Codes and standards
NFPA Impact: September 2012
Some say that the best areas on which to focus risk-management efforts are those that keep you awake at night.
September 6, 2012 By Sean Tracey
Some say that the best areas on which to focus risk-management efforts are those that keep you awake at night. I lose sleep over care and nursing-home occupancies – not because my wife says she’ll commit me to one someday, but because they concentrate our most vulnerable citizens in one location. It turns out we are killing them in greater numbers in fires because of this.
Recently, we have heard much about this in Ontario. In fact, the evening after the Orillia coroner’s jury announced its findings in the deaths of four elderly Ontarians in early May, two more seniors died in a fire. Let me assure you, this is not just an Ontario problem but one that exists in all provinces where we have residents in older buildings without sprinkler protection. The others have just been lucky so far.
What should keep you awake at night is that, under our fire codes, the local fire authority must approve fire-safety plans for these buildings. That is you. You are the ultimate arbiter of the fate of these vulnerable wards and cannot pass this off. Some jurisdictions pretend not to approve fire-safety plans but simply “review” the plans. This does nothing to absolve you of these duties. What is even more disconcerting is that there is little or no provincial guidance on how to approve these plans and no guidance on the time required to evacuate these facilities. You are in a no-win position.
Part of our problem is that provincial regulations often have different titles for these facilities than what is used in the building and fire codes.
We have even seen operators exploit these differences to avoid fire-code decisions. In my view, and according to the NFPA 101 Life Safety Code, nursing homes (B2 occupancies) should all be retroactively sprinklered. In the United States, this is required of any facility receiving federal funds. This was also a change initiated by the nursing-home industry after several fatal fires in 2003. All other care or assisted-living occupancies, be they B3 or C occupancies, should be prepared to prove that all their residents are capable of self- or assisted evacuation in a reasonable time before conditions become untenable and when staffing is at its lowest level.
Currently, fire-safety plans must be submitted annually for your approval. This can be an overwhelming task if your department has too few resources, so I suggest that facility operators complete the evacuation templates found in chapter six of NFPA 101A. This is a tool NFPA has developed to assess occupants’ capability for self-preservation without having to participate in drills. If the facility is unwilling to complete the form or it fails to do so, then the facility should be put through the rigors of a timed evacuation to prove its evacuation capability. The use of NFPA 101A can thus identify potential problem facilities. Those that pass the NFPA 101A requirements should still be evaluated every three to five years.
When evaluating a facility using a timed evacuation drill, a target time must be determined. What is an appropriate time for safe evacuation?
This is left for the authority having jurisdiction to determine. NFPA 101 uses 13 minutes, but recent experiences in Niagara Falls, Ont., and our current understanding of fire behaviour indicates that this too long. The best tool developed in recent years is a Quebec Ministère de Sécurité report that identifies times for evacuation based on the method of construction, size of facility and fire-alarm and protection systems in place. This document was produced with the involvement of the care industry in Quebec. The times for evacuation range from three minutes for a nine-room facility of combustible construction with smoke alarms, to 13 minutes when protected with sprinklers.
Non-combustible structures would have between 13 and 21 minutes to evacuate. This guide is great because it shows how times can be increased depending on the protection features added. Regardless of evacuation time, any facility in Canada that fails in its evacuations should be required to be sprinklered, construct fire walls or increase staffing. The facility can choose, but it must meet the times.
I have a presentation on this topic available for free download in the NFPA Section of the PTSC-Online website at www.PTSC-Online.ca. We have conducted a number of workshops on this topic in British Columbia and in Alberta. If you are interested in learning more, please contact me.
The lack of resources and guidance in the fire codes and at the provincial level should be causing you to lose sleep. You are ultimately responsible for approving these fire safety plans. It is my hope that we have given you some guidance in the absence of provincial support. I, at least, can sleep a little better at night knowing that when the time comes for my wife to commit me to a care home it will hopefully be protected with a sprinkler system. We all may need these facilities someday so let’s make sure we get them protected.
Sean Tracey, P.Eng., MIFireE, is the Canadian regional manager of the National Fire Protection Association International and formerly the Canadian Armed Forces fire marshal. Contact him at firstname.lastname@example.org
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