Picture this: an NBN technician swaps out the copper line in your comms room on a Tuesday. The lift phone — a white handset bolted to the wall of car 2 since 2008 — goes silent. Not obviously silent. There is no alarm, no fault light, no call from a tenant. The phone looks exactly the same. The PSTN line it ran on simply no longer exists.
Three weeks later, a SafeWork inspector visits for an unrelated matter. He presses the emergency button in car 2. Nothing happens. He asks for your test log. You open a spreadsheet that was last updated in 2021.
That moment — not a dramatic rescue failure, just a quiet administrative inspection — is where lift phone compliance exposure actually lands. The question is not whether someone will be trapped. The question is whether your documentation, your technology, and your duty-of-care record can survive scrutiny. For owners corporations, the answer carries a potential $2.373 million penalty under the Work Health and Safety Act for a Category 2 breach. SafeWork NSW increased its penalty notice amounts by 24% from 1 July 2024 under the Work Health and Safety Amendment (Penalty Notices) Regulation 2024. This is not a hypothetical risk.
This guide maps what compliance actually requires, what two specific events made millions of buildings non-compliant overnight, and how to think clearly about the technology decisions involved.
What AS1735.19 Actually Requires
The governing standard is AS1735.19:2019 — the current version of the Australian Standard for lifts, escalators and moving walks, Part 19, covering remote monitoring. It sits alongside state WHS legislation as the technical benchmark auditors and inspectors use. Here is what it mandates.
Two-way hands-free voice communication. The phone must be push-button initiated and provide audio confirmation to the passenger when a connection is established. A ringing tone is not confirmation — the passenger must know they are connected.
Building and car identification without passenger input. The monitoring centre must be able to identify the specific building AND the specific lift car independently of anything the passenger says. In practice, this is delivered through CLI (Calling Line Identification) — the lift phone calls from a registered number that is mapped to a specific building address and car. If two lift cars in the same building share a caller ID, the monitoring centre cannot tell which car is calling. This is a direct compliance exposure.
Network redundancy. The system must not fail solely because a single communications path is unavailable. This requirement is the technical foundation for the single-SIM versus dual-path debate covered below.
Power backup. A minimum of two hours of operation during a mains power outage is required. This is a significant and commonly overlooked point for NBN-connected systems: NBN services go dark during a blackout unless the CPE (modem/router) is connected to an independent battery or UPS. A lift phone connected to an NBN service without a UPS fails at exactly the moment it is most likely to be needed.
24/7 staffed monitoring. The call must connect to a person or a permanently staffed monitoring centre at all times. Dialling a facility manager's mobile, an office number that closes at 5pm, or any line that could go unanswered is non-compliant.
Regular testing with records. A monthly functional test call is standard practice under AS1735.19 and is what an auditor will ask for first. The log must record date, time, who conducted the test, which car was tested, and the outcome.
| AS1735.19 Requirement | What It Means in Practice | Common Failure Point |
|---|---|---|
| Two-way hands-free voice | Push-button initiated, audio confirmation of connection | Old handsets with no connection tone |
| Caller ID per lift car | Monitoring centre identifies building and car without passenger input | Multi-car buildings sharing one caller ID |
| Network redundancy | System survives single-path outage | Single SIM with no failover |
| Power backup (2 hrs min) | Operates during mains blackout | NBN CPE with no UPS |
| 24/7 staffed monitoring | Call answered at any hour, every day | Unmanned office numbers, mobile voicemail |
| Test records | Monthly functional test log retained | No log, or log not updated for months |
Two Events That Made Millions of Buildings Non-Compliant
The NBN Copper Cutover
From roughly 2017, NBN Co began retiring the copper telephone network that most Australian lift phones relied on. The NBN had a temporary accommodation called the Fire and Lift Register, which allowed registered services to remain on copper. That register closed to new registrations on 25 February 2022.
Any building that did not register before that date, or that subsequently changed its lift phone setup, now has no copper path available. The consequence was the scenario described at the opening of this post: phones went dead during cutovers, and because lift phones are not tested frequently enough in many buildings, the failure went undetected for weeks.
The 3G Shutdown
Buildings that responded to the NBN copper retirement by installing a GSM/cellular lift phone module received a second blow. Telstra and Optus both shut down their 3G networks on 28 October 2024.
Any gateway that connects via 3G-only is now making zero calls. The device is powered. The handset looks functional. Nothing happens when you press the button. Before the shutdown, SafeWork SA wrote directly to registered lift owners noting that approximately 5,900 lifts in South Australian business premises were potentially affected. The actual national figure across all states is substantially higher.
There is an important technical addendum: a device labelled "4G" is not automatically safe. A 4G device that does not support VoLTE (Voice over LTE) cannot make voice calls on modern networks, because 4G data and 4G voice are separate capabilities. If your gateway was installed before VoLTE became standard, confirm explicitly with your provider that it supports VoLTE — not just 4G data.
Who Is Actually Responsible
This is the most misunderstood question in lift phone compliance, and the confusion is actively exploited by parties who want to pass liability to someone else.
| Party | Role | Compliance Duty |
|---|---|---|
| Owners corporation (strata) | PCBU under the WHS Act | Primary duty holder. Cannot be delegated away. |
| Building owner (commercial) | Operator of the premises | Primary duty holder alongside facilities management |
| Strata manager | Administers operations on instruction | No direct WHS duty — acts on behalf of the OC |
| Facilities manager | Day-to-day site management | Carries operational duty; OC/owner remains ultimately responsible |
| Lift maintenance contractor | Services mechanical equipment | Responsible for what is in their contract — not the comms path |
| Lift phone/monitoring provider | Supplies and maintains the phone system | Responsible for the service they supply — not the compliance outcome |
The critical point: the owners corporation is the PCBU under the WHS Act. This is not a technicality. If a person is harmed in a lift due to a non-functional emergency phone, the OC is the party facing prosecution — not the strata manager who forgot to arrange testing, not the lift company whose contract did not cover the GSM module, and not the monitoring provider if no monitoring contract was in place.
The OC cannot point to a maintenance agreement and walk away from liability. Outsourcing a function does not transfer the duty of care. The OC must satisfy itself that the function is being performed.
In commercial buildings, the building owner and the facilities manager carry equivalent responsibility. A thorough facilities management agreement should address lift phone compliance explicitly — not leave it to the lift maintenance contractor by default.
The Technology Decision: What Your Options Actually Are
PSTN copper is gone. 3G is gone. These are the current options, with their compliance characteristics stated plainly.
Lift Gateway LTE — Single SIM
Connects via one mobile carrier (typically Telstra). Supports one lift. Unique caller ID. The lowest-cost option and the simplest to install.
The limitation: if that carrier experiences an outage in your area, the phone fails. A single-SIM solution does not inherently satisfy AS1735.19's network redundancy requirement by itself. For a single-lift, lower-risk building with strong carrier coverage and active device health monitoring, this can represent a proportionate and defensible solution. It is not appropriate as the only safeguard in high-consequence environments such as aged care, hospitals, or high-rise residential.
Lift Gateway LTE — Dual SIM
Telstra as the primary carrier, Optus as automatic failover. Supports one lift. If the primary path goes down, the device switches without intervention.
One thing to confirm before installation: the caller ID changes on failover because each SIM has its own number — your monitoring centre must be configured to accept and correctly identify both numbers as the same building and car. For a single-lift building this is straightforward to manage. For multi-car buildings, see the Dual SIM, 4-Car option below.
Lift Gateway LTE — Dual SIM, 4-Car
The same dual-carrier failover as the Dual SIM, extended to support up to four lift cars on a single gateway. Telstra primary, Optus failover.
The compliance consideration: when multiple lift cars share a single gateway, all cars present the same caller ID to the monitoring centre. The monitoring centre cannot identify which car is calling without asking the passenger — which is a direct AS1735.19 exposure. This product is suited to buildings where cost is the primary constraint and the monitoring centre has an alternative identification protocol in place. For buildings where full per-car identification is required, the VoIP/NBN gateway is the correct solution.
Lift Gateway VoIP — nbn + LTE Backup
The lift phone runs over NBN or a dedicated Opticomm line as the primary path, with automatic 4G mobile failover. The phone carries a standard landline number (02 XXXX XXXX format) that does not change when failover occurs — the mobile backup presents the same caller ID to the monitoring centre.
Each lift car is assigned its own dedicated landline number, so the monitoring centre always knows exactly which car is calling — regardless of which network path is active. This scales from one lift to 24, requires a properly sized UPS on the NBN CPE, and carries unlimited call allowance and a 36-month warranty.
Settling the Single SIM vs Dual-Path Debate
AS1735.19 requires the outcome of network redundancy, not a specific technology. A single SIM on a robust 4G network with active device monitoring that alerts when connectivity is lost can satisfy the standard for a single-car, lower-risk building.
For multi-car buildings, aged care facilities, hospitals, or any high-rise where the consequence of a missed emergency call is severe, dual-path or VoIP with 4G failover provides materially better protection and a materially stronger compliance record.
| Solution | Lifts Supported | Network Failover | Caller ID on Failover | Best For |
|---|---|---|---|---|
| Lift Gateway LTE — Single SIM | 1 | None | Stable | Single lift, lower-risk buildings |
| Lift Gateway LTE — Dual SIM | 1 | Optus 4G | Changes (new number) | Single lift requiring carrier redundancy |
| Lift Gateway LTE — Dual SIM, 4-Car | 1–4 | Optus 4G | Changes — all cars share same ID | Budget multi-lift where monitoring centre has alternate ID protocol |
| Lift Gateway VoIP — nbn + LTE Backup | 1–24 | 4G Mobile | Stable — landline number never changes | Multi-car, compliance-critical, high-rise |
The Multi-Car Caller ID Problem
When two or more lift cars are connected to the Lift Gateway LTE — Dual SIM, 4-Car, all cars call out from the same number. The monitoring centre receives a call and cannot determine which car it is coming from without asking the passenger, who may be incapacitated, panicking, or a child.
This is a direct breach of AS1735.19's requirement that the monitoring centre identify the specific lift without relying on the passenger. For multi-car buildings where full compliance is required, the Lift Gateway VoIP — nbn + LTE Backup assigns each car a unique dedicated landline number that never changes. The cost saving from the shared LTE gateway is real; the compliance exposure is also real, and should be disclosed in writing before any multi-car LTE installation is approved.
Device Certification: The Question Nobody Asks
Any cellular device installed in a building in Australia must carry ACMA/RCM (Regulatory Compliance Mark) certification under the Telecommunications Labelling Instrument 2015. The RCM mark confirms the device has been assessed for electromagnetic compatibility and electrical safety in the Australian context.
This matters for two reasons. First, an uncertified device is non-compliant with Australian telecommunications law regardless of how well it functions. Second, if an uncertified device contributes to an incident, the building operator's legal position is materially worse.
Ask your provider directly: does the gateway carry the RCM mark? Request documentation. This is a standard professional ask, not an unusual one.
Ongoing Obligations After Installation
Installation is not the end of your compliance obligation. It is the beginning.
Monthly Functional Test Call
Press the button. Confirm the call connects. Confirm the monitoring centre receives the correct caller ID and identifies the correct building and car. Record the result.
Your test log should include:
- Date and time
- Who conducted the test
- Which lift car was tested
- Whether the connection was established successfully
- Whether the monitoring centre correctly identified the building and car
- Any faults noted and follow-up action
Annual Battery Test
Test backup power operation at least annually. NBN UPS batteries degrade over time and do not announce their failure. The first time many buildings discover their UPS battery is flat is during a blackout — when the backup is needed most.
SIM Plan Continuity
A lapsed SIM plan is one of the most common silent failures in the industry. The device is powered. The gateway is connected. The SIM expired three months ago when a credit card changed and nobody updated the billing details. Set a quarterly calendar reminder. Confirm your provider has an automated alert mechanism before a plan lapses — not after.
State Registration and Inspection
SafeWork SA requires annual lift registration and inspection. Other states operate equivalent regimes. Lift phone function is part of what inspectors check. Retain records for at least five years — inspectors and insurers will request them.
Questions to Ask Any Provider Before You Sign
| Question | Why It Matters |
|---|---|
| Does the gateway carry RCM certification? | Uncertified devices are non-compliant under the Telecommunications Labelling Instrument 2015 |
| Is this single SIM or dual-path, and what happens to the caller ID during failover? | Determines your redundancy posture and monitoring centre configuration |
| If I have multiple lift cars, does each car get a unique caller ID at the monitoring centre? | Shared caller ID across cars is a direct AS1735.19 exposure |
| What happens to my service if I change lift maintenance companies? | Your phone contract should be independent of your mechanical maintenance arrangement |
| What does your monitoring centre do when a call comes in at 3am on a public holiday? | 24/7 staffed monitoring is a compliance requirement, not a premium feature |
| How will I know if the SIM plan lapses? | Silent SIM failures are common — confirm the alert mechanism |
| What battery backup runtime does the device provide, and how is it tested? | Minimum 2 hours required; degradation must be actively managed |
| Is device health monitoring included, and what alerts does it generate? | Proactive fault detection is the difference between catching a failure on Tuesday and discovering it at a SafeWork inspection |
Frequently Asked Questions
Q: Our building has three lift cars and we were told a single gateway is fine. Is that true? A: A single gateway can serve multiple cars, but only if each car is assigned a unique caller ID at the monitoring centre. If all three cars share the same caller ID, the monitoring centre cannot identify which car is calling — which is a direct breach of AS1735.19. Ask your provider specifically whether each car presents a unique caller ID to the monitoring centre, and get the answer in writing.
Q: We upgraded from copper to a 4G GSM module a few years ago. Are we still compliant? A: Possibly not. If the upgrade was done before 2022, the device may be 3G-only and now non-functional following the 28 October 2024 network shutdown. Even if it is a 4G device, confirm explicitly with your provider that it supports VoLTE — a 4G data device without VoLTE cannot make voice calls on modern Australian networks. Test the phone and check with your provider.
Q: The lift maintenance company says compliance is their responsibility. Is that correct? A: No. Under the WHS Act, the owners corporation (in a strata building) or building owner (in a commercial building) is the PCBU — the primary duty holder. A maintenance contract can assign service obligations to a contractor, but it does not transfer the duty of care. If the phone fails and someone is harmed, the regulator will look first to the OC or building owner, not the contractor.
Q: Is monthly testing really required, or is annual testing sufficient? A: Monthly functional test calls are the standard practice expected by auditors and regulators. Annual testing is insufficient — a phone can fail at any point in a 12-month period, and a year-old test record does not demonstrate that the system was functional on the day of an incident. Monthly testing, with a maintained log, is both the regulatory expectation and the practical minimum.
Q: What is VoLTE and why does it matter? A: VoLTE (Voice over LTE) is the technology that allows a 4G device to make voice calls — as distinct from 4G data, which only handles internet traffic. Following the 3G shutdown in October 2024, all voice calls on Australian networks must travel over VoLTE or 5G voice. A gateway that supports 4G data but not VoLTE cannot make calls. This distinction is not always clear in device specifications, so confirm it explicitly with your supplier.
Q: Does a VoIP/NBN system work during a power outage? A: Only if the NBN CPE (modem/router) is connected to an independent UPS with sufficient battery runtime. NBN Co's network does not provide power to customer equipment — if your CPE loses power, the NBN connection fails. A properly specified VoIP/NBN lift phone system includes a UPS on the CPE as a standard component. If yours does not, the system fails the AS1735.19 power backup requirement.
Q: Can one gateway serve multiple lift cars? A: Yes, but there is a critical compliance condition: each car must be assigned a unique caller ID so the monitoring centre can identify which car is calling. This is achievable with a VoIP/NBN multi-car system, where each car is assigned a dedicated landline number. It is not achievable with a shared LTE gateway where all cars call out on the same number — if your building has multiple lifts on a shared LTE connection, the monitoring centre cannot distinguish between them and this needs to be resolved.
Where to Go From Here
If you are reading this because you are not certain whether your building's lift phone is compliant, the first step is a straightforward site assessment — not a sales call.
Pickle offers a no-obligation site assessment. We will tell you exactly what you have, whether it meets AS1735.19:2019, and what it would cost to fix if it does not. No lock-in contracts.
We also have a one-page compliance checklist you can use right now to work through your current setup — test log, SIM plan status, device certification, caller ID configuration. Request it here or book a site assessment.
The standard is not complicated. The obligation is clear. The gap between where most buildings are today and where they need to be is usually smaller than facility managers expect — and the cost of finding out is zero.