Elevator Phone POTS Replacement: What ASME A17.1 Actually Requires
Elevator phones are usually the largest single count of copper lines in a commercial building, and the one nobody wants to get wrong. The good news is that the code is more permissive than most vendors imply. It never required a copper line in the first place. What it requires is a set of behaviors, and the failure mode when a migration goes wrong is not bad audio. It is a daily self test that passes while the system is dead.
ASME A17.1 section 2.27.1 is performance based and technology neutral. It names VoIP in its own text and does not require a copper line. Cellular and VoIP are both acceptable when they deliver: two way voice to a staffed location, automatic redirect to an alternate location if the call is not acknowledged within 45 seconds, no handset and no automated answering system, building and car identification on demand, at least 4 hours of backup power, and automatic verification of the line at least daily. The 2019 edition added one way video and text messaging so responders can assess entrapment and communicate with passengers who cannot speak or hear. The catch is that your jurisdiction may still enforce a much older edition, and several states adopted 2019 while specifically excluding the video requirement.
The code never said copper
The most common misconception here is that elevator phones legally require a POTS line and that anything else is a workaround. That has never been true. ASME A17.1 describes what the communication means must do, not what technology carries it.
The standard settles it in its own text. Section 2.27.1.1.6(a)(4) says that if means other than a telephone line are used, giving VoIP, network and intercom as its own examples, then equivalent verification of that means must be performed. The code contemplates non-copper transport directly and simply attaches the same testing obligation.
Two regulators have said the same thing in plainer language. Ontario's TSSA issued an advisory specifically on this question, stating that the requirements are performance based and do not mandate nor exclude any one telephone technology, and that POTS, VoIP, cellular and wireless are all acceptable provided they are configured to satisfy the communication requirements. Washington State's elevator program permits cellular with four conditions, and its fourth condition simply says VoIP or other similar systems meeting those conditions are acceptable.
Washington's other three conditions are the practical ones, and they are worth quoting in substance:
- The communication system must be hardwired from the car to the point where the signal leaves the building. In other words, the radio cannot live in the hoistway.
- The signal to the device must be monitored as required by 2.27.1.1.6.
- Where cellular signal is known to be weak, problematic or weather impaired, the phone must be on a landline.
Washington also makes two points that save money. The code does not require a dedicated telephone line to each elevator, nor to a group of elevators, though the emergency line must take priority over anything sharing it. And existing installations do not have to be retrofitted to current requirements unless certain alterations are performed, so a like for like replacement of a failed device does not trigger the newest rules.
What section 2.27.1 actually requires
| Section | Requirement |
|---|---|
| 2.27.1.1.1 | Communication between the car and a location staffed by authorized personnel who can take appropriate action |
| 2.27.1.1.2 | If the call is not acknowledged within 45 seconds, it must automatically redirect to an alternate on site or off site location |
| 2.27.1.1.3(b) | A single push button marked with the phone symbol. Communication starts when it is pressed, so no dialing by the passenger |
| 2.27.1.1.3(f) | Building location and elevator number available on demand to the answering party |
| 2.27.1.1.3(h) | No handset in the car |
| 2.27.1.1.3(i) | No automated answering system. A person must answer |
| 2.27.1.1.3(g) | The call disconnects only when authorized personnel end it, or on a timed termination with a voice warning after at least 3 minutes |
| 2.27.1.1.4 | Where the rise is 60 feet or more, a second in building means for emergency personnel that overrides outside communication |
| 2.27.1.1.5 | 4 hours of backup power for the communication means, 1 hour for the audible signal |
| 2.27.1.1.6 | Automatic verification of line operability, continuous or at least daily, without placing a call. On failure, an audible and visual alarm at the fire recall switch |
That failure indicator has surprisingly specific requirements: a red label reading ELEVATOR COMMUNICATIONS FAILURE in letters at least a quarter inch high, visible at the designated landing, with an audible signal at least 10 dBA above ambient sounding at least every 30 seconds, silenceable only by authorized personnel and only for at least 12 hours.
The real failure mode: a self test that lies
This is the one thing to take away from this page. A legacy elevator phone verifies the line by checking for dial tone or loop current. Put an analog adapter in front of it and the adapter supplies dial tone from its own circuitry, whether or not the internet connection behind it is working. The daily verification required by 2.27.1.1.6 passes. The failure indicator stays dark. The system is dead and nobody knows until somebody is trapped in a car.
Ontario's regulator described exactly this: a phone that met the requirements on POTS may not meet them on VoIP, because the existing phone may only be capable of confirming a connection to a modem rather than confirming that a functioning connection exists beyond the modem. Their prescription is the right one, and it is what to write into any scope of work: end to end verification, a check from the car phone through to the location that actually answers the call.
Ask any vendor two questions. What exactly does your daily test verify, and does it confirm reachability of the answering point or only local dial tone? If the answer is dial tone, the product does not satisfy 2.27.1.1.6 no matter what the brochure says.
Backup power is a whole path problem
Section 2.27.1.1.5 requires the communication means to keep working for at least 4 hours after building power fails. On copper that was free, because the phone company powered the line from its own building. On any replacement it is a design problem.
The obligation attaches to the communication means, not just to the phone. On a VoIP path that means 4 hours has to cover the analog adapter, the router, any switch, and the modem or ONT. A battery on the car station alone does not satisfy the requirement if the adapter dies in the first minute. On a cellular path it covers the radio, and the carrier's tower needs its own backup in a regional outage, which is outside your control entirely.
The code also does not distinguish talk time from standby time, and that ambiguity is where cheap devices fail. A device advertising 4 hours of standby may deliver far less under an active call. Some vendors sidestep the argument by shipping far more capacity than required, which is a reasonable thing to ask for.
What the 2019 edition added, and what vendors get wrong about it
The 2019 edition made the first substantive change to elevator emergency communications in years, adding four capabilities. Section 2.27.1.1.3 now also requires a message acknowledging that communications are established, messages that let authorized personnel query a passenger who cannot speak or hear and receive responses, a message indicating help is on the way, and a means to display video for entrapment assessment.
It is one way video, not two way. Plenty of vendor pages and summaries describe the 2019 edition as requiring two way video. The industry body that helped draft the language is explicit that there is one way video, so that authorized personnel can verify a passenger is present in the car. The passenger gets a text display, not a video feed of the operator. If a proposal is priced around two way video in the car, somebody has misread the code.
A second common error: the video requirement is often described as applying only to elevators with a rise of 60 feet or more. That understates it. The video requirement in 2.27.1.1.3(k) applies to every elevator in scope. The 60 foot threshold in 2.27.1.1.4 adds a second viewing point inside the building for arriving emergency personnel.
One genuinely useful fact for budgeting: the 2019 requirements were written as additions to the previous edition, so equipment meeting the 2019 rules can be installed in a jurisdiction enforcing an older edition without creating a conflict. Buying to the newer standard is never wrong, even where it is not yet required.
Which edition applies to you, and why it matters so much here
ASME publishes the code. States and cities adopt it, often years later and with amendments. The spread in the United States is unusually wide, and unlike most code questions this one changes what hardware you need.
| Adopted edition | Examples | What it means |
|---|---|---|
| 2007 to 2013 | Indiana (2007), Tennessee (2010), New York State, Kentucky, Massachusetts, Maine, Vermont (2013) | No video or messaging requirement. Audio only equipment can still be compliant |
| 2016 | Texas, Michigan, Minnesota, Wisconsin, Arkansas, Rhode Island, Missouri | Still no video or messaging |
| 2019 | Most states, including Florida, Georgia, Ohio, Washington, Virginia, New Jersey, Arizona, Colorado's neighbors | Video and messaging required |
| 2019 with the video section excluded | Alabama, Idaho, Montana, Utah, and Oklahoma outside Oklahoma City | Adopted 2019 but specifically carved out section 2.27.1.1.3. Video is not required |
| 2022 | Colorado, Kansas, New Hampshire, Wyoming | Substantively the same as 2019 for communications |
| Varies by county or city | California, where Los Angeles and San Diego counties adopted 2019, and Illinois, where Chicago follows 2016 while the state is on 2019 | Ask locally. The state answer may be wrong for your building |
The 2025 edition was published in January 2026, but it changed emergency responder radio coverage, buffers and seismic requirements. For elevator emergency communication, 2019 is still the operative edition and nothing material has changed in seven years.
State by state tables for this are maintained by vendors rather than by any authority, and at least one of them contradicts itself. Treat the table above as a starting point for a conversation with your elevator inspector, not as an answer.
The 911 question nobody asks until afterward
Elevator phones usually call a monitoring center rather than 911, so this gets skipped. It should not be, for two reasons.
First, some adapters sold for exactly this job do not support 911 at all. At least one well known cellular POTS adapter lists elevator phones, roadside call boxes and gate intercoms as its intended applications, with a footnote stating the product does not support 911 or E911 emergency calling. Nothing about that is improper, and the disclosure is right there on the page. But a facilities manager scanning a feature grid will not read the asterisk, and the gap stays invisible until someone needs it.
Second, the location record stops being automatic. On copper, the address tied to a 911 call was a property of the physical pair, maintained by the carrier. On any replacement it becomes a provisioned database entry that somebody has to populate and keep current. If a vendor bulk provisions a fleet of devices against a billing address, every call delivers a confident, validated, wrong address. The call completes and nothing looks broken.
The question to ask. What exact street address, suite and floor is provisioned against this specific line, who updates it if the equipment moves, and has a live test call been placed and confirmed with the serving dispatch center? A validated address only means the address exists. It does not mean the device is there.
Two things that are not the elevator phone
Buildings frequently discover a second and third system during a POTS migration, and both get confused with the car phone.
Landing and area of refuge phones
The International Building Code section 1009.8 requires a two way communication system at the landing serving each elevator on accessible floors above or below the level of exit discharge. Where the answering point is unattended, it requires automatic dial out to an approved supervising station or to 911. That is a separate system from the car phone, with its own copper dependency and its own 911 obligation.
NFPA 72 does not govern the car phone
Some vendor pages list NFPA 72 as covering elevator emergency communication. It does not. NFPA 72 chapter 21 covers elevator recall and fire alarm interfaces, meaning the system that sends elevators to the ground floor during an alarm. The passenger help phone answers to ASME A17.1. The two systems meet in exactly one place: the code requires the communications failure indicator to sit at the fire recall switch. Fire alarm panels have their own guide, covering what NFPA 72 actually requires for a fire alarm POTS replacement.
Vendor claims worth checking
| Claim | Reality |
|---|---|
| "VoIP is not code compliant for elevator phones" | Contradicted by the code and by two regulators. The standard names VoIP itself. The defensible version is that consumer grade VoIP usually fails the verification and battery requirements, not that VoIP is prohibited |
| "The 2019 edition requires two way video" | It requires one way video so responders can see the car. Passengers get a text display |
| "Video is required only above 60 feet" | Video applies to every elevator in scope. The 60 foot rule adds a second in building viewing point |
| "The call must be answered within 30 seconds" | Obsolete. That was the 2004 edition. Current code is 45 seconds to acknowledge, then automatic redirect |
| "Our cellular phone meets all ADA and building codes" | Blanket claims like this are unsupportable. Compliance is installation specific and determined by your inspector, and cellular is expressly barred where signal is known to be weak |
| "UL listed, therefore A17.1 compliant" | There is no UL listing category for A17.1 elevator phone compliance. A UL mark on the device says nothing about code compliance here |
| "The 2022 edition introduced video communication" | Video arrived in the 2019 edition. The 2022 change list does not include emergency communications |
What to ask before you sign
- Which edition of ASME A17.1 does my authority having jurisdiction enforce, and does it include the video and messaging section?
- What exactly does the daily verification test, and does it confirm the answering point is reachable rather than just local dial tone?
- Does the 4 hours of backup power cover the entire path, including the adapter and network equipment, and is that talk time or standby?
- Is the signal path hardwired from the car to where it leaves the building, and has cellular coverage been surveyed at that location?
- Who answers the call, is it staffed continuously, and is the redirect to an alternate location configured and tested?
- Does the answering party receive the building address and car identification without asking the passenger?
- Will this change trigger an alteration requirement, and does the elevator inspector need to witness a test?
Our view
Elevator phones are the easiest of the life safety lines to move and the easiest to move badly. The code is on your side: it is performance based, it explicitly contemplates VoIP and cellular, and it does not require a dedicated line per car. What it does require is that the system prove it is alive every single day, and that is exactly the requirement a generic analog adapter quietly defeats.
Buy on the verification method and the backup power path, not on the price per line. Then confirm the adopted code edition with your inspector before anyone orders hardware, because in four states the video requirement you were about to pay for does not apply, and in several others the equipment you were about to buy is a year out of date.
For the wider migration, including what the FCC actually did, what copper costs now, and every other device still on an analog line, see the POTS line replacement guide.
Sources
- ASME A17.1/CSA B44, Safety Code for Elevators and Escalators, section 2.27.1, 2019 and 2022 editions
- National Elevator Industry Inc., guidance on the 2019 emergency communications requirements
- Washington State Department of Labor and Industries, Technical Circulars 18-04 and 18-08 on elevator and cellular communication devices
- TSSA Ontario, Advisory Ref. 290-20, Elevator Phones and the Acceptability of Communication Technologies, September 2020
- International Building Code section 1009.8, two way communication at elevator landings
- Code editions and local amendments change. Confirm the enforced edition with your elevator inspector before relying on any date or section number here.
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