Elevator MCP Requirements: What §8.6 Really Says

By Mr. Sumeet Katariya, ElevatorPlus · Published 18 August 2026· Last updated  18 August 2026·· ~9 min read · Compliance reviewed by Mr. Sumeet Katariya

In short: Every unit needs a written Maintenance Control Program under ASME A17.1/CSA B44 §8.6. This is written for the contractor who has to produce it when an inspector asks. It covers what §8.6.1.2.1 actually lists, the difference between the MCP and the On-Site Documentation, and the retention rule that most contractor guidance cites under the wrong clause number.

Key takeaways

• The MCP does not have to be kept on site. §8.6.1.2.1(a) says it must be viewable on site. §8.6.1.2.1(d) expressly allows it to be maintained remotely, provided instructions for locating it are posted on the controller.
• The On-Site Documentation is different, and it does have to be physically there. §8.6.1.2.2 requires those documents "written and permanently kept on-site… in hard copy for each unit". Wiring diagrams and written checkout procedures cannot live only in the cloud.
• The retention clause is 8.6.1.4, not 8.6.1.4.1. Five years, or from installation, whichever is less. Ontario adds a separate one-year minimum for callback records.
• Callback records sit at 8.6.1.4.2 in every current edition. If a document cites 8.6.1.4.1(c) it is quoting a code edition from 2007 or earlier.
• BC requires both hard copy and electronic. The base code allows either. BC Reg 101/2004 substitutes its own version of 8.6.1.4.1(a)(3) requiring both formats, plus the contractor licence number and the mechanic's certificate number on the record.

What this guide covers: what §8.6.1.2.1 lists · viewable versus kept on site · the On-Site Documentation · callback records · retention · provincial variations · what an inspector actually opens first · FAQs.

What the code actually asks for

Definition, Maintenance Control Program: a written programme, provided per unit by the firm maintaining the equipment, specifying the examinations, tests, cleaning, lubrication and adjustments applied to components at stated intervals.

§8.6.1.2.1 runs (a) through (e). There is no (f) in the 2016 or 2019 editions, which matters because several published checklists still list one.

What those five subsections require, in plain terms. An MCP for each unit, provided by the firm doing the maintenance, viewable on site by elevator personnel from the acceptance inspection or from installation or alteration onward. Content that includes the Code-required maintenance tasks, procedures, examinations and tests set out in 8.6.4 through 8.6.11, updated whenever those requirements are revised in the Code. Cross-references to the on-site Equipment documentation and to the maintenance records. Posted instructions where the MCP lives remotely. And intervals set against equipment age, condition, accumulated wear, design quality, usage, environment, improved technology and the manufacturer's recommendations.

Note what is not there. The phrase "unique identification of equipment" appears nowhere in §8.6.1.2. The word "unique" in this clause attaches to procedures, not to asset tags. Conveyance identification is a requirement, but it sits in the records clause at 8.6.1.4.1(a)(3)(c), not in the MCP clause.

Viewable on site is not the same as kept on site

This is the most commonly mis-stated point in the sector, and it usually costs contractors money in the wrong direction.

§8.6.1.2.1(a) requires the MCP to be viewable on-site by elevator personnel at all times. It does not require it to be stored there. §8.6.1.2.1(d) then makes the remote case explicit: where the MCP is maintained remotely from the machine room, machinery space, control room or control space, instructions for locating or viewing it, in hard copy or electronic format, must be posted on the controller or at the means necessary for test. Those instructions must be permanently legible with characters at least 3 mm high.

So a cloud-hosted MCP on a tablet is compliant. A cloud-hosted MCP with nothing posted on the controller is not, and that is the failure we see most often.

The phrase "on the premises" does not appear in §8.6.1.2 at all. It is industry shorthand and it is worth dropping.

The On-Site Documentation is a separate obligation

§8.6.1.2.2 is a different clause with a stricter rule. Those documents must be written and permanently kept on-site… in hard copy for each unit for elevator personnel.

What falls under it: up-to-date wiring diagrams for electrical protective devices and critical operating circuits; written procedures for inspections and tests not described in ASME A17.2, including levelling checkout, overspeed valve checkout and reversal stop switch checkout; procedures for SIL-rated devices, alternative-arrangement equipment and A17.7/B44.7 components; traction-loss and broken-suspension-member detection procedures; seven specified written checkout procedures; and written evacuation procedures.

The 2019 edition adds two more, covering software unique-identification and escalator skirt-panel deflection test documentation. British Columbia is on the 2016 edition, so those two do not apply there. If you operate across provinces, that is one of several places where a single national checklist quietly goes wrong.

One further clause is worth knowing by number. §8.6.1.2.3: where a defective part directly affecting the safety of operation is identified, the equipment is taken out of service until that part is adjusted, repaired or replaced. Older documents cite this as 8.6.1.2.2, which was correct up to the 2007 edition and has been wrong since 2013.

👉 Building your own MCP structure from scratch? Start from our free lift service checklist and breakdown report templates and adapt them to your units.

Callback records, and how long everything is kept

The callback clause is 8.6.1.4.2. It requires a record of callbacks including the description of reported trouble, dates, time and the corrective action taken, reported by any means to elevator personnel. Those records must be available to the personnel performing corrective action, and available on request to other elevator personnel. Instructions on how to report a trouble call must be posted on the controller, again permanently legible at 3 mm minimum.

Retention sits in 8.6.1.4, one level up. Records are retained for the most recent five years, or from the date of installation or adoption of the Code edition, whichever is less. Existing records up to five years are retained.

Provincial variation matters here and it runs in both directions.

Technical Safety BC put its position beyond doubt in Directive D-ED 2020-03: the most recent maintenance and test records are retained for no less than five years, and the requirement applies to both the hard copy and the electronic records.

Maintenance intervals are capped, and not by the base code

The base code sets intervals by the eight factors listed at §8.6.1.2.1(e). It does not name a maximum. Two provinces do.

Ontario's CAD 295/22 caps maintenance intervals at three months, with doors at six months and suspension means at twelve, and requires the mechanic's printed name, signature and certification number on each task record. British Columbia's Schedule s.5 caps intervals at the lesser of three months and the manufacturer's specified limit.

If your MCP was written against the base code alone, it is not compliant in either province.

What an inspector opens first ?

In practice the sequence is predictable. Whether the MCP exists for this specific unit. Whether it can be viewed on site right now, from where the inspector is standing. Whether the posted instructions on the controller are legible and actually lead somewhere. Whether the hard-copy On-Site Documentation is present. Then the records, and whether the last few tasks were signed by someone whose certification is current.

The failures we see are rarely about the quality of the maintenance. They are about a programme that exists in a template on a head-office server, with nothing on the controller pointing to it, and a records trail that stops eighteen months back because a mechanic left and took the folder with him.

Frequently asked questions

Does the Maintenance Control Program have to be kept in the machine room?

No. §8.6.1.2.1(a) requires it to be viewable on site, and §8.6.1.2.1(d) expressly permits it to be maintained remotely. What must be in the machine room is the posted instruction telling elevator personnel how to locate or view it.

What is the difference between the MCP and the On-Site Documentation?

The MCP is the programme: tasks, procedures, intervals. The On-Site Documentation under §8.6.1.2.2 is the supporting material, including wiring diagrams and written checkout procedures, and that must be permanently kept on site in hard copy.

How long must elevator maintenance records be kept in Canada?

The most recent five years under §8.6.1.4, or from installation or Code adoption, whichever is less. Ontario adds a one-year minimum specifically for callback records.

Which clause covers callback records?

§8.6.1.4.2 in all current editions. Documents citing 8.6.1.4.1(c) are quoting the 2007 edition or earlier.

Can the MCP be entirely electronic?

The MCP itself, yes, subject to the posted-instruction requirement. The On-Site Documentation cannot. In British Columbia, maintenance records must exist in both hard copy and electronic format.

Does the MCP need updating after an alteration?

The Code ties the two together at §8.6.1.2.1(a), which runs the viewability requirement from the time of installation or alteration. §8.6.1.2.1(b) covers updates when the Code's own 8.6 requirements are revised. There is no general clause requiring a rewrite every time equipment changes.

Is there a maximum maintenance interval?

Not in the base code. Ontario caps it at three months, with doors at six and suspension means at twelve. British Columbia caps it at the lesser of three months and the manufacturer's limit.

What does §8.6.1.2.3 require?

Where a defective part directly affecting the safety of operation is identified, the equipment is taken out of service until that part is adjusted, repaired or replaced.

📲 Join our WhatsApp channel for compliance tips, updates: ElevatorPlus - Business Automation Tool

Most contractors we speak to have an MCP. What they often do not have is a programme that names the specific unit, an instruction posted on that unit's controller pointing to it, and a records trail that survives a mechanic changing jobs.

The code is less demanding about storage than the industry believes and more demanding about traceability. Get every unit's programme, documentation, task records and callback history onto one record tied to the unit itself, and an inspection stops being an exercise in finding things.

👉 See what an audit-ready MCP looks like across a multi-province portfolio. Book a demo →

Related reading

• Elevator service software built for Canadian contractors
• Elevator Service Software Canada 2026: CSA B44 and Provincial Compliance
• The Complete Lift Maintenance Checklist for 2026
• Elevator Preventive Maintenance Schedule: A Practical Guide

About the author. Mr. Sumeet Katariya is the founder of ElevatorPlus, the Elevator Business Operating System used by 200+ elevator companies across 20+ countries. Compliance reviewed by Mr. Sumeet Katariya.

Sources: Seattle Building Code 2021 Chapter 30, reproducing ASME A17.1-2019/CSA B44:19 (PDF) · TSSA Elevating Devices Code Adoption Document Amendment 295/22 (PDF) · Elevating Devices Safety Regulation, B.C. Reg. 101/2004 · Technical Safety BC Directive D-ED 2020-03, MCP maintenance record requirements · Technical Safety BC, Elevating devices

Book a Demo with ElevatorPlus

 👉 Follow ElevatorPlus on,
Instagram LinkedIn Facebook YouTube Qoura Substack Twitter