Introduction:
In this paper, we will discuss the conflict created by the inclusion of elevator emergency communication requirements in the 2018 and newer editions of the International Building Code (IBC). The conflict occurs in jurisdictions that are enforcing the 2018 or newer editions of the International Building Code (IBC) and the 2016 or older editions of ASME A17.1/CSA B44 Safety Code for Elevators and Escalators (A17.1/B44).

This paper will elaborate on the updates made to the elevator emergency communication language in requirement 2.27.1 of the 2019 edition of A17.1/B44 to address the intent of the IBC emergency communication requirements. It will also discuss the accessibility considerations of the operational components and the various iterations to the IBC requirements.

Code Conflict:
Jurisdictions typically adopt a newer edition of IBC before adopting a newer edition of A17.1/B44. Coordination between codes is critical to prevent conflicts and to enhance safety. Even when a jurisdiction adopts the latest edition of both codes, a conflict could still occur if requirements are changed in one code but not the other. A further complication of coordinating IBC and A17.1/B44 is that each are published in different years and under different revision cycles.

It is critical to mitigate conflicts by avoiding overlap of code requirements. IBC has traditionally not duplicated or stated requirements for the design, construction, installation, alteration, repair, and maintenance specific to the elevator systems but instead kept the primary focus on building systems that support the elevators. The details of the elevator system are included in IBC by reference only in Section 3001, which specifies conformance to A17.1/ B44. When elevator technical design criteria are defined in IBC this can result in conflicts. Such a conflict exists because of a change to section 3001.2 in IBC 2018. This conflict is between the building code and editions of A17.1/B44 prior to 2019. IBC 2021 modified section 3001.2 to provide less conflicting language but it still conflicts with A17.1/B44. A change has been approved for inclusion in the IBC 2024 edition that aligns with the requirements in the 2019 edition of A17.1/B44 and the 2022 edition of A17.1/B44.

Specifically, IBC requirement 3001.2 mandates an elevator emergency communication system for the deaf, hard of hearing and speech impaired. NEII recognizes the potential merit of the IBC guidance in Section 3001.2, but the code language in the IBC 2018 and IBC 2021 editions does not provide detailed technical requirements to ensure consistent enforcement and conflicts with the technical requirements for emergency communication in requirement 2.27.1 in the 2016 and prior editions of A17.1/B44. This will create an ongoing issue for the life of the elevator because the provisions in IBC do not include technical criteria or a reference to another standard containing such criteria. This will potentially result in a wide variety of communication systems and ultimately a disservice to all passengers.

NEII members worked very closely with the American Society of Mechanical Engineers (ASME) Emergency Operations Committee to develop technical requirements for a communication system that would meet the intent of the IBC code change. It is important to remember that the emergency communication system in the elevator is provided to request help for an elevator entrapment, not to connect to the 911 system; therefore, the amount of information that needs to be shared with authorized personnel is minimal.

The requirements in in the 2019 edition of A17.1/B44 were developed for consistency with the guidelines in the Americans with Disabilities Act Title III - the regulation specifically for effective communication with the deaf, hard of hearing and speech impaired. In the in 2019 edition of A17.1/B44 requirement 2.27.1 provides clear guidance to manufacturers and code authorities to ensure new systems will meet the needs of the deaf, hard of hearing, and speech impaired users. It is strongly recommended that jurisdictions that have adopted IBC 2018 or newer editions also adopt the 2019 edition of A17.1/B44, amend IBC section 3001.2 to match the language approved for 2024, or take an exception to section IBC 3002.1 until the 2019 or later edition of A17.1/B44 is adopted to avoid this conflict between codes.

Elevator Emergency Communication Background:
Elevator car emergency communication has been required in A17.1/B44 since the 1930’s to allow trapped passengers the ability to notify authorized personnel so that help can be dispatched. This has been the purpose dating back to the original alarm bell through the ADA phone. There are various reasons for the changes in the 2019 edition of A17.1/B44, but primarily to provide authorized personnel enhanced functionality to better assess an entrapment. Recent industry data indicates that between 95% to 98% of all car emergency phone activations are false alarms (i.e., non-entrapments). This high rate of false alarms consumes resources for call center personnel, building representatives, elevator mechanics and/or emergency responders who are incorrectly dispatched to non-events. This extensive reduction in resources can jeopardize passengers when an actual rescue is required.

ASME A17.1-2019/B44-19 requirement 2.27.1:
Advances in communication technology over the last decade have been underutilized by elevator emergency communications. Advances such as accessing video remotely and text messaging are commonplace in everyday communication. IBC 2018 attempted to address improving the elevator communication but only provided general language without clarity of the technical design or inspection criteria. The 2019 edition of A17.1/B44 clarified the requirements by providing the detailed operation and design criteria to utilize the advances in communications technology to better serve passengers who are unable to hear or unable to verbally communicate effectively when entrapped.

The 2019 edition introduces new components to the communication means. There is one-way video to allow authorized personnel the ability to verify the presence of a passenger in the car. There is additional status information provided to the passenger and the authorized person will be able to query the passenger visually as well as verbally.

The primary goal of the changes in the 2019 edition of A17.1/B44 is to clarify section 3001.2 of IBC-2018 and later editions with technical criteria, focusing on the communication required to accomplish a successful rescue of passengers including alternative methods of communication for those who may not be able to hear or communicate verbally. The changes made in the 2019 edition of A17.1/B44 are in addition to the 2016 requirements so all existing requirements from the previous A17.1/B44 edition remain intact. Therefore, a communication means conforming to the 2019 requirements can be applied in jurisdictions enforcing an older edition of A17.1/B44 without conflict with the older requirements. For example, the communication means is still required to be actuated by pressing the phone button, to automatically connect to authorized personnel who can take appropriate action, and to provide the visual indication to the passenger acknowledging communication is established. The communication means is also still required to provide on demand to authorized personnel the building location and elevator number and it is still required to automatically perform verification of operability and provide notification if it fails.

In addition to all the functionality required in the 2016 and earlier editions, the 2019 edition provides enhanced functionality that can be classified into three key parts:

1. Video: Ability for authorized personnel to assess an entrapment by viewing the cab.
2. Notifications: Ability for authorized personnel to initiate in-car notifications
3. Visual Messages: Ability for authorized personnel to query passengers by visual messages and receive non-verbal responses

Video:

The video provision addresses multiple issues, but the primary advantage is to allow authorized personnel to assess an entrapment regardless of the passenger’s ability to hear or communicate verbally. Without video or any audible response from a passenger, an authorized person has difficultly in determining if there is an entrapment. Industry data shows that approximately 95%-98% of all activations are not for an entrapment; therefore, an actual entrapment without an audible response could be incorrectly dismissed. With the addition of video, the authorized person can observe if passengers are entering and exiting the elevator normally or if the elevator is empty providing positive feedback to the authorized person allowing them to dismiss the call with no additional action if there is no entrapment. The visual assessment by authorized personnel further reduces the need for communication with passengers in determining an entrapment because it addresses other issues preventing effective communication, such a language barrier or diminished cognitive functions.

Stated in performance language for entrapment assessment, the video is to provide authorized personnel the ability to observe passengers in any location on the car floor. Therefore, the field of view is not required to be the entire floor or entire car volume but as stated in the requirement to view possible passengers whether standing or laying on the floor. This means the minimum field view is to ensure the minimum body size of a potential passenger on the floor is within the field of view. Because a passenger could be a small child, a reasonable assumption of the smallest passenger using an elevator is a four-year-old child. Based on various anthropometric references, a young child has a head diameter greater than 8” inches. This 8” diameter value is in alignment with the target requirement specified for the approaching object detection device of section 2.13.5.3 of A17.1/B44. Therefore, the camera’s field of view should be the entire floor to within 6” of any wall or door. This ensures that a small child standing or sitting against a wall will still be in the field of view of the camera. Additionally, the view angle is required to be toward the floor; therefore, it is not required to provide the full view of the entire car volume. There should be no expectation that a standing adult’s upper body is required to be within the camera’s field of view. Furthermore, the video resolution and quality should be enough to distinguish a person from other objects that may be left on the car floor.

With the goal to provide the ability to identify passengers that are trapped, the video frame rate can be very low. This helps in areas that do not have high speed connectively where a frame rate of greater than 1 second will still provide the authorized person the ability to observe passengers and determine if an entrapment exists.

Visual Notifications:

The notifications that “help is on the way” and “help is on-site” have been provided on some older phone implementations, these were recognized as helpful information that confirms to passengers that the authorized person has acted on their call for help. This additional visual communication should provide additional comfort to most passengers that rescue actions are underway.

In addition to the call acknowledgement notification of earlier codes, the 2019 edition now requires these two additional notifications that help is on the way and help is on site. All notifications are required to be activated by authorized personnel, but unlike earlier editions, it is not specified that an indicator lamp also be provided. The 2019 edition uses performance language requiring that there are messages that need to be communicated. This could be implemented in multiple ways, from labelled indicators that illuminate on demand, to messages displayed on the new text message display system or a combination of both.

A rescue typically requires no action from the passengers except to wait until the doors are opened; therefore, information that is exchanged between the authorized person and passengers after help is dispatched is typically not critical to the rescue.

Text Messages:

The A17.1/B44 2019 edition also requires a means for an authorized person to be able to query the passengers and receive responses to better accommodate passengers who cannot verbally communicate or hear. Because of possible language barriers, it is strongly recommended that questions be simple to understand and limited in scope so they can be answered with YES and NO responses. Because the authorized person has the new ability of viewing the passenger in the car, the need to ask complex questions to assess if someone is trapped has been effectively eliminated. The scope of the messaging could be as simple as displaying “Hello” to acknowledge communication is established, followed by the message “Do you need help?” with response options of “YES” or “NO”. If the response is “YES”, then displaying the message that “Help is on the way” or “Help is dispatched” or any other message to indicate help has been sent. Once help arrives on site, the display message should change to acknowledge that ”Help is on site” or “Help has arrived” or some other message to communicate help is there. The A17.1/B44 requirement is written in performance language to avoid prescriptive wording of the required visual notifications and any query questions.

Accessible Access:

Per A117.1-2017, Standard for Accessible and Usable Buildings and Facilities (A117.1-2017), the operable parts of the communication means shall comply with section 308 with a forward unobstructed reach range defined as 15 inches (380 mm) to 48 inches (1220 mm) above the floor. All the buttons from the phone pushbutton to initiate the call, through the “YES” and “NO” response buttons need to be within this forward reach range.

A117.1-2017, does not address the new elevator visual message interface. It is not a variable message sign addressed in section 703.7 because it is not viewed from a distance but is only used by a passenger immediately in front of the display screen who just pressed the phone pushbutton. Other sections of A117.1-2017 provide guidance for accessibility of a similar user interface. An example is the guidance for the interactive user terminal of section 707.7.2 required for automatic teller machines (ATM) and fare machines. Like the elevator text message interface, an ATM is used by someone immediately in front of the device within the reach ranges of section 308. Based on section 707.7.2, the message display characters shall not be italic, oblique, script, highly decorative or other unusual forms. The uppercase letter “I” shall be used to determine the allowable height of all characters of the font. The uppercase letter “I” shall be 3/16-inch (4.8 mm) minimum in height and all characters shall contrast with their background as either light characters on a dark background or dark characters on a light background.

The display should be legible over a vertical height range to accommodate a person in a wheelchair to a standing adult who is immediately in front of the display. The display does not have to be legible to someone who is elsewhere in the elevator as they did not press the phone pushbutton and are not within the reach range to respond “YES” or “NO” to the questions from the authorized person. Based on section 707.7.1, an ATM screen shall be legible from a point located 40 inches (1015 mm) above the center of the clear floor space in front of the display to accommodate both someone in a wheelchair and a standing adult within a 24-inch (610 mm) reach. This new elevator display should follow this same guidance for viewing and legibility. There is currently a proposal for the next edition of A117.1 to add these prescriptive message display screen requirements as well.

Proposals have been made to update A17.1/B44, including Appendix E, and the next edition of A117.1 section 407.4.10 for Emergency communications to specify these as requirements for the car emergency communication system. Until the accessibility code is updated, it is recommended to consider the relevant parts of section 707.7.2 for the user accessibility requirements. The change has also incorporated message size requirements into the 2022 edition of A17.1/B44.

A17.1/B44 does not prescribe how to implement the messaging and response means. It is encouraged that the implementation be intuitive to avoid providing operating instructions in the car. A117.1-2017 section 407.4.10.3 requires only essential instructions for using the communication means to be raised characters and in braille complying with sections 703.2, 703.3 and 704.4. These tactile requirements only need to be applied to the phone symbol adjacent to or on the pushbutton to initiate the call because the operation of a pushbutton is intuitive and there is no additional action required by the passenger. With the ability to access video and observe elevator occupants, access to both building location and car number, the authorized person can assess if there is an entrapment independent of any further communication with the passenger. Any communication after the activation of the phone button is not essential to implement a rescue.

The A17.1/B44 requirement does not specify how to implement the in-car message but instead uses performance language to allow the designer flexibility, for example, the “YES” and “NO” responses could be accomplished by repurposing the existing door open button and door close button as dual functions. Alternatively, there could be dedicated “YES” and “NO” buttons or the message display could provide the “YES” and “NO” functions if it is a touch screen. If a touch screen is used, then the screen is required to be within the forward reach range of section 308.

Conclusions:

The car emergency communication required by A17.1/B44 is for entrapment notification but due to incomplete communication an incorrect response could occur. The added functionality of the communication means required by the 2019 edition of A17.1/B44 will provide better entrapment assessment for authorized personnel and additional information to passengers who are unable to hear or unable to verbally communicate effectively. These improvements will help reduce errors, so an entrapment can be identified on the first activation of the phone button independent of the ability of the passenger to communicate.

The addition of video is a game changer for authorized personnel in understanding what is occurring in the elevator. The scope of the video is to identify passengers in the car. The 2019 edition of A17.1/B44 defines the operational design requirements. The video feature will greatly help in assessing passengers who are unresponsive or who inadvertently press the phone button. The requirements of A17.1/B44 will help in addressing the 95% to 98% call volume due to non-entrapment activations.

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This position paper is issued by the National Elevator Industry, Inc. (NEII) in response to concerns about a conflict between the requirements for Fire Service Access Elevators (FSAE) in the 2021 IBC and ASME A17.1/CSA B44. In addition, it addresses a clarification provided by the 2015 IBC.

The 2012 IBC added a new requirement addressing elevator Phase I emergency recall operation. This requirement was deleted in the 2015 IBC.

“3007.2 Phase I Emergency recall operation. Actuation of any building fire alarm-initiating device shall initiate Phase I emergency recall operation on all fire service access elevators in accordance with the requirements in ASME A17.1/CSA B44. All other elevators shall remain in normal service unless Phase I emergency recall operation is manually initiated by a separate, required three-position, key-operated “Fire Recall” switch or automatically initiated by the associated elevator lobby, hoistway or elevator machine room smoke detectors. In addition, if the building also contains occupant evacuation elevators in accordance with Section 3008, an independent, three-position, key-operated “Fire Recall” switch conforming to the applicable requirements in ASME A17.1/CSA B44 shall be provided at the designated level for each fire service access elevator.”

The conflict is created by the first sentence. It requires initiation of Phase I emergency recall operation in accordance with ASME A17.1/CSA B44 but also states that it should be upon activation of any building fire alarm initiating device.

The ASME A17.1/CSA B44 Safety Code for Elevators and Escalators referenced by the IBC requires fire alarm initiating devices installed in conformance to NFPA 72 to be located at each elevator lobby, associated elevator machine rooms and spaces, and in the elevator hoistway to initiate FEO Phase1 emergency recall operation (section 2.27.3.2.1).

The NFPA 72 Fire Alarm and Signaling Code, section 21.3.3 requires only the elevator lobby, hoistway and machine room detectors to be used to recall elevators for fire fighter service unless otherwise required by the AHJ. Initiation of Phase I elevator recall upon activation of any fire alarm initiating device in the building is not permitted.

Elevators recalled unnecessarily by FAIDs outside of the elevator lobby, hoistways and machine rooms are not available to persons with disabilities who require elevators to egress the building. This will require resources from first responders to locate and evacuate those persons. The use of these resources could be better deployed addressing the fire/emergency.

Unnecessary recall of the elevators may also create confusion and cause delays for the firefighters. The confusion and delays would occur if all elevators are recalled because the firefighters will not know which ones are safe to use. If only the affected elevators are recalled the firefighters can capture a non- recalled elevator immediately for their use.

Elevators that are recalled on Phase I Emergency recall operation by “any fire alarm-initiating device” will require either elevator personnel or emergency personnel to reset Phase I Emergency recall operation so that the recalled elevator(s) can return to automatic operation. By code this cannot be done by building personnel. The result will be unnecessary removal of elevators from automatic operation and significant delays in returning these elevators to automatic operation.

Requiring compliance with this policy in existing buildings that currently comply with ASME A17.1/CSA B44 creates significant burdens in the areas of permitting, inspections, equipment, and costs.

Another concern expressed with the 2012 IBC was the requirements in 3007.7.5 for the Fire Service access elevator symbol are not clear. There were two issues. The first was that it was not clear how the three inch minimum dimension was applied. The second was due to the fact that the code book is not printed in color and there was some confusion as to whether the symbol had to be black and white only. Both of these issues were clarified in the 2015 IBC. The three inch dimension applies to the rectangular field around the fire hat. The symbol is allowed to be any combination of light and dark colors to provide contrast.

NEII is committed to public and elevator personnel safety and is ready to support the authorities having jurisdiction in understanding the latest version of the code and assisting in the process of adoption. To this end NEII provides information and training on the code and related issues, using webinars and podcasts in addition to meetings with interested parties.

Approved:

The NEII Central Code Committee is responsible for maintaining this position paper. This position paper shall be in effect for three (3) years from the date of approval by the NEII Central Code Committee.

NEII Central Code Committee: February 19. 2016