Comments in Opposition to Proposed HB 107 Language

Summary

Written comments dated April 12, 2021 to the Ohio House of Representatives Commerce and Labor Committee, addressed to Representative Baldridge, from the president of Access Solutions, Inc., an Akron accessibility business. The letter opposes the proposed HB 107 language as of April 2021. It argues that the licensing requirements appear to be based on commercial elevators and that accessibility equipment such as stairlifts, vertical platform lifts and incline platform lifts should be exempt, noting that this equipment falls under the A18.1 safety standard. It states that current Ohio Revised Code requires permit applications to the Ohio Elevator Division and inspection for such lifts in non-residential buildings, and that the bill would add administrative burdens and disadvantage smaller companies. The two-page letter asks that the bill not be voted into law in its current form.

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Full text

ACCESS SOLUTIONS”
EEE

INCORPORATED]

Residential Elevators * Lifts * Stairway Lifts

April 12, 2021

Ohio House of Representatives Commerce and Labor Committee
Comments in opposition to proposed HB 107 language as of April, 2021.
Representative Baldridge,

My name is Mike Simko, president of Access Solutions, Inc., a veteran owned accessibility business
based in Akron and serving northeast Ohio that opened 24 years ago.

We are opposed to the current language and intent of the proposed bill for a few reasons:

The proposed licensing requirements appear to be based solely on larger commercial elevators and their
attributes. While there has been some revision with respect to residential elevators and stairlifts, we
feel that the entirety of what is typically referred to as accessibility equipment (i.e., stairlifts, vertical
platform lifts, incline platform lifts) should be exempt from the proposed language. This equipment all
fall under A18.1 safety standard, which itself is in section A17.1.

Additionally, accessibility equipment is not “elevator equipment” With the current language, any
personnel engaged in installing or servicing accessibility equipment would be required to obtain an
elevator mechanic’s license. Likewise, any company engaged in selling, installing and servicing
accessibility would be required to obtain an elevator contractor’s license. The required curriculum as
mentioned in the proposed bill is focused on commercial elevators. This could be likened to anyone
driving an automobile being required to obtain a CDL. This is a case of grouping “apples and oranges”
together when they are, in fact two different things.

Additionally, the bill is being touted as a public safety measure. To date | am not aware of any data
indicating statewide public safety concerns involving the accessibility industry. Current Ohio Revised
Code requires that any vertical lift, stairlift or incline lift in a non-residential building have a permit
application and drawings submitted to the Ohio Elevator Division for review for a permit. Once the
project is complete, the equipment cannot be put into service until it has been and inspected and a
weight & safety test is witnessed by the inspector for compliance with the applicable national safety
code. It would appear that current regulation for this type of equipment is quite reasonable.

When evaluating whether current regulation needs to changed, Or if there is enough regulation, | would
have to answer “no”, it doesn’t need to change in terms of requiring a full elevator mechanic’s license to
work in the accessibility arena and I'd have to say yes, there is currently enough regulation. If either of
these questions need debated, the debate should be made and conclusions arrived at prior to moving
this legislation forward.

o 2415 Gilchrist Road « Akron, Ohio 44305
hbal PH: 3307537499 » TOLL-FREE: 888+269«1622 « FAX: 330°753°7488
BSB ™hbal E-MAIL: AccessSolutions@msn.com wey

www.AccessSolutionsOnline.com
ACCESS SOLUTIONS”
RES |

INCORPORATED]

Residential Elevators * Lifts « Stairway Lifts

Additionally, in terms of regulation, should this legislation end up coming to fruition, it would result in
additional layers of administrative and regulatory burdens at the state level, as described in the
proposed bill, yet with no real change in public safety since the current permitting and inspection
regulations would not change.

Overall, it is our opinion that enacting the bill as currently written would result in the many smaller
companies and employees working in the accessibility industry being put at a disadvantage. It can also
be interpreted as imposing limitations on who can perform their trade in an industry they have helped
establish.

It seems prudent to not vote this version into law but to allow additional discussion and revision of the
language for the mutual benefit of all in the industry.

Thank you again for your time and consideration of these matters.

Zyf J J 4

Access Solutions, Inc.

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2415 Gilchrist Road *« Akron, Ohio 44305

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BEB PH: 33075307499 » TOLL-FREE: 88842691622 » FAX: 330*753+7488 Be

i guantees E-MAIL: AccessSolutions@msn.com
www.AccessSolutionsOnline.com

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