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USE OF SIGNALINK’S FIRE-LINK® II SYSTEM

Special Note to readers of this article from Frank Kurz:

On Friday, January 17th, 2014, the Mircom Group of Companies escalated the response posted on January 16th by David Sylvester in the CFAA Member Restricted Forum.  They have employed the services of McConchie Law Corporation’s, Alan McConchie, Canada’s foremost legal expert in Internet Libel Law.  As we anticipate this article will become significantly larger than originally planned, we have included helpful navigational markers to make it easier to find the latest information.  In addition to posting our response to Mr. McConchie, we will also be replying to Mr. Sylvester’s accusations and publishing any additional comments we receive.  We will endeavour to ensure that frequent updates are provided so our readers can remain abreast of the latest developments.

January 20, 2014 - We have determined that significant confusion (and mis-interpretation) may have resulted from the unfortunate use of the word “retrofit” in the originally published article.  The primary purpose of the article was to assist individuals engaged in contemplating an UPGRADE of an existing fire alarm system in determining the suitability of employing the Fire-Link® II equipment as the sole source of in-suite notification.  We have reviewed the comments posted to the CFAA Member Restricted Forum and determined the best course of action was to make the appropriate editorial changes and thereby avoid any further confusion or misunderstanding.  It must be noted, for the record, that it was never our intention to suggest that the Fire-Link® II system is not suitable for a “retrofit” application.  We wish to apologize for any misunderstanding.  Members of the CFAA Restricted Forum enjoyed the advantage of having further clarification in this regard in the subsequent comments that were posted, and which we believe our editorial changes should now reflect.
-- Frank Kurz

January 16, 2014 - MIRCOM’S RESPONSE (As posted by David Sylvester in the CFAA Member Restricted Forum.

January 19, 2014 - Frank Kurz and The Fire Protection Technicians Network responds to the demand letter submitted by Alan McConchie of McConchie Law Corporation, dated January 17th, 2017.

January 23, 2014 - Frank Kurz replies to David Sylvester and The Mircom Group of Companies.

December 3, 2014 - UPDATE!  Check out this convenient application chart designed to provide additional guidance and clarification for Jurisdictional Authorities contemplating acceptance of Signalink’s Fire-Link® II as the sole means of providing in-suite notification.

December 17, 2014 - UPDATE!  Our “encounter” with Rien van den Enden, SignaLink’s Product Manager at the Fire Prevention Officers Association of British Columbia monthly meeting hasn’t changed our opinion.

December 20, 2014 - Do you have any comments, questions, or concerns about Fire-Link® II?  Take a few moments and register on our NEW SignaLink FORUM and let us hear from you!  You can also email us!

September 17, 2015 - UPDATE!  We have divided the original article into sections that follow the three main questions it attempted to answer in order to provide further clarification.  We’re working on updating this article to include some additional information with respect to the installation of this equipment in jurisdictions requiring conformance with NFPA 72 (2010).  I should also state that we have yet to receive the promised response from Mircom which they indicated they would provide following the Fire Prevention Officers Association of British Columbia meeting in December 2014.

 

USE OF SIGNALINK’S FIRE-LINK® II SYSTEM IN CANADA

Vancouver, British Columbia - I’ve been in engaged in some discussions with a number of contractors, Engineers, and Jurisdictional Authorities across Canada concerning the use of the SignaLink Technologies Fire-Link® II in-suite signaling appliances (http://www.signalink.com).  This article is intended to provide answers to the more frequently asked questions and, hopefully, will help to provoke some additional discussion that may offer further insight to an Authority Having Jurisdiction (AHJ) that is contemplating acceptance of the equipment for a complete fire alarm upgrade application.
 

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The SignaLink website raised a number of questions with the various individuals I spoke with but the three that were most often asked were:

1.  While the equipment is both UL and ULC Listed, what provision does the system employ to differentiate the floor AREAS when this equipment is installed?

2.  Can you use the Signalink equipment as a substitute for the sounders required in a sleeping room in a retro-fit application?  Does such an installation meet the requirements of the Building Code?

3.  What provision is there to supervise the wiring to the remote signaling appliances?

While the equipment is both UL and ULC Listed, what provision does the system employ to differentiate the floor AREAS when this equipment is installed?

Let’s take the example of a three storey walk-up.  You would normally require three (3) separate central controllers triggered by three (3) separate signal circuits in order to achieve compliance with the Building Code (a three storey walk-up would normally require two signal circuits for each floor, one for the common floor horns/bells, and one for the suites on that floor).  When there is a fire separation dividing the floors of the same three storey walk-up, you would need six (6) signaling circuits.  If AHJ’s across Canada are contemplating acceptance of this technology for use as one of the notification components of a fire alarm system, the big question is:  How are you achieving compliance with the relevant Clauses of your Provincial Codes [in British Columbia it’s Clauses 3.2.4.18(11) of the 2006 Code and 3.2.4.19(9) of the 2012 Code]?  It’s important to keep in mind that the use of the product still requires that the installation complies with NBC, and Provincial Codes.

My research into this equipment suggests that it would be problematic (read impossible) to employ separate controllers in the same building on the same power feed (via the house electrical panel).  The redundancy which our Building Codes provide is noticeably absent if that same power feed provides the only notification source for all the suites in a multiple story residential building.  As a consequence, use of this equipment without the requisite number of floor AREA signaling circuits should result in an automatic FAIL by the individual performing the Fire Alarm Verification.

Can you use the Signalink equipment as a substitute for the sounders required in a sleeping room in a retro-fit application?  Does such an installation meet the requirements of the Building Code?

The Signalink website references a listing under CAN/ULC-S527 as “an accessory to a fire alarm control unit for supplemental fire signaling” (reference the question “Does the Fire-Link system have any fire alarm initiating capability?” at www.signalink.com/fire-authorities/frequently-asked-questions/).

“Supplemental fire signaling” can only be interpreted as a signaling means (either audible or visual) that is proposed for use in addition to (or to supplement) what is required by NBC/BCBC.  “Supplemental fire signaling” should therefore, not be considered as a substitute for the installation of fire alarm interconnected and supervised signaling components within a suite as mandated by the referenced Building Codes. 

I also reviewed the relevant certification of the equipment on the ULC website during the course of my research.  There are three (3) listings for the product:

UTUOC.S8580 as a “Household Fire Warning System Unit”;

UOXXC.S8580 as a “Control Unit Accessory, System, Fire Alarm”;

ULSZC.E332892 as “Audible Signal Appliances, Fire Alarm, Including Accessories”.

Signalink’s product brochure states that “it is intended to supplement the signaling capabilities of all fire alarm systems”, but there is one misleading (I would even go so far as to call it disturbing) set of images on their website that is used to promote the use of the product which could lead someone to infer that you can install these devices in lieu of properly supervised, Code mandated signaling appliances.  In one image you have two electricians (complete with hard hats) standing in a floor space filled with conduit, reels of wiring, electrical boxes and in-suite low voltage buzzers along with their tools of the trade (fishtape, meter, etc.) and this is juxtaposed against another image of a lone technician pictured holding his laptop along with the components that make up a Signalink system.  Under the one image you see an installation time of five (5) weeks.  Under the latter you see an installation time of seven (7) hours (http://www.signalink.com/property-managers/property-manager/).

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l_signalinkinstall

Images are the Copyright © of SignaLink Technologies and are used here for illustrative purposes only.

 

The Signalink equipment is designed to achieve but one aim and that is to improve audibility of fire alarm signals within a sleeping room.  It does not meet the requirement mandated by BCBC 2006 or BCBC 2012 where separate signaling circuits must be provided for each floor area and for each floor area serving suites of a residential or care occupancy (in which the fire alarm is being upgraded to achieve modern Code compliance).  It seems that, in the rush to find a viable alternative to chopping holes and running conduit, some jurisdictions have fixated on the Signalink equipment and, in the absence of proper consultation, have accepted this as an ALTERNATIVE to what the Building Code requires.

An engineer’s response to my concerns was that his insurers will carry the ultimate liability and that he is going ahead with a number of upgrades utilizing this equipment (as long as the AHJ continues to accept it). I’m going to suggest that, while this particular jurisdiction’s building department may have accepted the sole use of this equipment for in-suite signaling, the individual performing the Verification may (should?), in fact, reject it.  In addition, the provision of the Canadian Electrical Code (CEC) 2012, Rule 2-026(c) may be invoked by the Electrical Inspector.

For the benefit of our readers, Rule 2-026 is headed “Powers of rejection” and states:

    “Even though approval has previously been granted, the inspection department may reject, at any time, any electrical equipment under any of the following conditions:

      a)  The equipment is substandard with respect to the sample on which approval was granted;
      b)  The conditions of use indicate that the equipment is not suitable; or
      c)  The terms of the approval agreement are not being carried out.”

What provision is there to supervise the wiring to the remote signaling appliances?

In utilizing this technology, the question of wiring supervision should, I believe, be rendered moot by the fact that each audible appliance is individually enrolled and supervised by the controller in a fashion similar to what you would achieve with an addressable field device on a Data Communications Loop (DCL) or Signaling Line Circuit (SLC for you guys south of us).  In the latter instance, “T” taps are permissible as the absence of an enrolled device causes a specific trouble at the common control which equates to what would normally be achieved by employing a conventionally supervised circuit.  What the Signalink equipment does NOT deliver is the means to mitigate a failure of the communications link to a specific floor area (which happens to be a requirement of CAN/ULC-S524-06 when employing an addressable type of fire alarm system).  I suppose one could also make the case that it would be fairly easy to interfere with the communications to the field devices by plugging in another wireless device that uses Powerline Technology, for instance, and thereby compromise Clauses 3.4.2 and 3.4.3 of this same Standard (the proliferation of home-automation systems in recent years makes this aspect a very real concern).

To clarify (for the benefit of those of you doing work related to the City of North Vancouver’s Bylaw 8090 - Life Safety Upgrade):

The fire alarm SYSTEM must be installed in accordance with CAN/ULC-S524-06 and BCBC 2006/2012.  You could use the Signalink Fire-Link® II equipment in an upgrade to supplement the in-suite signaling appliances required by BCBC to ensure you achieve the 75dBA at the pillow.  You would still be required to provide installation of signaling appliances within the suite, connected, isolated, and supervised by an output circuit serving the suites on that floor (or within the specific floor area). 

The Signalink equipment may well represent a viable solution to the problem of achieving the required sound pressure levels when retrofitting signaling appliances in older buildings.  Its use, however, must still be carefully considered, strictly monitored, and regulated to ensure we’re not compromising the safety of residents or recommending an alternative that may, in fact, compromise the Building Code and the Installation Standard.  In older apartment buildings which may employ aluminum or other substandard wiring components, it is even more important, in my view, to carefully examine any formal submission in which the use of the Signalink equipment is proposed.  Keep in mind that if the fire is electrical in nature (the single most likely cause in older buildings), the ability of the Fire-Link® II system to notify occupants may become impaired (or completely compromised) because it’s utilizing that same wiring that could have sparked the fire in the first place in order to transmit the alarm signals.

 

MIRCOM’S RESPONSE! (As filed on January 16th, 2014 by David Sylvester in the CFAA Linkedin Forum which is restricted to members only).

I will be posting a series of comments (addressing Mr. Kurz' (sic) statements here and on his website) due to word count limit.

In preamble I wish to highlight the following:

1. The Mircom Group of Companies is 100% committed to life safety and code compliance and stands behind its UL and ULC listed Signalink Fire-Link II system for its intended application

2. The Mircom Group of Companies does not wish to stifle healthy industry debate and while we are prepared to readily accept constructive and responsible criticism, we cannot reasonably stand by and allow misinformed individuals to make unreasonable and factually inaccurate statements impugning our product lines or technology;

3. We question whether the CFAA LinkedIn forum wishes to be brought into debates about proprietary technologies and give voice to fringe opinions that otherwise could not access such an important audience.

We now wish to directly respond to Mr. Kurz’ (sic) statement regarding the “Use of Signalink’s Fire-Link II System in Canada”. 

Across North America, we have been pleased to see the local Building and Fire Authorities embrace innovation -- leveraging the Codes’ functional statements and logically implementing their intent and rationale to ensure society is protected from the ravages of fire.

The statements posted by Mr. Kurz’ (sic) are not only negative but are also thoroughly misinformed regarding Fire-Link II. The intent of this post is to provide clear and concise guidance with the view of correcting the statements originally provided by Mr. Kurz’ (sic).

For the record, I am a former life safety consultant with 22 years of experience in the industry and currently the Director of Research and Industry Affairs for Mircom Group of Companies.  My speciality (sic) is fire alarm system design, having worked at such prestigious engineering consulting firms as Leber Rubes and Morrison Hershfield. Unfortunately, I have often encountered the miss-application of Codes and Standards, primarily due to improper use of “context”.

Let me start by going back to the basics regarding the primary goals of life safety solutions:

  • Protect life -utilizing automatic early warning detection and manual initiation;
  • Ensure appropriate communication- alerting occupants and initiating evacuation movement);
  • Alleviate human suffering and hardship- allowing sufficient time to escape safely.

Since the early 1990’s, Authorities across North America have been concerned about multi-residential alarm audibility to ensure that everyone is evacuated in a timely manner during a fire condition.  Unfortunately, fire rated doors and sound absorbent materials often prevent the existing fire alarm systems’ signal from penetrating into the bedrooms. Solving the fire alarm audibility problem and ensuring a compliant building, requires a minimum Sound Pressure Level of 75 decibels in each bedroom. 

Fire-Link II is an audibility upgrade solution that makes it possible to quickly retrofit low-rise multi-residential buildings. This solution uses the existing AC wires to communicate between the ULC listed controller and the ULC listed in-suite horns which are digitally addressable and supervised. This provides a significantly higher level of device supervision than conventional horn signal devices, since each in-suite horn is digitally addressed and monitored.

This means no new wires, dust, drilling and raceways in the occupant’s home. When the fire alarm system is activated, Fire-Link is simultaneously activated and the in-suite devices sound immediately in the bedrooms, alerting the residents.

To summarize, these are the main benefits of Fire-Link: it is a less costly and more readily available solution to cash strapped older buildings seeking to improve life safety through better audibility, can be installed in as little as a few days, requires no intrusive construction, and ensures efficient compliance including UL and ULC approvals.

The intended and primary use and application of the Fire-Link II solution is in retrofit (not new construction) applications.

Now to specifically address Mr. Kurz’ questions:

QUESTION ONE  - “While the equipment is both UL and ULC Listed, what provision does the system employ to differentiate the floor AREAS when this equipment is installed?” 

Mr. Kurz’ cites the 2006 British Columbia Building Code (2006-BCBC) Division B Part 3 Clause 3.2.4.18(11): “In a building or part thereof classified as a residential occupancy, a) separate circuits shall be provided for audible signal devices on each floor area, and b) audible signal devices within dwelling units or suites of residential occupancy shall be wired on separate signal circuits from those not within suites of residential occupancy or dwelling units. (See A-3.2.4.18.(10) in Appendix A.)” 

The first question we must ask is in regards to the application of 2006 BCBC 3.2.4.18 (11) and 2012 BCBC 3.2.4.19(9) as applied to residential audibility fire alarm retrofit applications and also in context with Part 9 residential occupancies.

“Division B 9.10.18.3. Design and Installation Requirements sentence 2 states: “The following Articles in Subsection 3.2.4. regarding fire alarm systems 
do not apply to Part 9 buildings: Articles 3.2.4.1., 3.2.4.11., 3.2.4.12. , 3.2.4.13. , 3.2.4.14., 3.2.4.21., and 3.2.4.22.” 

Many building and fire officials will tell you that zoning of signalling devices is not directly addressed in the Building Code, unless the building is required to have a voice communication system.  In Group C residential low rise applications, specific zoning of signalling devices is simply not required.  Obviously in a single stage fire alarm system, all signalling devices sound simultaneously.

In many multi- residential buildings, that have poor or suspect audibility, the existing horns or bells were often wired in a vertical riser format, with a discrete circuit provided per riser.  In fact, we have typically seen more than three to five circuits per floor where the bell or horn risers have traveled from the control unit on discrete class B circuits at various locations on the floor’s foot print to provide fire alarm signalling.   The use of 3.2.4.18 (11) “….separate circuits shall be provided for audible signal devices on each floor area…” has been misapplied re Part 9 residential retrofit applications.  Furthermore CAN/ULC-S524-06A, Clause 5.4.2.1 clearly states: “Audible signal devices shall be installed in accordance with Manufacturers recommendations”. 

Fortunately hundreds of AHJs across North America that have reviewed and accepted Fire-Link II due to its complete stability and proven performance. They understand that Fire-Link II actually leverages the existing discrete AC power circuits for survivability within the buildings’ core.  In many multi-residential applications, we typically encounter the bedroom suite receptacles fed with 300 volt insulated copper conductors encased in EMT raceway in the building’s concrete slab.  By leveraging this construction technique, along with the proven AC line carrier technology that has been in existence since the 1950s -- remember your grade schools time clocks, they used line carrier technology to sync the clocks -- we ensure that the evacuation signal operates at its intended location.  We should note that each in-suite device is uniquely digitally addressed and polled by the Fire-Link II controller. If for any reason the device is removed from the AC circuit or fails to report to the controller, the fire alarm system is notified to this off-normal condition. The LCD indication at the controller, located next to the fire alarm control unit, shall annunciate the specific in-suite device location for efficient trouble shooting and repair of the situation.

In summary, Mr. Kurz cites the 2006 British Columbia Building Code as applied to residential signalling device circuit wiring requirements. In 99% jurisdictions across Canada the current Building Code (BC) is not applied to Fire-Link II residential audibility upgrades, for the following reasons: 

  • The Building Code is not retroactive (building built in 1920 does not apply to 2012 BC)
  • When there is a “Change of Use” – BC applies (i.e. shoe store to paint factory)
  • When there is a “Renovation or extension” - BC applies (add 10,000 sq. feet, replace the complete fire alarm system etc.)
  • When installing Fire-Link a Building Permit is typical not requested or required.

In most cases each Province adopts the National Building Code of Canada with or without amendments and creates the Provincial Building Code Act.  Since Fire-Link II is an extension to the existing fire alarm system, similar to providing higher luminous light bulbs to plug in standalone emergency lighting units or exit signs, no building permit is required and as such the most current BC simply does not apply to legacy buildings requiring Fire Code driven fire alarm signal audibility.   The Functional Statements and Appendix supplemental non-legal recommendations in the Fire Code, will reference older Building Codes as a guide to achieving the desired level of life safety. i.e. we must achieve 75dBA in the sleeping room.

To complete the answer to question 1: “…what provision does the system employ to differentiate the floor AREAS when this equipment is installed?” 
Fire-Link II leverages the discrete branch circuits serving the receptacles connected to the in-suite devices as per the manufacture and ULC listed installation requirements. In addition, discrete device supervision is afforded to each in-suite device to ensure performance as intended during fire emergency conditions. In context with floor zoning or differentiation, the requirements of Division B Part 3 - 3.2.4.18(11) have been miss-interpreted in context with fire alarm audibility retrofit applications as applied to Fire-Link II.

Clearly Mr. Kurz’’ (sic)  statement is misinformed at best:   “….. It does not meet the requirement mandated by BCBC 2006 or BCBC 2012 where separate signaling circuits must be provided for each floor area and for each floor area serving suites of a residential or care occupancy. It seems that, in the rush to find a viable alternative to chopping holes and running conduit, some jurisdictions have fixated on the Signalink equipment and, in the absence of proper consultation, have accepted this as an ALTERNATIVE to what the Building Code requires.”   This statement appears to us to be inflammatory and insulting to the good work of many AHJs and Consulting Engineers across North America. These professionals have carefully reviewed, witnessed the performance, and accepted the Fire-Link II solution in the protection of life and property. The application of one basic building code sentence, without a holistic view of the functional statements, and intentions of both the Fire Code and Building Code as provided by Mr. Kurz’ is a suspect approach.

“As a consequence, use of this equipment without the requisite number of floor AREA signaling circuits should result in an automatic FAIL by the individual performing the Fire Alarm Verification.”   This statement is incorrect on many levels. The application of CAN/ULC-S537-04 in context with the manufacturer installation requirements is subject to the verifier’s understanding of the specific technology being verified.   For example we do not perform an end of line resistor test on the phone circuit while operating the fire fighter telephone system. This is because the test will not work while the phone is live.   In the same way, we do not apply the tests designed for discrete notification appliance circuits on the Fire-Link II solution since ULC approved manufacturer commissioning tests are specific to this solution. Fire-Link leverages digital addressability and AC line carrier technology to achieve 75dBA in the required location. The comment exhibits a surprising lack of understanding in this context.

As other life safety technologies advance, such as addressable visible signals and addressable speakers come onto the scene, applying Kurz’ (sic) logic in the same way creates a negative implication to these burgeoning solutions. What other excuses negating a proven innovative solution will he come up with next? Perhaps, we should re-iterate that a short on a digital circuit causes total circuit communication failure. With Kurz’ (sic) logic, perhaps all addressable devices should be banned from Canada?

QUESTION TWO -  Can you use the Signalink equipment as a substitute for the sounders required in a sleeping room in a retro-fit application? Does such an installation meet the requirements of the Building Code?

Fire-Link II is an audibility upgrade solution that makes it possible to quickly retrofit multi-residential buildings.  Clearly Fire-Link II is provided to enhance an existing system where no signal appliance is provided in the sleeping room.  If a signal appliance or horn already existed in the sleeping room, but did not provide the desired output then a new a horn with the correct output would be provided on that hard wired circuit.  Fire-Link II was never intended to replace hard wired signalling devices.

In context with “Does such an installation meet the requirements of the Building Code?  We must note that the Building Code is not an installation manual.  In context with residential retrofit and the functional statements of the National Building Code and National Fire Code of Canada and the specific ULC listing for the Fire-Link II application, it is clear that this solution provides the prescribed 75dBA evacuation signal, with device supervision.  In life safety applications, we cannot pick and choose the Code and Standard clauses with neglect for the holistic approach to meeting the intent and rational of the performance based Codes. 

The question should be this: Does the ULC listed Fire-Link II provide a safe and reliable fire alarm audibility retrofit solution for multi-residential occupancies, in context with providing the 75dBA evacuation signal, with device supervision? The answer is yes. 

Mr. Kurz’ stated: “I’m going to suggest that, while this particular jurisdiction’s building department may have accepted the sole use of this equipment for in-suite signaling, the individual performing the Verification may (should?), in fact, reject it.”  This misguided statement defies reason, in context with the application of the Building Code and its referenced CAN/ULC-S537-04 Verification Standard.

Let’s take a closer look at the Scope statement in CAN/ULC-S537-04:   “The requirements of this Standard contemplates that the verification procedure described herein will be conducted by an organization other than the installing contractor and designer, and that the verification will be carried out by qualified personnel in the employ of an organization acceptable to the authority having jurisdiction.”

Clause 5.1.3 states: Each function/feature of the field device shall be tested and annunciation confirmed while connected to the control unit or transponder. 
Also, let’s review: 5.9.1.1 in CAN/ULC-S537-04: 5.9.1.1 Each device shall be inspected and tested to confirm the operability of the following functions, as applicable: 

A) Installed correctly; and 

B) Tested in accordance with the manufacturer's requirements or an appropriate test means, to ensure that the correct operation will result in an audible trouble signal and a visual indication. 

Clearly not every sentence in either a Building Code or Standard will address the specific application requirement for the installation as deemed by the manufacturer and designer.  Qualified Personnel that are trained and understand the manufacture commissioning requirements as in Fire-Link II application ensures that the signalling provided is fully functional in context with its intended application.  I suggest that those interested review the commissioning tests that are provided with Fire-Link II.  As such, there will be no issue in context with providing the Fire-Link II commissioning test report as a supplement to the CAN/ULC-S537-04. This approach is similar to the typical administration requirements for smoke control testing.

QUESTION THREE - “What provision is there to supervise the wiring to the remote signaling appliances? “

Fire-Link uses the existing building’s AC wires to communicate between the ULC listed controller and the ULC listed in-suite horns which are digitally addressable and supervised. Since each device is polled and monitored the supervision of the wiring is a moot point. It would be like asking:  “Why does this Data Communication Link not have an end of line resistor to supervise the wiring?  It does not require wiring supervision since each device is digitally placed and digitally monitored utilizing differential data communication protocol technology, developed in Bell labs in the early 1960s.

We look at Mr. Kurz’ (sic) statement -- frankly, one that references Codes and Standards without carefully applying the proper context, as a means to discredit a technology -- as a call to action in our industry.  We must continually challenge the “old-school” indoctrinated way of thinking.  To reiterate, Fire-Link II provides these main benefits:

  • This solution is less costly than traditional new hard wired horn retrofit installations
  • Fire-Link II can be installed in as little as a few days
  • It ensures efficient compliance for audibility in low rise residential retrofit
  • Requires no intrusive construction 

 

January 23, 2014 - FRANK KURZ RESPONDS TO DAVID SYLVESTER AND THE MIRCOM GROUP OF COMPANIES

I would like to lead this off with the reply I filed in the member forum shortly after Mr. Sylvester posted his:

    David's response to my article would have been far more readable as a link to one of his blog articles. In fact, I would go so far as to suggest that if you KNOW what you're intending to post to the forum exceeds the allowable character count, extend some consideration to the other participants and utilize the "link" function instead.  I note that David's "call to action" includes an inference to my being "old school", accuses me of insulting the hard work of AHJ's and Engineers, discrediting the technology, providing inaccurate information based on my lack of knowledge (or personal bias), and impugning the integrity of the manufacturer (his employer).  I plead GUILTY to the first (I definitely am "old school" - although "old" is NOT how I feel most days).  The numerous responses that preceded David's diatribe in this forum bears witness to what it is I'd hoped to achieve with the article.  Genuine, objective discussion that would provide the information to an AHJ (and the Engineering community) so that they could make an informed decision as to the use of the Fire-Link II equipment.  I've copied David's response, in its entirety to the same page as the original article.  (sic)  I have always welcomed any comments I've received in response to articles I've published to the site.  I will be responding to David in more detail on the same page in the coming days.  In the meantime, I invite all of you to peruse the original article in the context of David's response.  And yes, I'll still welcome your comments.

I will be addressing Mr. Sylvester’s response utilizing a method that should present less confusion to the readers.  Mr. Sylvester’s comments are in violet, whilst ours are in black

“1. The Mircom Group of Companies is 100% committed to life safety and code compliance and stands behind its UL and ULC listed Signalink Fire-Link II system for its intended application.”

There is simply no argument I could present to the contrary.  To do so would indeed impugn either the technology or the Mircom Group of Companies.  I, in fact, whole-heartedly agree with the fact that they are “100% committed to life safety and code compliance”.  The two questions I have regarding this particular statement are:  Why avoid stating Fire-Link® II’s “intended application”?  Why not come right out and say it’s specifically designed for a “retrofit” application where a building owner has decided to augment the audible signalling of an existing fire alarm system? 

    “The intended and primary use and application of the Fire-Link® II solutions (sic) is retrofit (not new construction) applications.”

“2. The Mircom Group of Companies does not wish to stifle healthy industry debate and while we are prepared to readily accept constructive and responsible criticism, we cannot reasonably stand by and allow misinformed individuals to make unreasonable and factually inaccurate statements impugning our product lines or technology;”

I’ll respond with a direct quotation from Mr. McConchie’s demand letter:

    “Schedules A and B falsely and recklessly allege that: (i)  Fire-Link II is unfit to be used as an audibility retro-fit upgrade solution; and (ii) Mircom intentionally misleadingly promotes Fire-Link II as a substitute for the installation of hard-wired fire alarm signalling components required by the British Columbia Building Code.

    Schedules C through H unlawfully convey the false and reckless impression that Mircom trained and employed technicians regularly conduct “bogus” and / or “botched” verifications of Mircom fire alarm systems, unnecessarily putting lives and property at risk of danger from fires.

    Mircom wants to give you both an opportunity to rectify this unacceptable situation by immediately removing Schedules A, B, C, D, E, F, G, and H from the Internet.  Mircom also reasonably requests that you provide it with an undertaking in writing to not republish the same or similar defamatory imputations about Mircom in the future on the Internet or elsewhere.”

Quite obviously, this means that they’re NOT prepared to “accept constructive and responsible criticism”.  I figure the part about the “misinformed individuals making (sic) unreasonable and factually inaccurate statements” sort of nicely ties in with the accusations made by Mr. McConchie against me as well.  It should be noted that his reference to Mircom’s technicians “unnecessarily putting lives and property at risk of danger from fires” is NOT a “false or reckless impression”.   While a “bogus verification” would only, in the most unfortunate of circumstances, figure in actually starting a fire, I will come right out and state (for the record) that it’s far more likely that incorrectly installed equipment could negatively impact the operation of the fire alarm system at a crucial moment (more on this later).

If you haven’t had an opportunity to read my response to Mr. McConchie, I’ll include this little tidbit here:

    “I take exception to your accusation (and your client’s repeated inferences) that I have libelled Mircom in the Schedule items you indicate. While they do employ strong language (“botched”, “bogus” as examples), they also present an honest, objective assessment of failed inspection “work” (performed by factory trained technicians no less) and are held up as examples of what individuals engaged in the performance of a Verification (or an annual inspection) should remain vigilant against. Let us take Schedule “E” as an example:

    When Mircom’s SENIOR technician in Vancouver is seen to perform an annual inspection of a suppression releasing panel mounted twelve feet from the floor (located above a “T-Bar” ceiling), I find myself harbouring sincere reservations over his ability to satisfy the professional credentials expressed in both Appendix “A’s” of CAN/ULC-S536 and CAN/ULC-S537. This stands out as one of the worst examples of a botched inspection that I’ve seen in my thirty (30) year career. It’s particularly troubling because he was performing this work within a community subject to a Bylaw requiring ASTTBC certification in the specific discipline (Special Suppression), which he DID NOT possess.”

3. We question whether the CFAA LinkedIn forum wishes to be brought into debates about proprietary technologies and give voice to fringe opinions that otherwise could not access such an important audience.

Constructive debate is healthy, Mr. Sylvester.  Picking up the phone and dialing 1-888-340-3473 (or clicking on the email link) would have likely made this experience far more constructive and much less confrontational.  Actually, if you had taken the time to objectively read some of the responses to the article in the CFAA LinkedIn Forum before you rushed off to sound “battle stations”, you should have perceived the actual intent (discussion and debate).

But then, mine is only a “fringe opinion” and therefore not, apparently, even worth MY dime!

Now to specifically address Mr. Kurz’ questions:

QUESTION ONE  - “While the equipment is both UL and ULC Listed, what provision does the system employ to differentiate the floor AREAS when this equipment is installed?” 

Mr. Kurz’ cites the 2006 British Columbia Building Code (2006-BCBC) Division B Part 3 Clause 3.2.4.18(11): “In a building or part thereof classified as a residential occupancy, a) separate circuits shall be provided for audible signal devices on each floor area, and b) audible signal devices within dwelling units or suites of residential occupancy shall be wired on separate signal circuits from those not within suites of residential occupancy or dwelling units. (See A-3.2.4.18.(10) in Appendix A.)” 

The first question we must ask is in regards to the application of 2006 BCBC 3.2.4.18 (11) and 2012 BCBC 3.2.4.19(9) as applied to residential audibility fire alarm retrofit applications and also in context with Part 9 residential occupancies.

“Division B 9.10.18.3. Design and Installation Requirements sentence 2 states: “The following Articles in Subsection 3.2.4. regarding fire alarm systems do not apply to Part 9 buildings: Articles 3.2.4.1., 3.2.4.11., 3.2.4.12. , 3.2.4.13. , 3.2.4.14., 3.2.4.21., and 3.2.4.22.” 

Many building and fire officials will tell you that zoning of signalling devices is not directly addressed in the Building Code, unless the building is required to have a voice communication system.  In Group C residential low rise applications, specific zoning of signalling devices is simply not required.  Obviously in a single stage fire alarm system, all signalling devices sound simultaneously.

True, but only IN A “RETROFIT” where the Local Authority has had an opportunity to carefully consider it as a viable alternative.  The part about “careful consideration” was, incidentally, the whole purpose behind the article.  But I digress.  A good part of Mr. Sylvester’s response actually applies to a mandated fire alarm upgrade in, for example, the City of North Vancouver’s Fire Alarm Upgrade Bylaw.  The Bylaw requires - at a minimum - compliance with BCBC 2006.  There are a number of other jurisdictions in which contractors and engineers alike have consulted with me and who are facing the same conundrum.  What’s really troubling is that Mr. Sylvester is wrong when he states that

    “In Group C residential low rise applications, specific zoning of signalling devices is simply not required.” 

The entirety of 3.2.4.19 is not included in the exemptions listed in Division B 9.10.18.3.  Where a fire alarm system is installed, there must be separate signal circuits for every floor area, PERIOD!  “Specific Zoning of signalling devices” IS, most definitely, addressed within the British Columbia Building Code!

In many multi- residential buildings, that have poor or suspect audibility, the existing horns or bells were often wired in a vertical riser format, with a discrete circuit provided per riser.  In fact, we have typically seen more than three to five circuits per floor where the bell or horn risers have traveled from the control unit on discrete class B circuits at various locations on the floor’s foot print to provide fire alarm signalling.   The use of 3.2.4.18 (11) “….separate circuits shall be provided for audible signal devices on each floor area…” has been misapplied re Part 9 residential retrofit applications. 

Mr. Sylvester is correct.  There are many buildings (built prior to 1992) in which signal circuits were wired in a format employing such discrete risers (this includes high-rise structures).  Mr. Sylvester goes on to support his erroneous argument, however, using what I can only term “fuzzy logic” and “shotgun rhetoric” (in reference to the amount of verbiage he’s had to use to get his point across).  The 2006 Building Code introduced an approach that ensured occupant notification and survivability of the fire alarm signalling circuits.  The manufacturer’s recommendations will NEVER supersede the Building Code.  CAN/ULC-S524 is the reference Standard for the installation of a fire alarm system.  The Building Code doesn’t tell you how high to mount a particular device, or how to ensure survivability of a Data Communications Loop (DCL).  It does make several specific statements, which make up the various points incorporated in Sentence 3.2.4.19. 

Furthermore CAN/ULC-S524-06A, Clause 5.4.2.1 clearly states: “Audible signal devices shall be installed in accordance with Manufacturers recommendations”. 

Clause 5.4.2.1 has been amended in the newest version of CAN/ULC-S524 to more accurately reflect the original intent of this sentence.  The “Manufacturer’s recommendations” has usually been interpreted to mean the “manufacturer’s published installation instructions” (which happens to coincide with the new wording adopted by the Standard).  The instructions include things like this way up when mounting a bell or horn, how to physically terminate the unit, mount it to a pre-installed back-box, etc.  But then, I’m just another ”fringe opinion”, right?

In summary, Mr. Kurz cites the 2006 British Columbia Building Code as applied to residential signalling device circuit wiring requirements.  In 99% jurisdictions across Canada the current Building Code (BC) is not applied to Fire-Link II residential audibility upgrades, for the following reasons: 

  • The Building Code is not retroactive (building built in 1920 does not apply to 2012 BC)
  • When there is a “Change of Use” – BC applies (i.e. shoe store to paint factory)
  • When there is a “Renovation or extension” - BC applies (add 10,000 sq. feet, replace the complete fire alarm system etc.)
  • When installing Fire-Link a Building Permit is typical (sic) not requested or required.

When in the context of an audibility retrofit, Mr. Sylvester is correct, the Building Code is not retroactive.  I do take exception to the last part, however.  Most Jurisdictions DO require a Building Permit when anyone is contemplating modifying, upgrading, retrofitting or extending a life safety system.  This is definitely something that anyone contemplating such work should verify first because the submittal process may require you to provide drawings and involve a Professional Engineer.

In most cases each Province adopts the National Building Code of Canada with or without amendments and creates the Provincial Building Code Act.  Since Fire-Link II is an extension to the existing fire alarm system, similar to providing higher luminous light bulbs to plug in standalone emergency lighting units or exit signs, no building permit is required and as such the most current BC simply does not apply to legacy buildings requiring Fire Code driven fire alarm signal audibility.   The Functional Statements and Appendix supplemental non-legal recommendations in the Fire Code, will reference older Building Codes as a guide to achieving the desired level of life safety. i.e. we must achieve 75dBA in the sleeping room.

Fire-Link® II cannot be compared to a “higher luminous light bulb” that simply screws into an existing light socket.  It requires (and certainly is not be limited to):

  • more than one permanent and dedicated connection to the main electrical panel,
  • a careful site survey that includes an examination of the main electrical feed and distribution meter stack,
  • the layout of the individual bedrooms (with relocation of an available outlet requiring the employment of a licensed electrical contractor), and,
  • a supervised connection between the fire alarm control unit and the Fire-Link® II controller. 

To suggest that this can be accomplished without a Building Permit (or Verification as Mr. Sylvester seems to suggest later) is simply beyond my ability to comprehend (I see it, but I don’t believe it).

To complete the answer to question 1: “…what provision does the system employ to differentiate the floor AREAS when this equipment is installed?”  Fire-Link II leverages the discrete branch circuits serving the receptacles connected to the in-suite devices as per the manufacture and ULC listed installation requirements.

Those ULC Listed installation requirements wouldn’t, by any chance, be a reference to CAN/ULC-S524-06 (Standard for Installation of Fire Alarm Systems), would they?  The receptacles you suggest that will be used within the “five minute” installation time referenced for each suite are usually located where, a foot above the floor?  Is that anywhere close to what the Standard requires in either height or optimal location?

In addition, discrete device supervision is afforded to each in-suite device to ensure performance as intended during fire emergency conditions. In context with floor zoning or differentiation, the requirements of Division B Part 3 - 3.2.4.18(11) have been miss-interpreted in context with fire alarm audibility retrofit applications as applied to Fire-Link II.

There’s that word “retrofit” again.  The Code references provided are in the context of a full fire alarm upgrade (along the lines of the City of North Vancouver’s Bylaw).  Now Mr. Sylvester can’t be blamed for his misinterpretation of the article.  Since its publication it has undergone some additional editorial changes that more accurately reflect what it was our intention to present in the first place.

Clearly Mr. Kurz’’ (sic)  statement is misinformed at best:   “….. It does not meet the requirement mandated by BCBC 2006 or BCBC 2012 where separate signaling circuits must be provided for each floor area and for each floor area serving suites of a residential or care occupancy. It seems that, in the rush to find a viable alternative to chopping holes and running conduit, some jurisdictions have fixated on the Signalink equipment and, in the absence of proper consultation, have accepted this as an ALTERNATIVE to what the Building Code requires.”   This statement appears to us to be inflammatory and insulting to the good work of many AHJs and Consulting Engineers across North America.  These professionals have carefully reviewed, witnessed the performance, and accepted the Fire-Link II solution in the protection of life and property. The application of one basic building code sentence, without a holistic view of the functional statements, and intentions of both the Fire Code and Building Code as provided by Mr. Kurz’ is a suspect approach.

Again, we’ve actually edited the article for clarity.  I guess what it really comes down to though, is a matter of interpretation.  When you’re really close to a subject (i.e. an employee of the company), your views can become aligned along the rhetoric used to pitch the product to the masses.  Yes, Fire-Link II IS a well conceived, well tested, well engineered product, designed specifically to help building owners and managers sleep better at night secure in the knowledge that their tenants will be adequately alerted to an emergency.  What you’re missing though, is “consultation”, careful consideration, and a cautious approach to acceptance (as I advocate in the article).  The building owner is ALWAYS going to opt for the cheaper, less invasive solution.  You haven’t provided him with all the facts, however.  It’s quite simply NOT a “five minute” install, is it?  In EVERY CASE, it will involve some cutting and repair, the services of a qualified electrican (or two).  And it most definitely won’t take seven hours!  You, quite obviously, haven’t provided AHJ’s with all the facts either, or there wouldn’t be so much confusion out there regarding its use and application.  Whose “approach” is more suspect?

I would like to see some actual case studies.  I would like to see the actual acceptance criteria used.  What did the AHJ’s (in the various successful installations you state have already completed), actually specifically require in the way of installation, testing, and documentation?  These are the questions I was hoping to put to Rien when I called, left a message and emailed him.

My investigation into the product’s use determined its suitability in an audibility retrofit, but NOT as the sole solution for insuite notification in an UPGRADE that required modern Code Compliance.  This is where I failed to provide clarity in the article but thought that the discussion in the CFAA Member Restricted Forum was moving towards.  Some of the discussion was included in the documentation provided by Mr. McConchie as Schedule “B”.  For the edification of those readers that don’t have access to the forum, here are the applicable entries (names of other participants have been excluded):

    Forum Member **:  I believe this system works well in instances where it is almost impossible to add to the current Fire Alarm system without doing major renovations. I have had it installed with a previous employer and it works very well. I have also installed it recently and the customer loves it. I don't believe it is an answer to the hardwired system and suggest that would be the first solution, but when you need to consider another option for some instances, the Signallink Technologies' Firelink system is another avenue.

    Frank Kurz:  Well said, **. There is a place for this type of SUPPLEMENTAL signalling technology, although I think I would prefer a full wireless alternative in this instance. Reliance on what could be outmoded electrical wire (aluminum or insulated fibre) for the transmission of signals in an actual fire where there is a very real prospect of it actually STARTING in, or adversely affecting, those same key circuits is problematic. When people need to be notified of a life threatening emergency is exactly when you don't want your proposed alternative solution to those "costly renovations" to fail. Call me "old school" if you like, but if a Jurisdictional Authority is going to mandate a fire alarm retrofit to achieve the 75 dBA in the bedrooms on a pre-1992 constructed multi-tenant building, is exactly when you DON'T want to ignore a Building Code (or Standard) that has developed and improved public safety through the examples of years of bitter experiences and poor practices. This having been said, I'm curious as to how your installations were actually vetted through the local Jurisdictional Authority and how the individual performing the Verification dealt with it (as it represents a radical departure from what they would expect to see). Is the equipment the ONLY audible signal source in the suite, or does it supplement what's already there?

    Forum Member **:  I agree Frank that there needs to be a system out there that works in all applications and is approved. In regards to the installation we did, it is an addition to what they already have in the suites. The reason for this was due to elderly individuals who could not hear the alarms and wanted to know what other options there were. It was approved as it was an addition to that increased their chances of hearing in case of fire.

    Frank Kurz:  This stands as a model of what it is I'm trying to point out in the article. The Signalink Firelink II system is tailor-made for this type of retrofit (when used in conjunction with existing in-suite signalling means). It should NOT be used as a substitute for properly supervised, isolated and installed fire alarm signalling components. I'm pleased the installation went well and that your customer is happy too.

There’s more, but this wasn’t included in Mr. McConchie’s submittals.

“As a consequence, use of this equipment without the requisite number of floor AREA signaling circuits should result in an automatic FAIL by the individual performing the Fire Alarm Verification.”   This statement is incorrect on many levels.

No, actually, I’m right (in the context of a mandated fire alarm upgrade).

The application of CAN/ULC-S537-04 in context with the manufacturer installation requirements is subject to the verifier’s understanding of the specific technology being verified.   For example we do not perform an end of line resistor test on the phone circuit while operating the fire fighter telephone system.  This is because the test will not work while the phone is live.   In the same way, we do not apply the tests designed for discrete notification appliance circuits on the Fire-Link II solution since ULC approved manufacturer commissioning tests are specific to this solution.

So, what you’re saying is that the technician depicted in the picture does the installation, the programming and will also perform the commissioning test.  And ULC approved this?  The local AHJ’s that have accepted your solution in a retrofit application DIDN’T require a third party Verification?  You’ve got to be pulling my leg, right?  And since WHEN does ULC “approve” a manufacturer’s commissioning tests?  I believe THAT falls within the jurisdiction of the Local Authority.

Fire-Link leverages digital addressability and AC line carrier technology to achieve 75dBA in the required location. The comment exhibits a surprising lack of understanding in this context.

Chaulk it up to a “fringe opinion”.

As other life safety technologies advance, such as addressable visible signals and addressable speakers come onto the scene, applying Kurz’ (sic) logic in the same way creates a negative implication to these burgeoning solutions. What other excuses negating a proven innovative solution will he come up with next? Perhaps, we should re-iterate that a short on a digital circuit causes total circuit communication failure. With Kurz’ (sic) logic, perhaps all addressable devices should be banned from Canada?

The extent that an addressable circuit (DCL) is compromised by a “short” imposed on it is mitigated by a little device called a data loop isolator.  It’s supposed to be installed (it actually makes its first appearance in the “01” version of the Installation Standard) and Verified.  It’s also supposed to limit the failure of the data communications loop to a single floor area.  Something your guys missed when they Verified THIS little puppy.  And THIS little puppy.

QUESTION TWO -  Can you use the Signalink equipment as a substitute for the sounders required in a sleeping room in a retro-fit application? Does such an installation meet the requirements of the Building Code?

Fire-Link II is an audibility upgrade solution that makes it possible to quickly retrofit multi-residential buildings.  Clearly Fire-Link II is provided to enhance an existing system where no signal appliance is provided in the sleeping room.  If a signal appliance or horn already existed in the sleeping room, but did not provide the desired output then a new a horn with the correct output would be provided on that hard wired circuit.  Fire-Link II was never intended to replace hard wired signalling devices.

Let’s not confuse the issue by using “upgrade” and “retrofit” in the same sentence.  Let’s go with what you’ve already stated Fire-Link II’s purpose is: “The intended and primary use and application of the Fire-Link II solutions (sic) is retrofit (not new construction) applications.”

In context with “Does such an installation meet the requirements of the Building Code?  We must note that the Building Code is not an installation manual.  In context with residential retrofit and the functional statements of the National Building Code and National Fire Code of Canada and the specific ULC listing for the Fire-Link II application, it is clear that this solution provides the prescribed 75dBA evacuation signal, with device supervision.  In life safety applications, we cannot pick and choose the Code and Standard clauses with neglect for the holistic approach to meeting the intent and rational of the performance based Codes. 

What was the middle part again?  How about we use: “The intended and primary use and application of the Fire-Link II solutions (sic) is retrofit (not new construction or mandated upgrades that require current Code compliance) applications.”

The question should be this: Does the ULC listed Fire-Link II provide a safe and reliable fire alarm audibility retrofit solution for multi-residential occupancies, in context with providing the 75dBA evacuation signal, with device supervision? The answer is yes. 

Perfect!

Mr. Kurz’ stated: “I’m going to suggest that, while this particular jurisdiction’s building department may have accepted the sole use of this equipment for in-suite signaling, the individual performing the Verification may (should?), in fact, reject it.”  This misguided statement defies reason, in context with the application of the Building Code and its referenced CAN/ULC-S537-04 Verification Standard.

The statement isn’t misguided.  You’re still in “retrofit” mode.  We’re talking a mandated Code Compliant UPGRADE.  Section 6 of the referenced Standard REQUIRES you to Verify any addition to an existing fire alarm system.  Clause 6.7 states:

    “Where a control unit or transponder is added to an existing system, the control unit or transponder and all new and existing field devices connected to it shall be verified in accordance with this Standard.”

Let’s take a closer look at the Scope statement in CAN/ULC-S537-04:   “The requirements of this Standard contemplates that the verification procedure described herein will be conducted by an organization other than the installing contractor and designer, and that the verification will be carried out by qualified personnel in the employ of an organization acceptable to the authority having jurisdiction.”

And the “context” of this statement is?  I sincerely doubt it refers to the Schedule Items submitted by Mr. McConchie, because if it did, every one of the Mircom “qualifed personnel” involved should have their “qualifications” revoked and the referenced installations which they passed (often more than once!) should all be re-verified by a properly qualified individual in the employ of any acceptable organization OTHER THAN MIRCOM!

Clause 5.1.3 states: Each function/feature of the field device shall be tested and annunciation confirmed while connected to the control unit or transponder. 

I thought only a “ULC approved commissioning test” was required.  Didn’t you state that earlier?  Which “control unit or transponder” are you referencing?  If the Fire-Link II, then there are several tests that won’t be applicable.  Have you provided your Dealers with a list of them all and explained why they don’t apply?  Perhaps such a list would also help an AHJ determine the suitability of the Fire-Link II equipment in an UPGRADE situation versus a “retrofit” or as a “supplemental signalling component”, rather that the sole source of in-suite signalling?

Also, let’s review: 5.9.1.1 in CAN/ULC-S537-04: 5.9.1.1 Each device shall be inspected and tested to confirm the operability of the following functions, as applicable: 

A) Installed correctly; and 

B) Tested in accordance with the manufacturer's requirements or an appropriate test means, to ensure that the correct operation will result in an audible trouble signal and a visual indication. 

Again, you’re referring to Verification.  What happened to “ULC  approved manufacturer commissioning tests”?  But, by all means, let’s discuss Verification.  I should venture to state that Section 5.9 references “Supervisory Devices - Other Types”Section 5.10 References “Signal Devices”.  5.10.1 states: 

    “Each audible signal device and visible signal device shall be inspected and tested to confirm operability, including the following functions as applicable:”

Then we have that pesky little “A”.  It starts with

    “Proper installation...”

And let’s not forget 5.1.1 A (under “Verification Requirements for Field Devices”):

    “Installation in accordance with the design and CAN/ULC-S524, Standard for Installation of Fire Alarm Systems;”

Clearly your “five minute” in-suite installation using existing wall outlets will fail.

Clearly not every sentence in either a Building Code or Standard will address the specific application requirement for the installation as deemed by the manufacturer and designer.  Qualified Personnel that are trained and understand the manufacture commissioning requirements as in Fire-Link II application ensures that the signalling provided is fully functional in context with its intended application.  I suggest that those interested review the commissioning tests that are provided with Fire-Link II.  As such, there will be no issue in context with providing the Fire-Link II commissioning test report as a supplement to the CAN/ULC-S537-04. This approach is similar to the typical administration requirements for smoke control testing.

Nope.  I disagree.  You are installing Listed signalling appliances that fall directly under the purview of the Installation Standard and must be VERIFIED to that Standard.  You’re also installing a control unit that will be interconnected to an existing fire alarm control panel (or transponder). 

But then, I’m just a “fringe opinion” and my opinions shouldn’t be given any credence whatsoever.

QUESTION THREE - “What provision is there to supervise the wiring to the remote signaling appliances? “

Fire-Link uses the existing building’s AC wires to communicate between the ULC listed controller and the ULC listed in-suite horns which are digitally addressable and supervised. Since each device is polled and monitored the supervision of the wiring is a moot point. It would be like asking:  “Why does this Data Communication Link not have an end of line resistor to supervise the wiring?  It does not require wiring supervision since each device is digitally placed and digitally monitored utilizing differential data communication protocol technology, developed in Bell labs in the early 1960s.

I still like my answer better (and I didn’t even have to make any editorial changes to it).

We look at Mr. Kurz’ (sic) statement -- frankly, one that references Codes and Standards without carefully applying the proper context, as a means to discredit a technology -- as a call to action in our industry.  We must continually challenge the “old-school” indoctrinated way of thinking. 

Now them thar’s fightin’ words!  I have in NO WAY discredited your technology.  I’ve suggested a cautious, contemplative approach to its acceptance by any Jurisdictional Authority.  I guess you missed that part in your rush to “battle stations”.

To reiterate, Fire-Link II provides these main benefits:

  • This solution is less costly than traditional new hard wired horn retrofit installations
  • Fire-Link II can be installed in as little as a few days
  • It ensures efficient compliance for audibility in low rise residential retrofit
  • Requires no intrusive construction 

Properly installed, it will be “intrusive”, and it will take longer to install in a suite than the literature so generously underestimates. 

But then, I’m just a “fringe opinion” and shouldn’t be given any credence whatsoever.

In conclusion, I will reiterate:

    “The Signalink equipment may well represent a viable solution to the problem of achieving the required sound pressure levels when retrofitting signaling appliances in older buildings.  Its use, however, must still be carefully considered, strictly monitored, and regulated to ensure we’re not compromising the safety of residents or recommending an alternative that may, in fact, compromise the Building Code and the Installation Standard.  In older apartment buildings which may employ aluminum or other substandard wiring components, it is even more important, in my view, to carefully examine any formal submission in which the use of the Signalink equipment is proposed.  Keep in mind that if the fire is electrical in nature (the single most likely cause in older buildings), the ability of the Signalink system to notify occupants may become impaired (or completely compromised) because it’s utilizing that same wiring that could have sparked the fire in the first place in order to transmit the alarm signals.”

 

UPDATE!  A “CHANCE” ENCOUNTER?

Port Moody, British Columbia - December 17, 2014 - I had an opportunity to make a presentation on the various changes affecting many of the Standards currently referenced in the British Columbia Fire Code 2012 to representatives of FPOABC’s Region 2 at Port Moody’s new fire hall on Newport Drive.  It is truly an amazing facility and features a large, beautifully appointed conference room on the third floor.

Fire Prevention Officers from across the Lower Mainland attended.  I saw shoulder patches from Chilliwack, Vancouver, Burnaby, North Vancouver District, North Vancouver City, West Vancouver, Maple Ridge, Pitt Meadows, Coquitlam, and Langley.  ASTTBC’s Compliance Officer, Dave Clou was there (I was a bit disappointed that he didn’t ride in on his hog) as well as Mircom’s Gord Morrison and Rien van den Enden, SignaLink’s Product Manager.  At the end of the meeting we were all informed by Dave Merrill, recently retired Captain - Fire Prevention from City of North Vancouver, that Mircom would be responding to our SignaLink Application Chart, an earlier version of which had been circulated throughout the Association’s membership.  It’s also made the rounds in Saskatchewan (from what I hear).

I did take the opportunity to talk with Rien after the meeting as the attendees were in the process of leaving the room.  Our conversation touched on a number of aspects regarding the “second generation” Fire-Link® II currently being installed in several City of North Vancouver buildings.  I expressed my concerns regarding the application of the product as the sole source of insuite signalling (which the City of North Vancouver has allowed).  I was also concerned with some potential issues surrounding the annual testing requirements.  The insuite appliances (whether audible or visual) employ a Lithium ion rechargeable battery with integral charger.  How is the battery’s condition supposed to be tested?  CAN/ULC-S536-04 requires the charger and battery test results to be recorded on an ANNUAL basis.  How often will the batteries have to be replaced?  Is Mircom/SignaLink the only source for them?

Unfortunately we didn’t have a lot of time to address my concerns (Rien had another meeting he had to go to).  I actually remain hopeful that we will continue our dialogue and will work together to clarify the issues surrounding SignaLink’s implementation and proper use in enhancing audibility in jurisdictions across Canada. 

Not-with-standing, I still harbour many reservations about how it’s been accepted for use in the City of North Vancouver.  Considering the product is listed as a “supplemental signalling appliance”, I feel strongly that the technology (as it’s being implemented here) is being “pushed” into something for which it was not originally intended.  To put it another way, there shouldn’t be a difference between how you would look at at alternative solution for “new construction” as compared to a Code compliant “upgrade” in an existing building.  Logically, if a product (and I don’t just mean to single out Fire-Link® II) isn’t acceptable in one, it should follow that it wouldn’t be acceptable in the other.  Just ask any building owner that’s recently been faced with an elevator modernization in British Columbia.

Let’s review some of the answers I received from the questions I posed earlier in this update:

How is the signalling appliance integral battery tested?

Apparently the charger and battery are continuously undergoing a “self test”.  The battery’s condition is checked for voltage and capacity which is, in turn monitored by the Fire-Link® II controller.  Rien explained that a “low battery” signal will cause a “trouble” on the controller, which should also trigger a “trouble” on the fire alarm system.  He also indicated that SignaLink’s R&D division elected to install a three cell Lithium ion battery in each audible and visual signal module to facilitate being able to add a satellite buzzer or lamp assembly powered by the local module at some later date.  Great idea.  According to Rien, we now have a higher capacity battery installed with the actual supervisory and alarm times required by the Building Code being exceeded by a significant margin.  So far so good.

Now comes the ability to “prove” the battery’s performance on an annual basis in accordance with CAN/ULC-S536 (Standard for Inspection and Testing of Fire Alarms).  Rien confirmed that there is no facility at the module that would allow you to perform such a test (on either the battery or the power supply).  Rien suggested that the module be treated as a “wireless device” (which falls outside of the currently employed testing Standard).  I mentioned that most wireless smoke and thermal detectors I’m familiar with provide a “low battery” signal at the common control a full thirty (30) days before the device goes off line.  With a rechargeable Lithium ion battery the “low battery” signal is normally generated at the end-of-life when the power curve starts to fall very steeply towards “zero”.  Additionally, since all of the batteries in a typical Fire-Link® II installation would tend to have the same date codes and “in-service” dates, a building owner can expect to replace them ALL at the same time (a process that can take about fifteen minutes for each module and which must be performed by a qualified technician who is required to test each one as he goes).  Not-with-standing, the current version of CAN/ULC-S536 (-13) requires replacement of the fire alarm system’s batteries every five (5) years regardless of how “good” their condition might be in.  Would this not apply to all the field modules installed as part of a Fire-Link® II system?  What are the costs over the life of the system?  How does this compare to, say, the service/inspection costs of a fire alarm system which employed properly installed buzzers, suite isolators, and dedicated signal circuits?

My online research into this battery technology yielded an interesting article (granted the subject is Lithium ion batteries used in an automotive application, and it’s also jam-packed with formulas and data charts) - http://komar.bitcheese.net/files/JensGroot.pdf - but recent manufacturer sponsored recalls involving catastrophic (often explosive) battery failures from the likes of HP, Asus, Lenovo, and Samsung (which all utilize other Lithium battery chemistries) would still tend to favour Mr. Groot’s conclusion:

    “The ageing (sic) processes of Li-ion batteries are complex and strongly dependent on operating conditions. In addition, it is difficult to quantify the different mechanisms without performing an extensive post mortem analysis of aged cells. In addition, a test matrix covering all possible combinations of operating conditions is extremely large and such test would require many years of testing to obtain relevant and reliable results.”

How would a Verifier determine what the proper testing parameters of a FireLink® II installation are?  Does the manufacturer provide any guidelines?  Have these been vetted by ULC?

Rien suggested that “NA” would apply in a number of fields within the standard Verification Appendix “C” form.  This is, of course, based on his suggestion that the equipment is essentially employing “wireless technology” whose testing parameters would certainly differ from standard wired-in field devices, but which also have NOT been discussed in the ULC Working Group I happen to Chair.  The latest versions of the Standards (CAN/ULC-S536 and CAN/ULC-S537) just recently released don’t mention the testing of field devices which employ wireless technology because they’re based on CAN/ULC-S524-06.  “Wireless technology” is, however, included in the new Standard for Fire Alarm Installation (CAN/ULC-S524-14), so let’s see if Fire-Link® II at least fits the definitions provided in this Standard’s amended glossary:

    “3.85  WIRELESS DEVICE - See definition for short-range radio frequency device.

    3.60  SHORT-RANGE RADIO FREQUENCY DEVICE - Any device that communicates with control / receiving equipment by low-power radio signals.

    Note:  These devices are commonly referred to as wireless devices and may be subject to the requirements of Industry Canada Radio Standards Specification.

    3.61  SHORT-RANGE RADIO FREQUENCY DEVICE LINK - A low-power radio signal that provides a data channel between short-range radio frequency devices.

    Note:  Short-range radio frequency device links are commonly referred to as wireless device links and may be subject to requirements of Industry Canada Radio Standards Specification.”

Here’s a direct quote from the SignaLink.com home page (as of December 17, 2014):

    “Fire-Link® II is manufactured by Signalink Technologies Inc.  Fire-Link® II is a complete audibility upgrade solution, utilizing a revolutionary new power-line communications technology that signals through the building’s existing AC Power electrical wiring.  This advanced Fire Alarm notification signaling device has a fully addressable and supervised 87 dBA in-suite device mini-horns that can be installed anywhere there is an AC outlet.  The Fire-Link® II system attaches to any existing Fire Alarm Control Panel and is a CSFM and UL / ULC listed Fire Signaling System, created to meet NFPA72 standards for the purpose of overcoming audibility issues prevalent in older multi-unit residential buildings.”

I’m a little concerned about any technology that uses household “(AC Power) electrical wiring” to transmit data being classified as “wireless technology”.  And since when are “NFPA 72 standards” (sic) used (or referenced) in any fire alarm system installed in Canada?

The questions I’d asked Rien, and the answers I received, just raised a whole lot more questions and I’m standing by the assertion I voiced at the end of the original article, written almost a whole year ago (which I’ll repeat here so you don’t have to scroll all the way back up):

    “The fire alarm SYSTEM must be installed in accordance with CAN/ULC-S524-06 and BCBC 2006/2012.  You could use the Signalink Fire-Link II equipment in an upgrade to supplement the in-suite signaling appliances required by BCBC to ensure you achieve the 75dBA at the pillow.   You would still be required to provide installation of signaling appliances within the suite, connected, isolated, and supervised by an output circuit serving the suites on that floor (or within the specific floor area).

    The Signalink equipment may well represent a viable solution to the problem of achieving the required sound pressure levels when retrofitting signaling appliances in older buildings.  Its use, however, must still be carefully considered, strictly monitored, and regulated to ensure we’re not compromising the safety of residents or recommending an alternative that may, in fact, compromise the Building Code and the Installation Standard.  In older apartment buildings which may employ aluminum or other substandard wiring components, it is even more important, in my view, to carefully examine any formal submission in which the use of the Signalink equipment is proposed.  Keep in mind that if the fire is electrical in nature (the single most likely cause in older buildings), the ability of the Signalink system to notify occupants may become impaired (or completely compromised) because it’s utilizing that same wiring that could have sparked the fire in the first place in order to transmit the alarm signals.”

I look forward to reviewing Mircom’s/Signalink’s response!  I’m hoping it will include answers to some earlier inquiries posed in my response way back in January 2014.

 

ADDITIONAL RESOURCES:

Fire Alarm Verification Appendix “C” & Fire Alarm Inspection Appendix “E” Forms
Fire Alarm Installation FAQ
Fire Alarm Verification FAQ
Fire Alarm Inspection FAQ

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