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[Interpretation of the Special Equipment Safety Law] Article 22

2021-01-17View Original

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Article 22: The installation, modification, and repair of elevators must be carried out by the elevator manufacturer or by a unit entrusted by it that has obtained the corresponding permits in accordance with this Law. If an elevator manufacturer entrusts another entity to carry out the installation, modification, or repair of elevators, it shall provide safety guidance and supervision for such installation, modification, or repair, and conduct inspections and adjustments in accordance with the requirements of safety technical specifications. The elevator manufacturer is responsible for the safety performance of the elevator. Interpretation of the provisions: This article sets out the requirements for the entities responsible for the installation, modification, and repair of elevators, and clarifies the responsibilities and obligations of elevator manufacturers in these processes. The quality of elevator manufacturing, installation, modification, and repair has a direct impact on the safety of elevators; these activities must be strictly regulated with clear requirements established. Having the same elevator company responsible for the manufacturing, installation, modification, and maintenance of elevators helps ensure elevator safety and protect the brand, clarifies responsibilities, and is also the trend in the development of elevator manufacturing companies. As the market approaches saturation, many large elevator manufacturers are now shifting from a focus on manufacturing to one centered on installation, renovation, repair, and maintenance. An elevator is a special type of electromechanical product; it leaves the factory in the form of components, and only after installation does it become a complete product. Installation is essentially the final assembly process for the elevator, representing a continuation of the manufacturing process. Elevator products are installed by installation units, which play a decisive role in the quality and safety of the elevators; the installation process has a significant impact on the quality and safe operation of elevators. Many of the technical requirements for installation should be in accordance with those of the manufacturing company, and it should be carried out under the guidance of that company. Currently, the post-installation testing of most elevators is carried out by the manufacturing companies, which effectively ensures the quality of the elevators. After the elevator is put into use, it also maintains an inseparable relationship with the manufacturing company, such as providing spare parts, outlining maintenance requirements, and offering technical support in case of problems. Elevator renovation is essentially a special form of elevator manufacturing; it requires not only strong design, commissioning, and testing capabilities but also an installation team with corresponding skills. In fact, elevator renovation involves a higher level of technical expertise than ordinary elevator manufacturing. To address the aforementioned issues, this provision stipulates that the installation, modification, and repair of elevators must be carried out by the elevator manufacturer or by a unit entrusted to it and that has obtained the corresponding permits in accordance with this law. Elevator manufacturing companies possess the technical knowledge related to elevators and play a key role in determining their quality; therefore, they are obligated to provide guidance to other companies involved in installation, modification, and repair, to oversee the quality of their work, and to test the elevators after they have been installed. This allows elevator manufacturers to make the most of their technical advantages to serve society, while also clarifying the safety responsibilities related to elevators. The term “units that have obtained the corresponding permits in accordance with this law” refers to enterprises that have acquired the qualifications for elevator installation, modification, and repair ; The said “elevator manufacturer”, in terms of installation and repair activities, refers to the original elevator manufacturer. Such regulations enable a \"one-stop\" service for elevator manufacturing, installation, and repair, ensure the supply of spare parts, give better play to the primary role of manufacturing enterprises, and contribute to improving the quality and safety standards of elevators as well as clarifying responsibilities. In the case of renovation, when the original manufacturer no longer exists, the entity that owns the elevator may choose a qualified company to carry out the renovation. It is necessary to replace the product nameplate in accordance with the relevant safety technical specifications for elevators, and the company responsible for the renovation must be accountable for the quality of the elevator as well as any quality issues related to its safe operation.

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