CFSA Blog
What does it mean to “Implement” the Fire Safety Plan in your high-rise building?
Author: Jason Reid
Fire Prevention Week was first proclaimed by the Governor-General in 1923. Since then, innovative educational and awareness programs have been highlighted during the second week of October, through municipal fire services, private industry and workplaces across the country. The clear objective; to increase awareness - and reduce injuries, fatalities and property loss everywhere.
Navigating the Fire Code can be a daunting task. That’s why, to protect high-rise buildings, we use Fire Safety Plans.
A Fire Safety Plan is more than a code compliance document, it’s fundamentally designed to be a “go to” reference for how the building Owner is planning to prepare for, prevent, mitigate and respond, effectively using the fire safety team’s resources and life safety systems available to them at their unique building.
These detailed documents are required by law for buildings listed in Section 2.8 of the Ontario Fire Code, and similarly required across Canada.
Here in Ontario, with respect to high-rise buildings, the Fire Code also requires that every Fire Safety Plan be reviewed and approved by the Chief Fire Official or the local Fire Department. Upon approval, the building manager, on behalf of the building Owner, is typically assigned with the important task of “Implementing” the plan – typically within 30 days of approval, and having that plan reviewed and updated every 12 months.
According to sentence 2.8.2.1. (1) of the Ontario Fire Code: A Fire Safety Plan shall be prepared, approved, and implemented. It is this “implementation” that we will focus on in this short article, after all – we all have a plan that sits in the little white box at the front of the building, but the implementation is a vital component of having a Fire Safety Plan and code compliance - for very good reasons.
Distributing the Fire Safety Plan to all building Staff with roles and responsibilities.
This important first step ensures that the Manager of the building has informed all of the parties who have roles and responsibilities in that plan – exactly “what” are those roles and responsibilities. In all high-rise fire safety plans, the building Owner, the Manager (representing the Owner), the superintendent or building Operator, building concierge / security staff all have roles.
This distribution of the plan to these individuals should be made in writing and should always be documented by the property manager complete with date and time evidence. In fact, the fire safety plan should be re-implemented with all building staff every 12 months, immediately after completing the annual Fire Safety Plan review an update. Doing so, allows a building Owner to have actual evidence of compliance, and engaging their staff every year.
Training of all Staff with roles and responsibilities
Persons identified as “supervisory staff” in your high-rise fire safety plan are required to be trained on their roles and responsibilities – before being assigned any fire safety responsibilities at the building. This is a Fire Code requirement, and a part of the implementation process – required by all high-rise building owners in Ontario.
After all, high-rise fire safety plans assign roles and responsibilities for internally completed daily, weekly and monthly inspections required of the building Owner. These are typically assigned to Security and operations staff – and without training, how would these staff members be aware of their responsibilities? How would they know what to check, how to check, and what to look for? How does a security guard know how to implement a fire watch at 2:00 AM? They need to be trained on that plan, and their roles to prevent, prepare for, mitigate and respond. Through training, they are afforded to question "why" we do things a certain way, and it allows for a deeper understanding of their roles, leading to a better performance of those roles.
A high-rise fire safety plan in 2023 is a valuable tool to both building staff and arriving fire services, and can be a lengthily document. While most high-rise fire safety plans a re bound and tabulated for rapid reference, it’s simply not enough to send them “some pages” of the plan to read – and expect them to perform.
Staff must be fluent on both how they respond, and how their actions everyday – prevent and mitigate fire. Building staff require training under both the Fire Code, and the Occupational Health and Safety Act for their own safety as well.
Building Owners are required to maintain evidence of building supervisory staff training – as they are required for all training programs delivered in a workplace. Failing to complete or maintain evidence that your staff have been trained, can lead to costly fines, errors and omissions, and occupant distrust in the plan – even lead to higher complaints after the fire alarm. It is recommended that training rosters, certificates, or proof of training, is maintained by every building owner / Manager, to defend your actions and prove your efforts to implement the fire safety plan.
It is likely that the question around “staff performance” will come up in your building – its good to have evidence you have provided all the tools and skill sets required for staff to complete those responsibilities.
Upon completion of the training, most fire safety plans have an “acknowledgement table” for supervisory staff to sign every 12 months to ensure (and document) that they themselves are aware of their roles and responsibilities. Completing this step enhances staff response and provides evidence of compliance for the property manager. Failing to have the plan signed-off on, as required, may also result in a Notice of Violation for not “implementing” the fire safety plan.
Further to the above, ongoing training (and testing) of building supervisory staff is a requirement of the Ontario Fire Code. This is completed through the requirement for High-Rise building fire drills. These are required to be completed every 3 months – just for those with roles and responsibilities in the plan – not the occupants.
If these quarterly drills are effectively completed, typically led by a high-rise fire safety experts or the Manager themselves, it will ensure you as the building Owner have an active program, retraining and testing staff on their roles and responsibilities – every 3 months.
Building Owners, under the assigned role of the building Manager, shall maintain evidence of these quarterly fire drills at the building as part of their fire safety plan implementation requirements.
As a best practice, the quarterly fire drill reports should include what was reviewed, who participated, what was the staff’s knowledge base, areas for improvement and action plan to implement the lessons learned during the drill.
Distribute applicable pages of the Fire Safety Plan to all occupants / tenants within the building.
Also a requirement of the building Owner, this vital step allows the building occupants to understand what they should do in the event of a fire alarm and understand what staff will (and won’t) do during fire alarms and evacuations. This communication allows the general occupants, to understand they too, have unique roles and responsibilities for fire safety in the building, and a big part of those roles, is understanding the life safety systems in the building, and what to do when they go off. What to do when exit is blocked from smoke? How to defend in place? The answers to these questions are found in the building’s approved fire safety plan.
When each team member of your fire safety team, and yes – residents are a part of the fire safety team, understands their roles and others, it creates a greater awareness for all. This transparency and sharing often reduces complaints “after” the fire alarm, made by residents by over 50%, because they are educated as a team and know what to do, and have reality based expectation of building staff. Beyond this, having occupants understand their options for fire safety before the fire – saves lives.
In addition to the above, having occupant’s aware, means additional safety for arriving firefighters and first responders – with less rescues to perform.
Occupant’s roles and responsibilities is a dedicated section of every high-rise fire safety plan, and building Managers can effectively communicate this information to occupants via email using a PDF attachment of the roles and responsibilities, emergency procedures (and more) from the approved fire safety plan. The Fire safety plan must be implemented with the occupants, by distributing the information they need to action their own roles and responsibilities. The only way this can be achieved is through sharing the plan. This should be done every 12 months by the building Owner.
For Commercial High-Rise buildings, the building owner is required to do much more by way of “implementing” a fire safety plan. Employers and tenants operating in the building must implement the fire safety plan in their area of control and building owners are required to ensure training of fire wardens – but let’s save that for the next blog.
Distribute the Fire Safety Plan to Fire Alarm / Sprinkler / Generator Service Providers:
On behalf of the building Owner, your professional building Manager uses the building’s approved fire safety plan to engage their third party service provider. An entire section of a high rise fire safety plan outlines the building Owner’s requirements for both internal and external checks, inspections and tests.
Now that the internal checks and inspections have been assigned to the internal building staff, and they have been explained their roles and responsibilities through training, its time to ensure that the service provider is aware of the third party external requirements at this building.
An entire section of your fire safety plan provides everyone on the fire safety team, full transparency, listing all of the checks, tests and inspections required for the building. This includes monthly fire alarm / sprinkler testing and inspections, smoke control, generator testing and an assortment of monthly, semi monthly, quarterly, biannual, annual tests and inspections. In some high-rise buildings they have two-year, three-year, 10 year and 15-year Fire Code requirements. Failing to implement these and maintain evidence of completion onsite will result in a Notice of Violation.
Implement the roles and responsibilities of the building Owner
Found within your condominium’s approved Fire Safety Plan, is a list of items that the building owner must do, as part of the Fire Safety Plan implementation.
This list is specific to your building’s fire safety plan, and assigned to the building Manager – as a representative of the building Owner. While there are many responsibilities, the following is a very high level of what needs to be implemented at the building by the Manager, on behalf of the Owner;
- Building Staff are aware of the internal daily, weekly and monthly checks and inspection required of them, and these are being completed.
- Staff have been trained on how to perform the daily, weekly, monthly inspections.
- Staff are aware of the preventative measures found within the fire safety plan and have the tools to implement a fire watch or HOTWORK process if ever needed at the building.
- Staff are aware of the official emergency procedures and how to operate the emergency voice communications system, fire alarm system, etc.
- Implement the annual review and update of the fire safety plan, including the responsibility to notify the Authority Having Jurisdiction (AHJ) of any changes that will affect the Plan.
- Maintain a current list of occupants requiring special assistance during an evacuation (PRA) and ensure they too have been engaged and that the PRA requirements of the plan have been implemented.
- Ensure staff is using the fire prevention requirements of the fire safety plan to educate the occupants.
- Ensure a Fire Safety Plan box is maintained with the required content.
- Ensure internal checks and inspections are being completed by building staff.
- Ensure external checks, inspections and tests are being completing by third party service providers.
- Ensure other life safety systems are maintained such as CO Detection systems, Refrigerant detection systems, etc.
- Ensure signage is posted as required throughout the building including stairwells, common areas, exits and entrances.
The above is not an all-inclusive list of what’s required to implement the fire safety plan, and is intended to provide a brief overview only to showcase the importance of implementing the fire safety plan, to achieve fire code compliance, compliance to the applicable requirements under OHSA, and to ensure we are creating fire safe buildings through a team approach.
Jason Reid; Senior Advisor
Fire & Emergency Management
