Buildings, Condo & Co-op NYC Elevators Require Two-Way Text Communication Panel Under LL126

On November 7, 2021, Local Law 126 of 2021 was enacted with an effective date November 7, 2022. Impacting requirements of this regulation have trickled out to stakeholders, such as new elevator upgrades needing to employ a two-way text communication device which may be used under rare circumstances. The device is costly, but it is even more important to ensure proper button layout to avoid false alarms. This article will provide you with an understanding of this new elevator regulation and how to best address it and avoid long-term problems.

The new elevator modification of New York City Local Law 126 (NYC LL 126), which purports to improve two-way communications services to deaf persons who may be trapped in an elevator, is based on American Society of Mechanical Engineers (ASME) 17.1 2019 regulation update, sections 2.27.1.1.3 and 2.27.1.1.4. The standard elevator panel will now feature a conspicuous (and often unmarked monochrome) LCD display with "yes" and "no" buttons. The photo represents the panel we installed in our building (updated in 2024.) Cost is expected to range from $8,000 to 14,000 per elevator car plus additional recurring expenses.

The rollout of information regarding this two-way communication began with the New York City Department of Buildings (NYC DOB) sharing the information with industry (elevator consultants, installers, etc.) which eventually made its way to building management companies. It is critically important for building owners and board members to have a well informed building management company who have good lines of communications with experienced licensed consultants since the exchange of knowledge with regard to new regulation can be the difference maker in whether your building will be required to comply with potentially costly new Local Law.

The specific section of NYC LL 126 which applies is set forth below:

Rules of the City of New York, Chapter 3600, Appendices, § 3610-03 Emergency Operation and Signaling Devices.

Pursuant to § 28-103.19 of the New York City Administrative Code, Section 2.27 of American Society of Mechanical Engineers A17.1-2013, as modified by of the New York City Building Code, is hereby amended to read as follows:

Section 2.27 EMERGENCY OPERATION AND SIGNALING DEVICES
2.27.1 Car emergency signaling devices.
2.27.1.1.3 The permanent two-way communication means within the car shall comply with the following requirements:

• (d) On the same panel as the "PHONE" push button, messages shall be displayed which permit authorized personnel to communicate with and obtain responses from a trapped passenger(s) including a passenger(s) who cannot verbally communicate or cannot hear.
• (e) On the same panel as the "PHONE" push button, a message shall be displayed that is activated by authorized personnel to indicate when help is on the way. The message shall continue to be displayed until a new message is displayed [see Subsection 2.27.1.1.4(c)] or the communication is terminated.

The American Society of Mechanical Engineers (ASME) published ASME A17.1-2013/CSA B44-13 on October 2, 2013. The book is titled Safety Code for Elevators and Escalators.

Motivation for the LL 126 Elevator Two-Way Communications Device

In 2019, a woman was trapped for three days in the elevator of the Manhattan townhouse in which she worked at a time when the owners were away for the weekend. She was discovered and released from the elevator on Monday morning by a delivery person, who contacted the homeowners. Further concerns by advocates for the deaf and hearing impaired, who would be unable to hear message communication via the emergency communications system, purportedly led to this change.

Limitations and Caveats Regarding Implementation of the LL 126 Two-Way Communications Device

While this costly solution may improve access and communication for the hearing impaired to rescue services, should such an event arise, the current system has significant limitations that building owners should be aware.

• No two-way texting capability – it only has 'yes' and 'no' buttons to communicate with an operator and no touch screen or keyboard.
• No known language communication options other than English.
• No other capability, such as being able to display building messages - note that the screen is very small and limited to two lines of text.

Most important for building owners is to ensure that the layout of the buttons is not commingled with the existing elevator controls. The original panel layout shown to me and appearing in many other elevators appears below, with the emergency signaling buttons placed in an area commonly pressed by passengers, leading to accidental presses. Because there is typically no identification of this panel's use, it is important to ensure that operational elements are separated from emergency areas, such as being within proximity of the top area placement of the emergency call button - as is displayed above.

In summary, it is critically important for New York City building owners and managers engaged in elevator upgrades to be aware of NYC LL 126 and its requirement of a two-way communications device and ensure that it is implemented in a cost effective fashion with an optimal layout.