Information Bulletin: Maintenance Control Program Transition Plan

Topic: Licensed elevating devices contractors (contractors) to prepare Maintenance Control Program Transition Plan

Contractors performing maintenance must prepare a Transition Plan for submission to Technical Safety BC. This plan must be submitted in a form that is acceptable to the provincial safety manager and must contain a detailed plan describing how each contractor will bring all of the units upon which they perform maintenance into compliance with the Maintenance Control Program (MCP) requirements of ASME A17.1 – 16/CSA B44 – 16. 

The purpose of the Transition Plan is to demonstrate to Technical Safety BC that the contractor will achieve compliance within the timeline set by the Elevating Devices Safety Regulation.

Effective April 30, 2020, contractors must ensure that maintenance performed on all elevating devices (that are subject to ASME A17.1 – 16/CSA B44 – 16) is in compliance with the requirements of section 8. 6, including the requirement to have an MCP in place for the unit, on or before the earliest of the following dates:

• The date on which an acceptance inspection is requested;
• The date on which a new maintenance contract is entered into for the unit;
• The date on which a maintenance contract with respect to a unit is revised or renewed;
• September 30, 2021.

Contractors are responsible for determining their plans to bring all devices for which they provide maintenance into compliance. Technical Safety BC recommends that the Transition Plan is provided as a high-level summary document of the plan to achieve compliance. Technical Safety BC does not intend to request a transition plan that details each specific unit’s transition to compliance with MCP requirements.  The plan should incorporate all the deviations and steps that one may encounter upon bringing their portfolio into compliance by the completion date.  

In preparing a transition plan, the contractor should consider:

• Number of units in portfolio
• Number of qualified individuals to complete the required work
• Distribution of units (geographically, by customer, device type, device vintage, etcetera)
• Contracts that may be terminating
• Work already committed to/on the books
• Workforce fluctuations/availability at certain times of year (vacations, known medical leaves, maternity/paternity leaves, etcetera)
• Assessment of existing data sets including where data gaps exist

A Transition Plan is expected to:

• Describe a contractor’s plan to inform/communicate to their client (asset owner) that an MCP is in effect as of April 30, 2020, and that data collection/site assessment may be required.
• Include steps/timing to have asset owner sign/accept the new maintenance plan.
• Demonstrate that the contractor has a solid understanding of what an MCP is.
• Include details as to the back end work a contractor might be taking to achieve compliance (building forms, system development, etcetera).
• Show a plan to complete site visits to obtain required data/replace log books.
• Show a plan to obtain missing data sets (how/who/when, etcetera).
• Indicate the responsible persons/resources for certain roles (data collection/site evaluation, MCP reviewer, etcetera).
• For contractors with large maintenance portfolios, it is highly recommended that a progress reporting component is included.

Contractors may prepare Transition Plans using Microsoft Word or a similar software for creating documents. Transition Plans shall be submitted to the Provincial Safety Manager for review as PDF copies via email to elevating@technicalsafetybc.ca no later than April 30, 2020.               

 

Nav Chahal
Manager, Transportation

References:
Safety Standards Act
Elevating Devices Safety Regulation
Safety Standards General Regulation