Individual 64176's submission
This clause is meant to outline the general principle of a single stage fire alarm system. Remove the term "shall be".
Substitute "shall be" with "is". Add "fire" to, an emergency exists. A single-stage system is designed so that, when activated, the alarm signal is immediately transmitted throughout the building to warn the occupants that a fire emergency exists.
This verbiage is in line with the first part of the sentence, A single-stage fire alarm system is ... Adding "fire emergency" is inline with the general definitions in the ULC fire alarm standards.
The first sentence does not align with the ULC fire alarm standards.
In a two-stage alarm system, a distinct alert signal advises designed persons of a emergency.
Expand on the first sentence to align with the fire alarm standard and provide additional context that not all people in the building are notified of the alert signal.
The 3rd sentence describes the second stage, but is not accurate.
The second notification in the two-stage alarm system will transmit an audible signal to a zone, zones or throughout a building to advise occupants that a fire emergency exists.
This clarifies that the fire alarm system does not "advise occupants on how to proceed." The second stage signal is to notify occupants that a fire emergency exists and that they need to implement the procedures noted in the fire safety plan.
"Both single stage and two stage systems cause the fire alarm panel to send signals to the fire department or monitoring station (fire alarm receiving centre or 9-1-1 Centre)." This is not correct. I'm not sure what the intent of this statement was for.
Not all fire alarm systems are designed to transmit a signal to the fire department or monitoring station (fire alarm receiving centre or 9-1-1 Centre).
Not all fire alarm systems are required to transmit a signal to the fire department or monitoring station (fire alarm receiving centre or 9-1-1 Centre). This is a common misconception. If there was a specific intent of the original sentence, maybe that can be explored and additional verbiage can be added.
Alarm signals to evacuate occupants do not sound. Notification is via a voice announcement. I don't understand the intent of either sentence. Neither are true.
Delete both sentences.
Not all buildings are provided with a voice communication system. Typically only high buildings, as required in the NBC, or provincial codes.
Technical requirements for fire alarm systems are provided in the NFC.
Technical requirements for fire alarm systems are provided in the NBC.
The National Building Code of Canada and provincial building codes provide the technical requirements for the installation of fire alarm systems. CAN/ULC-S524 provides the technical requirements for the installation of fire alarm systems.
Visible signal system
Unknown
Not all fire alarm systems are provided with visible signaling devices.
Visible signal system
Unknown intent.
Further explanation of how a visible signalling system will be installed is required. What device/s will initiate the visible signals? What are they connected to? How does this system operate?
Add an Annex
Annex F Emergency Communication
Clauses 22.5.1 through 22.5.5.4 appear to be related to emergency communication rather than Occupant Evacuation Elevators.
Firefighter elevators can be used to evacuate an occupant.
Firefighter elevators can be used to evacuate occupants.
Firefighters elevators can be used to evacuate more than one occupant if required.
Some building codes require firefighter elevators in high-rise buildings.
The NBC and provincial building codes require firefighters elevators in high-rise buildings.
The word "some" indicates that not all high-rise buildings require a firefighters elevator. The Canadian buildings require firefighter elevators in all high-rise buildings, not just some.
Remove question, "Do you require assistance in an emergency?"
Remove the question from both employee and visitor PEEP questionnaire.
Unless every employee is completing the questionnaire, the question is redundant. They are completing the form because they require assistance. The subsequent questions establish the type of assistance required.
Add an additional question before, "Do you require assistance going to the area of refuge?"
Add a new question. "Do you know where the areas of refuge are located in the building, and which one is nearest to your work area?"
There is no question confirming that the employee has been made aware of the location of the area of refuge. The same can be added to the visitor PEEP.
Add "floor areas" to one of the questions.
Will you be going to different/other floor areas or buildings?
The employee may not only go to other buildings, but may also go to other floors, or floor areas in the same building. The details may be important for them, and also responding emergency services.
Add a confirmation to some of the questions.
Some of the questions ask the employee/visitor if they know where something is located. The question is YES/NO. Add a confirmation question if the person indicates NO.
It is important to follow up with the individual to ensure that if they answered NO to a specific question, that they then are educated and can answer YES to the follow up confirmation. It is important to close the loop.
The form asks if they have a buddy, YES/NO.
Add some indication of who the buddy is, and who the back up buddy is.
It's important to document that the buddy has been established and who the buddy/back up are. There should also be some confirmation from the buddy that they are aware of their voluntary obligation.
There is no indication that there is a summary page for emergency services to understand who may need assistance, where they are located, how to contact, or what type of assistance may be required.
Add a summary example that can be included in the FSP for emergency services. For example a table with Name, location, contact, type of assistance required, # of personnel required to assist.
Emergency services do not have time to flip through pages to determine who may be in danger when responding. Firefighters can prioritize assisting evacuation if required if they know where the individuals are located.
Add information to the visitor sentence.
" ... is for visitors (Visitor PEEP) and employees that may be in the building on an intermittent basis."
Adding additional context after visitor to include employees reiterates that the Visitor PEEP is not just for visitors, but also includes employees that may not work in the building on a full time basis.
There is no question that asks about the normal working hours, or off hours.
Include a question asking if the employee works during hours the building is normally occupied, or if they work during off hours.
The employee may have a buddy during normal work hours. But they may also work after hours when a buddy is not available. The employee should understand and have knowledge of the procedures for evacuating in both situations.
Change the word process. Communication is vital during an emergency egress process.
Maybe change to "situation".
Emergency evacuation in this context is more of an event or situation rather than a process.
... component of the person’s PEEP
... component of a PEEP.
A PEEP is more general.
There are no requirements for the inspection, testing and maintenance of evacuation devices.
Add requirements for following manufacturer's instructions for the ongoing inspection, testing and maintenance of the various devices.
The manufacturer's may have specific information related to the inspection, testing and maintenance of the devices to ensure they are operational. In addition, as the devices will be identified, not locked and accessible, they may be moved or stolen. It's important to ensure they are replaced, or relocated back to their intended location.
Clause r) states, use official pictograms.
Unknown
There are no official pictograms for fire safety plans in Canada. The pictograms provided in sample fire safety plans from province-to-province and from various municipal fire departments differ. There is no "official" pictograms.
Clause k)
add, "and type". Identify the location and type of the evacuation device.
This is to clearly indicate which devices are at specific locations.
Clause e) states "manual pull stations".
Change to manual stations.
Manual pull station is the old term. Manual station is the new term referenced in the NBC, and ULC fire alarm standards.
Clause g)
Unknkown.
It is not clear what "fire alarms" is referring to. A fire alarm system is installed throughout a building. Manual stations, the manual device used to activate the fire alarm system is identified in clause e). If this clause is referring to the locations of smoke detectors, or heat detectors, there is no added benefit to these being on an emergency evacuation map. They would add clutter to the map.
Change the word "Map".
Change map to floor plan. In some instances in this document site plan may be more applicable. Such as when referring to identifying the muster point.
The term floor plan is more appropriate for the context.
Clause f)
Identify the location(s) of the accessible exits.
For consistency.
The last sentence refers to signs.
Unknown.
What signs are being referenced? Signs indicating how to use the OEE? If so, that should be specified. Maybe another sentence at the end. The sign shall provide information on how to operate the OEE.
Clause c) refers to fire safety evacuation plan. This is the first use of this wording.
Unknown.
If the intent is to post the operating procedures for the OEE on all posted procedures throughout the building, this will additional information that is not relevant to most people, and is not appropriately located. The last sentence in this clause indicates that signage should be posted adjacent the OEE. This is the appropriate location. Also, the operational procedures should be inside the elevator.
Clause b states that major renovation is defined in the NBC.
Delete the reference.
Work is ongoing in relation to establishing renovations and major renovations in the NBC. However, major renovation is not currently referenced in the 2020 NBC.
Sprinklering of a building shall not be considered the only acceptable provision of fire safety and does not negate the need for compliance with this Standard.
Unknown.
Consider rewording the sentence to clarify the intent. Consider, Installation of a fire sprinkler system in a building does not negate the need for compliance with this Standard. While fire sprinklers provide a degree of fire safety, this standard is intended to provide life safety for people with disabilities that is commensurate with that provided to other occupants of the building.
Definition of Buddy
A volunteer, such as a friend, colleague, family member or staff member ...
Volunteer and friend should be separate to denote that volunteer applies to the position. In addition, add that a family member can be a buddy.
There is no definition of floor warden, or emergency warden, but these terms are referenced in the standard.
Add definitions, but maybe state that other terminology can be used for the various roles.
These terms are used but not defined.
Add a definition, "Supervisory Staff".
Supervisory staff means those occupants of a building who have some delegated responsibility for the fire safety of other occupants under the fire safety plan.
This term is defined in the NFC and provincial fire codes. The term can used in this standard rather than warden.
Add a definition for shelter-in-place.
Add definition
There are various references to shelter-in-place, but there is no definition. In addition, there are no procedures identified for shelter-in-place, or how it differs from an area of refuge. While some people may understand, others may not.
Modify the last sentence of definition of "means of egress"
Means of egress includes exits, access to exits, path to a muster point and a muster point.
The path to the muster point should also be included.
Major renovation
Provide more clarification as to what is considered a major renovation.
The definition is too vague, and subject to interpretation.
PEEP. ... information on how to evacuate in the event ...
add reference to shelter-in-place and area of refuge.
The PEEP should outline the conditions under which an individual may need to shelter-in-place, or proceed to area of refuge if they cannot evacuate the building. These options should be identified in the definition.
Add other abbreviations from the standard.
add ULC CSA ASME ITU
These abbreviations are used in the standard but not noted in this clause.
The first sentence states that all buildings have a fire safety plan. This is not true.
... require that certain buildings have a fire safety plan ...
Not all buildings require a fire safety plan.
Clauses e) and n)
Move hazardous materials from clause n). It may be appropriate to add it to clause e).
A hazardous material response is different than a response to an explosion. A haz mat incident is more inline with clause e) toxic fumes/gas leaks.
The term floor warden.
supervisory staff rather than warden.
Terminology for supervisory staff (as defined in the NFC) may differ. Some may use wardens, others may use other terms. Supervisory staff is generic.
This section does not describe the types of emergencies that require horizontal evacuation.
Change the title to delete "Types of".
The clause outlines a horizontal evacuation, not the types of emergencies that may require a horizontal evacuation.
"Outside ground level" and "unaffected wings of multi-building complexes".
... to proceed to designated exits that lead through a firewall to an unaffected area of the building. Sometimes the door through the firewall is considered to be entering a separate building.
The terms used were unclear and not necessarily specific to horizontal evacuation. Horizontal evacuation does not require taking individuals to the exterior of the building.
add but not limited to
The fire safety plan shall include, but not limited to, information on ...
This clause does not outline all of the requirements for fire safety plans specified in the NFC and provincial fire codes.
j) requested
request
Grammar
add updating/review requirements.
The fire safety plan and PEEPs shall be reviewed at intervals not greater than 12 months to ensure that they take account of changes in the use and other characteristics of the building and occupants.
It is important to review the FSP and PEEPs at regular intervals, and when there are changes to the building, or changes to the occupants and their abilities.
Change "provided", ... a copy of that plan is required to be provided to the arriving emergency services – typically through a fire safety plan box
... a copy of that plan is required to be available to the arriving ...
Available is a more accurate term than provided.
The fire safety plan is intended to be used during all emergency situations.
The fire safety plan is intended to be used by fire department operations to provide insight into the characteristics of the building, hazards and occupants. The FSP can be used to assist building management, occupants and fire department operations in evacuating the building.
The fire safety plan can be used in fire emergencies and emergencies requiring evacuation. But it is an overstatement to say that FSP is intended to be used during all emergencies.
change emergency warden
The role of Supervisory Staff
Change emergency wardens to supervisory staff throughout. This aligns with the NFC terminology.
Add clause f)
f) Inform persons with a PEEP and their buddy of any changes that may effect the PEEP.
This places the responsibility on the supervisory staff to advise of any changes that may effect a PEEP.
First responders
Unknown
Various terms have been used. First responders, emergency personnel, emergency services. Consider a review of the document and consolidate terms where appropriate.
Clause e) & f)
Unknown.
Should this Standard dictate the operational priorities of first responders? The clauses state that the fire department will assist them to evacuate. Evacuation may not be warranted at the time, however there are no options provided. Consider revising.
Review and submission to the fire department.
Unknown
Many provinces require that fire safety plans be submitted to the fire department for review. Note that the FSP is submitted to the department, but it's not under the role of first responder. Is it intended that the fire department review the PEEPs as well. If so, this should be included in the Standard. Possibly add another clause for the submission and review of PEEPs
Capitalize or don't capitalize the first word in each clause.
Capitalize or don't capitalize the first word in each clause.
There are inconsistencies throughout the document.
add clause h)
h) Inform Supervisory Staff of any conditions may effect their PEEP, either due to changes in the site, building or their abilities.
This puts the responsibility on the individual to notify the supervisory staff of any changes.
add i)
i) Inform Supervisory Staff and person requiring assistance of any conditions may effect the PEEP, either due to changes in the site, building or if they can no longer fulfill their responsibilities as a buddy.
This places the responsibility of notifying the appropriate people of any changes.
h) "fire drill"
Unknown
The term fire drill is used in the NFC. Several terms are used in the document including emergency drill. Considering reviewing the document and using a single term.
The NFC and the Provincial Fire Codes that require that all buildings have a fire safety plan ...
The NFC and the Provincial Fire Codes require certain buildings to have a fire safety plan. Fire safety plans must include information on emergency egress for all occupants, including people with disabilities.
There was a redundant "that" which should be deleted. Not all buildings require a fire safety plan.
2-3 days a week.
Delete
Consider not providing a specific number of days. Consider using a term such as intermittently.
Visitor PEEP form
Visitor/Short Term PEEP Form
Provide the additional Short Term to be specific. Some people don't read the text that accompanies the form.
Registry list
include a template document of a registry list.
Another comment was provided in the Annex information regarding the registry list and providing a template document.
Clause c) notes an emergency response plan
Unknown.
This is the first time that the term emergency response plan is noted. Should the term be defined? Should emergency response plan be identified elsewhere in the document?
clause e) emergency floor warden
Supervisory staff
Consider a review of the document for the various terms. Maybe consolidate to supervisory staff so that the terminology is in line with the NFC.
Who is developing the PEEP.
Unknown.
11.3.2. notes that the manager and person with the disability will prepare the PEEP. Is the manager or FSP provider working with the person?
clause d) personalized
delete the term personalized
It's redundant.
clause f)
add, ... annually, or when changes occur ...
changes may occur and it's important to capture the changes in the FSP and PEEP as soon as possible.
clause g)
add, ... during emergency drills, or more frequently as needed.
It may be important to practice more often.
clause h)
Test all equipment and procedures identified in the PEEP.
Or should be changed to and to identify that both equipment and procedures should be tested, not one or the other.
clause g)
change fire alarms to manual stations
By identifying the manual station locations the individual knows where to manually activate the fire alarm system.
clause s)
add that the diagram should identify the manual station locations.
It is important that occupants know where the manual stations are located so that they can manually activate the fire alarm system.
Reword the paragraph starting with "Given that ..."
Given the importance of the emergency egress drills all individuals shall participate in emergency egress drills. This ensures that all occupants of a building know the necessary procedures to safely exit the building, or to safely access an area of refuge.
Reworded for ease of reading.
fire drill frequency
Fire drills shall be practised as required by the NFC or Provincial Fire Code.
The NFC and Provincial Fire Codes require more fire drills at least annually but more often for specific buildings.
Add a sentence after, greatest degree possible.
In some circumstances practising the drill may be completed at a different time or more often.
Some individuals may need to practise a drill at a different time or more often. This should be stated in the standard.
clause e)
add buddy
Buddy should be added as they are assisting individuals in evacuation.
clause g)
delete call boxes
Call boxes is not a term used in Canada.
Add another clause, i)
i) all people, including those working off hours, or after normal working hours participate in emergency egress drills.
It is important to ensure that all occupants know, understand and participate in drills.
c) states "remaining", while the others relate to evacuating.
c) proceed to the area of refuge and remain until instructed further.
There is no indication to proceed to the area of refuge.
Add or drill, after emergency situation
After an emergency situation or drill has taken place ...
It's important to capture feedback after drills as well as after emergency situations. Add similar statement throughout section.
Clause d) there is no follow up if communication was not effective.
... was effective and inclusive, if not, investigate further and provide recommendations for improvement.
The original statement is only confirming that the communication was effective. If the communication was not effective, there should be follow up.
Change, "personal emergency egress plan" "emergency egress plan".
PEEP, or personal emergency evacuation plan.
Consistency
Add a change in the buddies abilities.
add another clause, "changes in a buddies abilities to assist as noted in the PEEP;"
The abilities of a buddy may change over time. If they are no longer able to assist as noted in the PEEP, the PEEP should change.
"an acceptable form of refuge."
consider, shall not be considered an acceptable form of refuge in lieu of an area of refuge."
The term "area of refuge" is used. But then the term refuge is used. Consider revising to use the term area of refuge rather than refuge.
clause b) notes floor area, should this change to building
within a fire compartment that is separated from the remainder of the building by a fire separation...
The area of refuge should be separated from the remainder of the building by the required fire separation rating. The fire resistance rating of the fire separation should extend not only to the walls, but also the floor and ceiling above.
Clause c)
Provide clarification of the 200 lux.
Is this an average level? where is the measurement taken? The NBC specifies the average level of illumination at floor or tread level, etc with a minimum level of illumination.
clause d)
Provide a maximum distance. Does any evacuation device satisfy the requirement?
Vague language results in future issues. Clarifying a distance will help with enforcement, and provide guidance in complying. Consider specifying that the evacuation device at an area of refuge should be the one noted in a persons PEEP for that area. Considering providing language for what devices, if any, are required in areas where there are no PEEPs with specified devices.
Clause c)
add, power door operators installed on closures in fire separations shall be rated for use on fire doors.
All hardware used on fire doors must be rated, however this is often overlooked.
Clause e) & f)
Unknown
Clarify what specifically needs to be connected to backup power. Clarify what dimensions need to be free from protrusions. Is it from floor level to ceiling, etc?
Clause f)
Unknown
Clause f notes that the ventilation system is separate. But there are no design parameters, or additional information. Should there be a note somewhere in the standard indicating that the ventilation system must be designed in conformance with the NBC, or other design parameters?
Clause b)
Unknown
Is it worthwhile specifying that the max height is to the top of the device, (if that is the intention)? Some standards state from the top, while others such may reference the mid point of a device.
Clause f) references an "emergency response system".
Unknown
What is an emergency response system? There is no definition, nor is it a common term used in the building code or fire code. Provide clarification.
Clause h) indicates that the communication system must be linked to security or emergency call centre.
Unknown.
Provide clarification as to the intent of this clause. A security system may not have an immediate response from anyone. Security systems and fire alarm systems have different installation standards; fire alarm is much more stringent. Are there inspection, testing and maintenance requirements for the communication system?
12.2 states Exit Doors
Either delete "Exit", or add separate clauses 12.2.1 Egress Doors 12.2.2. Exit Doors
The requirements pertain to both exit and egress doors, not just exit doors.
Delete the bullet point a)
one sentence Doors forming part of an egress route shall be provided with a vision panel or side light with its bottom edge not higher than 900 mm.
There is only one bullet point, so it is a single sentence.
Add a bullet point to the horizontal exits.
) provided with emergency lighting (add whatever parameters, such as the 200 lux noted elsewhere).
There should be emergency lighting at the horizontal exit.
Last sentence mentions locks.
Unknown.
What is the intent? Can a door be equipped with a lock, or not have a lock installed? May also encounter electromagnetic locking devices. Provide further clarification of intent.
Clarify the intent of the first clause a)
to and from all areas within a floor area of a building
Is the intent that all areas of a floor area within a building need to be accessible? The current wording states that only access to the floor is required. I've had discussions with architects in which they want to provide access to the floor only, and not throughout a floor area. Provide clarification.
200 Lux
Unknown
Similar note provided previously. Clarify the 200 lux, similar to the NBC.
Clause a)
Unknown
Specifying two maximum distances is confusing. To me, you can only have one maximum distance. The noted distances may exceed the travel distances in the NBC. Provide clarification as to the intent.
NFPA 72
Delete
Why reference NFPA 72? There has been no mention of NFPA 72 in the standard.