There is a belief common among California building owners that goes roughly like this: the building is fully sprinklered, therefore areas of rescue do not apply to us.
Half of that is correct, and the wrong half is the expensive one.
A fully sprinklered building generally does not need the area of refuge — the protected space itself, sized and located to hold someone who cannot use the stairs. But the two-way communication system at elevator landings is a separate requirement that the sprinkler exemption does not touch. Most commercial buildings in California are fully sprinklered, which means most of them still owe the communication system, still owe the annual testing on it, and a fair number have never had either verified.
This article covers what is actually required, where the exemptions stop, and why these systems tend to be found dead rather than found working.
What an Area of Rescue Is
The terminology shifts depending on who is talking. The California Building Code calls it an area of refuge. Manufacturers and contractors often call it an area of rescue or area of rescue assistance. NFPA calls the equipment an area of refuge emergency communications system. They describe the same thing.
The underlying problem is straightforward. During a fire, elevators are recalled and taken out of general service. Anyone who cannot use stairs — a wheelchair user, someone with a temporary injury, an older occupant on the eleventh floor — has no way down and no way to tell anyone where they are. An area of refuge is a place to wait that is relatively protected, and a two-way communication system is how the person waiting tells somebody they are there.
It is a small system with a very specific job on the worst day the building will ever have. That is also why it is the system most likely to have been quietly broken for eighteen months.
The Sprinkler Exemption, and Where It Stops
Under the accessible means of egress provisions of the California Building Code (Section 1009), areas of refuge are not required at stairways in buildings equipped throughout with an automatic sprinkler system. There are further exemptions — open parking garages, Group R-2 occupancies, smoke-protected assembly seating, stairways accessed from a horizontal exit refuge area.
What survives all of that is the two-way communication requirement at elevator landings. The code requires a two-way communication system at the landing serving each elevator or bank of elevators, on each accessible floor that is one or more storeys above or below the level of exit discharge.
So a sprinklered ten-storey office building with one elevator bank does not need areas of refuge at its stairs, and does need two-way communication stations at nine elevator landings.
| Building Condition | Area of Refuge (the space) | Two-Way Communication |
| Fully sprinklered throughout | Not required at stairways | Still required at elevator landings |
| Not sprinklered, multi-storey | Required at stairways | Required in each area of refuge |
| Open parking garage | Not required | Confirm with the AHJ |
| Group R-2 (apartments) | Not required at stairways | Still required at elevator landings |
| Horizontal exit refuge area | Not separately required | Confirm with the AHJ |
| Single-storey, at exit discharge | Not required | Generally not required |
This table is a planning aid, not a determination. Exemptions interact with the full egress design, and local jurisdictions adopt amendments. The building official and the fire department make the final call, which is why this gets settled at plan check rather than in a blog post.
What the System Has to Do
A call button and an intercom is not the requirement. The system has performance obligations under both the building code and NFPA 72, and these are what a commissioning test actually checks.
| Requirement | What It Means in Practice |
| Where it connects | Each call station communicates with the fire command centre, or a central control point approved by the fire department |
| Unattended control point | If the central point is not constantly attended, the system needs timed automatic dial-out to a monitoring location or 911 |
| Signals | Both audible and visible — a light confirms to the caller that rescue has been requested, and a light at the control point shows a request is in |
| Hands-free operation | The remote station provides hands-free two-way communication with audible and visual confirmation that communication has occurred |
| Pathway supervision | All pathways between remote stations and the master unit are monitored for integrity; a fault reports as trouble |
| Secondary power | Under NFPA 72 (2022), 24 hours quiescent standby plus 4 hours with all stations active |
| Pathway survivability | Level 2 or Level 3 — in practice, 2-hour fire-rated circuit integrity cable or an equivalent protective system |
| Listing | NFPA 72 (2022) requires these systems to be listed to UL 2525, the standard for two-way emergency communication for rescue assistance |
| Signage | Identification and instructions for use posted at each station, with the international symbol of accessibility |
| Mounting height | Operable parts within the reach ranges of the CBC accessibility chapter — typically around 3½ to 4 feet above the floor |
The secondary power figure is the one that quietly fails. Batteries degrade, and a system that met 24 hours of standby at commissioning in 2015 may not hold four hours under load now. Nobody notices, because the system is silent when it is healthy and silent when it is dead.
How It Ties Into the Fire Alarm System
In most California buildings the two-way communication system is not fully independent. Pathways and power supplies are supervised, and supervision usually reports through the fire alarm system by way of monitor modules. That interface is where a lot of projects come apart.
Jurisdictions commonly treat the two-way communication system as a deferred submittal requiring its own plan review, with the fire alarm interface — the monitor modules and how the trouble signals are reported — shown on a separate fire alarm submittal. Two submittals, two review cycles, one system. Projects that scope this as a single line item on the electrical package discover the sequencing late, usually when the certificate of occupancy is on the critical path.
The same interface is why a fire alarm panel replacement is rarely just a fire alarm panel replacement. If the monitor modules and supervision points move, the area of rescue system has to be re-verified and re-commissioned along with everything else.
The Annual Testing Obligation
Two-way communication systems for areas of refuge are required to be inspected and tested annually to verify that all components are operational, under the means-of-egress maintenance provisions of the fire code, with records of inspection, testing and maintenance retained. NFPA 72 carries the corresponding inspection, testing and maintenance requirements. Where the fire code official requires it, the test is witnessed.
This is a separate obligation from the fire alarm test. It is not discharged by an annual fire alarm certificate, and in the City of Los Angeles it is not discharged by a Chief’s Regulation 4 certificate either. Buildings frequently hold current paperwork for the fire alarm system and nothing at all for the call stations.
A proper annual test exercises every station, not a sample. It confirms two-way audio at each one, confirms the audible and visual acknowledgement at both ends, confirms the supervision reports a fault when a pathway is opened, confirms the dial-out where the control point is unattended, and load-tests the batteries against the standby and alarm durations. Anything less is a walk-through with a clipboard.
What Failure Looks Like
These systems fail silently, which is the whole problem. The common findings, roughly in order of frequency:
- Dead or depleted batteries in the master control unit — the system appears healthy on mains power and has no reserve.
- One or more stations with no audio in one direction. The caller hears the control point; nobody hears the caller.
- Stations disconnected during a tenant improvement and never reinstated, with the wiring capped above a ceiling tile.
- Missing or painted-over signage and instructions, so the station is not identifiable as what it is.
- A control point that was constantly attended when the building was commissioned and is now unstaffed after hours, with no dial-out configured.
- Supervision reporting into a fire alarm panel that was replaced, with the monitor modules never re-mapped.
- Stations mounted or obstructed outside the accessible reach range — often by furniture, planters or a recycling bin.
None of these produce a symptom anyone would notice during normal occupancy. They are found at annual test, at inspection, or on the day someone presses the button.
Retrofits and Renovations
Existing buildings are generally allowed to remain as built, which is why a 1990s building without call stations is not automatically in violation. That position changes when the building undergoes significant alteration, a change of occupancy, or an addition past the thresholds in the California Building and Fire Codes, at which point the authority having jurisdiction can require accessible means of egress to be brought to current code.
Owners are most often caught by this during a tenant improvement. The budget is set, plan check comes back, and two-way communication at every elevator landing lands on the critical path with a deferred submittal attached to it. If a renovation is anywhere in the next two years, get the accessible means of egress scope assessed before the design is finalised.
The cost driver in a retrofit is almost never the stations. It is the pathway — running survivable, fire-rated cable to each landing in a finished, occupied building.
What Else Shares the Retrofit
An area of rescue project rarely stays inside its own scope in a larger building. High-rise properties have smoke control sequences that interact with the same panel and need re-verification. Emergency responder radio coverage systems may share pathways, power or monitoring points. If the fire alarm panel is being replaced at the same time, all of the supervision interfaces move at once.
That is an argument for scoping it once with one contractor who understands all of it, rather than finding the dependencies halfway through when a second trade has to be brought in and the schedule slips.
Commissioning and Plan Submittal
- Establish with the building official and fire department what is required for your specific egress design — areas of refuge, elevator landing communication, or both.
- Confirm whether the two-way communication system is a deferred submittal in your jurisdiction, and whether the fire alarm interface needs a separate submittal.
- Specify equipment listed to UL 2525, which NFPA 72 (2022) requires for these systems.
- Confirm the pathway survivability level required by the construction type, and price the cable accordingly — this is the budget item that moves.
- Establish whether the central control point is constantly attended. If not, the dial-out path has to be designed in, not added later.
- Commission every station, not a sample, and keep the commissioning record as the baseline for future annual tests.
- Put the annual test on the same schedule as the fire alarm test so it is not orphaned.
How to Stop Discovering This at Inspection
The buildings that do not get caught treat the area of rescue system as part of the life-safety programme rather than as a fixture. They keep the commissioning record, test every station annually alongside the fire alarm test, re-verify after any tenant improvement that touched a lobby or landing, and re-commission whenever the fire alarm panel changes.
It is a small system and a small line item. The cost of neglecting it is not measured in correction notices. It is measured in someone sitting on a landing pressing a button that does nothing.
Read More:
Top Signs Your Commercial Fire Alarm System Is About to Fail
When did someone last press the button?
BEC has designed, installed, commissioned and serviced area of rescue systems across California since 1995 — courthouses, hospitals, high-rise towers and everything between. If you are not certain your stations work, or whether you needed them in the first place, we will test every one and tell you where you stand.
Call (909) 305-1600 for 24/7 emergency service, or (909) 305-1605 for the service desk. Typical response in under four hours.
Frequently Asked Questions
A. Generally not the area of refuge itself — the California Building Code exempts stairways in buildings equipped throughout with an automatic sprinkler system. But the two-way communication system at elevator landings is a separate requirement that the sprinkler exemption does not remove. A sprinklered multi-storey building still needs communication stations at each elevator landing on accessible floors above or below the level of exit discharge.
A. They describe the same thing. The California Building Code uses “area of refuge”, while manufacturers and contractors commonly say “area of rescue” or “area of rescue assistance”. NFPA refers to the equipment as an area of refuge emergency communications system. The terminology varies; the requirement does not.
A. At the landing serving each elevator or bank of elevators, on each accessible floor that is one or more storeys above or below the level of exit discharge, and within each required area of refuge where areas of refuge are provided. Elevators sharing a common landing may share one station, which reduces the count in buildings with a single bank.
A. Annually. The fire code’s means-of-egress maintenance provisions require two-way communication systems for areas of refuge to be inspected and tested each year to verify all components are operational, with records retained, and NFPA 72 carries the corresponding inspection, testing and maintenance requirements. Where the fire code official requires it, the test is witnessed.
A. No. It is a separate obligation with its own record. A current fire alarm certificate does not cover it, and in the City of Los Angeles a Chief’s Regulation 4 certificate does not cover it either. Buildings frequently hold complete fire alarm paperwork and nothing at all for the call stations.
A. The system needs timed automatic dial-out capability to a monitoring location or 911. If your building was commissioned with a constantly attended control point and the staffing model has since changed — which happens often — the dial-out path has to be designed and verified, not assumed.
A. Not automatically. Existing buildings are generally permitted to remain as built under the code in force when they were constructed. That changes with significant alteration, a change of occupancy, or an addition past code thresholds, at which point the authority having jurisdiction can require accessible means of egress to be brought to current code. Tenant improvement projects are where most owners encounter this.
A. UL 2525 is the standard for two-way emergency communications systems for rescue assistance. The 2022 edition of NFPA 72 requires systems used for area of refuge, stairway, elevator landing and occupant evacuation elevator lobby communications to be listed to it. Whether it applies to your project depends on which code edition your jurisdiction has adopted, so confirm with the AHJ before specifying equipment.
A. The stations are rarely the cost driver. The pathway is — running survivable, fire-rated cable to each landing in a finished and occupied building. Cost scales with the number of landings, the construction type that sets the required survivability level, and how accessible the routes are. A site assessment gives a real figure; a per-station rate does not.
A. You do not, unless it has been tested. These systems are silent when healthy and silent when dead, so there is no symptom during normal occupancy. A proper test exercises every station for two-way audio, confirms audible and visual acknowledgement at both ends, verifies supervision reports a fault when a pathway is opened, checks the dial-out where the control point is unattended, and load-tests the batteries against the required standby and alarm durations.
