Of the several structural and life safety updates in the 2025 BCNYS, the elevator hoistway smoke curtain change under § 3006.3 Item 5 stands out for one specific reason: it doesn't just affect new construction. Through the EBCNYS compliance pathway, it also reaches existing buildings undergoing Level 2 Alterations to elevators or elevator lobbies. For fire alarm contractors and expediters working on renovation projects, that distinction changes the scope of what you need to coordinate with the design team before filing.
TWO COMPLIANCE PATHS — BOTH ARE VALID
The code provides a choice: either install a smoke protective curtain assembly at each elevator hoistway door opening, or enclose the elevator in a fire and smoke protected lobby. One or the other is required — both satisfy the code. The design team selects the appropriate path based on architectural and cost constraints.
What Changed: Item 3 to Item 5
The NYSED Notable 2025 Code Changes document describes this update under Item #3 of the BCNYS section:
"Item 5 now explicitly requires a smoke protective curtain assembly at hoistways. This curtain shall be provided at each elevator hoistway door opening, unless the elevator is enclosed by a fire and smoke protected lobby. For existing buildings undergoing Level 2 Alterations, according to EBCNYS 801.4 Compliance, new construction elements must comply with the requirements of the Building Code of New York State. So a smoke curtain or a smoke protected lobby is required when performing Level 2 alterations to an elevator or the elevator lobby."
— BCNYS § 3006.3 Item 5, Notable 2025 Code Changes, NYSED OFP (12/15/2025)
The key word is "explicitly." Under the 2020 BCNYS, the smoke control requirements for elevator hoistways existed under Item 3 but left room for interpretation on whether the physical curtain assembly itself was mandatory. Item 5 in the 2025 code removes that ambiguity entirely.
The Two Compliance Paths
When § 3006.3 Item 5 is triggered, the code offers two valid design approaches:
Path A: Smoke Protective Curtain
A listed smoke protective curtain assembly at each elevator hoistway door opening. Deployed automatically upon smoke detection. Typically the more cost-effective option for existing shafts where lobby reconfiguration isn't feasible.
Path B: Fire and Smoke Protected Lobby
Enclosing the elevator within a dedicated lobby with the required fire and smoke ratings. Eliminates the curtain requirement per opening. More architecturally disruptive but preferred in some renovation scenarios.
The design professional selects the path based on project constraints. What's not acceptable is providing neither — that's the interpretation the 2025 code update closes off definitively.
The Level 2 Alterations Trigger: Existing Buildings
This is where the change gets operationally significant for renovation projects. Under EBCNYS § 801.4, new construction elements introduced during alterations must comply with the current BCNYS. This means that when a project performs Level 2 Alterations to an elevator or its lobby, the smoke curtain or protected lobby requirement follows — even if the building was built under an earlier code edition that didn't require it.
| Project Type | § 3006.3 Item 5 Applies? | Notes |
|---|---|---|
| New Construction | Yes — always | Full compliance required |
| Additions | Yes | New elements comply with 2025 BCNYS |
| Change of Occupancy | Yes | Per the scope of the change |
| Level 2 Alterations — elevator or lobby work | Yes — via EBCNYS 801.4 | New elements must meet current BCNYS |
| Level 1 Alterations | Not directly triggered | Confirm scope with RDP |
Your Filing Package Doesn't Have to Be the Bottleneck
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Access the Filing Tools →Fire Alarm Interface: What Contractors Need to Coordinate
The smoke protective curtain assembly doesn't operate independently — it's triggered by the fire alarm system. This creates a direct coordination requirement for fire alarm contractors on any project where a curtain is the chosen compliance path. Specifically:
- The curtain's activation sequence must be documented in the fire alarm system sequence of operations
- The smoke detection device(s) that trigger the curtain must be specified and located per the system design
- The TM-1 or equivalent filing documentation should reflect the curtain as an auxiliary control function of the fire alarm system
- Interface wiring between the fire alarm control panel and the curtain motor/controller must be coordinated with the curtain manufacturer's specifications
On renovation projects with Level 2 Alteration scope, this often means the fire alarm system itself needs to be updated to support the new curtain interface — which can expand the project's fire alarm filing scope unexpectedly if not identified early.
Checklist: Elevator Projects Under the 2025 Code
- Confirm project type: new construction, addition, change of occupancy, or Level 2 Alteration
- If Level 2: confirm whether alteration work touches the elevator or elevator lobby
- Confirm the chosen compliance path: smoke curtain or protected lobby
- If smoke curtain: confirm fire alarm interface requirements are reflected in the system design and TM-1
- If protected lobby: confirm fire and smoke ratings are specified in the construction documents
- For multi-elevator banks: confirm each hoistway opening is addressed individually unless covered by a single protected lobby