My previous post for the KiloLima community (here) was about Annual Life Safety System Inspection Reports and what elements to look for when reviewing them. This post expands on that topic, to answer the question that is often asked about inspection reports – what governs the Inspection, Testing and Maintenance of our Life Safety systems? The simple answer is always “The Fire Code”.  We can go a bit further and point out that the answer is also very dependent on which Fire Code applies in the province where the inspection is taking place.  When we inspect the requirements  even closer, it is rare to see the specifics of how to carry out the actual testing, inspecting and maintaining in the language of the Fire Code (with a few exceptions, like for sprinkler systems in the Ontario Fire Code). When it comes to prescriptive direction on standardized forms and templates to use when conducting these services –  there are very few clear examples of what and how the pertinent information needs to be recorded in the Fire Code. 

What you will find in the Fire Code are directions to specific reference standards in each of the areas regulating the inspection, testing and maintenance of life safety systems. The technical  requirements relating to how testing is to be conducted, what performance data must be recorded and which maintenance activities are necessary live in those documents. What I want to speak to in this post is the importance of practitioners’ attention to the correct editions of these reference standards when creating an inspection, testing and maintenance program.

I was also inspired by the recent post by Jim Burns (here) which points out that all of our codes and standards are ever evolving and we as professionals and practitioners have a duty to stay informed as to the appropriate editions, amendments, etc. This responsibility also applies to the reference standards being used to undertake inspection, testing and maintenance programs.

In my early years in the industry I, like many others (I hope), often asked “why are we not automatically using the latest edition of standard XYZ?”. The misconception that many may share is that the most recent year of a reference standard isn’t necessarily the one recognized in the Fire Code; and, therefore we may be required to perform an inspection to a previous edition of a standard. This attribute of the Code can occur for many different reasons; whatever the case, if we are going to follow the Code then we must use the appropriate edition of the referenced standard.

In my last post I said, in relation to evaluating the quality of an inspection report: “Are Vendors referencing the wrong standards or incorrect editions? – It‘s a quick check to see if the standard referenced on their forms matches the current Fire Code edition”. What I was referring to is a practice that can be common in the industry and which can cause compliance issues – when service providers use generic online templates or previous reports  to create the inspection documents and programs. A generic online template or older report may have been developed to reflect the correct edition of a reference standard. Just as easily, it may reflect the wrong reference standard, inaccurate testing requirements, or the incorrect edition (or the latest one, that is not referenced by Codes yet). It is important that attention is given to the correct reference standard to ensure that the inspection, testing and maintenance activities completed conform to the Fire Code.

Table 1.3.1.2. of the 2015 National Fire Code of Canada is where we can find the proper referenced documents for each section of the Code. This table shows the following information: Issuing Agency, Document Number, Title of Document and Code Reference.  

The 2015 National Fire Code of Canada has about 175 different standards referenced and listed in Table 1.3.1.2.  Here is an example of one related to inspecting, testing and maintenance of a life safety system: ULC, CAN/ULC-S536-13, Inspection and Testing of Fire Alarm Systems, 6.3.1.2.(1).  

Let’s use this example to look at the listed version of the reference standard and see if there is a chance for confusion on the correct version to apply. So if we are performing a fire alarm inspection, then we are on the right track just looking at the “Title of Document” being “Inspection and Testing of Fire Alarm Systems”. If we were to just go from the title and perhaps search the internet for the latest ULC standard for this type of testing, we would see the most recent version is “CAN/ULC-S536:2019”. Being 2021, some could make an assumption that the 2019 edition of the standard would be the correct edition to use. This logic is often not correct for the Canadian Code landscape.   

Let’s take a look at the correct process. Depending on your location you would need to determine which Fire Code applies and then look at the table of reference standards. For this example, let’s assume you are in a jurisdiction using the 2015 National Fire Code of Canada. You would go to Table 1.3.1.2. and as mentioned above see that CAN/ULC-S536-13 is the appropriate reference standard to apply (not the one found on the internet or the latest version). Alternatively, let’s consider we are somewhere in Ontario where we are under the jurisdiction of the Ontario Fire Code (O. Reg. 213/07). In this Fire Code we would be directed to Table 1.2.1.A., and when looking up our ULC standard for fire alarm testing we would see “CAN/ULC-S536-04”. This provides yet another example of the appropriate standard being a different version than perhaps the most intuitive, or the latest one found on the internet. It also demonstrates that the edition of a referenced standard is not consistently applied across Canada. 

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This one, simple example outlines the importance of paying particular attention to your location, the Fire Code that applies and the edition of the reference standard called out therein. It also showcases how a simple misunderstanding of the relevant standard edition could result in a serious compliance challenge across our industry. For this reason, generic online templates and previous inspection reports cannot be blindly relied on for Code compliance. It is important to point out that newer editions of reference standards may or may not call out the same testing procedures or provide examples of forms for recording the required testing, inspecting and maintenance information. 

At the far end of the spectrum – it is not hard to imagine, for example, that  a service company that spans different jurisdictions and that is trying to create an efficient, standardized process to complete inspections for its customers could miss this important detail – that is, which edition of a reference standard must be applied to an inspection for a building life safety system. Such a program would require frequent assessment – to ensure that the correct edition is called out, that the correct inspection, testing and maintenance procedures are followed and that the program picks up variations specific to each province. 

To conclude, the reference standards are the one place that bridge the gap between what the Fire Code has prescribed and what actually needs to occur in an inspection test and maintenance program and it’s important as professionals that we help service providers and building owners cross that bridge.

Want to Dive Deeper?

Gerry’s Precision: Life Safety Systems, Inspection, Testing and Maintenance is available in the Code School for $59. In the 1.75 hour course, you’ll walk through the codes, responsibilities and requirements that apply to the inspection and testing of life safety systems in buildings.