“In Suite” Accessibility Challenges Faced During COVID-19

A building owner is responsible for ensuring that the building and facilities comply with the provisions of the Fire Code.  Part of that responsibility includes performing the checks, tests, and inspections as required by the Fire Code are completed on schedule and that records are retained and maintained

Annual inspections of every device attached to your fire alarm system are required to be tested or inspected.

During these annually scheduled test and inspections, sometimes rooms and certain devices are not accessible - at the “time” of scheduled inspection.

Perhaps an area of the condominium is undergoing a renovation, and the device needing testing cannot be reached, for which the building staff does not have access to.

Another example of an access issue  is during an annual fire alarm test and inspection, the service provider is testing "in suite" devices, they cannot access a certain resident's suite because the building's master key is not working on this particular door, and perhaps the resident "changed the locks" without notifying  or receiving permission from the Corporation.

In both examples, the annual service provider would document that during their scheduled test and inspection of your building's fire alarm system, these devices were "not available" for inspection.

The building owner is still required to ensure that measures are made, to obtain access to these areas so that the devices can be inspected, as required.

That being said, there is a clause in CAN / ULC S536 that allows service providers to document "inaccessible" areas, described in the clause itself as, "All field devices shall be tested on a yearly basis, except that in the event of a device cannot be reasonably be made accessible for safety considerations (for example continuous process operations, energized electrical equipment, radiation, and height), the device and its location shall be recorded and identified as "inaccessible" in the remarks column of the report.

The last test date shall also be recorded in the remarks section...Those field devices identified as being inaccessible  as noted in the remarks column, shall be tested at least once every two years.”

While this clause specifically addresses "access" issues for "safety" reasons and presents great examples, it's important to note that none of the examples relate to a public health emergency that includes a stay-at-home order, with potentially quarantined individuals inside suites.

Currently, in suite devices can and are being inspected safely in residential buildings throughout Ontario.

You may have residents who refuse entry to technicians based on their own perceptions of “safety” in their home combined with the current COVID concerns. 

To include in this, we must also consider those directed to quarantine inside their suite by order of public health, including those residents in the building caring for elderly, susceptible persons at higher risk.

On the other side of the coin, we must consider that if residents do not provide access to “in suite” devices we could have a percentage of fire alarms and basic fire protection devices  such as smoke alarms, designed to protect building residents   not be tested and potentially not function when required.

An industry leading fire protection firm in Toronto has met this challenge head on by ensuring that any resident that denies access to their suite during  an inspection for “safety” reasons, then the technician has  been directed to document this refusal of access and  “stand in the hallway,  minimally, watch/witness/listen for the resident to press the smoke alarm test button to confirm that it works.  The technician can actually hear the horn/speaker from the hallway and confirm that it  functions.  Then, the access issue  regarding this suite is documented and the comments / findings are captured within a usable report for the building owner.  The building owner, then has the basic information in their annual report and the evidence required to follow-up on access issues.

Based on the above, I provide the following considerations for your residential fire safety program;

1) Fire Code compliance is not impacted or revised in Ontario.  There is no special provisions for residential high-rise building compliance.  All aspects of the Fire Code and system test requirements are still required to be completed. Do not delay any life safety system Inspections.

2) Documentation of all tests and inspections must be maintained at the building for a period of 2 years.  Evidence of compliance rests on the building owner and proof of daily, weekly, monthly, annual, etc., tests and inspections must be maintained at the building for inspection by the Fire Services.

3) Fire Protection companies are deemed essential services and are highly trained professionals who utilize industry standards to keep themselves and the residents of  the building safe.

4) Ensure that resident communications are provided well in advance of the inspection, clearly speak to the safety of those inspections, provide education to the residents that it's critically important for the "in suite" devices to be tested and confirmed working in a building every year and that additionally it remains an active code requirement that the condominium corporation is required to follow.

Remember, the “in suite” device inspections also ensure common smoke alarms are present and working. It's not  simply the resident safety in the suite  they are testing the devices for, but it's also for their neighbor's safety.  Communicate to residents the detailed safety precautions taken by you and your service providers to ensure everyone’s safety during the “in suite” inspections.”

5) Engage your fire alarm / sprinkler inspection company to ensure that the annual inspection report they provide clearly identifies any access issues.  Review your annual test and inspection report in detail once received and specifically address access issues.

6)  Your service provider and the Authority Having Jurisdiction (local Fire Services) should be engaged to understand the required next steps for any access issues that are not able to be resolved.

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National Life Safety Group is an industry leading consultancy firm specializing in public and workplace safety, with a focus on best practices in facility fire, life safety and emergency management.

 If you have any questions or would like further information, please call 647-794-5505 or email solutions@nationallifesafetygroup.ca.

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