Two-way communications at elevator

[Sifu]

2018 IBC. 1009.8 requires two-way coms at the elevator. Section 1009 is for AMOE's. 1109.8 doesn't say the elevator must be an AMOE or it is for required elevators or any other qualifying language...other than it is in the section for AMOE's and directed by 1009.2. Do you apply this section only to elevators that are an AMOE or all elevators?

 

[Yankee Chronicler]

IBC section 1009 is Accessible Means of Egress, so if an elevator isn't part of a required accessible means of egress nothing in 1009 would apply. That said, I'm an old man and I can't recall ever being in an elevator that didn't have two-way communication. (Whether it worked or not is an open question.)

IBC 3008.6.6 requires a two-way communication system in each occupant evacuation elevator LOBBY, but doesn't require it in the elevator car(s).

 

[RLGA]

I interpret Section 1009.8 as required at all elevators, whether or not an elevator is used as one of the required means of egress.

My reason for this interpretation is that areas of refuge require two-way communication, but if a sprinkler system is installed throughout the building, areas of refuge are not required; thus, no two-way communication is required.

So how does a person on an accessible floor notify someone they need assistance? The solution is Section 1009.8 because the sprinkler system has, in effect, turned the entire story into a quasi-area of refuge, and the elevator is a logical means for assisted rescue.

 

[Sifu]

The two differing opinions are the conflict I have. The section does not eliminate the requirement from a non-AMOE elevator, but the location might.

 

[Yankee Chronicler]

The two differing opinions are the conflict I have. The section does not eliminate the requirement from a non-AMOE elevator, but the location might.

I don't follow you. Other than "Exceptions," the building code doesn't tell us when something is not required, the code tells us when something IS required. Section 1009 is Accessible Means of Egress, so if something is not part of an accessible means of egress, section 1009 (all of it) simply doesn't apply. So where else in the IBC do you see a requirement for elevators to have 2-way communication?

 

[steveray]

Stop....you are both right....sort of....It is required at the elevator or the area of refuge if you follow the bouncing code path...And if the AOR is required...You have to look at 1009.6 also

1009.6.2​

Every required area of refuge shall have direct access to a stairway complying with Sections 1009.3 and 1023 or an elevator complying with Section 1009.4.

Exception: An interior area of refuge at the level of exit discharge that provides direct access to an exterior exit door.

 

[Sifu]

This building is messy. There is an existing building. The existing building consists of a basement and 1st floor. There is an elevator in the existing building serving both levels. An addition is proposed. It consists of a 1st floor and 2nd floor. It also has an elevator. The existing building elevator does not serve the addition's 2nd floor. The addition's elevator does not serve the existing basement. Plus, the addition has a large public assembly space that has 2 required exits. One of those exits has a path that goes through a stair enclosure that deposits the occupants to the exterior at an exterior area for rescue assistance (EAAR), which also serves as the AMOE from the 2nd floor.

The addition's 2nd floor has two exit access stairs, stair 1 being the aforementioned stair that utilizes the EAAR. That path is now a compliant AMOE. Stair 2, also a compliant AMOE, deposits the occupants to the 1st floor, then on to a ramp. So after they installed the EAAR at the stair 1 discharge they have two compliant AMOE's from the building and the public assembly. On my first review they did not have the EAAR, so they only had one compliant AMOE from the building, and only one from the public assembly space. They did not show me the accessible route from the building nor the AMOE's. So if the new elevator was an AMOE, and the 2nd stair was an AMOE they would have had two compliant AMOE's from the building, but only one from the public assembly space. Commenting that they needed a 2nd AMOE from the public assembly space was certain, and it would also serve as the 2nd AMOE from the 2nd floor. However, they still have not shown the accessible route, nor the intended AMOE's, so I don't know if the elevator can also serve as, or was intended as an AMOE. Where I am stuck is this: They have two compliant AMOE's, so them showing me what their intent for the accessible route and AMOE's is academic. But I still have the elevator, which is not required to be an AMOE since they have two already. But if 1009.8 requires coms either way, they need to know this.

If 1009.1 is limiting everything in the section that follows to compliance only if they are an AMOE why does 1009.3 say "in order to be considered a part of the AMOE"? If 1109.8 was intended to only apply to an elevator that is part of the AMOE, should it not also say something similar? Such as "where an elevator serves as a part of the AMOE a two-way communications shall be provided"?

Code is not perfect, so I try to find the intent. It seems the intent is that all the requirements that follow 1009.1 are only applicable if they are an AMOE. But then I see individual requirements that specify "in order to be considered". In my world, they don't need to do that, or they need to do that everywhere. In 1009.3, if they were consistent with the language in 1109.8 they would say "A stairway between stories...." without the qualifier. Or, in 1009.8, to be consistent with 1009.3, they would say "where an elevator is a part of the AMOE, a two-way communications system complying with....." with the qualifier.

My thinking is that of Yankee, that 1009 provides requirements for an AMOE, and nothing beyond. But I also had the same thought as RLGA, which is how a person makes a notification if they are sitting at an elevator. Because there are compliant stairs, in a sprinklered building, there is no other requirement anywhere for that notification as far as I can tell. So I have to wonder if this is the catch so that in the event someone is stuck, they can make the call. Or is it just a different code, written at a different time, with different, inconsistent language?

Commentary makes me lean towards the idea that it is required no matter what, but again, this is commentary to a section that MAY only apply to the AMOE.

 In multistory buildings, unless provided in areas of
refuge, a two-way communication system must be
located at the elevator landing of each accessible
floor level other than the level of exit discharge. The
system is intended to offer a means of communication
to individuals with mobility impairment, either permanent
or temporary, who need assistance during an
emergency situation.

 

[Yankee Chronicler]

Going all the way back to the original ADAAG from 1994, I have always had an issue with the way the ADA handled egress for persons with disabilities. Basically, under the ADA we are required to get persons with disabilities into buildings but, if the building is sprinklered, we are not required to get them out. The provisions we see in the IBC are supposed to be a codification of the ADA, so that's some background on how we've arrived at where we are.

Sifu, what section does that commentary apply to? If it's 1009.6.5, Section 1009 is Accessible Means of Egress. If an elevator is not part of an accessible means of egress, there is no path by which to apply 1009.6.5. It doesn't apply. If the code wants all elevators to have 2-way communication (either in the elevator or at each landing), then the ICC needs to put it somewhere else in the code other than Section 1009.

 

[Sifu]

Going all the way back to the original ADAAG from 1994, I have always had an issue with the way the ADA handled egress for persons with disabilities. Basically, under the ADA we are required to get persons with disabilities into buildings but, if the building is sprinklered, we are not required to get them out. The provisions we see in the IBC are supposed to be a codification of the ADA, so that's some background on how we've arrived at where we are.

Sifu, what section does that commentary apply to? If it's 1009.6.5, Section 1009 is Accessible Means of Egress. If an elevator is not part of an accessible means of egress, there is no path by which to apply 1009.6.5. It doesn't apply. If the code wants all elevators to have 2-way communication (either in the elevator or at each landing), then the ICC needs to put it somewhere else in the code other than Section 1009.

That is the commentary from 1009.8, but the point is still valid, and I agree with the sentiment. It is the "If" part of "if the code wants" I am trying to make sure of. The way they articulate some of the requirements in 1009 it makes it clear...such as the stair where it says :in order to be considered". The fact that that language does not appear in 1009.8 for elevators is what makes me uncertain. I requested a technical opinion, so we'll see what their opinion is.

 

[arwat23]

1009.8 only applies to elevator landings on accessible floors. If the floor isn't accessible, that specific section doesn't apply.

3001.2 requires two-way communication inside all elevators.

3008.6.6 requires two-way communication at all occupant evacuation elevator lobbies.

 

[steveray]

It's a little weird, as ex 3 talks about elevators not part of the route, not just AMOE...And 2 of the other exceptions are also typically non-AMOE

1009.8​

A two-way communication system complying with Sections 1009.8.1 and 1009.8.2 shall be provided at the landing serving each elevator or bank of elevators on each accessible floor that is one or more stories above or below the level of exit discharge.

Exceptions:

1. 1.Two-way communication systems are not required at the landing serving each elevator or bank of elevators where the two-way communication system is provided within areas of refuge in accordance with Section 1009.6.5.
2. 2.Two-way communication systems are not required on floors provided with ramps conforming to the provisions of Section 1012.
3. 3.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.
4. 4.Two-way communication systems are not required at the landings serving only freight elevators.
5. 5.Two-way communication systems are not required at the landing serving a private residence elevator.
6. 6.Two-way communication systems are not required in Group I-2 or I-3 facilities.

❖ In multistory buildings, unless provided in areas of refuge, a two-way communication system must be located at the elevator landing of each accessible floor level other than the level of exit discharge. The system is intended to offer a means of communication to individuals with mobility impairment, either permanent or temporary, who need assistance during an emergency situation. Such a system can be useful not only in the event of a fire, but also in the case of a natural or technological disaster by providing emergency responders with the location of individuals who will require assistance in being evacuated from floor levels above or below the discharge level. The ability of emergency responders to quickly locate persons needing assistance is an important part of the fire safety and evacuation plan. The two-way communication system is a critical element in that plan.


Maybe a move to Ch. 11 or a pointer?

 

[Sifu]

Steveray, I saw that exception, but it is for "service" elevators, which I take as elevators not for the general public. Anyway....

Here is the question and opinion from ICC. The way I read it, it is required either way.

Question: In a new three story building, are two way communication systems required at the lobby for the elevator, or are two-way communication systems only required at elevators that serve as part of an accessible means of egress?

Answer: Accessible means of egress are required from all accessible spaces (Section 1009.1). In a sprinklered building, an area of refuge is not required (Section 1009.3.3, Exception 2 and 1009.4.2, Exception 2). However, since elevators are required to have automatic recall by ASME A17.1, there may still be a need for anyone on an upper floor that cannot use the stairway, to have a way to communicate with emergency responders that they need assistance to evacuate; thus, the requirement for a two-way communication system (Section 1009.8). It was decided that locating the two-way communication system at the elevator landing would be the best, most consistent place for people to find the two-way communication system. Typically, an evacuation plan showing the stairway locations is also provided at the elevator landing. In addition, the fire department can always choose to use the elevator for assisted, even if there is not standby power to that elevator.

 

[steveray]

Steveray, I saw that exception, but it is for "service" elevators, which I take as elevators not for the general public. Anyway....

Here is the question and opinion from ICC. The way I read it, it is required either way.

Question: In a new three story building, are two way communication systems required at the lobby for the elevator, or are two-way communication systems only required at elevators that serve as part of an accessible means of egress?

Answer: Accessible means of egress are required from all accessible spaces (Section 1009.1). In a sprinklered building, an area of refuge is not required (Section 1009.3.3, Exception 2 and 1009.4.2, Exception 2). However, since elevators are required to have automatic recall by ASME A17.1, there may still be a need for anyone on an upper floor that cannot use the stairway, to have a way to communicate with emergency responders that they need assistance to evacuate; thus, the requirement for a two-way communication system (Section 1009.8). It was decided that locating the two-way communication system at the elevator landing would be the best, most consistent place for people to find the two-way communication system. Typically, an evacuation plan showing the stairway locations is also provided at the elevator landing. In addition, the fire department can always choose to use the elevator for assisted, even if there is not standby power to that elevator.

Yeah..kinda what I figured...1009 seems like the right place when you are writing it, but Ch. 11 would be better place for clarification that this is a route requirement moreso or in conjunction with AMOE