Date: August 10^th 2026

ASME A17.1-2022 – Controller Replacements and Alterations

The Oklahoma Department of Labor, Elevator Safety Program, is issuing this notice to clarify the Department's policy regarding the application of ASME A17.1-2022 alteration requirements when an elevator controller is replaced.

The Department will continue to consider the replacement of an elevator controller to be a complete alteration requiring compliance with the applicable requirements of ASME A17.1-2022, Section 2 for electric elevators or Section 3 for hydraulic elevators, as applicable.

However, the Department recognizes that the alteration requirements contained in Section 8.7 establish specific provisions and exceptions that govern the application of the requirements of Sections 2 and 3 to alterations. Where Section 8.7 specifically excludes or does not require compliance with a particular provision, that provision will not be required solely as a result of the controller replacement.

Specifically, the Department will no longer require compliance with ASME A17.1-2022, Section 2.1.7, Illumination of Hoistways, solely as a result of a controller replacement when the applicable alteration provisions of Section 8.7 do not require compliance with that provision.

This clarification does not change the Department's position that a controller replacement is a complete alteration requiring compliance with the applicable requirements of Section 2 or Section 3. Rather, this clarification recognizes that the specific alteration provisions contained in Section 8.7 govern the application of those requirements and that any exceptions or exclusions identified within Section 8.7 shall be observed.

This policy clarification is intended to provide consistent application of the requirements of ASME A17.1-2022 and to provide clarity to elevator owners, building owners, elevator contractors, design professionals, and other affected parties regarding the requirements applicable to complete alteration projects.

The Department will apply this clarification to applicable permits and projects currently under review, previously approved, or otherwise in progress, regardless of the date the permit was issued or approved, provided the project has not already completed the installation of the hoistway lighting at issue.

If you have any questions regarding this policy or its implementation, please contact

Neal Petersen
Department of Labor
Chief Elevator Inspector
405.763.8059
Neal.Petersen@labor.ok.gov