If you’re in the fire protection and life safety industry you’ve undoubtedly heard about the tragic incident at the Astroworld Festival in Houston Texas on November 5, 2021. I think it’s important that we reflect on these types of events and think about whether they can occur in our own community. I’m not going to comment on the specific incident. I want to shine a light on the additional requirements of NFPA 101 for crowd managers and drills. The requirements, that I believe are imperative and that go beyond the requirements of the National Building Code of Canada (NBC) and the National Fire Code of Canada (NFC). This is important because many, if not all large stadiums as well as some other assembly occupancies in Canada have used NFPA 101 in part of the design. This blog post is not an in-depth review of NFPA 101 and the requirements, but rather to identify two critical elements in relation to crowd management that are in NFPA 101 that are not part of the NBC or NFC.
A few years ago, we were in a facility conducting an after-hours inspection. This event had been known to have overcrowding issues in the past. As we were walking through the building checking various items, we noticed that the crowd was getting smaller, and people were flowing to a specific set of doors. Apparently, a fight had started and moved outside, drawing a crowd with it. They funneled out multiple doors at the side of the building. The event was setup so that the main entrance doors were the only doors that people were allowed to enter. Once the fight was over, all these people came back to the main doors, a single set of outward swinging double doors. What we observed next left indelible memory. As we walked to the main doors, we could hear screaming and yelling. I will never forget seeing the mass of people outside of the closed main entrance doors. The people at the front were smeared into the doors. A woman’s face pushed up against the glass unable to raise her arms to help protect her. There was fear in her eyes as she was screaming. She was helpless. The people at the front of the crowd were screaming. Those behind who could see what was happening were yelling at others to stop pushing. But through all the screaming and yelling nothing was intelligible. Luckily, in this scenario the crowd was dispersed by police sirens. The woman that was being crushed at the front was shaken but thankfully not injured. There were no other reported injuries. This story was a reminder to me that these types of events may not always occur in anticipated ways, they may occur quickly, that crowd management is crucial and that adequately trained staff with the proper plans in place can help mitigate these types of events.
I’ve been fortunate enough to work on stadiums, as well as other large assembly occupancies on both the design side and enforcement side. Both sides provide unique challenges. The seating requirements for large assembly occupancies, smoke protected seating assemblies and outdoor assembly occupancies aren’t adequately addressed by the prescriptive requirements of the NBC. As such, the NBC contains specific requirements for the use of NFPA 101, Life Safety Code. It is important to identify that the Notes to Part 3 of the NBC states, “… it is not intended that Code users randomly select and apply a mix of provisions from both the NBC and NFPA.” The NBC through its prescriptive adoption of specific NFPA 101 requirements includes a requirement for a life safety evaluation. In my opinion it’s also important to dig a little deeper in Chapter 12 of NFPA 101 for the requirements for “crowd managers”, and “drills”, as these are not specifically referenced.
This blog post references the 2015 Edition of NFPA 101 as this is the referenced edition in the amended edition of the 2015 NBC.
NBC Requirements
Sentence 3.3.2.1.(2) of the NBC states, “Except as required in Sentence (3), provisions … 12.4.1 and 12.4.2 of Chapter 12 of NFPA 101, Life Safety Code are permitted to be used in lieu of Articles 3.3.2.4., 3.3.2.5., 3.3.2.9., 3.3.2.11. and 3.3.2.12.” The requirements for a life safety evaluation are outlined in 12.4.1 of NFPA 101.
Life Safety Evaluation
A life safety evaluation is extensive and far more in-depth than a fire safety plan, which is required by the NBC and NFC. The life safety evaluation is essentially a written document that covers not only the systems in the building, but also the occupants, the events, management, and communication. The life safety evaluation consists of life safety building systems document, life safety management document and the building systems reference guide. The life safety building systems document consists of life safety narrative, life safety floor plans as well as engineering analysis and calculations. The life safety management document consists of facility management as well as operational plans and records. The building systems reference guide contains the “important key information for the venue management’s use when planning events/activities for the safety of patrons, performers/participants, employees and vendors.” NFPA 101 outlines in detail the specific requirements for all the above identified components. In addition, the Annex contains a wealth of supplemental information.
There are several references to take note of, specifically 12.4.1.5.2.(5) for crowd management training plan and 12.4.1.5.2.(6)(a) training plans. Also, NFPA 101 requires that records of crowd management training (12.4.1.5.3.(1)) and safety training (12.4.1.5.3.(2)) be maintained.
Crowd Manager Requirements
The requirements for crowd managers are outlined in 12.7.6 of NFPA 101. There are specific ratios for crowd managers to occupants. Also, every crowd manager must be trained in the following 10 duties and responsibilities:
- Understanding crowd manager roles and responsibilities,
- Understanding safety and security hazards that can endanger public safety,
- Understanding crowd management techniques,
- Introduction to fire safety and fire safety equipment,
- Understanding methods of evacuation and movement,
- Understanding procedures for reporting emergencies,
- Understanding crowd management emergency response procedures,
- Understanding the paths of travel and exits, facility evacuation and emergency response procedures and where provided, facility shelter-in-place procedures,
- Familiarization with the venue and guest services training, and
- Other specific event-warranted training.
NFPA 101 also requires crowd manager supervisors. These supervisors must be trained in the following 5 duties and responsibilities:
- The duties described above for crowd managers,
- Understanding crowd manager supervisor roles and responsibilities,
- Understanding incident management procedures,
- Understanding the facility evacuation plan, and
- Understanding the facility command structure.
Drills
The requirements for drills in assembly occupancies are outlined in 12.7.7 of NFPA 101. These requirements include staff to be “trained and drilled in the duties they are to perform in case of fire, panic, or other emergency to effect orderly exiting.” Note that this doesn’t say “fire” drills, but drills. This requirement is far more encompassing, including not only fire but panic, or “other emergency to effect orderly exiting.” If we focus on “other emergency to effect orderly exiting”, this can and does encompass many possible scenarios. The possible scenarios will change from event to event. I’ve been to concerts where people sat on the floor, while the performer came on stage with a chair and a guitar. At the same venue I’ve seen the entire floor as a giant pit with stage diving. A friend of mine is from Vancouver, he mentioned the smell at outdoor festivals is different in British Columbia than in Saskatchewan … Think ULC-S4400 or NFPA 420, the cannabis standards. The cognitive state of the crowd plays a role in their ability to respond to an incident. The performers, the crowd, the staff, the location, the environment, the venue, the setup all play a role in envisioning the possible scenarios.
The trained staff must also be instructed in the proper use of portable fire extinguishers and other manual fire suppression equipment, where provided. In addition, in specific assembly occupancies such as theatres, motion picture theatres and auditoriums an audible announcement, or projected image must be shown at the start of each program that notifies occupants of the location of the exits to be used in the event of an emergency.
Crowd Managers & Drills and The Canadian Codes
The requirements for crowd managers and drills are outlined in 12.7.6 and 12.7.7 of NFPA 101. Neither 12.7.6 nor 12.7.7 are referenced in the NBC. In my opinion this is an oversight. NFPA 101 is similar to the NBC in that the provisions of the specific Chapter, such as Chapter 12 for Assembly Occupancies are applicable to all assembly occupancies unless there is an exemption. Similarly, Subsection 3.3.2. of the NBC is applicable to all assembly occupancies unless there is an exception. Yet the NBC only references specific portions of Chapter 12 of NFPA 101. I can see only referencing the portions in relation to seating layouts, etc. But the Operating Provisions outlined in 12.7, of which I’ve mentioned two based on the current discussion, should be adopted in whole. Section 12.7 also contains provisions for
- means of egress inspection,
- special provisions for food service operations,
- open flame devices and pyrotechnics,
- furnishings, decorations, and scenery,
- special provisions for exposition facilities,
- smoking,
- seating,
- maintenance of outdoor grandstands,
- maintenance and operation of folding and telescopic seating,
- clothing,
- emergency actions plans.
The reason for not cherry-picking code requirements from another Code/Standard is that the requirements are layered and should be applied holistically. By layering one over another over another, we build up a resilient and robust framework. By removing layers, such as crowd managers and drills, or the other operational provisions of Section 12.7, we have left ourselves with some assessments & plans, but not necessarily adequate staff or adequately trained staff to carry-out the requirements of the plans. The life safety evaluation is one component. But without the proper staff and without staff that are adequately trained we are left with inadequate ability to implement and carry out the plans.
These additional items outlined in Section 12.7 are all based on experience. Clearly there are individuals on the committee that have attended large events and have seen how things change. Leading up to an event the venue is in a constant state of flux with things moving from place to place. We often found that items begin finding homes in corridors, obstructing exits, obstructing fire alarm devices and extinguishers. As such, the means of egress inspection is important. All the requirements listed Section 12.7 are important, however not all addressed in the Canadian codes.
If you’ve ever seen the setup of an event, it is incredible. Depending on the show they may take hours, and sometimes days to transform a venue. One of the things I will miss is going through the show before the crowds arrive. I love seeing everything in its raw state without all the lighting and effects. I love watching how the space is transformed, then to watch the tear down begin as soon as the performers leave the stage. Before the last people are out of the venue, a massive amount of work has already begun as they’re tearing down for the next show. It’s incredible – like its own little city that moves from location to location. One worker told me that every event is the same, just a different location. I disagree. Every event is different. The performance may be the same, but the event is different. The venue is different. The building systems are different. The crowd is different. The staff are different. Security is different. While the performer may be the same, they may be in a different state of mind. This all leads to a new event each time.
A life safety evaluation is not a onetime document, but rather NFPA requires that it “be approved annually by the AHJ and shall be updated for special or unusual conditions in accordance with the provisions of 13.4.1 for existing assembly occupancies.” But the life safety evaluation is one component that helps maintain life safety within these assembly occupancies. We also need properly trained crowd managers, and crowd manager supervisors. The crowd managers are instrumental in maintaining the life safety of the occupants of the building. In addition to the training, they need to be drilled. These drills test the crowd managers in their abilities and can assist in guiding further training needs. This is a critical element in the ongoing development of properly trained staff.
I would like to know your thoughts on life safety evaluations, crowd managers and drills. Let’s get the discussion going. Reach out on LinkedIn or on comment on the blog post on the KiloLima.com webpage.
Additional Resources
If you know me or have read some of my blogs, you know that I’m a fan of podcasts. I’ve written two blog posts about podcasts related to fire protection and life safety. The list keeps growing.
They describe the podcasts as, “your source for ideas, discussions, and news from the world of live event safety, brought to you by the Event Safety Alliance.”
Episode topics: Event Fire Safety Requirements, Event Security Survey, Crowd Lessons from the Capitol Hill Unrest.
Number of episodes: 46 episodes.
Time commitment: 10 minutes to 66 minutes. The average is roughly 45 minutes.
Event Safety Guide – The Event Safety Guide — Event Safety Alliance
ANSI ES1.4 – 2021 – Event Safety – Event Fire Safety Requirements ANSI ES1.4-2021, Event Safety – Event Fire Safety Requirements (squarespace.com)
ANSI ES1.7 – 2021 – Event Safety – Weather Preparedness ANSI ES1.7-2021, Event Safety – Weather Preparedness (squarespace.com)
ANSI ES1.9-2020 – Event Safety – Crowd Management ANSI+ES1.9-2020.pdf (squarespace.com)
Houston Concert Tragedy Casts Crowd Management into the Spotlight | NFPA | NFPA by Cathy Longley
Strategies for Crowd Management Safety | NFPA by Krista Bigda
Crowd Manager Training (iafc.org) endorsed by the International Association of Fire Chiefs (IAFC)
