The Provincial Fire Marshals and Commissioners offices are not giving direct instruction on how you are to implement the fire code in your condo currently.
Why is that? The Fire Code is the law and officials are not going to instruct you to disobey the law.
These are unprecedented times. Some provinces have far more active cases which may limit condos ability to conduct testing. Others may have multiple active cases in their area or building raising concerns of in-suite access. You must do all you can to meet the fire code, where safe to do so.
We are experiencing a significant increase in home fires, up to 65% in some provinces, with the leading causes being cooking and careless smoking.
SO, how do you keep both your people and your residents safe?
The Canadian Fire Alarm Association (CFAA), a national organization; released guidelines in April stipulating that it may be reasonable to postpone in-suite testing. Testing is regulated by the National test Standard CAN/ULC-S536, which you and your service providers follow for annual and monthly testing. May 5th, CFAA released a COVID-19 Bulletin stating you must track who helped you to make any decision to deviate from the fire code, when postponing any testing. UL released a statement saying – If circumstances prevent you from complying with the written requirements of the Standard you must document your alternate procedure, when the change went into affect & when it will go out of practice.
How do you differentiate and determine what’s right in your building?
There are three categories –
If your condo is in Nova Scotia, Saskatchewan, Manitoba or regions, with low COVID-19 numbers, you may not have to modify your fire code protocols at all. If your building is a resort or vacation community with limited occupancy, or a condo with limited to no COVID-19 impact, you should be able to conduct all fire code testing including in-suite inspections. This is recommended in all buildings, where feasible.
In buildings with active COVID-19 cases you may only be able to test the common areas and some suites. For these cases, many service providers have developed safety protocols for in-suite testing under these circumstances that may help them to test most of your suites.
In Ontario, Quebec or regions with higher active COVID-19, it may only be reasonable to conduct common area inspections and postpone all in-suite inspections. The annual test standard ULC-S536, has a clause which allows for inaccessible devices. This clause could be used to postpone in-suite testing where residents are vulnerable or suites inaccessible due to COVID-19.
As a Fire code consultant, with more than 30 years’ experience, I’m advising my clients; that there are no one size fits all answers. But you may not be able to conduct in-suite testing during COVID-19. The fire code allows for alternate measures or Interim Fire Safety Plans under special circumstances.
Continue testing and maintenance of all Life Safety Systems. Provide reminders to residents about Fire Safety. Document any deviation from your fire safety plan or test Standard. You may require a professional opinion to review your options.
It is essential that you comply with the fire code, but you also must consider the risks of going in suite.
With more people home and fires on the rise there has never been a more crucial time to ensure your building is safe. Where you can test; test. Where you can’t, get advice. Keep records and communicate with your residents.
Be Reasonable, Be Informed and Be Realistic! You are not alone! Reach out; we are here to help!
Michele Farley, FCS Fire Consulting Service Ltd.
President & Senior Fire Code Consultant
**The information in this article is general information and is current as of the date of publication, May 14, 2020. For information specific to your building or situation please reach out to your professionals or to FCS Fire Consulting Services directly.**