If an elevator is not required to be an accessible means of egress, does it's lobby need two-way communication?

[Ryan Schultz]

If a building has an elevator, but it is not required to be an accessible means of egress per an exception outlined in 1009.4, does the 3rd exception in 1009.8 allow you to forgo adding a Two-Way Communication in the elevator lobby?

3rd exception: Two-way communication systems are not required at the landings serving only service elevators that are not designated as part of the accessible means of egress or serve as part of the required accessible route into a facility.

 

[RLGA]

Only if it is a service elevator. If it is a service elevator but is also used as an accessible route (although not an accessible means of egress), Exception 3 would not apply and two-way communication would be required.

 

[e hilton]

I would expect the fire marshall to require it.

 

[Yikes]

Good question! It is poorly structured/worded in the code. 1009.8 is not subordinate to 1009.4, but it is subordinate to both 1009.3.3 exc. #1 and 1009.1 in general.

If you look close at 1009.8 exception #3, it states two-way comm is not required at service elevators that are not designated as part of the AMOR or serve as part of the required accessible route into a facility.

Note that "service elevator" is not explicitly defined in the code, but is commonly known to mean an employee-only elevator not used by the general public. The elevator used by the public is colloquially known as a "passenger elevator".
If your building has only one elevator, it is both a passenger elevator and a service elevator.

The thing is, unless you floor has multiple remote banks of elevators, or has a giant exit ramp, chances are that you are using an elevator as your accessible route into a facility. Thus, by reading 1009.8 exc. #3 inversely(?), the implication is that a two-way communication system IS required when your elevator serves as the accessible route up to a floor.

I've sliced and diced this question before. In the end, most of my projects have a budget that can support the 2-way comms, and the CASP consultants always interpret this conservatively - - so I pick my battles elsewhere and just go ahead and specify the comm system at the elevator.