Facility Management and the Ontario Fire Code

FACILITY MANAGEMENT & THE ONTARIO FIRE CODE Whether your workplace and facility are owned or leased, facility management professionals are the dedicated industry leaders that continue to innovate, refine, and make safe facilities for everyone. Fire Safety Plans in facilities across Ontario, often appoint the Facility Manager, as being tasked, amongst other things, to oversee, control, and implement the fire safety plan. In some facilities, this is a shared task between the landlord or the Building Owner, and the tenant in control of the space, but either way, the role and responsibility of the Facility Manager for Fire Safety – is a major one. The facility management industry has long been recognized for its unique expertise, and tireless efforts to ensure a safe workplace. Our area of focus for this short blog – fire code compliance – the standard foundation of an industry-leading facility-based risk management program. As part of IFMA Ottawa’s Professional Development for its members, I was approached to contribute a brief blog, in advance of an upcoming educational session for IFMA Ottawa members. I thought I’d provide a brief overview of Fire Safety programs in Ontario, which typically involve the Facility Manager. I offer the below quick read in the format of a Q&A. I look forward to seeing many of you at the event and look forward to supporting this important educational session.   DOES MY FACILITY NEED A FIRE SAFETY PLAN IN ORDER TO COMPLY WITH THE ONTARIO FIRE CODE? Fire safety plans are required for almost all buildings in Canada. In Ontario, a Fire Safety Plan is a document required by Section 2.8 of the Fire Code and is needed for the following buildings:
  • required for all buildings and premises containing 4-stories or more,
  • an assembly occupancy,
  • a care occupancy,
  • a care and treatment occupancy,
  • a detention occupancy,
  • a residential occupancy where the occupant load exceeds 10,
  • a retirement home,
  • a business and personal services occupancy where the occupant load exceeds 300,
  • a mercantile occupancy where the occupant load exceeds 300,
  • a high hazard industrial occupancy where the occupant load exceeds 25,
  • a medium hazard industrial occupancy where the occupant load exceeds 100, or
  • a low hazard industrial occupancy where the occupant load exceeds 300.
  WHAT ARE THE OBJECTIVES OF A BUILDING FIRE SAFETY PLAN? Your Fire Safety Plan – is a plan that clearly identifies the Building Owner / Occupier / Employer relationship, and who is responsible for what – when it comes to meeting the requirements of the Ontario Fire Code. The same plan will assign roles and responsibilities to each of the parties to effectively prevent, prepare, mitigate fire, and be able to respond, and recover from Fire alarms and Fire Incidents. The Fire Safety Plan also provides detailed lists of fire code compliance required at your facility, and so much more. In fact, your Fire Safety Plan provides a detailed handout for all employees!   DOES MY FIRE SAFETY PLAN HAVE TO BE APPROVED BY THE LOCAL FIRE SERVICES? Yes. In fact, this is one of the greatest benefits to Building Owners, that once your Fire Safety Plan is developed, it is then submitted to the local fire services for their approval. Once it is approved, the Fire Safety Plan must be “Implemented”, which is also required by the Ontario Fire Code.   DOES MY FACILITY FIRE SAFETY PLAN REQUIRE AN ANNUAL REVIEW AND UPDATE? Yes. Every Fire Safety Plan shall be fully reviewed and updated as changes to the building occurs, but at minimum, every 12 months, to maintain accuracy and compliance with the Ontario Fire Code. The annual review and update ensure that your Fire Safety Plan is always accurate and code compliant. Why? Because your Fire Safety Plan is what you are required to use to train your staff. In fact, when your plan is current to the last 12 months, the preventative maintenance section of the plan provides a complete list of what you as a representative of the Building Owner, or the Facility Manager are responsible for. If the plan is outdated, so too will your preventative maintenance schedules. Annual reviews of Fire Safety Plans are typically completed by third party experts such as www.nationallifesafetygroup.ca.   DOES MY FACILITY FIRE SAFETY PLAN REQUIRE ACCURATE FLOOR PLANS OR DRAWINGS? Yes. The Building Owner, or responsible party controlling the premise, like the facility Manager, is required to maintain accurate and up to date floor plans that must accompany the Fire Safety Plan. This includes:

✓ Site Overview / Aerial Overview

✓ Each floor above grade

✓ Each floor below grade

✓ Roof

The drawings must clearly show all life safety systems, required devices, and emergency shut off/isolation valves. As part of the annual review and update of your fire safety plan, this drawing review is also completed.   IS TRAINING REQUIRED FOR FACILITY MANAGERS IN ONTARIO? All persons having roles and responsibilities within a Fire Safety Plan in Ontario require training – before being given any responsibilities under that plan. This is a requirement of the Ontario Fire Code. Fire Safety Plans, when required by Fire Code, must be developed, approved, and implemented by the responsible parties at each facility in Ontario. Part of this implementation, required by the Ontario Fire Code, is that all “Supervisory” staff, identified within that “approved” fire safety plan, be trained on how to implement the Fire Safety Plan and understand their individual roles and responsibilities under the plan – before being given any responsibilities at the building. The building’s approved Fire Safety Plan is the “approved” training material. This means if you have staff responsible for fire safety in the building or workplace, who have not been trained as yet, this represents an Ontario Fire Code Violation. The Facility Manager (or Building Owner) is required to maintain evidence of this training by way of certificates for their staff and/or a letter proving the training has been completed. In fact, it is a fire code requirement to have proof of this training – readily available onsite.   HOW DOES A FACILITY MANAGER IMPLEMENT THEIR ASSIGNED ROLES AND RESPONSIBILITIES? Navigating the fire code can be a daunting task – that’s why we use Fire Safety Plans. It is these plans, which are easily implemented, and try to answer every question anyone could have on their roles and responsibilities – once all responsible parties have been trained. Upon Fire Services approval of the fire safety plan, the plan must be fully implemented typically within 30 days. While each Fire Safety Plan is unique, and to be followed directly, Facility Managers often have the responsibility to fully understand the Fire Safety Plan, and document that the plan has been implemented by:

✓         Distributing the Fire Safety Plan to all persons required: Owner, Property Manager, Facility Management, Workplace Supervisors, Tenants, Employees, PRA’s and more.

✓         Place an entire copy of the plan, drawings, and Persons Requiring Special Assistance Lists inside the Fire Safety Plan Box for arriving fire services. (I’ll explain more on this requirement at the upcoming training session).

✓         Training of Fire Safety Plan “Supervisory Staff” and maintaining those training records. (This includes at times, fire wardens, workplace supervisors, health and safety reps etc.)

✓         Have those staffs with responsibilities “sign off” on their roles and responsibilities within the fire safety plan “Acknowledgement Table”, every 12 months.

✓         Implement the roles and responsibilities found within your Facility’s “approved” Fire Safety Plan.

✓         Communicating the Emergency Procedures to occupants (tenants, employees, guest, visitors, and employers) in the Facility.

✓         Maintain proof (date stamped evidence) of all the above as required by the Ontario Fire Code.

The above is not an all-inclusive list and is intended to provide a brief overview only. If you are looking to learn more about your Fire Safety needs, to ensure both compliance and a safe building, reach out, connect with us, and visit www.nationallifesafetygroup.ca.   WHAT IF I RECEIVE A NOTICE OF VIOLATION FROM THE FIRE DEPARTMENT? Fire Services in Ontario have robust fire prevention programs and are actively engaged in every community. Fire Services will periodically conduct both targeted and random Fire Prevention Inspections. Violations found within those inspections will likely result in a formal Notice of Violation issued to the responsible parties at your Facility. If you receive a Notice of Violation, respond, and take control of the violation immediately. Document each step with the date and time included for evidence. You will need it. As a responsible party, you typically have 30 days to respond, and the violation should be corrected immediately. In Ontario, “Every person who contravenes any provision of the Fire Code and every director or officer of a corporation who knowingly concurs in such contravention is guilty of an offence and on conviction is liable to a fine of not more than $50,000 (first offence) and $100,000 (subsequent offence) for an individual or $500,000 (first offence) and $1,500,000 (subsequent offence) for a corporation or to imprisonment for a term of not more than one year or both”. Navigating and responding to Notice of Violations is a serious subject. We have documented and responded to thousands of Notices of Violations and would be happy to assist you with yours.   ABOUT THE AUTHOR Jason Reid is the proud father of two amazing girls that keeps him extremely busy, but after that, Jason is a recognized building fire safety & emergency management specialist, known for innovative best practices in the integration of fire, safety & security in protecting critical infrastructure, high-rise buildings, mass venue & high/low risk facilities and vulnerable populations. He can be reached at www.nationallifesafetygroup.ca.
© 2014 IFMA Ottawa Chapter