AGREEMENT REACHED WITH THE ELECTRICAL SAFETY AUTHORITY IN ONTARIO THAT AN “ELECTRICAL PERMIT” IS NOT REQUIRED FOR THE INSPECTION OF FIRE ALARM SYSTEMS
About 2 years ago, one of the fire alarm companies servicing fire alarm systems in Ontario was charged by the Electrical Safety Authority for carrying out emergency service and maintenance work on a fire alarm system without taking out an Electrical Permit. The service work included the replacement of circuit boards in a fire alarm panel. The Electrical Safety Authority believed that they had both the jurisdiction and the responsibility under Rule 2-004(1) of the Ontario Electrical Code to perform an inspection on this work as well as at any time a wire was touched when the work is completed.
It was the CFAA’s opinion, that service and maintenance of fire alarm systems, including the replacement of modules, alarm signalling devices and initiating devices could be carried out by fire alarm service technicians without the need for a permit or inspection by the Electrical Safety Authority. This is in recognition of the operating voltage of the equipment, the unique supervision of the fire alarm system circuits, and the fact that the technicians responsible to carry out the work are trained and qualified under the Ontario Fire Code .
The charge went to trial and the service company prevailed solely on the basis of a technicality, which in no way resolved the heart of the issue; the need to take out Electrical Permits for fire alarm system service.
The CFAA position has always been that all of the requirements of service and maintenance as described in ULC S 536 Inspection and Testing of Fire Alarm Systems can be carried out by registered fire alarm technicians under the Ontario Fire Code. Extension of circuits to accommodate additional devices, or any work involving the addition of field wiring is subject to the Electrical Code, requiring that an Electrical Permit be taken out by a licensed electrician, resulting in the appropriate inspection by the Electrical Safety Authority upon completion.
The CFAA arranged a meeting between the Electrical Safety Authority, the Ontario Fire Marshal’s Office and the CFAA. The CFAA presented a brief and a visual presentation based upon some detailed research of the issues and demonstrated how the requirement for a permit does not alter the electrical safety, while imposing a very significant burden of cost and administration on the fire alarm industry and all building premises. As a result of the discussions following the presentation, an agreement in principal on a resolution to the issues was reached through the effort and cooperation of all parties.
The following is a copy of a document prepared by Mr. Ted Olechna, P. Eng., of the Electrical Safety Authority, outlining the information contained in a bulletin issued to all inspectors. This Bulletin 2-15-0, clarifies how the inspection and testing of fire alarm systems by authorized technicians is to be interpreted.
Please note the need for the Owner to retain copies for all work performed and for the records to be made available to the Electrical Safety Authority inspector if so requested.
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Inspection Requirements for Fire Alarm Systems
Rule 2-004 (1) of the Ontario Electrical Safety Code states that a contractor shall file with the Electrical Safety Authority an application for inspection for any work on an electrical installation within 48 hours. There were concerns raised that Electrical Safety Authority would require an application for inspection for the replacement of devices associated with a fire alarm system or for the testing of a fire alarm system.
For example, during the testing of a fire alarm system, one test requires the removal of an end of line resistor to do the test. Strictly speaking this involves the breaking and remaking of a connection. Similarly, during the testing of the fire alarm system it may be discovered that a smoke detector or other devices needs to be replaced. Again, strictly speaking, this would involve the breaking and remaking of a connection.
Regular inspection and testing is required to be performed by the Ontario Fire Code (OFC) on existing fire alarm systems. Persons performing this work are required to be recognized in accordance with Article 1.1.5.3 (1) of the Ontario Fire Code. Service and maintenance requirements for fire alarms systems are covered by the regulations of the Ontario Fire Code.
Bulletin 2-15-0 was developed in conjunction with the Ontario Fire Marshall (OFM) office; the Canadian Fire Alarm Association and the Electrical Contractors Association of Ontario to identify the inspection requirements associated with the testing and maintenance of existing fire alarm systems.
The bulletin gives the following Direction
An application for inspection under rule 2-004 is not required for the inspection and testing of fire alarm systems for conformance to CAN/ULC-S536, "Inspection and Testing of Fire Alarm Systems", provided that accurate record keeping is made available to the Electrical Safety Authority (ESA) upon request. Examples of the type of work that do not require an application for inspection are:
* Control unit components, transponder component and/or field device component replacement;
* Like for like active field device and supporting field device replacement;
* Removal and replacement of devices for testing, and maintenance purposes.
An application for inspection is required under 2-004 when repair, replacement and alterations of fire alarm system components require compliance with CAN/ULC-S524, "Installation of Fire Alarm Systems". Examples of this are:
* Extension of the existing fire alarm system;
* Replacement of Control unit and or transponder;
* Relocation of field devices, control units and/or transponders;
* Replacement of fire alarm system wiring.
Rationale
The inspection and testing of fire alarm systems is required to be in accordance with Article 6.3.2.2 of the Ontario Fire Code, which requires conformance with CAN/ULC-S536, "Inspection and Testing of Fire Alarm Systems" This means that all fire alarm inspection and testing excluding alterations or addition of components fall under this category. ESA would rely on the record keeping that is required under the Fire Code and associated standards as the application for inspection, as permitted by Subrule 2-004 (5). These records would be available to the Electrical Safety Authority upon request.
(Note: it is the Owners responsibility for record keeping..... 2-004 (5) ...states that inspections as required by the Inspection department may be made at such time and in such manner as the inspection department determines. Rule 2-003 states that it is the owner's responsibility to maintain a record of electrical installations. The Service Provider will provide S536 documents to the Owner.)
Persons who repair, replace or alter components of a fire alarm system are required to conduct this work in accordance with Article 6.3.1.8. in conformance with CAN/ULC-S524, "Installation of Fire Alarm Systems"., and requires an Application for inspection (Rule 2-004 (1) of the Ontario Electrical Safety Code)
Bulletin 2-15-0 (Inspection Requirements for Fire Alarm Systems), was issued in May 2003, details the inspection requirements for these systems.
For further information and how to acquire the complete bulletin, as well as others, please visit our website at www.esa-safe.com .
Ted Olechna, P.Eng
Provincial Code Engineer
Electrical Safety Authority