Cover story: Fire safety plans
Do more with less
March 15, 2021 By Paul Johnson
The BC Fire Code sets out the minimum life safety requirements for buildings within the province of British Columbia. Section 2.8, Division B of the BC Fire Code discusses emergency planning and applies to buildings with assembly, care, treatment or detention classifications. Emergency planning is legally required in buildings with fire alarm systems and required for construction and demolition sites. Emergency planning is required for storage areas, hazardous operations and for areas where flammable liquids are stored or handled. In my role as the fire prevention officer for the Kelowna Fire Department and as 3rd vice-president of the Fire Prevention Officers Association of BC as well as NRC Codes Standing Committee member on fire protection, I have become particularly familiar with the ins and outs of fire codes and emergency planning.
Arguably, the most important component of emergency planning is the creation of a fire safety plan. The BC Fire Code lists clause (a) through (g) which identifies seven criteria that must be provided within the fire safety plan. The plan shall identify procedures to be used in a fire, the appointment of supervisory staff as well as the training of staff and occupants. The plan is required to include documents showing type, location and operation of the building fire emergency systems. Furthermore, it discusses fire drills, the control of fire hazards in a building and the inspection/maintenance of building facilities provided for the safety of occupants. Specific buildings or operations have additional requirements, such as assembly occupancies, hazardous operations and care/treatment or detention occupancies.
The BC Fire Code has had the requirement for emergency planning since its inception. The code states “a fire safety plan conforming to this section shall be prepared in cooperation with the fire department and other applicable regulatory authorities.” Even with a statement like that, many departments will not “accept” a submitted fire safety plan, they will only review it. There is a concern with the fact that the department would be accepting liability for their respective municipality. But doesn’t our code state “in cooperation?” We are required to assist them with the plans, but have we essentially farmed out the entire industry to contractors?
The inspection branch of the fire service has allowed contractors to take the seven criteria listed in the BC Fire Code and create a niche in the fire life safety industry. A business/building owner can typically pay in excess of $1500 for a cookie cutter template fire safety plan. The contractors then add a copyright warning onto their plan. The information is essentially all the same; it’s just laid out in a different format from the other contractor.
The fire safety plan is a document for the owners. The fire service will extrapolate information from the plan to help create our pre-plans but for the most part it is an owners document. I have “reviewed” plans containing well over a hundred pages. Some plans have taken the wording from the code and rewritten it for the building. No wonder we are having a tough time gaining compliance when we make the “person in care and control” of a building study a book where there is no exam at the end. Why would I want to read 85 pages when I could read 10 pages?
Recently, our office received a fire safety plan that was submitted to our department for review. The plan contained 190 pages of information. In fairness to the creator of that plan, they had enclosed alternative solutions (building code equivalencies) which had been accepted by the building branch. It had 90 pages of the alternative solution with 100 pages of the seven requirements listed in the Fire Code. This one of the most thorough plans we have ever seen for a building. The irony is that when our inspector conducted an inspection of this property a year later, no maintenance had been done. Upon further discussion with the property maintenance manager, he said he didn’t know what he had to do. He didn’t have the ability to leaf through a document that would quickly tell him what he had to do as the building manager.
The average layman struggles to determine what his or her obligations are as the building manager. An example of excessive information within a plan would be for the water-based protection systems. Section 6.4 of the BC Fire Code states: “Water-based fire protection systems shall be inspected, tested and maintained in conformance with NFPA 25. Inspection, Testing and Maintenance of Water-Based Protection Systems.” I have reviewed several plans which list the sequential testing requirements for the system. Ultimately, we are not trying to educate the property representative on being a fire sprinkler technician. All we are doing is advising the property representative what their respective role is regarding the maintenance of the system. The property representative must be able to pick up the fire safety plan, open it to the maintenance section and see what the maintenance obligations are for that month. If the plan says retain a contractor to conduct the service requirements, then it should be stated in the plan so that the property representative can hire an approved contractor.
We must ask ourselves if the pendulum has swung too far. In our desire to improve life safety within the province we have essentially allowed contractors to create a book that in all likelihood no one will typically read. In competitive industry, contractors try to create a better product than their competitors, consequently excessive information is added to the plan. A thicker fire safety plan does not necessarily mean it is a better product. It does mean there is more information in it that the reader may not read or understand. A concise plan that contains less material written in an easy to read format is worth considering. It is more user friendly and would be better understood by the customer.
The Fire Prevention Officers Association offers a free template available on the association’s website. The Fire Inspection and Prevention Initiative (FIPI) is currently available for property owners to download the information and essentially fill in the blanks. The City of Halifax has also incorporated a free downloadable fire safety plan, which is more in line with the requirements of the code. In a quick online search, I was able to find several generic fire safety plans which could be downloaded and used for their building at no cost. The plans are available for small buildings, high buildings, single stage alarms and two stage alarms, etc.
Many fire safety plans can be created from the free downloadable templates. Ultimately, it is a business decision to hire a contractor. However, the more complicated plans such as hospitals, storage areas, hazardous operations or buildings which have been constructed using alternative solutions should continue to have the plans created by contractors. At times, customers are not made aware of the templates and are consequently saddled with a bill for a product that very well may closely resemble their neighbour’s fire safety plan.
Fire safety plans are a legal requirement for business, buildings and industry and are required to teach the building/business representative the emergency planning requirements for their specific building. I feel the content of the plans which we are reviewing as the ‘authority having jurisdiction’ should be limited in the hopes that the property representative will use the plan and understand the plan. ››››››››Ultimately, our goal is to promote life safety and limit fires. Perhaps we can do more with less.
Paul Johnson is the fire prevention officer for the Kelowna Fire Department, 3rd vice-president of the Fire Prevention Officers Association of BC and an NRC Codes Standing Committee member on Fire Protection.
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