like if the US adopts this we have very little say, like like with China.

John Koshak (19:24)
They get one vote.

The biggest

Donald A Gelestino (19:28)
Yeah, we got one. Yeah.

John Koshak (19:29)
So it’s thir

David Guerin (19:32)
I mean I mean that’s that’s why me and John authored the Fees Act to try to to try to, you know, let’s save let’s save it. Let’s save our code. You know, a hundred years of history, great engineering behind it, you know, factors of safety, not just it looks good to me. You know, like there’s a lot of differences between between ASME and EN. And I’m sorry there isn’t even how it’s allocated. And I think this country deserves to have

It’s in control of its own destiny. Because that’s what we’re talking about here. So you know, I I what I would like to implement in the Fees Act and one of the pillars is that have a a national database of an elevator and an application. And let’s see let SPS, you know, Consumer Product Safety Commission let that let them host it. And we have a checkbox for every you know, to so we know that they comply with our code.

And if they comply then they get the permit. But you shouldn’t put it on the the AHJ. Now that’s just wrong. So the AHJ is supposed to be handed a piece of equipment that conforms to code. And and that’s not what’s gonna happen. He’s gonna go there and like he’s not gonna you know, he doesn’t know if this this if this part was you know it it i he’s you know, he’s it’s either he’s gonna accept it or he’s not. But it’s you know, he

Matt Allred (20:54)
Okay. Okay.

David Guerin (20:55)
could look at different things, but

Matt Allred (20:58)
Right,

right. Well and and yeah, I mean solutions are are yeah, obviously there’s a lot of different routes. I I do want to kind of stay with a little bit just kind of defining, you know, what it is. so for example, proponents will argue that ISO eighty one hundred can provide comparable safety while reducing unnecessary cost. What Don, let’s go with you. What what concerns do you have with that argument?

Donald A Gelestino (21:21)
Well, I I s again I I still look at just, you know, the concept that you can come up with with something that’s just so out of the norm from what we’re even used to dealing with

Matt Allred (21:36)
Mm-hmm.

Donald A Gelestino (21:37)
and still get it signed off at some level to me. It just it’s just a recipe for disaster in my opinion.

Matt Allred (21:46)
Yeah, yeah, yeah. Well I mean it if

If the people working on it, yeah, aren’t familiar with it, you know, it it could I mean safety could be a real issue. John, what are your thoughts on that?

Donald A Gelestino (21:56)
Mm.

And you have to I

Matt Allred (22:00)
sorry.

Donald A Gelestino (22:00)
I wanna chime in with one other other idea that people also don’t really think about or even really talk about. But the the issue is everyone talks about the elevator on the day that it’s installed. What about five, ten, fifteen years later? you know

There’s right now there’s X amount of brands in the US. People become generally familiar with those. you know, I and I do think across the globe there are some amazing material, me amazing manufacturers and great technology, right? But how many can you have coming and going built under a different code that nobody’s used to and different diagnostic tools? So, you know, the question is.

Not about the day that we install this elevator, it’s also about fifteen years down the road when maybe some of those companies close up, who’s who’s got the diagnostic tools, who can get the parts, can an independent contractor service it? and can a building owner, you know, change contractors even? Who knows? You know?

Matt Allred (23:17)
Yeah. Yeah. John, you had some thoughts on that?

John Koshak (23:21)
So

yeah, generally,

An effort was started in in Washington making the argument that an ASME A seventeen B forty four elevator costs so much more than an elevator in Europe. And the reason is they don’t have the same requirements. For instance, ISO eighty one hundred doesn’t have any maintenance requirements or inspection requirements or zero, yeah.

Matt Allred (23:49)
Zero. Is that is that correct? Just

just for me to get that clear. Zero maintenance

and zero inspection. Wow.

John Koshak (23:53)
Yeah. So you you design

something, you get it approved by a notified body, and then you provide the inspection document for that elevator or model elevator, but it’s not codified anywhere. We’re not looking at, you know, the safety, the buffer, the you know specifically sp specific things that have specific prescriptive requirements for them to be inspected.

For instance, in America, we have to do a safety test on acceptance. In Europe, they certify the safety at the factory, and there is no acceptance safety test. So most Americans don’t know that. So the argument in Washington, where it actually went to legislation and was overturned, and it’s gone to IBC as well and was denied that approval of equivalency to A17 B44.

It it’s not comparing apples to apples. It’s our codes are written because of the incidents and fatalities and injuries that have occurred in our century of of history. And they they basically are saying, Hey, look, you know, we’re smart enough now we know how not to do that, and we’re just gonna use risk assessment to reduce our cost. And if you look

Lastly, at eighty one hundred and the World Elevator Escalator Federation, whose scope is nothing other than

Matt Allred (25:21)
Mm-hmm.

John Koshak (25:22)
to make ISO eighty one hundred the law of the world, to make it the global code. Well that that neglects, in my opinion, all the prescriptive work that’s been done in our century.

Matt Allred (25:38)
Right. Well and and it sounds like what from what you’re saying, the the prescriptive work has been done because of inch incidents and accidents and things that have happened to make sure we protect the writing public, which should, in my mind, be first and foremost is that this and and the mechanics obviously working on it, right? It’s safety has got to be first. And and if you’re saying there’s no maintenance requirement and there’s no inspection requirement, safety doesn’t feel like it’s it’s

very important at all. It sounds like, no, we just need to sell more machines.

John Koshak (26:09)
And it’s all just simply done to reduce costs. And so therefore

Matt Allred (26:14)
Mm-hmm.

John Koshak (26:14)
you’re you’re trading a reduct a reduced cost because you can manufacture globally, but it’s at the dumping out of all the safety that we’ve improved the codes with, in my view. So

Matt Allred (26:30)
Sure. Sure. So so talk to me a little bit about you know, I know one of the one of the comments you guys made in the the article in Elevator World was was an incident database. Does that exist anywhere? Is there anywhere any way to compare one standard to another and say, hey, X number of incidents per person per ride, is that is that even possible?

David, you want speak to that?

David Guerin (26:55)
Well

some jurisdictions most a lot mostly most jurisdictions have you know part of the permit process or them for them to keep their license, their elevator license has to be, you know, inspected every year. But they have to if there’s an accident, usually it says it on the inspection certificate that if the accident happens they have to call a certain number. But you know, that but it doesn’t it doesn’t happen. Like it doesn’t happen and then you know, and that’s what I always ask, like, well somebody got hurt

And you know, they were were they trans if they were transported, then did that unit go back in service? And it’s not supposed to go back in service. So,

Matt Allred (27:32)
Mm, mm-hmm.

David Guerin (27:33)
you know, and then it’s just I don’t think there’s there’s no database. So there’s no database at all. No, no, no, it doesn’t.

Donald A Gelestino (27:38)
Yeah.

Matt Allred (27:38)
There is so it doesn’t exist. That that was my question, right? Does it even exist? There’s no way to compare. Okay.

David Guerin (27:43)
No, I mean

Donald A Gelestino (27:43)
No.

David Guerin (27:44)
Consumer Product Safety Commission, they estimate an estimation of how many a people are you know hurt and on escalators and elevators annually.

Matt Allred (27:54)
Okay, so they can guess,

Donald A Gelestino (27:55)
See that’s

Matt Allred (27:55)
but okay, Dawn?

Donald A Gelestino (27:57)
Yeah, see that’s another that is an initiative here as a country, as a society that we need to really tighten up. you know, obviously, you know, governing jurisdictions, there’s hundreds of You know, New York, just in Long Island, you have counties and then you have towns and then you have parts of the towns and these the inspect the inspectors, they they’re doing their job and same with

Department of Buildings and the five boroughs. But the reality is everything is in a vacuum right now. And even like Dave said, if there’s an accident in an elevator, all right, the inspection certificate says to call the local DOB. The local DOB, this the same person that just, you know, looked at an accident in a supermarket with a food spill is the guy looking at this elevator accident.

Highly unlikely he’s an elevator expert, right? and then that data that goes into a file cabinet or now a PDF or something and sits in a drawer and nobody knows anything with it. We really need as a s a society to get those all of that up and into one mainframe that then we could take the analytics and look at hotbeds like hey, this part of the country, this type of elevator.

We have such a big lift that we should be focusing on, but if we don’t get our heads around this situation that we’re talking about right now, this it’ll become a bigger problem and I’d I’d hate to say it, but the way there I I don’t want to use the word sneaking it in, but this is exactly how strange things happen because if this code change could be snuck into a document

And then adapted. God forbid it got adapted and here we are dealing with it. It can happen with plenty of other things that our our culture and our country currently has at stake. So, you know, there’s there’s a there’s a lot here that people don’t realize.

Matt Allred (30:04)
Yeah, yeah. No, absolutely. Absolutely. And and actually we’re getting, you know, some questions from our listeners. you know, we asked about the database. Thomas is just saying, is there any analysis that we that we use to compare a code, you know, implemented on one one versus the other? Any way to kind of yeah, I think you said an estimate, but

John Koshak (30:23)
I I’ll speak to that. Richie from Australia brought that up as

Matt Allred (30:26)
Yeah, please.

John Koshak (30:27)
well. no is the answer. Don’s right. many jurisdictions do require if there’s an injury incident of some level, if it required a paramedic or if it required a hospital

Matt Allred (30:41)
Mm-hmm.

John Koshak (30:41)
visit or that it has to be reported. And the incidents are getting so common. Nevada changed the law that if you have an entrapment

you have to call Nevada Dosh to do an investigation. Yeah. So

Matt Allred (30:59)
really?

John Koshak (31:01)
ASJs are you know, in in high dense cities like Vegas, New York, you’re you’re starting to see that, hey, you know, we’re we’re not happy with the consistency of or the increase in incidence.

When I was on ISO, that’s the question I would ask, because that’s the common sense question to ask. Okay, you want this EN eighty one hundred, you want EN eighty one at all, how many incidents do you have? And everybody says, there’s no database. And the people that I would get personally friend with in Italy and Germany, they’d say, yeah, there’s accidents, but we don’t we don’t we don’t keep a record.

Well and and it was hard for me because we didn’t keep a record here. And so for the last nineteen years doing litigation work, I I feel like I don’t want to be the the cop who says, Okay, everybody I stop on the street is gonna pull a gun on me. But that’s almost the condition I see and the the attitude I get because we have such a lack of maintenance.

inbred in the major company portfolios that we’re seeing. I’m seeing an uptick in these incidents. And so to answer the question broadly, there there is nothing, there’s no available data that you can say we have this much and you have that much to to determine which is the better code. But my gut feeling is ours is the better code because

Again, we go to risk assessment and sound engineering practice. And those are subjective items. And y you can pick a risk assessment team that won’t even identify a risk that another one would pick to mitigate. And I’ve been doing certification work enough to know that that that truly has happened. And I know that that happens in Europe as well. So

Matt Allred (33:04)
Sure. I mean I talked to an expert yesterday just just in regard to this, won’t won’t name any names, but you know, a lead a lead inspector for a certain state and and he said the same thing, right? That that if if some it’s not picked up in a risk assessment, it doesn’t exist, right? So somebody is an oversight and hey, we didn’t pick up on that, then we’re not gonna r remediate for that because we didn’t identify it as a risk, even if it later, you know, bites somebody.

I mean, and I don’t know how that that is handled, but but it does kind of lead to, you know, a question about and we’ve talked a little bit about this, right? manufacturers get get the chance to claim equivalents through this risk assessment. who independently validates that? You said something about a notified body, I think you use the term. Is that what is that?

John Koshak (33:52)
Is in

Europe.

There are components that are required to be approved. And it’s it’s kinda like when a a manufacturer of something in US or Canada designs something, you design it to the design code of A seventeen B44.

And then you have to certain jurisdictions, for instance, Ontario, TSSA, are diligent in they have a list of approved products that have to be reviewed and approved by them before you can sell them. California still does for certain components. But it used to be Wisconsin and Pennsylvania and New York, and now we’re essentially down to TSSA because that running that kind of operation is expensive. But those are for specific approved items, not all of them.

In Europe, if I want to design something, I have 129 notified bodies that I can go to. So think of 129 ULs where I take I take my design and

David Guerin (34:54)
Yeah.

John Koshak (34:54)
I say, you know, notified body number one, here it is, here’s my risk assessment. And if they say no, I say, Well, I think you’re wrong, and then I I go over here to number two and I say, Hey, I’ve got this risk assessment, this design, please approve it.

David Guerin (35:09)
Yeah.

John Koshak (35:10)
He may get five no’s, but he’ll evolve ultimately can get a yes. And with that yes becomes the ability to put a CE mark on it. And the there’s no way for the number five notified body to know that four others previous said no. And so you shop around. And it it’s

To try to eliminate the possibility of notified body shopping, when we wrote A177 in in the US, we limited it to three bodies so that hopefully that they would intercommunicate. And then in my experience, they didn’t. And now we’re down to just two.

Matt Allred (35:50)
Even with three. So you’re saying hundred and twenty nine is i it almost sounds like lowest common denominator, right? If there’s one out there stamping, do the validate the risk assessment to say, Well, you didn’t you didn’t even look at this risk. I mean is there is that

John Koshak (36:05)
Yeah.

Matt Allred (36:06)
does it happen?

John Koshak (36:06)
They they take the risk assessment as you wrote it. And if there’s something glaringly obvious, they’ll say, Hey, you know, you you didn’t examine this risk. Part of the risk assessment process is going through the sixty-four global essential safety requirements. And it says things like shock hazard, flood hazard, sharp edge hazard, electrical fire.

Sixty four of And you’re supposed to pick all the ones that you apply. Your team is supposed to say this one applies, that one applies. And then some of don’t, of course, apply. And then you you assess each one of those identified GESRs. Well, if you don’t bring it up and the notified body or the ACO doesn’t s see it, because it was your job to bring them the risk assessment, then it gets overlooked.

Donald A Gelestino (37:00)
And we and we have seen that. Like that has happened. Like o legitimately and unfortunately, but there have been instances where things like that happen in general.

Matt Allred (37:12)
Right.

Right. well let’s let’s talk for we’re gonna pivot just a little bit. obviously there’s there’s strong interests on both sides, right? who who stands to benefit the most from having essentially one standard around the world, right? Who’s who’s who’s kind of pushing?

Donald A Gelestino (37:33)
I think it’s more the OEMs. I mean I don’t wanna bush it, I wanna make any enemies really out there. But the reality is if as a as a manufacturer and you when you have the capability to mass produce or you know, hire sub mass producers, so I think it’s those who with the deep pockets have the most to gain probably and you know, that’s my opinion.

Matt Allred (37:58)
Yeah, yeah. Yeah. Well, and I don’t know, you know, all the the reasons. I have heard people say, it’s gonna drive down costs. I I won’t name the the company or the person because I was told not to, you know, quote But but he did say to me in a in an offline conversation that he didn’t anticipate any cost savings to the end user. And and the the expert I spoke with yesterday kind of said the same thing that the average American is not gonna benefit in any way from from a code change, right? They wouldn’t know about it. you know, it’ll

But I I just found that it that interesting.

Donald A Gelestino (38:32)
Well, probably the only my opinion again is you know, when you start putting things on like the logistic part of this, you know, bringing things in, I don’t know if the tariffs are gonna last forever or whatever, but like that added cost. just our cost here in the US transporting around locally, logistics I think plays a pretty good part in our you know, our cost.

and then remember our labor rates here and the the insurance rates, the labor rates, that’s all driving our cost. So the product cost may be cheaper, but by the time it gets here and does it, unless they plan on opening up factories in the US to build the stuff, which would be a strange thing, maybe Mexico or something like that. But I think that I don’t think there will be much of a savings.

I think that what we’re gonna see is just a change in the product. And then just like John said a few minutes ago, you know, he’s an expert witness and he’s and he has a lot of knowledge and education and and has seen a lot of things. And he actually said, Well, he goes out and looks at maintenance evaluations and sees that there’s not much maintenance being done on elevators with our code right now that defines that you must have maintenance.

Imagine we stamp something in where you don’t have to have it. It just gives everyone even more of an excuse not to do elevator maintenance. And I’m a big proponent of I’m a guy who I I know it’s old school and getting great beard or whatever, but the reality is I think you have to do maintenance once a month. You have to see, touch, feel, smell the elevator. You know, so that’s how you know what’s

Matt Allred (40:24)
Sure.

David Guerin (40:24)
Totally agree.

Donald A Gelestino (40:25)
yeah.

Matt Allred (40:26)
Yeah, yeah. Yeah. So I I just want to ask this question. If if you know the global manufacturers, let’s say they tool once for the the ISO and and John, this may be a question that that you had helped with. What happens to North American specialty manufacturers, independent suppliers over a cycle if they’re competing you know, with with products that are, you know, instead of you know, it’s a whole a whole new code system. Is this one that you would

shared.

John Koshak (40:56)
Yes, in general terms, not very to the granular specific component level, but during my time on ISO, we were comparing, you know, G B codes in China, the AS seventeen thirty-five in Australia, US codes, Japanese codes, Russian, German, before they were all harmonized.

Matt Allred (41:18)
Mm-hmm.

John Koshak (41:18)
You know,

basically every s every code has a a requirement for a buffer and buffer stroke and energy dissipation. But you know, if it’s a sixteenth or thirty millimeter difference, if you’re making a buffer and it doesn’t comply with the thirty two millimeter difference, now you gotta retool for a a bigger or a shorter buffer. So there are ramifications that I mentioned back when knee N A E C twenty years ago.

I wanna go back to who benefits and it I it’s the OEMs,

Matt Allred (41:51)
Yeah, sure.

John Koshak (41:52)
period.

David Guerin (41:52)
Excellent.

John Koshak (41:53)
It it can only be them. Can’t an elevator is not gonna benefit because they don’t sell anything in Europe. But if you can make one thing and make it either here, as Don mentioned, or ship it cheaply to get here, but again, as Don mentioned

you know, parts cost is the smallest of all the cost of an installation of an elevator. You know, delivering it, getting installers, the building so they’ll benefit because they’re essentially going to try to put Minnesota and Canton and other, you know, pick you an elevator out out of business. less competition, period.

Donald A Gelestino (42:33)
And I I I’ll chime in with that because the reality is, remember, the labor laws and the package that is provided to workers and workforces outside of the US, we will always it isn’t like we there’s other societies out there making a lot more money and and labor rates are higher than the US, right? So everybody can come in with their product at a cheaper price, but our workforce here

that’s paid pretty well, they’re not gonna retool and try to manufacture and then sell everywhere overseas and grow that way. So we’re really handicapped in this in this whole environment of this concept.

Matt Allred (43:20)
So

so I I’m hearing you say that yeah, it would put at risk, right? possibly put some of these US companies out of business because hey, you change the rules. It’s like how long does it take to to change the rules? I do have one comment here. The end user being the writing public, he says reaps the reward of lower if non existent maintenance and testing requirement. I don’t see I don’t

let me read it again. The end user being the writing public is the one that reaps the reward of lower if not non-existent maintenance. I don’t I don’t necessarily agree with that, but I don’t see that I don’t think there’s a reward for not getting maintenance other than getting your finger cut off in the elevator. But David, you wanna respond to that?

David Guerin (44:11)
I mean, I I don’t know I don’t know what to say about that that particular comment, but no, I I don’t have anything to add to that one. No,

Matt Allred (44:21)
Yeah.

David Guerin (44:22)
but I I mean to me to me I think a lot of things would help would you know John and I did write an act of visa, right? So a national if we had a national database, even a even an initial application nationally, so like you know, you could they can check all the boxes and then and then that

whatever that the unit number is or the elevator, that would be followed from, you know, permit to to end use. And then all the maintenance records would would, you know, follow through that, inspection records, you know, and then if and then if and then we would know what what’s installed, like naturally. You know, and then have some accountability. And then maybe even try to, you know, have the registration for each every elevator and escalator.

in the national database and and monitor maintenance and histories of accidents and you know, I I I think it’s just you gotta treat elevators like they are. They’re they’re you know, they’re safety sensitive, especially escalators, you know. I I’ve I’ve seen way too many elevator I mean elevator accidents, escalator a lot of escalator accidents. You know, I think I think the public deserves it. I mean even me, I go through the airports, I’m always traveling

And you I go through the airports, I see missing coal plates, you know, broken comb teeth and and slipping handrails and I’m like, Yeah, you know it’s just from you know, I can’t even ride an elevator without diagnosing it. Like, you know, what’s you know, there’s

Matt Allred (45:50)
For sure. Yeah.

David Guerin (45:52)
a roller guy, you know, it’s just it’s just and I think John’s probably the same way. And Don too. You know, we go around and it’s like but that delayed person don’t see that. They they push the button and it takes them to the floor. If it don’t light up, okay. But like me, you know, these fellas and me

You

know, well, John and I, we see a lot of accidents and and I’m sure he does and I do and and conditions where and then you worry about the safety of the public. You know, like escalators will eat you up. You know, they get missing, you know, po I got bad rollers, you you they get entrapments, you know. What how many thousands of kids have to get hurt before there’s something’s done? You know, with with foot entrapments. I mean,

Matt Allred (46:28)
Right. Right.

David Guerin (46:30)
like, you know, and there’s been a lot of issues with recalls, but they don’t get involved.

When something tragic happens, like the kids in the doors, you know, with the with the home elevators. And the home elevators is another mess because a lot of jurisdictions don’t require permits. So they don’t even know what they’re getting. But you know what I keep saying is we gotta have a national database, we gotta have a national permit process, we gotta know what’s coming into our country and say no to it if it doesn’t comply. You know, simple as that. But but John knows and I know even even suspension means. You know, we we

We have factors of safety. With our machines, with our gear boxes, you know, there’s factors of safety involved. That’s not the case over there, like John pointed out. So, you know, I I think honestly, you know, I I we wrote an Act Both Visa. It was at the beginning of the podcast. I recommend everybody listen to it, makes sense, contact your congressman. I mean, Senator, we need to push this through to get some, you know, to to and and also to protect ASME.

and and and kind of have a floor for the country as far as who can inspect our elevators. They have to have a certification, QEI, whichever one of the three they have, you know, but d we have to have standards. And and you know, there’s there’s there’s ca other states here that they don’t even require a QEI. So it’s like

Matt Allred (47:53)
Yeah, yeah.

David Guerin (47:54)
well, you know, and that’s you gotta know you gotta know what you’re looking at, you know, even

Matt Allred (47:58)
Yeah, yeah.

David Guerin (47:58)
with the inspectors and even with the mechanics. The mechanics all need to be licensed. I’m sorry.

They need we need to know that they went through a training program and they were trained by a mechanic. So, you know. And they and they got it

Matt Allred (48:11)
No, it’s it’s well said,

David Guerin (48:12)
and they gotta know safety. They gotta know safety for the public too. So, like, you know, I’ve been facilitating a training program for twenty one years, you know, and it all starts, you know, you gotta learn how to go somebody has to teach you there has to be a a formal process involved. You know, I I don’t know. I’ll let somebody else talk now. Yeah.

Matt Allred (48:30)
Yeah, no, thank you. Thank you. I think it’s I think it’s well said. I

I think what honestly one of the things that’s coming to mind here is, you know, having this conversation really I hopefully makes us more aware of, you know, whether it’s doing proper maintenance or or, you know, creating a national database or just saying, hey, we can do better with what we’ve got, right? Whether it happens or not, I mean, I don’t I don’t really have a dog in the fight as much as I hear I hear anxiety from different people. But I’m hearing you say, David, is and and John and Don, all of you is.

We

can do better with with what we’ve got and and this seems like a an invitation to do that, right? To really, you know, let’s let’s make elevators the, you know, world class here and and safer than anywhere.

David Guerin (49:11)
Well, I think

Donald A Gelestino (49:12)
Yeah.

David Guerin (49:12)
we have to protect what we have right now. So I

Matt Allred (49:14)
For sure.

David Guerin (49:15)
think we have to protect A seventeen and they have to comply to A seventeen. We don’t have to comply to Now that’s I think that’s I that’s what has to happen. So but we need we need a we need a federal floor. So we need a federal agency to jump in and say, you know, in conjunction with but they’ve always said, well, you know, A seven A S E is the you know, they’re the AHJ of it, you know, but that’s really we need a f just like the aviation.

Aviation nineteen fifty eight, they created that’s what that you know, there was accidents, right? But how many accidents have to happen before we actually have do something about it? So, you know, let’s let’s you know, that’s all I’m here to do is try to get something

Matt Allred (49:54)
Yeah, no, I appreciate that. you know, we’re we’re kind of getting close. So I I think what I’d like to do is I do want to I’ve I’ve continue to invite outside questions. I’m seeing some comments, which is good. You know, stricter requirements, Lewis says, rather than the fantasy of lower costs. I did

Donald A Gelestino (50:12)
I love it.

Matt Allred (50:13)
I did get a a clarification from the gentleman earlier. He said he was being sarcastic when he said that the end user benefits from no maintenance. That makes sense. I just did not.

Pick up on the sarcasm there. and

Anyway, there’s there’s a gentleman saying he agrees with you, David. So getting getting some resin resonates. these things are, I guess, resonating with our listeners. why don’t why don’t we just go around the horn and you know, let each of you just kind of respond to if, you know, if you had five minutes in front of the people who will ultimately decide the future of codes, what would you want them to understand before making that decision? John? so

Donald A Gelestino (50:56)
I’ll take it I’ll

I’ll take it just from a quick down and dirty perspective because I’m not definitely not the most technical guy in this room. But for me it isn’t like the di the difference between Europe and America, it i it it isn’t really like ISO versus ASME. I I think we’re all trying to move people safely. the question is, you know, can we take the best ideas from around the world while still preserving regional requirements?

that exist for legitimate reasons, right? And I think maybe we can do that at some level. but I just do I’m a big firm believer in the cultural differences are going to be what should ultimately govern the code. And you know, I I just that’s my take on this.

Matt Allred (51:46)
Yeah,

yeah. Yeah. I I do have a a couple questions popping in here. I mean, what one I guess is a comment. Patrick’s saying let’s get all jurisdictions in North America on the same version of ASME, permit editions,

Donald A Gelestino (52:00)
That’ll be nice.

Matt Allred (52:01)
but not deletions. I don’t even know what what I mean, it sounds like there’s, you know, kind of everybody runs their own jurisd area of jurisdiction. Is that how it’s said? The the

John Koshak (52:12)
Yeah.

Matt Allred (52:13)
authority having jurisdiction. Yeah, thank you.

David Guerin (52:14)
jurisdiction authority having

jurisdiction. Yeah. So I mean some some jurisdictions, some states they’ll adopt the newest latest code and but it’s not really the adoption of it. It’s the implementation of it, you know, like the the whole thing with the code. I mean, you know, we we gotta have maintenance on the elevators and escalators. But but some some jurisdictions are so far behind that, you know, or they don’t have a program at all, really.

Matt Allred (52:43)
Yeah yeah, yeah. So

Donald A Gelestino (52:44)
Yeah. And remember there’s a big there’s a

David Guerin (52:44)
So

Donald A Gelestino (52:47)
big there’s a big put there’s a big pushback with the idea of all getting on the same code. I mean it would be great if everybody knew like yeah, hey, this date we’re all gonna be with the latest codes. But the reality is when you get down to the building owner who owns the elevator, the you know, getting up to code, obviously a new construction has to be at a certain code and you know

when you’re modernizing in New York, you have to meet a certain code. But it’s not the latest code, right? Like if you were to go out and try to implement the latest code to exist in building owners, those building owner organizations are gonna, you know, push back on that saying these building owners don’t get the rent increases, they don’t have the money, they can’t do

Matt Allred (53:36)
Yeah, yeah, yeah. Okay.

Donald A Gelestino (53:36)
this. So that’s the that’s the another big hurdle us as an industry

have to deal with. Well, so we’re dealing with that kind of hurdle. We’re dealing with financial hurdles in general with the the interest rate right now, right? Congestion pricing in New York. So like there is every hurdle in front of us and this this code right now, what we’re dealing with is is tremendous.

Matt Allred (54:00)
Yeah, yeah. Yeah. So d I do have a comment here that that’s right along what you’re saying. Mark is saying that building owners in California are fighting A seventeen dot one twenty nineteen due to retroactive three and five year testing. So kind of exactly what you’re saying. They’re they’re like, Hey, we don’t we don’t want to pay for it, I s I assume is what that’s saying. Is that right?

Donald A Gelestino (54:21)
Probably if

John Koshak (54:21)
Mm.

Donald A Gelestino (54:21)
it was free they would do it.

Matt Allred (54:23)
Yeah.

John Koshak (54:25)
Well, being from Local Eight, California, California never had the five-year requirement for safety testing until they did. And if I recall, thirty percent of the safeties didn’t work when the requirement came in.

Matt Allred (54:39)
Wow.

John Koshak (54:39)
So imagine that. And it would it came in because of earthquakes and earthquake adoption, code adoptions.

Correct one thing, they do have safety factors for suspension, David, in Europe. In fact, it’s I think an equivalent method of of determining the factor of safety for suspension ropes. to me the biggest hurdle, two of

When you have OEMs who produce a product that’s proprietary to them, Ajax Elevator’s gonna not be able to service and maintain it. So this is purely a we’re we’re the big gorilla, we’re gonna take take the chips and we’re gonna put all of our stuff in, and we’re gonna take little companies like Champion and you know ASG and we’re gonna wipe them out because they’re they’re carving into our our banana, so to speak.

The the second thing about

Matt Allred (55:36)
Ha ha ha.

John Koshak (55:37)
it

David Guerin (55:37)
Mm.

John Koshak (55:37)
is in our code we have inspection codes and we define what needs to be inspected and we, as certified elevator inspectors, have a list to inspect things. And when you don’t have that, how do we teach our inspectors if OEM number one just comes up with a a code compliance document or that certification and says, Here’s what you test on this elevator? It could be anything they want.

It could neglect, you know, stuff that we’ve done for a long time. Now, can some things be done safely? Yes. Can some things be manufactured, designed, installed safely without an inspector’s oversight? Yes, absolutely. But who’s making the decision and who’s doing the risk assessment? And that to me

If you if the sole goal is to reduce barriers to trade, which is the scope of ISO, that’s its sole scope. It doesn’t say to make the world safer. It may somewhere, but paragraph one is the purpose of ISO is to reduce barriers to trade. So it’s purely a market driven adoption that they’re in in involved in here.

Matt Allred (56:57)
Yeah. Thank you. So we are just about out of time. What I want to see is I’m gonna ask one more question. I like this from from Craig who’s listening in. in two or three words, we don’t have time to expound too much, but he’s saying if a convergence, a convergence of these two codes, ESME and ISO, were to happen, knowing the vast differences, what would be your number one priority issue? You know, what what really, you know, are you most concerned about? So in just just two or three

Maybe sentences, John, David and and Don. Yeah.

John Koshak (57:29)
I’ll go first. STP seventy-two, I

believe it is, is a comparison between A seventeen B forty-four and ISO eighty one hundred. It’s a ninety-page document. It’s pointing out the differences between the two codes. And when you look through it, I think David did the numbers, you said there were ninety not referenced components in A one hundred that are referenced in the SME.

Doors are are something that are particularly interesting to me. In the US we do UL ten B testing and in Europe they don’t. So number one, our entrances have to withstand a tremendous, tremendous amount of damage and still hold, prevent people from falling in to a hoist wave, where in Europe they don’t. So as one example, and I’ll let you guys go.

Matt Allred (58:21)
Yeah, David?

David Guerin (58:23)
No, I mean I like I I just think there’s they don’t have any maintenance requirements on ISO. There’s a lot of problems with ISO. So it’s like why do we wanna try to adopt something that isn’t up to our standards? A and we already have a problem here. So we have a problem with all the AHJs not being on the same page. We we wrote we wrote this visa act to have, you know, they could go through

The first five years go like three code year editions behind and then catch up af you know. So but that’s where new installation started. It’s not for ex you know existing buildings. But there would be, sure, mandated things that, you know, maybe safety-wise that it would be mandated that people would might meet might have to install, but it’s just the same thing. Everything gets grandfathered. We accept, we keep our codes, and and they have to comply to us. So we’d have to have testing.

You know, if they have to outside of their testing, ISO, we don’t I don’t think we should adopt our code. I think their code. I think we need to have our code and they need to make sure that they comply to our code. And we

Matt Allred (59:31)
In that.

David Guerin (59:32)
need we need to have a database that that we could reference the whole the whole unit, where it came from, what happened, and then moving forward. You know, as far as going back, re registering all the units, I I think that could happen too. I mean most j lot of jurisdictions have national

their own database that I’m sure they could share. But you know, you have a good a good reference on what’s installed and, you know, so everybody’s on the same page. But like

Matt Allred (59:59)
Thank you.

David Guerin (59:59)
you you take some home elevators, they don’t even pull permits to install. You know, so in some jurisdictions. So it’s like, you know, and commer some of the you know, some of the AHJs, if they’re, you know, in a rural area, they don’t they don’t know what they’re looking at. You know, they they try to hire a third party, but you know, it’s it shouldn’t be up to the

It shouldn’t be up to AHJs. We sh they should know that they’re they got you know that they had when they pulled the permit that that unit what was complying to our codes. And if it did it, then

Matt Allred (1:00:31)
Thank you. Thank you.

David Guerin (1:00:32)
we have a reference to say, you know, this is this is wrong and we have something to go back to. And then also like we talked about earlier, a national database. We have to have a national database for you know all the accidents that happen.

And we should have and that same product that I’m talking about, having a database, MCP. Did maintenance get done? Was there an accident? When was the inspection? You know, may I don’t know if we do fire testing, but you know, that’s a requirement too. Every month you’re supposed to test the fires, you know, the fire in the building. Well, that’s oil usage flops, everything that’s related. But you know, that’s where I come from. I I want quality, I want safety, I want a safe product for everybody to ride. You know, so so I don’t you know.

I mean, I’m sure that there’s some excellent, amazing European products. Amazing. But you know, do they comply to our code? And does the unit comply? The whole unit. So it’s like so that that’s where there it would go into an application process.

Matt Allred (1:01:30)
Thank

you. Thank you. Let’s Don, what parting comments.

Donald A Gelestino (1:01:31)
Yeah. Yeah, so

yeah, and I’ll just say it from this as an as an operator. You you get the issue you’re gonna have is almost what Dave was saying about the residential elevators, sometimes they’re not even in compliance. And I’ll give you great example. Let’s just say tomorrow the code has harmonized, right? Boom, we all wake up, it’s done. I think what we’re gonna find out for the independent elevator companies

Is all of a sudden you’re getting a set of plans with some weird size, and you’re like, Where did the architect get this? But who cares? Because now that’s what’s spec’d in there. Now listen, it could be an OEM, right? Or it could be some other company, who knows? But right now, as an independent elevator company, when you’re bidding on jobs, you’re looking at shaft plans, mostly on new construction, and you’re seeing

You’re saying, that’s set up for a Koney, that’s set up for a TK, that’s set set up for an Otis. All of a sudden, I think you’re gonna start seeing all different variables. And then just in general, ordering equipment, figuring out where that comes from, you’re gonna be missing bid deadlines, you’re gonna be missing bid dates, you’re gonna be doing ten times more work trying to figure out half of these products and items. And it’s just gonna give the independent companies

less of a competitive advantage. And then let’s say you already know all that and you price it up. I’m telling you, it’s just I think the reality is is if this was implemented in the flip you flip the switch on and we all got to play the same game, I really think it’s just going to be a real issue for the independence and it’s going to be a real issue for the smaller manufacturers. And I’m not saying small manufacturers like little guys here in the US. I’m talking about

people that we know as bigger manufacturers, packages and stuff like that. It’s it’s just not gonna be I don’t think it’s gonna be very comfortable for this industry if this was to flip the switch. Let’s say none of us all knew about this and it just happened and we were like, my God, how’d they s how’d that get snuck in there? I think this country would wake up a different place in the elevator industry tomorrow.

Matt Allred (1:03:54)
Gotcha. Gotcha. Well, gentlemen, thank you all. I appreciate your time. obviously we’re we’re out of time, but I thank you, John, Don, and and David. This has been a great conversation. And we’ve we’ve got more material, so we might have to do this again in a few months. And yeah, appreciate y’all being here today.

Donald A Gelestino (1:04:11)
Right. And thanks thanks everybody for tuning.

John Koshak (1:04:11)
Thanks for having us. Yeah.

David Guerin (1:04:12)
Thank you for having me.