Elevator maintenance requirements for building owners come primarily from ASME A17.1, the national Safety Code for Elevators and Escalators, which nearly every state and city has adopted as binding law.1The American Society of Mechanical Engineers. A17 – Elevators and Escalators Offerings In practical terms, you must keep a written Maintenance Control Program on-site, have a licensed contractor perform scheduled maintenance and safety tests, pass periodic third-party inspections, display a current Certificate of Operation, and retain detailed records the whole time. Miss any piece of that and you face fines, forced shutdowns, and serious liability exposure if someone is hurt.
Which Rules Actually Apply to Your Building
The starting point is your local adoption of ASME A17.1. The current edition is ASME A17.1-2025, but many jurisdictions enforce an earlier cycle. Whatever edition your state or city has adopted is the one that governs your building, and that document sets the design, operation, testing, and maintenance rules for elevators, escalators, dumbwaiters, and moving walks.
OSHA reinforces the framework in narrow settings. Its construction standards require permanent elevators to comply with ASME A17.1, and its marine terminal rules require annual thorough inspections plus monthly operational checks in those facilities.2Occupational Safety and Health Administration. 1917.116 – Elevators and Escalators For most commercial and residential buildings, though, enforcement runs through your state or local elevator safety agency, not OSHA.
Older elevators are not off the hook. A companion standard, ASME A17.3, gives jurisdictions authority to require retroactive upgrades on existing equipment, including things like ascending car overspeed protection, unintended car movement protection, emergency brakes, and monitoring for faulty door contact circuits. Which retroactive items apply, and on what timeline, depends on which edition of A17.3 your jurisdiction enforces. A 30-year-old elevator in one city can face upgrade mandates the same elevator in another city does not.
The Maintenance Control Program
ASME A17.1 requires a written Maintenance Control Program (MCP) for every elevator. This is a specific document, not a general commitment. It must be in place from the moment the equipment passes its acceptance inspection, and it must be viewable on-site by elevator personnel at all times.
The MCP has to spell out the examinations, tests, cleaning, lubrication, and adjustments the equipment will receive, along with the interval for each task. Your maintenance company is responsible for creating it, but the document belongs to the building and stays with the building. The intervals must account for the age and condition of the equipment, how heavily it is used, the environment it sits in (humidity, temperature swings, dust), and the manufacturer’s recommendations, particularly for safety-integrity-rated components approved under ASME A17.7.
Two things must exist and both must be on-site: the MCP itself (the plan) and the maintenance records (proof the plan was followed). An inspector will ask for both.
Required Safety Testing
On top of routine preventive maintenance, ASME A17.1 requires periodic safety testing at two levels, and each has its own deadline.
Category 1 Tests, Every 12 Months
Category 1 tests run every 12 months, with no load in the car and at the slowest operating speed. They confirm that key safety devices activate correctly. For traction elevators, this includes testing the ascending car overspeed protection and the emergency brake at inspection speed in the up direction. Category 1 tests are usually coordinated with the annual inspection.
Category 5 Tests, Every 60 Months
Category 5 tests happen every 60 months and are far more involved. The elevator runs with 125 percent of its rated load so testers can verify that safety brakes and overspeed devices will stop a fully loaded car. On traction elevators, unintended car movement protection and the emergency brake are tested in the down direction with the overload, starting from a landing above the bottom floor, and the governor overspeed switch setting is verified. Hydraulic elevators follow their own Category 5 protocol; overspeed testing is generally not required on hydraulics because they operate on a different mechanical principle.
Missing a Category 5 deadline is one of the fastest ways to have a unit pulled from service. The tests require specialized equipment and a qualified team, so schedule them well before the 60-month mark.
Door Reopening Devices
Doors cause a disproportionate share of elevator injuries, and ASME A17.1 Section 2.13.5 requires reopening devices on horizontal sliding doors to detect both a person or object in the closing door’s path and a person or object approaching the entrance. Modern installations typically use infrared light curtains or time-of-flight sensors. Keeping these sensors in working order is a recurring MCP task, and a faulty reopening device is one of the more common inspection write-ups.
Emergency Communication Systems
The 2019 and later editions of ASME A17.1 expanded what emergency communication in an elevator has to do. A basic phone handset and an alarm bell no longer satisfy the code in jurisdictions that have adopted these editions.
Current requirements call for two-way voice, video, and text communication between the car and authorized emergency personnel. The text channel serves passengers who are deaf, hard of hearing, or speech-impaired. On elevators with a rise of 60 feet or more, the system must give emergency responders an on-site way to view passengers anywhere inside the cab through video monitoring. Passengers must receive visual confirmation that their call for help was received and that help is coming, and responders need the ability to update in-cab messaging to signal they are present. The 2022 edition added resilience requirements for power or network failures and introduced cybersecurity considerations for connected systems. If your emergency communication is still phone-only, an upgrade is almost certainly ahead of you.
Fire Service Operation
Elevators in buildings with fire service features must support two phases of emergency operation. Phase I (firefighter recall) automatically returns all cars to a designated landing, usually the ground floor, when the fire alarm activates or when a firefighter turns a key at the designated level. Phase II gives firefighters manual control of a specific car from inside the cab so they can override normal operation and travel to the fire floor.
Phase I operating instructions must be posted next to the Phase I key switch at the designated level and in the fire command center. Phase II instructions must identify the location of machine and control rooms. Fire service operation is a specific maintenance and inspection item under ASME A17.1, and every test has to be documented with the identity of the person who performed it.
ADA Obligations That Run Alongside
ADA accessibility is a separate legal track from the ASME code, and a passing ASME inspection does not mean you meet ADA standards. The 2010 ADA Standards for Accessible Design apply to new construction and alterations in most public and commercial buildings and cover elevator details that routine maintenance can quietly let slip out of compliance.3United States Department of Justice. 2010 ADA Standards for Accessible Design
- Hall signals must be visible and audible at each hoistway entrance, indicating which car is answering and its direction. Audible signals sound once for up, twice for down, or use verbal annunciators. Visible fixtures are centered at least 72 inches above the floor.4U.S. Access Board. Chapter 4: Elevators and Platform Lifts
- Floor designations at hoistways must appear in raised characters and Grade II Braille on both door jambs, mounted 48 to 60 inches above the floor. The main entry level requires a tactile star symbol on both jambs.4U.S. Access Board. Chapter 4: Elevators and Platform Lifts
- Door timing from arrival notification to the start of closing is calculated by dividing the distance from the farthest call button to the hoistway door centerline by 1.5 feet per second, with a 5-second minimum. Doors must stay fully open for at least 3 seconds in response to a car call.3United States Department of Justice. 2010 ADA Standards for Accessible Design
- Car control buttons must be at least three-quarters of an inch in the smallest dimension, raised or flush with the faceplate, and labeled with raised characters and Braille.4U.S. Access Board. Chapter 4: Elevators and Platform Lifts
Braille plates wear down. Hall signals burn out. Door timing drifts. Your maintenance contract should say, in writing, that the contractor is responsible for keeping these components within ADA specifications.
Inspections and the Certificate of Operation
Maintenance is what your contractor does. Inspection is the independent check that your contractor did it correctly. Most jurisdictions require these roles to be filled by different entities to avoid conflicts of interest.
You must arrange for a qualified third-party inspector to examine each elevator, typically on an annual or semi-annual schedule set by local rules. The inspector verifies that required maintenance and safety tests have been performed and documented and that the equipment complies with the adopted code edition. Inspectors are commonly certified as Qualified Elevator Inspectors under the ASME QEI-1 standard.5The American Society of Mechanical Engineers. QEI-1 – Standard for the Qualification of Elevator Inspectors
Pass and the regulatory authority issues a Certificate of Operation, which must be conspicuously displayed inside the car or attached to the equipment. Fail and you get a violation report; depending on severity, the unit may be placed out of service until repairs are made and a re-inspection confirms compliance. Annual permit and certificate fees vary widely, generally from under $100 to over $1,000 per unit.
Who Is Legally Allowed to Do the Work
Elevator work is not general contractor work. Jurisdictions require specific credentials at three levels.
The maintenance company must hold a jurisdiction-specific license and carry both liability insurance and workers’ compensation. General liability minimums range from around $300,000 per occurrence in some states to $1,000,000 or more in others. Hiring an unlicensed company can void your maintenance records for compliance purposes and leave you fully exposed if something goes wrong.
The individual mechanics on the job also need credentials. Requirements typically include documented journey-level experience (often two to five years), completion of a recognized apprenticeship, or passing a qualifying state exam. The systems involve high-voltage electrical work, hydraulic pressure, and mechanical safeties where errors can be fatal, so these are not paperwork formalities.
Third-party inspectors carry QEI certification through NAESA International, which requires substantial hands-on industry experience before a candidate can sit for the qualifying exam.6NAESA International. Elevator Inspector QEI Training
Records You Have to Keep, and for How Long
Most compliance failures happen here. Not because the maintenance was skipped, but because nobody can prove it was done. An inspector who cannot review the records treats it the same as if the work never occurred.
MCP records must be available on-site as a hard copy and must include, at minimum, the site name and address, the service provider’s name, conveyance identification and type, the date of each entry, a description of each maintenance task with its scheduled interval, and confirmation that the task was completed. Repair and replacement records are a separate category: they must include an explanation of the work performed, the date, and the name of the person or firm who did it.
Additional on-site records for each unit include oil usage logs, findings from firefighter service testing (with the tester’s identity), periodic test documentation, and component replacement compliance records. Instructions for locating the records must be posted on the controller or at the test access point, in permanently legible characters at least 3 millimeters high.
Retention periods split by record type. General maintenance records must be kept for the most recent five years or from the date of installation, whichever is shorter, unless local authority specifies longer. Repair and replacement records are permanent, kept for the life of the installation. Equipment documentation that must also stay on-site includes wiring diagrams, the initial declaration of conformity, and the current Certificate of Operation.1The American Society of Mechanical Engineers. A17 – Elevators and Escalators Offerings
One detail that trips people up during a sale or a service change: these records belong to the building, not to the maintenance contractor. When you switch providers, the outgoing company must leave the records behind. If they don’t, or the records were never properly created, the gap becomes your problem at the next inspection.
Choosing the Right Maintenance Contract
Contract scope varies more than most owners realize, and the difference has real consequences. The two main types are full-service contracts and oil-and-grease contracts (sometimes called examination-and-lubrication contracts).
A full-service contract covers routine preventive maintenance, parts, repairs, callbacks, and typically all labor. The maintenance company takes responsibility for keeping the equipment running and code-compliant. This is the contract type that provides the strongest liability protection because the contractor assumes comprehensive control of the equipment.
An oil-and-grease contract covers basic lubrication and minor adjustments on a schedule. Everything else, including parts, repairs, testing, and callbacks, is billed separately. These contracts cost less at signing but can run more expensive over the life of aging equipment, and they leave the owner holding more responsibility for spotting problems and keeping the equipment code-compliant.
Whichever you sign, verify that it explicitly covers all MCP tasks required by your adopted code edition, includes Category 1 and Category 5 testing, and addresses ADA components. Read the indemnification clause. A comprehensive maintenance agreement where the contractor has exclusive control of the equipment is a meaningful legal shield if something goes wrong. A minimal contract without clear indemnification language is not.
What Happens When Maintenance Falls Short
Building owners have a common-law duty to maintain their premises in a reasonably safe condition, and elevators are part of that. A person injured in an elevator can bring a premises liability claim by showing a defect existed, the owner had actual or constructive notice of it, and the defect caused the injury. Even with a maintenance company on contract, you can be held liable if you knew about a problem and did not notify the contractor.
The strongest defense is documented proof of regular inspections and maintenance, including what was done immediately before the incident. Courts and adjusters look for three things: when the elevator was last inspected before the incident, what those inspections covered, and whether they happened on every scheduled visit. If you cannot produce that evidence, it can be fatal to your defense. This is why the record-keeping requirements matter in the real world, not just on the compliance checklist.
A comprehensive full-service agreement where the contractor holds exclusive control of the equipment shifts significant liability to the contractor, and many such contracts include a clause requiring the contractor to defend and indemnify the owner for the contractor’s own negligence. Without that agreement, or with only a bare-bones oil-and-grease contract, the owner keeps more exposure. Penalties for operating an elevator with an expired permit or unresolved violations vary by jurisdiction but can reach several thousand dollars per unit per violation, on top of the injury liability if something happens while the elevator is out of compliance.