Get the app — iOSSSPI in British Columbia
When did the step/skirt test actually start applying? It has two defensible start dates here, not one — and the date most often quoted is wrong.
SSPI in British Columbia: when did the step/skirt test actually start applying?
The has two defensible start dates in BC, not one — and the date most often quoted is wrong. This traces every BC elevating-devices code adoption on the public record, and shows exactly where the SSPI confusion comes from. Every BC date here links to the regulation it came from.
Two different marks on this page: explains a term in place. A blue link with an arrow, like the Safety Standards Act, opens the source document in a new tab.
A code edition's year is not the date it applied to you
CSA and ASME publish an edition. Every province, state and city then decides separately whether and when to make it law — this second step is called . “B44-2000” is a document published in 2000 — it did not become mandatory in British Columbia until June 2003. Ontario was more than a year ahead — its published TSSA advisory (listed in the sources) applies B44-2000 to units registered from 23 March 2002.
Almost every question further down this page traces back to that gap. The limits that apply to a unit are set by the edition in force in your jurisdiction on that unit's .
From the invention of SSPI to today
Two kinds of event share this timeline: what the code did, and what became law in British Columbia. Keeping them apart is the whole trick — a requirement can exist in the code for years before it means anything where you work.
20031 Jun
How to find this in the document
1. Open the link above.
2. Use your browser's find-on-page and search for in the alternative
3. It sits in section 1, near the top.
It reads: “Effective February 1, 2003, the following safety codes in Column 2 are adopted in whole … and may be applied in the alternative to the safety codes in Column 1 between February 1, 2003, and May 31, 2003”
How to find this in the document
1. Open the link above.
2. Search the page for no longer apply
3. That is section 2. Section 3 immediately below it is the permit exception.
Section 2 reads: “Effective June 1, 2003, the safety codes in Column 1 of the table in section 1 no longer apply and the safety codes in Column 2 of the table in section 1 continue to apply.”
To confirm no updates were adopted: search the same page for Update No — you will get no results. That absence is the evidence.
How to find this in the document
Read this first. Searching this regulation for “loaded gap” returns nothing, and that is expected. A regulation adopts a standard by name; the technical rule itself lives inside the CSA book, which is not free to read. What this regulation proves is which book is law in BC and from when — not what the book says.
1. Open the link above. Check the header says “Deposited March 23, 2004”, “effective April 1, 2004”, and “current to April 2, 2004”.
2. Search the page for Update No.1 (no space after the full stop — that is how the regulation types it).
3. It lands you in the Schedule, the very last part of the document, below Part 7 — under Adopted Safety Codes → Canadian Standards Association (CSA) Standards → Item 1, Column 1.
4. Watch the columns. Search for Column 1 of the Schedule to land on section 17, which says the codes in Column 1 are the ones adopted and Column 2 holds the exceptions. In the older Reg 29/2003 the columns mean the opposite way round, so reading the wrong one reverses the answer.
How to find this in the document
What the Gazette is: the government's official record of new and amended regulations. Each entry gives the regulation number, the date it was deposited, and what it changed.
1. Open the link above and search the page for B44-04
2. In Schedule 2 of the order, Item 1 of the Elevating Devices Safety Regulation Schedule is repealed and replaced with “CSA Standard B44-04 with B44S1-06 Supplement No. 1 and Update No. 1 of May 2006”. The order is deposited 14 February 2007 and takes effect 15 February 2007.
For the directive's side of the story, see Directive D-ED 2014-01 in the sources at the foot of this page — the archived copy is a short PDF and the relevant sentence is on the first page.
How to find this in the document
1. Open the archived PDF above. It is two pages, so everything below is on screen quickly.
2. The dates sentence is in Specific Details, page 1: “Step/Skirt Performance Index Testing became part of the CAN/CSA B44 code in the 2004 code edition. The effective date of this edition in British Columbia was on 15th Feb 2007.”
3. Scope is the lettered parts: (A) New or Altered Escalators and (B) Existing Escalators. Part (B) has two branches — one for units built to B44-04 or later, one for units built before it. Both require verification.
4. The equipment deadline is the paragraph on page 2 beginning will have 60 days
Note the letterhead: it reads BC Safety Authority, the organisation’s name before it became Technical Safety BC.
The nine and a half year edition
Because BC skipped both B44-10 and B44-13, the province ran on B44-07 continuously from November 2010 to April 2020. Anyone assuming BC must have been on the 2013 code in, say, 2015 would be wrong — worth remembering when working out which edition governs a unit registered in that window.
So which date do I actually use?
First, the thing most people get wrong: these dates are about when the requirement entered BC law. They are not a cutoff for which escalators get tested.
SSPI is part of the Category 1 periodic test (requirement 8.6.8.15.19). Section 8.6 of the code governs maintenance and testing of units already in service, and it says plainly:
“Section 8.6 applies to maintenance, repairs, replacements, and testing. Maintenance, repair, and replacement shall be performed to provide compliance with the Code applicable at the time of installation or alteration.”
— ASME A17.1-2016/CSA B44-16, Section 8.6
So an older escalator is not exempt. What changes with a unit's vintage is the threshold it has to meet, not whether it gets tested. That is exactly why Ontario's published table lists every era from 1962 onward with different pass criteria — every row gets tested, the numbers differ. Existing installations have their own SSPI limits in A17.3 (0.15, or 0.4 with a skirt deflector).
Then what are the two dates?
They are two different answers to “when did this become a requirement in BC?”, because “SSPI” is used to mean two things:
- 1 April 2004 — the limit. When BC adopted B44-00 with Update No. 1, the update associated with the 5 mm loaded gap and the tightened index.
- 15 February 2007 — the edition the regulator points to. When BC adopted B44-04, which Technical Safety BC named as where SSPI testing came from.
Whichever of those two is right, it is not June 2003. That date brought in plain B44-00, which carried no loaded-gap requirement at all.
What the BC directive actually demanded
Worth reading carefully, because it is narrower than “test everything annually” and broader than “only new units.” Directive D-ED 2014-01 required SSPI testing:
- on all acceptance inspections for new escalators, and for major alterations; and
- after a step-to-skirt entrapment incident on an existing escalator — the unit is shut down and may not be worked on until the contractor has verified compliance in front of a safety officer.
And critically, that incident rule covers older units too. Where the escalator was installed under an edition prior to B44-04, the directive still requires verification — against “the applicable Code” for that unit's vintage. Pre-2007 units are measured by different numbers, not left alone.
If the regulation and a directive ever genuinely conflict, the regulation carries and a is guidance — though the directive still tells you what the inspector in front of you expects. This one was withdrawn after BC adopted B44-16.
That ranking is not an interpretation, it is written into the statute the directive was issued under. Safety Standards Act, section 30 lets a provincial safety manager “issue a directive on the interpretation, application or operation of this Act and the regulations,” and section 30(4) settles any clash:
“If there is a conflict between a regulation and a directive of a provincial safety manager, the regulation prevails.”
— Safety Standards Act, s.30(4)
Separate, genuinely enforceable instruments exist for when the regulator needs teeth: safety orders (section 31) and compliance orders (section 38), and contravening those is an offence. Directives are not in the offence provisions.
One honest limit: which CSA update first printed the loaded-gap clause has not been confirmed against the CSA text, which is paywalled. That is the single unresolved point on this page.
Reading these documents without getting caught out
The 2014 directive was rescinded. Does that mean I can ignore it — and does SSPI still apply?
SSPI still applies. Nothing about the rescission changes that.
Two separate things are easy to run together here:
- The code — SSPI is requirement 8.6.8.15.19, part of the Category 1 periodic test, in the edition BC has adopted. That lives in the regulation and is untouched by any directive being withdrawn.
- The directive — Technical Safety BC’s 2014 guidance, which added its own instructions on top: test at acceptance, and follow a set procedure after a step-to-skirt entrapment. That guidance is what was withdrawn.
Why it was withdrawn matters. Technical Safety BC’s own stated reason is that it was rescinded “as a result of the adoption of the ASME A17.1-2016/CSA B44-16 safety code” — the code moved on, so guidance written around the older edition was retired. It was not withdrawn because anyone decided it was wrong.
So why is it still on this page? Because it is the only document in which BC’s regulator ever said, in writing, where it considered SSPI to have come from. That statement is what creates the second candidate date. Its evidence value did not disappear when it was retired.
What to do today. Work to the current code, B44-16, in force in BC since 30 April 2020. For how Technical Safety BC now expects entrapment incidents and acceptance testing to be handled — the part the directive used to cover — ask them directly rather than relying on a withdrawn document or on this page.
I clicked through to the regulation looking for the actual rule, and it isn't there. Why?
Because regulations do not contain the technical rules — they adopt a standard by name. Search B.C. Reg. 101/2004 for “loaded gap,” “5 mm” or “110 N” and you will find nothing at all.
What the regulation gives you is the two things only a government can settle: which book is law here, and from what date. The measurements themselves live inside the CSA book, which is copyrighted and sold by CSA rather than published free.
That split is why this page ends up with an unresolved question. The BC dates are provable from free public records. What is printed inside CSA Update No. 1 is not — and that is exactly the piece that would settle whether SSPI starts in BC in 2004 or 2007.
What do “s.”, “ss.” and the regulation numbers actually mean?
Legal shorthand, and it is not obvious if nobody has told you:
- s.2 means section 2 — one numbered paragraph of the regulation.
- ss.2–3 means sections 2 and 3 — the double “s” is simply the plural.
- B.C. Reg. 101/2004 means it was the 101st regulation filed in 2004. The number after the slash is the year, not a section.
- O.C. 86/2003 is an Order in Council and M59/2004 a Ministerial Order — the two ways a regulation gets made. Which one was used does not change its legal force.
- Schedule is the list bolted to the end of a regulation. For elevating devices it is where the adopted code editions are actually named, so it is usually the part you want.
On this page the citations are written out in plain words, so “ss.2–3” appears as “sections 2 and 3.” You will still meet the short forms in the documents themselves.
The Schedule says “Update No. 1 of September 2002.” Doesn't that mean BC adopted it in September 2002?
No. September 2002 is CSA's publication date for that update booklet. It identifies which document is being adopted, the way a revision date identifies a manual. It says nothing about when BC took it on.
The giveaway: that single entry lists three different dates — Update No. 1 of September 2002, No. 2 of May 2003, No. 3 of December 2003. They cannot all be adoption dates, because one regulation comes into force on one day. BC's date is in the regulation's header: “Deposited March 23, 2004,” “effective April 1, 2004.”
Proof it was not in force earlier: CSA published Update No. 1 in September 2002. BC then drafted an entirely new regulation — Reg 29/2003, deposited 30 January 2003, four months later — and adopted plain B44-00 with no updates at all. The update already existed and BC did not take it. It sat unadopted here for roughly nineteen months.
Where in the regulation is this actually written? I couldn't find it.
It is in the Schedule — the last entry in the contents list, below Part 7, so scroll to the bottom. Then: Adopted Safety Codes → Canadian Standards Association (CSA) Standards → Item 1, Column 1.
Watch the columns — they mean opposite things in the two regulations. In Reg 29/2003, Column 1 is the outgoing code and Column 2 the incoming one. In Reg 101/2004, section 17 states: “The codes listed in the Column 1 of the Schedule are adopted with the exceptions indicated in Column 2 of the Schedule” — so there Column 1 is the code actually in force and Column 2 is the exceptions. Reading the wrong column reverses the answer.
Why link an old archived version instead of the current regulation?
Because a regulation is amended repeatedly, and the current text shows only today's wording. Quoting that leaves a fair objection open: was “Update No. 1” in the original, or inserted by a later amendment?
The consolidation current to 2 April 2004 is the text as it stood one day after the regulation took effect, before any amending regulation touched it. That is what pins Update No. 1 to 1 April 2004 rather than to some later date.
The other half of the proof is an absence check: the phrase “Update No.” appears nowhere in Reg 29/2003 — not in the consolidation current to 1 August 2003, and not in the consolidation current to 1 December 2003, which still shows plain B44-00 six months after the June 2003 changeover. (BC Laws does not publish an as-enacted copy of this one, so these two dated consolidations are the earliest checkable text.)
How can Technical Safety BC and the regulation say different things? Don't they have to agree?
Technical Safety BC is not a separate body from the regulation — it is the delegated authority that administers the Safety Standards Act and the elevating devices regulations. A genuine contradiction would be surprising, and there probably isn't one.
They answer different questions. The regulation answers “when did the code containing the loaded-gap limit become law here” — April 2004. The directive answers “when did SSPI field testing become an obligation” — and points at the 2004 edition, February 2007 in BC. Same three-letter shorthand, two different requirements.
Where they genuinely diverge, the regulation carries legal force and the directive is guidance.
Does BC publish an SSPI table with the index and clearance limits?
No. A sweep of Technical Safety BC’s published regulatory notices, plus archived captures of its older site, found no BC document stating a numeric index limit, a clearance table, or the 110 N force. Ontario's TSSA publishes exactly that kind of table; BC never has.
The closest BC-published figures appear in an incident investigation, which restates a 5 mm maximum loaded step gap and a 0.15 maximum index for escalators without — as narrative, not as a regulatory table.
Terms used on this page
- SSPI — step/skirt performance index
- A single number describing friction between the step and skirt panel while the escalator runs. Lower is better.
- Loaded gap
- The step-to-skirt gap measured while 110 N (25 lbf) is pushed sideways from the step against the skirt.
- Skirt deflector
- Brushes or rigid strips along the skirt panel that keep feet and clothing away from the gap.
- Adoption
- A government making an outside standard part of its own law. Until then the edition has no legal force there.
- Edition / update / supplement
- The full code book, versus the smaller booklets issued between editions. Each must be adopted separately to have force.
- Deposited
- The date a regulation is formally filed with the province — usually shortly before it takes effect.
- Schedule
- The list at the end of a regulation naming every outside standard it adopts.
- Consolidation
- A regulation's full text as it stood on a given date, with amendments folded in.
- Point-in-time record
- A BC Laws view showing what a regulation said on a past date and which amendment changed it.
- Directive
- Regulator guidance on interpretation and enforcement. Not legislation, and cannot override a regulation.
- Rescinded
- Formally withdrawn; no longer the regulator's current position.
- Authority having jurisdiction (AHJ)
- The body that enforces the code where you work — in BC, Technical Safety BC.
What this page does not settle
- What is printed inside CSA Update No. 1. That text is paywalled and has not been read directly. That Update No. 1 carries the loaded-gap clause is inferred from Ontario's published table and from the equivalent ASME change. Confirming it would settle the April 2004 versus February 2007 question outright.
- BC adoption dates for B44-85 and B44-94. The online archives do not reach back far enough. B44-94 can be shown in force immediately before February 2003, but not when it was adopted.
- Directive D-L4 101125 5 (“Adoption of B44-07 Safety Code,” 1 December 2010). Only a rescission stub survives; no archived copy was found. It is the last plausible place a BC edition-and-date table could be hiding.
Confirm before you rely on it. This is a research summary assembled from public records — not legal advice, and not a regulatory publication. Adoption dates and enforcement practice change. For a binding answer about a specific unit, ask Technical Safety BC or your authority having jurisdiction.
Every document behind this page
Keep BC's code history in your pocket
For code reference and adoption dates you can check on the job, Escalator Field Command's Field Guide covers this and more.
