Whether you are in design, inspections, code consulting or an inspection, testing and maintenance (ITM) contractor, there is no doubt that you’ve walked into a building and wondered, “I wonder why they did that?” or, “I’m not really sure what the intent of this is.” And you are knowledgeable about the codes and standards! Now, imagine you are a building owner, someone who does not necessarily know the codes and standards. How are they to answer your question? And yet, we require the building owner to maintain their building and ensure the fire protection and life safety features are maintained as designed. In my experience, it is not necessarily that the building owners do not want to know, it is that they either do not understand, or they do not know where to get the answers they need. This is where I believe a comprehensive fire safety plan (FSP) coupled with education and training are key.   

Fire safety plans encompass a wide variety of buildings from small to large, simple to complex and existing to new. The property manager at a residential high building has entirely different challenges than the facility manager at a pharmaceutical manufacturing plant. Yet, they both require the exact same document, a fire safety plan. This blog post is intended to provide a perspective on documentation that should be included in more complex FSPs as they pertain to high buildings, complex buildings, buildings containing the storage of flammable and combustible liquids, hazardous materials and operations, and storage facilities. That is a tall order, but I wanted to generate some discussion on thoughts, opinions, and experiences.

I also want to point out that this is a bit self-serving as well. As a fire inspector I should be able to review the FSP and see what materials and processes are in the building. I should be able to compare the FSP to the materials stored to assist in determining the correct quantities and storage arrangements. I should be able to request the ITM documentation solely from reviewing the FSP. Unfortunately, I find that many times this is not the case. 

The two key points I want to stress in this blog post are: 

• the need for complete documentation, and
• the need for a collaborate approach with the design team, building owner, end-user, equipment suppliers and installers, ITM contractors and person preparing the fire safety plan. 

A future blog post will tackle the education and training of occupants, building managers and owners. Which I believe is another imperative component and is often lacking.

This blog post is intended to provide a perspective on the documentation that should be included in more complex FSPs as they pertain to high buildings, complex buildings, buildings containing the storage of flammable and combustible liquids, hazardous materials and operations, and storage facilities.

Two Separate Fire Safety Plans?

It is important to point out that there are two separate and distinct fire safety plans. There is a fire safety plan for construction and demolition sites as well as a separate fire safety plan for occupancy of the building. The National Building Code of Canada (NBC) requires that FSPs be provided as required by the National Fire Code of Canada (NFC). The NBC also requires that construction and demolition sites meet the requirements of Section 5.6 of the NFC, which includes an FSP. 

1. Construction/Demolition Site FSP

The FSP for construction and demolition sites is to address the specific hazards associated with construction sites, such as access for firefighting, controlling ignition sources, temporary water supplies, etc. While the title of Section 5.6 of the NFC is Construction and Demolition Sites, this also includes alterations and renovations. FSPs for construction and demolition sites are not new, these have been in the Codes for many years.

2. Occupancy FSP

The FSP for occupancy of the building is the one which most people are familiar with. The basic requirements are outlined in Section 2.8 of the NFC. There are numerous other occupancy specific requirements outlined in other parts of the NFC, such as Parts 3, 4 and 5 as well as other Articles in Part 2, though some of these additional requirements tend to be missed or glossed over. 

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Fires Safety Plans: A Building Owner’s Maintenance Manual

I once heard that FSPs are akin to a building owner’s maintenance manual for fire protection and life safety. I have used this to describe to building owners, property managers and facility managers as to how they should think about FSPs. To me this makes sense.

The FSP is a legacy document. It should contain information related to every aspect of fire protection and life safety of the building, and be regularly updated with documentation that covers details such as:

• occupancy classification, and occupant characteristics,
• installed fire protection and life safety systems,
• ITM requirements for fire protection and life safety systems,
• specific equipment installed with engineered protection,
• training of “supervisory staff” and maintenance staff, and
• building design drawings, etc.

A new owner or property manager of a building, should be able to read the FSP and have an in-depth knowledge of the building. It should also provide necessary information to various entities, such as an ITM contractor for one of the fire protection systems, the municipal/provincial fire inspector, or a design professional working on future renovations. 

Supervisory staff is a defined term in the NFC, basically those individuals identified in the FSP that have been delegated a responsibility with respect to the fire safety of other occupants.

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What a Fire Safety Plan is NOT

A fire safety plan is not a generic template or checklist. No doubt that templates and checklists can be used by trained individuals in documenting and preparing a fire safety plan. But a fire safety plan is not something that should be distributed as a fill-in-the-blanks for non-trained individuals. Preparation of a proper fire safety plan takes considerable effort to ensure it includes all the required components. 

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But if the fire safety plan is for maintenance of the building and systems, why is it required in the NBC?

The fire safety plan is referenced in the NBC for two reasons. First, the reference acts as a pointer to direct users to the NFC for the specifics of FSPs. Note that the NBC directs the user to Article 5.6.1.3. of the NFC for the specifics on construction and demolition site fire safety plans, and directs the user to Section 2.8 for the general requirements of the occupancy FSP. In addition, the requirements of Article 3.3.1.2, and Subsections 3.3.5., 3.3.6.  direct the user to the NFC for areas where hazardous materials are stored, handled, or used. Secondly, it is acknowledged that in order to maintain the original design intent, the original design team should have input to ensure that the original design intent is documented for the ongoing maintenance over the lifespan of the building and/or system. The FSP should not be an afterthought. But rather, it should be an ongoing thought throughout the design process with constant input from the design team.

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What if my design is a prescriptive design?

Even with a prescriptive code approach, the architect and engineers make assumptions, calculations, etc. to arrive at the final design. These design assumptions and calculations need to be documented so that they can be maintained. Going into an existing building and trying to determine the original design intent without proper documentation can be a challenge. 

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Buildings, Occupancies, and Occupants Will Change

Over their lifetimes, all buildings change. At some point the building characteristics change, the occupant characteristics change, and building use changes. Are these addressed in the FSP? A new restaurant is being designed. Once the restaurant is up and running the chef realizes they do not like the setup of the appliances. So, they move the appliances from one spot to another. Or a new woodworking facility opens. At some point they realize the workflow is not right and they need to rearrange a couple of pieces of equipment, or they need some additional equipment, or larger equipment. Often these changes are made without considering that the systems designed to protect these specific hazards are engineered. Each piece of equipment was specifically designed in place. Changing their location may have a negative effect on the designed systems. These changes need to be reviewed and assessed. 

To effectively address any changes, the building owner needs to not only understand the building characteristics and the occupant characteristics, but also to understand the original design parameters and constraints.

Management of Change

The NFC has a provision stating that the FSP must be reviewed every 12 months “to ensure that it takes into account changes in the use and other characteristics of the building.” In process safety this is termed Management of Change (MOC). Inspectioneering.com defines Management of Change:   

Management of Change (MOC) is a best practice used to ensure that safety, health, and environmental risks and hazards are properly controlled when an organization makes changes to their facilities, operations, or personnel. Having a properly implemented MOC policy in place when implementing changes can help ensure that new hazards aren’t introduced and the risk levels of existing hazards aren’t being increased. Inadequate MOC on the other hand has the potential to increase risks to the health and safety of employees and the environment. (https://inspectioneering.com/tag/management+of+change)

The reality is that the simple statement, “review the FSP to assess changes in use and other characteristics of the building”, is a complex topic. I do not want to complicate an already complex document. However, for the building owner to effectively address any changes, the building owner needs to not only understand the building characteristics and the occupant characteristics, but also to understand the original design parameters and constraints. What is the benchmark from which they are measuring the proposed change? The building owners need documentation. 

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Documentation to Build a Better Safety Plan

The following are some examples of details that designers, code consultants and engineers could summarize in a document that an owner could add to their fire safety plan which would greatly improve the usefulness of the plan.

Smoke Control

• Design assumptions? Stair pressurization? Smoke venting?
• Automatic or manual? 
• Equipment location and type? Ratings and design of dampers and fans?  
• Smoke control sequence, matrix?

Industrial Spec Buildings

These can be basic buildings. But we still encounter several issues. 

• Change of occupancy? Are occupancy combinations permitted?
• Change of sprinkler hazard classification based on occupancy change?
• Change of commodity classification based on change in packaging materials or materials stored?
• Proper fire separation between occupancies?
• Moving or building interior partitions and the effect on sprinkler and fire alarm systems?

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The list of examples can go on and on, including all aspects of both active and passive fire protection systems. The question is, how is all this information passed down to the building owner so they can ensure that the building is operated and maintained as it was designed? Some people will say it is all in the building plans. Sometimes. In my experience a lot of these requirements are not specifically outlined in the plans, and they are not passed on to the building owner. Also, it is not often that a building owner maintains the plans of a building. We know that they are supposed to, but they don’t. 

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Alternative Solutions and Performance Based Approaches

The requirements for the documentation of alternative solutions, including not only the code analysis, but also information related to the maintenance and operational requirements must be provided as part of the alternative solution. I would suggest that an approved alternative solution, or at least the applicable portions be appended to the FSP with the specific maintenance requirements pertaining to the alternative solution to be included within the FSP itself.  

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What Should Not be Included?

The FSP is intended to ensure that the building and the fire protection and life safety systems are maintained. The FSP should not contain any of the following phrases, and yet we often see them in some variation:  

• Maintain as per manufacturer’s instructions, 
• Maintain as per engineer’s design, or 
• Maintain as per Subsection XYZ of the fire code. 

The requirements need to be specifically laid out for the owners if we want the systems to be maintained.

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Concluding Thoughts

Fire safety plans are often an afterthought with people scrambling to put together a document for approval. If you are preparing a document for approval, you have missed the whole point. If your client believes this is the case, you need to educate them. In addition to the potential loss of life, the cost of a fire or explosion can be devastating. Ask any business owner that has gone through a major loss and they will tell you the lengthy path to resuming operation, if it’s possible at all. 

Technology is changing at a rapid pace. This is driving change in the various aspects of our industry. From the materials used, to the systems installed; everything is more sophisticated than they were even a few years ago. Understanding the minute details, even to the simple systems such as fire doors or fire stopping, is becoming more challenging. Did you know that there are certifications for both these industries from inspectors to contractors, and there are certified consultants for fire doors? These are not new. What I am trying to say is that every system has nuances, subtleties, and complexity. There are experts in every area of our industry. It is difficult for those of us in the industry to keep up with the ongoing changes. How can we expect building owners to keep up these changes if we do not work collectively to educate them? We count on building owners to ensure the maintenance of the fire protection and life safety systems. To effectively maintain any building or system, they need the appropriate documentation, education, and training. In my mind the FSP is the documentation component. This requires a collaborative effort with the designers, installers or ITM contractors, equipment suppliers and installers, facility/property management, as well as the end-user. 

A follow up blog post will discuss the education and training components.