Fire code enforcement affecting installers
Recently, Patrick Straw, executive director of the Canadian Security Association, sent an email to CANASA regional council chairs regarding an incident where the fire department removed a Greater Toronto Area (GTA) member’s technicians from a jobsite. The technicians had been changing smoke sensors on a standard wired alarm system.
According to Straw, “The fire department happened to come in to do a fire inspection and advised the end user and the alarm technician that this work could only be done by a certified fire technician.”
SP&T News reached out to Peter Hallinan, executive director at the Canadian Fire Alarm Association (CFAA), via email to clarify how the Ontario Fire Code (OFC) applies to alarm installers.
While the Ontario Fire Code has not changed recently — the fire departments are still operating under the 2007 version — Hallinan says, “The Code is constantly being reviewed and revised with updates, amendments and supplements.”
The Ontario Fire Marshall (OFM) publishes any changes in advance and are available on the OFM website, he adds.
Ontario Fire Code requirements
According to Hallinan, “the change that has prompted this discussion has been in place for a number of years.”
However, now there is greater enforcement by the local Authorities Having Jurisdiction (AHJs).
As such, Hallinan says that the CANASA member’s technicians were removed from the job because “the AHJ felt they did not meet the requirements laid out … in the Code or the Technical Guideline.”
“There has been a greater emphasis on enforcement of the Code in the past few years, along with stronger educational opportunities for Fire Prevention Officers and a greater willingness by the Crown to prosecute offenders [and] additional and higher fines for non-compliance to the OFC,” explains Hallinan.
Division C, Subsection 1.2.2 of the OFC identifies the requirements for persons who maintain or perform annual tests on interconnected smoke alarm systems. This refers to any type of smoke alarm that is wired together.
“In subsection 188.8.131.52 (1), it states that a person who performs the work on these systems ‘must have successfully completed a program or course acceptable to the Fire Marshal.’ To date, the only two courses identified as acceptable to the Fire Marshal are Certified Fire Alarm Electricians licensed by the ECAO [Electrical Contractors Association of Ontario] or Registered Fire Alarm Technicians in good standing with the CFAA,” Hallinan elaborates.
The penalty for working on these systems without completing the required courses is determined by the local AHJ and varies from jurisdiction to jurisdiction, he adds.
“In most cases,” says Hallinan, “the technician would be asked to leave the site and the owner directed to engage properly trained and qualified staff to perform or re-perform the inspection.”
In an interview with SP&T, Straw said he does not know how many CANASA members have the required certifications. “I know that we have several fully certified fire companies that are members of CANASA, but a huge amount of them are members of the Canadian Fire Alarm Association because a lot of the fire alarm [work] is done by electricians,” he explains.
However, the issue is not as simple as it might sound. Some interconnected smoke alarms don’t require these certifications. The occupancies that do require them are identified in Division B of the OFC, section 184.108.40.206.
This section “applies to interconnected smoke alarm systems in all residential occupancies and care occupancies, except in individual dwelling units and in Buildings regulated by section 9.8.”
This means, “residential houses, which are all required to have interconnected smoke detectors, do not need to be checked by a licensed or registered technician,” explains Hallinan.
Moreover, the OFM has identified some fire protection systems in use in Ontario today that do not have identified qualification criteria for work on these systems.
Consequently, the OFM has published a technical guideline, OFM-TG-03-2000, “Qualification For Service Company Personnel,” which explains who can work on the system and the parameters local AHJs can use to determine if a person or company is qualified, Hallinan explains.
As a result of this ambiguity, Straw says CANASA’s concern would be if a member is working in a building that doesn’t require smoke detectors, but recommends installing them, “there shouldn’t be any reason why that can’t happen, if it’s not a fire code requirement.”
In his seven months as executive director, Straw says this is the only incident he has been made aware of where a member has complained.
“Frankly,” he says, “it might have just been a misunderstanding.”
So how can installers ensure that they are always in compliance with the OFC?
Hallinan recommends subscribing to the OFM’s e-bulletins and checking the CFAA’s website, which lists the criteria for working on systems. The CFAA also publishes and discusses proposed changes and those coming into effect via email and in the Journal.
“Going forward, both Patrick Straw and I are committed to a line of communication and finding mutual ways to work together,” Hallinan adds.
Additionally, Straw is in regular communication with AHJs, the CFAA and ULC “on any technical issues which require clarification,” and has met with several 911 centres in Ontario.
While AHJs often communicate with CANASA about procedure changes, CANASA also reaches out to them to ask for information. “Most of them reply because it’s really helpful for them if they can communicate [information] back to our members.”
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