Editorial Archives

May, 2012

WHO’S REALLY TESTING YOUR BUILDING?
(How Safe Are YOU?)

“No nation ever yet found any inconvenience from too close an inspection into the conduct of its officers, but many have been brought to ruin and reduced to slavery by suffering gradual impositions and abuses.” -- Edward Livingston

 “Truth is confirmed by inspection and delay; falsehood by haste and uncertainty.” -- Tacitus

Editorial by Frank Kurz

Vancouver, British Columbia - The owners of commercial and residential buildings in Canada have the responsibility to ensure the life safety equipment in their building is fully functional at all times.  This is articulated in British Columbia’s Fire Code (2006) Division B - Part 6.  Section 6.1.1.2. entitled “Maintenance” and reads:

“1)  Fire protection installations shall be maintained in operating condition. (See Appendix A.)”

Maintenance, testing, and inspection intervals are also mandated in this section.  In recent weeks, I’ve been focusing on the proper testing of fire alarm systems.  Section 6.3.1.2. states:

“1)  Fire alarm systems shall be inspected and tested in conformance with CAN/ULC-S536, ‘Inspection and Testing of Fire Alarm Systems’.

2)  Fire alarm and detection system components shall be accessible for purposes of inspection or maintenance.”

Building owners and managers must also ensure the building’s evacuation and fire safety plan is updated with the information necessary for the responding authority to ensure all hazards, areas of refuge, gathering places, and individuals requiring assistance are properly identified.  The fire safety plan also provides a convenient repository for documentation which must be completed for the daily and monthly testing of the project’s life safety equipment. 

The inspection tag affixed to the fire protection equipment is actually the means to identify that the required testing has taken place on a specific date and should indicate when the next inspection is due.  It doesn’t however provide the relevant details of the tests performed and, in some instances, falls short of even this.  Without the properly completed report, which will provide those detailed inspection results, the tag serves as nothing more than an expedience to witness the annual (or semi-annual) service being performed.  In fact, many building managers unknowingly wind up supporting the poor practices we’ve highlighted here when they decide to deal with a less-than-ethical fire service company that provides tags and incomplete (or improper) paperwork.  Bogus testing of fire protection equipment is quite often extremely difficult for the uninitiated to discern but there are some rather obvious things which are actually easy to check on if you know what to look for.

A case in point is the inspection of fire hoses.  The requirement to test a fire hose/stand-pipe assembly is articulated in NFPA 25 - “Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems”.  A fire hose must be inspected for cuts, abrasions, and other signs of wear or distress along it’s length.  The only way to accomplish this is to remove the entire hose from it’s cabinet “rack” for examination.  It must then be re-racked following the mandated inspection and, if the hose rack employs pins, it should be rehung along a different section of the hose from where it was originally to avoid damaging the fabric from prolonged exposure to the same fold/pin.  Depending on the hose length, this process could take anywhere between twenty to thirty minutes.  I’ve seen reports/work orders which bear witness to the fact that hose assemblies were tagged in less than ten minutes.  How do I know this?  Let’s “do the math” for a typical 12 story building that employs a fire alarm system, extinguishers inside the hose cabinets, sprinkler systems, and emergency lighting.  With twelve seventy-five foot hose stations, you’ve pretty well got a day’s work for one technician to remove the hose, inspect and re-rack it (this includes inspection of the hose valves, nozzles, and rack assemblies).  If two men are involved in the testing of all the systems I’ve mentioned, and they’re only on premises for eight hours (four of which are spent testing suite and common area fire alarm devices), you can pretty well be guaranteed the required testing of the fire hoses (let alone the rest of the equipment) isn’t being performed properly.  If what you’re paying for (as a property manager/owner) are simply “tags” to satisfy the requirements of the Fire Code, you have, however, got your money’s worth.

But is saving money worth the risk (to your tenants and the public) from an improper inspection?

Let’s examine your building’s last annual fire alarm inspection report.  If, at the bottom of the first page, the technician’s RFPT number (or stamp) has been appended to his signature, you should compare the report you have with the one he’s supposed to be using.  The annual test should have been performed to a Canadian Standard that’s often referred to as a 536 Inspection (short for CAN/ULC-S536).  There’s only one really official version of the Standard in use today and that happens to be mandated in Division B Part 6 of the same BC Fire Code I referenced above, CAN/ULC-S536-04.  A custom version of the report form has been made available to all ASTTBC Registered Fire Protection Technicians on their website and it’s available HERE.  A second, more detailed (and equally acceptable) version can be found on our FORMS page.

If the report you’re holding in your hand doesn’t look like either of the above referenced versions, then you have a problem (actually I should say that your equipment service provider really has the problem).  Technically, the inspection report you’ve paid for (no doubt you have several versions of it going back a number of years), DOES NOT COMPLY with the Standard.  It is therefore INVALID (not even worth the paper it’s printed on).  If (in the Individual Device Testing sheet) the installed correctly column is missing (or if there is NO Individual Device testing sheet but just a summary sheet listing the number of units of each kind tested), then the form DOES NOT COMPLY with the Standard.  But this is only the first of many clues (and probably the most obvious manifestation) of the outright FRAUD that has been perpetrated on building owners, Stratas, property managers, and jurisdictional authorities alike (and not just in British Columbia).
 

My God, Frank.  How can it get any worse?  Well, the progression from faulty documentation to incomplete (or bogus) testing is easier than one might imagine, and far simpler to cover up than the example of the fire hose inspection I’ve provided above.  To prove (or vet) a fire alarm annual test unfortunately, requires actual knowledge of the requirements of the Inspection Standard (some of which I’ve started to review HERE, and many failures of which I’ve documented HERE).  It helps if you also have a copy of the Standard handy so you can knowledgeably question the technician as to what he’s doing.

Let’s say, for instance, the technician is carrying around something that looks like a torch on a long stick and you notice the heat detectors he’s testing are blackened and scorched.  You can pretty well rest assured that he’s not testing them to the Standard.  Open flame butane torches (some have even taken to using the refillable barbecue lighters) are specifically forbidden in
Sentence 5.7.3.1 of the Standard:

“Each heat detector shall be tested to confirm operability.  (Refer to Appendix G, Testing of Heat Detectors.)
 NOTE:  An open flame shall not be used for testing the operation of heat detectors.” (Underlined for emphasis.)

If your technician is actually using our version of the report form he actually has to check off the part on page six where it states “Heat detectors tested to ULC CAN4-S536-04 5.7.3”.   For him to check this off when he’s using the very item which he’s been forbidden now becomes a very serious matter involving the violation of ASTTBC’s Code of Ethics, and this is where things get even more interesting (or worse, depending on where you sit). 

Whenever I raise the subject of conventional circuit end-of-line testing, I’m often presented with a “blank expression” followed by the question:  “We don’t have to do that, do we?”  Well, Virginia, “yes, there is a Santa Claus”, and YES, technicians performing annual testing of fire alarm systems MUST PERFORM the following tests on all conventional end-of-line devices in accordance with the Standard:

“5.7.11.1 Each input circuit end-of-line device shall be tested for open circuit fault, short circuit fault, and ground fault conditions.  The results shall be recorded in the Inspection Report.”

And

“5.7.11.2 Each output circuit end-of-line device shall be tested for open circuit fault, short circuit fault, and ground fault conditions.  The results shall be recorded in the Inspection Report.”

For anyone (or any company) to approach a building owner and offer that they’ll perform the requisite testing at a bargain basement price has been counting on a community of compliant technicians some of whom have been influenced (perhaps even coerced) to do testing in a manner which that employer has decided would best serve HIS bottom line.  That testing (of course) is always sold to you as being absolutely correct, much like the commercial I hear on the radio where the announcer boldly states “if you don’t have our (sic) voice activated alarm system then you’re wasting your money”.  Every Registered Fire Protection Technician in British Columbia that actively participates in an employer modified testing program which sanctions (or promotes) deviations from the accepted/required Standards is GUILTY of unethical conduct, malfeasance, and yes – even FRAUD. 

Strong words, perhaps.  I only have to reference ASTTBC’s Practice Guideline to back them up (relevant phrases are underlined).

Section 8 is headed Responsibility:

“It is the Building Owner’s responsibility to carry out the provisions of the Code (Note- Code is defined in Section 5 as ‘the Fire Services Act, Provincial or Municipal Fire Code’), which includes required inspections, testing and maintenance of fire protection systems. The FPT contracted by the Owner to provide this service shall ensure that all fire protection equipment and systems are inspected, tested, and maintained in accordance with applicable Codes.  In addition, the FPT shall ensure that the Owner is made aware of all deficiencies on equipment or systems.  The FPT shall advise the owner of any equipment or systems that have not been tested, inspected or maintained as required by the Codes.  If the FPT works for a company, it is then his responsibility to forward the report and any deficiencies to his/her supervisor for appropriate action.  It is the Owner’s responsibility to initiate repairs, additional testing or maintenance to the fire protection systems or equipment as required by the Codes.”

ASTTBC’s biggest promise to the communities which have adopted the Fire Protection Program has revolved around a commitment to levelling the playing field by ensuring that the technicians registered under their auspices are provided with technical oversight of their practice and would meet the requirements of fitness and merit stated in Appendix “A” of the Testing Standard:

“Any person who performs the annual test and inspection of a fire alarm system should be knowledgeable about this Standard and have received suitable formal training or sufficient experience acceptable to the authority having jurisdiction.”

The continued success of the program hinges upon a renewed commitment to that promise and the enforcement of a policy which ensures professional accountability through regular technician audits, field reviews, and ongoing education. 

For those fire service companies with a less-than-perfect record I think it behooves you to revisit your current business model.   And for those technicians that have so far acceded to the decidedly questionable practices your employer may be advocating, you can either start making the changes necessary now, or you will reap what you have sown.

As always, I welcome comments regarding any of my Editorials or articles.  Please feel free to contact me!