Sesame Access Systems in the North American, Canadian and USA market place.
Sesame have designed, built and installed the Sesame Seattle ADA Lift in Seattle USA specifically conforming to the relevant areas of ASME 18.1 and also to the requirements of the City of Seattle and The State of Washington.
Sesame Systems installed in the North American market need to be designed, built and installed to conform where possible to the North American standard ASME 18.1 “Vertical Platform Lifts Where Runway Enclosures are Not Provided”, amongst others later detailed.
It is important to note however, as the Sesame horizontal retracting stairs are patented to Sesame Access Systems, the North American standard ASME 18.1, and even the British and European equivalent Standards do not cover all elements of our novel invention.
So far this has not caused Sesame a problem.
We have installed Sesame systems in every country in the UK, Ireland, France, Germany, Qatar and even as far as Australia. In all these cases the elevators were design to conform to the local standards with the emphasis on quality and safety.
Like in the UK and in the US, these international elevators need to be and were successfully signed off by the local building control officer equivalent. Importantly, on all installations, including installs here in the UK, we speak to the Building Control Officer to make them aware of the product to seek their advice during the design stage to ensure they will be satisfied when it comes to final sign off.
The following image is the Sesame Seattle Lift designed specifically for the USA market conforming to the relevant areas of ASME 18.1
Sesame Entry into the North American Market “Self-Assessment” Option 1
The North American equivalent of our UK Building Control Officer is the relevant AHJ “Authority Having Jurisdiction”. As you probably know the relevant AHJ ensures that the construction adheres to the approved plans and the local building code. Other AHJ may be looking into electrical product safety for example. Once construction is complete and a final inspection has been passed, an occupancy permit may be issued, and equipment approval may be gained from relevant AHJ, noting that AHJ such as relating to equipment safety is not mandatory and in many cases such AHJ is never involved.
UL “Underwriters Laboratories Inc.” approval or listing is not legally required for product entry into North America or for the AHJ to issue a permit to use equipment. The general principle is that the company placing equipment into use is responsible for its safety but the manufacturer is also expected to take all reasonable measures to ensure the equipment is safe for the purpose. UL listing of a product is not a legal requirement . It's only common because many large companies will not buy equipment that has not passed UL's safety tests.
UL is not the only approved testing body, there others such as CSA ”Canadian Standards Association” and ETL “Originally a mark of ETL Testing Laboratories, now a mark of Intertek Testing Services.” Here in the UK we have CE “Conformance European” system.
All Sesame lifts are CE marked which shows that we have checked that our products meet EU essential safety, health or environmental requirements, it is also an indicator of a product’s compliance with EU legislation which allows the free movement of products within the European market.
All of the above bodies will test products to the relevant safety standards to show evidence to a client that the product is safe in accordance to those standards. However, when there are elements (such as horizontal retracting stairs) that are not covered in the standards this cannot be tested, at least not to a national or international harmonised standard.
Elements of the Sesame system which are not covered in the US safety standards, such as the horizontal retracting stairs will be risk assessed by a US acknowledged process known as the Engineering Hazard Safety Analysis. This could be handed to the AHJ if requested. However its main purpose is to facilitate a safety study of the equipment design by its manufacturer. As mentioned above it would be useful for the AHJ to be involved in the design phase where these elements will be highlighted so that the AHJ can have their input and the design can allow for their recommendations if any.
To cover Sesame for the complete electronic side of the install, which we have been informed is the most important part of a AHJ’s assessment (due to possible electric shock risk or fire risk with some kinds of electrical circuits), Sesame Access will have the electronic components of each Sesame system assembled by a UL approved Panel builder and the apnel will be UL approved. This way each bespoke panel is built to the high UL standards, and will importantly present the UL mark to the AHJ. Typically this should result in a simple boxed ticked for the electronic side of the assessment. If the AHJ were to investigate further then as the panel will be built by a UL Panel builder it will comply with all the relevant standards namely UL 508A and CSA C22.2 No. 14 plus relevant parts of US and Canadian electrical codes if the design is for the USA and Canada and we will simply issue the paperwork to ensure the box is ticked.
There are other specific safety standards that we will need to conform to as shown below, again which will be introduced during the design phase however it is important to note that the following standards are looking for the same quality control levels, and are similar to our European Standards and our Machinery Directive. In addition ASME 18.1 is very similar to our British Standard BS6440:2011 and our European equivalent EN 81-41:-
- The installation of electrical equipment and wiring shall conform to the requirements of ANSI/NFPA 70
- Electrical equipment shall be certified to the requirements of CAN/CSA B44.1/ ASME A17.5
- Driving-machine chains and sprockets found in our rising barriers shall conform in design and dimensions to the requirements of ANSI ASME B29.1
- Glass (when used) shall be tested and conform to the acceptance criteria for laminated glass as specified in ANSI Z97.1 or 16 CFR, Part 1201, Section 1201.4
- Welding of steel shall be done in accordance with the applicable section of ANSI AWS D1.1 or ANSI AWS D1.3. The welder shall be permitted to be qualified by the manufacturer as competent using internal testing’s.
- Hydraulic tubing and fittings in conformance with SAE Standard J524 for tubing and SAE Standard J514.
- CSA C22.2 No 14 for Canada
- NFpA 79 electrical safety of machinery for the USA
To give assurance to the client Sesame will instruct a local third party such as Product Approvals http://www.productapprovals.co.uk/ who will carry out an independent Compliance Strategy Review on the specific product coming to the clients site. They will consult with Sesame to ensure all the local standards are met and will issue reports to Sesame which will be shared with the client. Product Approvals Ltd is an established specialist global product certification consultancy with extensive experience in gaining UL and other third-party US product safety approvals and facilitating US and Canadian market entry. Founder John Showell first gained experience of obtaining UL approvals in 1995.
In summary to the information given above, Sesame Access Systems can bring our product range to the US market without UL Listing. The important element is the final sign off by the local AHJ if this is a local AHJ requirement. This is why, like all Sesame local and international installs, the Sesame System is designed, built and installed to conform to the local relevant standards and national / Federal standards and where the standards do not cover our lift or there are small variations to the standards Sesame will issue Engineering Hazard Safety Analysis for these areas. We ask to speak to the AHJ officer to lay out the designs to them for their input and would be happy to meet on site or their offices for this discussion.
Sesame Entry into the North American Market “UL Listing” Option 2
If the client insists on UL listing for the specific Sesame Product then that is possible, but it comes at a cost financially and with time. As stated above please know that this is not a legal requirement for the installation of the Sesame elevators.
UL operates under its own authority as an independent, , nongovernmental organization.
To establish certification, samples of a product submitted by manufacturers for certification are tested and evaluated. If UL decides the product fulfils all applicable requirements it authorizes the manufacturer to apply a certification mark to production of the samples submitted, or issues a certificate or notification that the product is now certified by UL. A report of the evaluation is provided to the manufacturer. Before the manufacturer releases products with a certification mark, UL must initiate Follow-up Service in which periodic audits of products at the factory are completed by UL Follow-up Services (FUS) department.
If we had one product that we built the same each time then we would have a UL listing already. This is not the case, Sesame currently has over 20 different product styles, please see the below just 5 examples of the 32 product range:-
- The Seattle ADA Lift
- The Mayfair Stairlift installed in locations such as the Institute of Civil Engineers, with variations of this style installed in The Institute of Engineering Technology and Sydney Opera House
- The Richmond Rising Platform Lift installed in Scotland and London
- The Victoria Chair Lift with vertically retracting stairs installed in locations next to Harrods in London and the University of Westminster.
- The Edinburgh Access Lift installed in private residences and soon to be installed in clinics in Harley Street London
To achieve UL listing for one of the 32 product styles would take approximately 6 months to complete and could cost approximately £45,000 with consultancy fees, and UL assessments, followed by an annual £3,500 fee for quarterly factory assessments. These figures are based on quotes received in May 2018.
As mentioned, if we were only bringing just one product to market then we would have already carried out this process.
The problem lies with the nature of what it is Sesame achieves as a brand. We build bespoke wheelchair lifts to sit hidden within its environment. As each staircase changes from site to site the product changes, which is demonstrated in our large range for products. According to UL listing criteria, each Sesame variation will need to have its own UL listing.
In summary to the above information, unless the client is willing to invest in this process with Sesame then it is not the way to proceed on a one off product, which brings us onto the next option.
Sesame Entry into the North American Market “UL field Evaluation” Option 3
Within this process UL will visit our workshop here in the UK to assess the specific Sesame system to be installed in the clients site. This process will assess the elevator for its conformance to the relevant local North American standards as detailed above. Once the assessment has been completed and the UK based UL inspector is satisfied, they will pass it for release to be installed in North America.
Once the elevator is then installed on site UL will then send another assessor to site to ensure that nothing has changed from the UK based assessment. They will also inform and invite the local AHJ along for this assessment. If successful the UL inspector will then pass the equipment to UL standards. Again, this is not a legal requirement (for example AHJs are able to authorise or not authorise use of equipment without involvement of a body such as UL). It would be then down the AHJ to carry out their own assessment to pass the Sesame lift to allow the building to achieve an occupancy permit or at least for the equipment to be ‘signed off’
While the UL pass will hold some credibility it does not automatically mean it will be passed by the AHJ. This is solely dependent on Sesame conforming to the local standards and as discussed any variations to the standards will need to be presented and approved by internal Engineers Hazard Safety Analysis.
This process is a good go between for a full UL listing and none at all. It is certainly significantly cheaper than a full UL listing but it still comes with a cost.
This process should not add a significant amount of time to the completion , but there will always be an element of time allocated to its estimated at 1 month to the Sesame schedule.
Sesame has completed a very similar process to this in the past for a lift installed in Germany with TUV rather than UL. The Sesame system was built to the local standards EN:81-41 and the Machinery Directive which is what TUV assessed the lift to. The Sesame system passed with flying colours. Again this was at a request of a client as it was not a legal requirement for install. It was not requested by other European clients.
For further information or questions on Sesames involvement in the North American market please give us a call