A question came to me about the survivability requirements for an elevator landing communication system required by 2018 IBC 1009.8/NFPA 101 22.214.171.124. 2016 is the applicable NFPA 72 edition.
The designer is arguing that since NFPA 72 Section 24.3.13 doesn't call out "elevator landing communication systems" by name that it falls under Section 126.96.36.199 and requires a risk analysis. They did note that the 2019 edition "clears up some confusion" but don't mention that the 2019 edition modifies section 188.8.131.52 to reference "elevator landing communication systems" and refer their design to the area of refuge/rescue assistance section 24.10 along with stair communication systems.
The 2016 edition of 184.108.40.206 just references "elevator emergency communication systems, section 24.11" which is pretty clearly about the in-car call systems, not the systems required at the landings by IBC/101.
Now I've done my homework, its pretty clear that from 2016-2019 NFPA wants elevator landing communication systems to meet the same requirements as an area of refuge communication system, and from 2019-2022 its explicitly clear that the elevator landing communication systems need to be robust; further more the commentary language of the IBC, NFPA 101 and NFPA 72 for the elevator landing and area of refuge communication systems all pretty much say the same thing that non-self-evacuating occupants needs a reliable means of communication for the duration they remain in the building, so the two systems would need to function the same.
My problem is that for the 2016 edition this is all implied and implicit language.
I am very confident that elevator landing systems require the same survivability as area of refuge systems but can't find an explicit code reference to support it. Is there a section/commentary section/something I'm missing?
Thanks in advance.
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