Imagination
Often, to understand what is really going on with the person sending in the question, once the testing of the fire alarm system (Planned Preventative Maintenance or PPM) has been completed, I have to imagine the discussion that person had with the building owner. A few building owners actually do have the following attitude.
Technician: I found that these two pull stations don't work.
Owner: That's OK, they aren't needed and I've had false alarms because of them. I had them disabled.
Technician: Well then, they have to be removed.
Owner: Why? Is there an actual law that specifies they have to be removed?
Technician: But, but, but, . . .
The technician is standing there, with tools for testing in hand, but not a couple of extra code books. Because the technician isn't carrying the extra books, it is really difficult to come up with an immediate legal answer on the spot. Usually, while standing there in the owner's office, the technician doesn't even have the extra time to look up the exact legal requirements.
Unless There's a Law
For nearly 20 years, one of my jobs as a fire alarm technician was inspecting Fire Detection and Alarm Systems (FDAS). During that time, almost every building owner was concerned with life safety. Without having to refer to any actual law, I was able to educate all of the owners, at least anyone concerned with life safety.
During this time, however, there were a very few owners that weren't interested in correcting any issues unless they were in jeopardy of losing their occupancy certification. In other words, unless there was a law requiring compliance, they weren't going to change.
Real Example: In a historic downtown area, there was a beautiful old hotel with a restaurant and ballroom that was having issues. I was there specifically to inspect the fire alarm system; it mostly passed, with a few smoke detectors needing replacement. There were no real issues with the replacement.
However, there were more problems outside the areas I was trained to properly inspect.
The most urgent problems were that one of the exits in the ballroom (having a lit exit sign over one of the doors) was blocked on the other side with permanent shelfing, and in the restaurant, under another another lit exit sign, an exit (you could see the nearby street through the plate glass windows), was blocked with temporary storage in the vestibule.
This was one of the very few times I wrote something like this up. While writing this violation up, the building owner asked me THREE TIMES if I would consider his removing the exit signs to be enough compliance so that I would not put this violation in writing.
Huh?
Each time he asked, I told him I didn't have the authority, and to ask the fire marshal if he was allowed to do that. (I was confident the fire marshal would go ballistic with that kind of request).
Yes, egress control was out of my jurisdiction because I was supposed to be only checking the fire alarm system itself. Also, besides being trained to inspect the fire alarm system, I really was not someone who was properly trained in all other aspects of fire protection. I did know, however, that this was an urgent life safety issue that needed immediate correction.
Legal Requirements
In the original letter, the contractor did know about the life safety aspects of the law, he just didn't know exactly where to find it. Also, the contractor had tried to educate the owner; you could see this attempt, because, after the contractor had left the scene, the contractor was still wanting to find the exact code number of the law.
In other words, if the contractor was required to find the exact law, the owner really didn't want to be educated. The real issue was that the owner wasn't concerned with life safety; the owner was only concerned in keeping the occupancy certification.
Because the contractor could not enforce the law, the only viable option was to use CYA paperwork to start the process to fix the issue: eventually, by letting the fire marshal enforce the law.
Douglas Krantz
