As fire protection professionals, we are obligated to comply with the requirements of the Codes and Standards. These requirements are very comprehensive, therefore, numerous discussions on Code interpretation for applications to solve our clients ‘life safety concerns’ continues to be prevalent.
For simplicity reasons, and since I reside in Ontario, Canada, I will primarily use Ontario references. However, most of these concepts will apply to both NFPA, and International Building Code concepts. I will excuse myself in advance to life safety professionals who work and reside outside of my home province, and have a much better understanding of the larger Canadian and international applications.
In general, people believe that they are safe when they are in a building and they should be for many reasons:
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- Canada is a world leader in the development of comprehensive, yet practical, construction codes;
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- The governmental authority, to ensure the public is safe, reviews the building following renovations, expansions or upgrades (i.e. new fire alarm system);
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- New buildings are designed and reviewed for compliance to the Building Code;
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- Following completion of construction, local authorities review new buildings before an occupancy permit is granted;
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- Fire Code requires owners to maintain their life safety building systems and train the occupants for evacuation during an emergency.
If Codes and Standards are necessary to build and allow occupancy of a building, why do the requirements dictated by the authorities appear to be inconsistent? Typically, the commercial, industrial and residential property portfolio managers, who are responsible for overseeing multiple buildings over many jurisdictions, will be challenged in understanding these inconsistencies that occur from jurisdiction to jurisdiction.
Why the inconsistencies? For instance, manometer readings for the duct smoke detectors are provided annually for the downtown high-rise fire alarm, but not for the suburban high-rise duct smoke detectors. A property manager’s discussions with two different fire alarm service companies on this subject will often result in two different recommendations, such as, “that section of the UL/ULC Standard is not enforced in this area,” and/or “we do not perform the manometer test”.
Some speculation? Perhaps some local fire inspectors are reading from the “wrong” version of ULC standard that is referenced in the current Fire Code, thus enforcing an amended article.
Or maybe the service provider is not aware of the current requirements, and since the fire inspector has not challenged them, the service provider continues to perform a suspect or incomplete service.
So where do we go from here? With all these challenges regarding the application of the Codes and Standards, I suggest one of a number of possible solutions.
We must improve our ability to select the right document for our applications.
Often, due to the pressures of everyday life, we get caught up in the moment or issue, without stepping back and reflecting on the simple procedures to determine the correct application. Having said that, we need to simplify our approach and review some simple, general questions.
1. “Where is it required?” – BUILDING CODE
If you are trying to confirm where a manual station is required, consult the 2006 edition of the Ontario Building Code. Division B, Clause 3.2.4.17 (1) (a) “near the principal entrance to the building” and (b) “near every required exit”.
Tip: Watch out for the “and” “or” statements in the Code. They could get you in trouble.
2. “When do I test or maintain?” – FIRE CODE
If you have been asked when a fire alarm system is to be inspected or tested then consult Section 6.3 of the Ontario Fire Code. When can you relocate a manual station if there is a high incidence of false alarms? In Ontario, Sentence 6.3.1.7(1) “… approved, manual pull stations for a fire alarm system in a building may be relocated if there is a high incidence of false alarms in the building”
Tip: Watch out for the “Bold” lettering; this is a defined term. “Approved” means approved by the Chief Fire Official (Section 1.2).
3. “Who” is responsible? – Fire Code (in Ontario) & Occupational Health & Safety Act, Applicable Provincial Trade and Qualification Act and other Provincial Regulations.
Who is responsible?
The Ontario Fire Code, Sentence 1.1.1.1(1) “the owner or the owner’s authorized agent is responsible for carrying out the provisions of this Code.”
Based on the code we know that the owner is responsible. Interesting that this is the first sentence in the Fire Code.
Who can test fire alarm systems annually?
In Ontario, Clause 1.1.5.3(1) (a) “have successfully completed a program or course acceptable to the Fire Marshal.” The CFAA program is an accepted program in Ontario.
Who can install fire alarm systems?
In Ontario, the Occupational Health and Safety Act and Regulations for Construction Projects requires electrical work to be performed by persons qualified under the Trades and Qualification Act.
4. “How do you install, verify and inspect properly?” – Standards
Earlier, I provided an example of the Building Code defining where a manual station is required. The Building Code does not provide specific information regarding how to install the manual station.
The how to verify a newly installed manual station is found in the CAN/ULC-S537-04, Verification of Fire Alarm System.
The how to inspect and test a manual station is found in the CAN/ULC-S536-04, Inspection and Testing of Fire Alarm System.
5. “What went wrong?” – Update to Codes and Standards and Training
The great thing about human nature is that we typically learn from our mistakes. The Codes and Standards have evolved based on this simple paradigm. Here is a case study of some lessons learned:
The Fire: (1995) 2 Forest Laneway, North York, Ontario
A fire in a 30-storey high-rise apartment resulted in six fatalities.
The emergency electrical system failures during this fire included:
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- Emergency lighting
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- Fire alarm system
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- Emergency voice paging system
Lessons Learned – Emergency plan:
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- Developed new training courses for supervisory staff of residential high-rise (December 1996 press release)
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- Modified the 1997 Ontario Fire Code to identify only qualified persons are allowed to install/verify and test fire alarm systems
6. “Why did it happen?” – Code Updates
The National Research Council Institute for Research in Construction’s Canadian Codes Centre plays a vital role in the process of understanding why something went wrong and how to improve it by providing technical and administrative support to the Canadian Commission on Building and Fire Codes (CCBFC). The CCBFC and its related committees are responsible for the development of the national model construction codes of Canada.
As fire protection professionals, we are obligated to comply with the requirements of the Codes and Standards. Our continued efforts to stay up to date, and apply the right document for the job, will ensure safer buildings for all.
Sincerely,
David Sylvester
Director of Research and Industry Affairs
Mircom
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