Expert guidance, good records and ongoing vigilance support compliance
Recent fire code updates may catch building owners/managers unaware, but it’s more likely to be longstanding easily understood requirements that put them afoul of inspectors. Drawing data from more than a hundred fire safety audits conducted over the course of one year, Michele Farley reports that malfunctioning or missing doors closers and deficient fire-stopping were identified in more than 90 per cent of the buildings.
During an online Buildings Week presentation last week, Farley — the president of FCS Fire Consulting Services and a recognized expert who has served on national and provincial code development advisory committees — stressed that there’s more to compliance than simply handing off fire plan development and implementation to a professional service provider. Owners/managers, building staff and occupants all need to know their roles and be prepared to fulfill them.
“More than 50 per cent of the fire code is not the responsibility of your fire code and life safety system service providers,” she said. “Door closers, for example, are generally the responsibility of (building) supervisory staff.”
All of the most common deficiencies her audits revealed can likewise be linked to building management and operations whether that’s: failing to ensure openings forged for cabling, piping and other structural/mechanical work are properly sealed against fire spread; storing combustible materials in inappropriate places; or lax record-keeping. Although they increasingly rely on professional service providers to keep up with the complexities of compliance, owners/managers ultimately carry the responsibility for life safety and bear the brunt of enforcement.
The latter has become more challenging to navigate in recent years. The fire code, and the standards referenced within it, have evolved from 20th century applications in which they remained relatively static until updated on a five-year cycle to the current model of more frequent adjustments.
Risks have also been evolving as new construction introduces taller buildings, denser development and new types of materials and configurations, while the existing stock can be very aged in comparison. Farley points to a confluence of pressure points including code complexity, vigorous enforcement and punitive measures for non-compliance.
“The codes and standards now utilize the term of ‘maintenance documents’ and technical bulletins may be issued within two to three years of the last changes, and sometimes at any time, if something arises,” she explained. “It’s very hard to keep up with all the changes and this is reflected in the huge volume of notices of violation and inspection orders that we are seeing in good buildings, doing a good job. This is about life safety and most fire departments are now inspecting buildings annually. They’re not just looking for your annual records; they are looking for complete fire code compliance.”
New requirements can increase risk of violations and inspection orders
Farley outlined examples of recent new requirements, emphasizing the importance of records to prove compliance. Notably, many building owners are not yet compliant with an Ontario fire code change introduced in July 2018 to prescribe hydrostatic testing of water pressure in buildings’ standpipe systems. As of January 2019, owners/managers are required to have a record to show that the testing has been conducted within the last five years.
“If your building does not have the five-year hydrostatic testing record and you did not do this test yet, you are in violation of this section of the fire code,” Farley warned. “When we conduct annual fire code reviews (for clients), we regularly find this testing has not been conducted and no record is available.”
Turning to potential new requirements, a 2019 CAN/ULC standard for the design, installation, testing and maintenance of safety way guidance systems (SWGS) is expected to be referenced in future editions of the building code, which would apply to new construction, expansions and major renovations. The new standard establishes the parameters for electrically powered or photoluminescent (glow-in-the-dark) guideways to building exits.
Farley speculates it could become mandatory for buildings with challenging evacuation logistics due to height or occupancy. “It is already being referenced across Canada,” she advised.
Even more recently, another new CAN/ULC standard establishes the criteria for an integrated test of all building life safety systems to certify that they perform together as designed.
“That’s what we all want and, as of June 2020, this is now a requirement,” Farley said. “There has never been a standard that required a standardized, certified integrated test until now. Systems are professionally designed, individually verified, certified, tested and signed off on. This test is conducted after all parties have signed off on their individual systems.”
ULC will issue a certificate of verification after the test is successfully completed and the integration of life safety systems will have to be recertified at five-year intervals. “It’s a great new tool to fill the gap for individual systems testing, and I think it’s going to be a benefit for many, many buildings,” Farley asserted.
Looking to the future, an update to the CAN/ULC standard for installation of fire alarm systems is expected soon. “These are likely to be the most substantial changes that will affect your annual inspections and may affect your budgets,” she projected.
Audits and staff training help identify and address hazards
Ultimately, Farley reiterates, the goal of enhanced safety underpins both the complexity of code compliance and enforcement stringency. It may look like fire inspectors or professional service providers are primarily concerned with finding problems, but their true priority is to protect people and property.
“Damaged closers are common in stairwells and service rooms. We’re seeing substantial notices of violation on combustible loads, on storage in areas where it doesn’t belong. We know that we have a problem with record management in most buildings,” Farley tallied.
Whenever possible, she invites building staff to join her or other fire code auditors on the exploratory journey through the building to help reinforce where vigilance is required.
“What is a fire code audit? It’s every room, every floor, every door, from the top to the bottom,” she said. “When people aren’t trained to look for fire code compliance issues or potential failures in fire equipment then those things are not always readily apparent. Staff with regular training learn to recognize and address deficiencies and system anomalies, and learn to listen to complaints about odour migration. Investing in your fire code compliance will reduce costs and reduce risks.”
Barbara Carss is editor-in-chief of Canadian Property Management.