Last year, the FDNY began enforcing RCNY 404-01 & 404-02, which calls for fire safety and evacuation plans to be combined with emergency action plans to form one submittal. The plan is referred to as a "Comprehensive Fire Safety & Emergency Action Plan."
Building owners of Group B office buildings that are greater than six stories or 75 feet in height or have more than 100 occupants above or below street level or have more than 500 occupants in the entire building are required to prepare a new comprehensive plan for FDNY approval.
The new plan requirements include architectural floor plans that indicate essential elements of a building's emergency response system including the fire command station, egress routes, fire barrier partitions, pull stations, sprinklers and standpipe-hose connections.
A narrative instructing the building's staff and occupants on how to react to various events is a major part of the comprehensive plan requirements. For example, events that would require the full evacuation of a building would be responded to in one way, while a shelter-in-place response may be required for a different type of event.
Office building staff members and tenant personnel are assigned important roles in implementing the response to certain events. In addition to fire safety directors, brigade members, wardens and searchers are assigned specific duties and locations to assist building occupants in the safe movement to in-building relocation areas or outside assembly areas.
Group B office buildings that have been permitted to have an approved central station monitored interior fire alarm system in accordance with the Department of Buildings Technical Policies and Procedure Notice 1/03 in lieu of a mini class E fire alarm system are exempt from these new requirements. Owners of these buildings are, however, required to submit an abbreviated plan referred to as Appendix 3. This plan differs significantly from the full comprehensive plan in that the extensive staffing requirements of the full plan are not required.
In addition to these changes, last year RCNY 404-01 has been modified and incorporated fire safety and evacuation plans to include hotel and motel occupancies. The new requirements for this group include standard procedures and language for the movement of occupants during an emergency and helps in addressing the roles of staff and their roles in different emergencies.
Creating an acceptable fire safety and emergency action plan is only the first step in complying with the new rule. Building owners must employ a fire safety director with a valid certificate of fitness issued by FDNY. This person must receive fire safety/emergency action director training and within one year of the plan approval, pass an on-site examination of the building's component administered by FDNY.
A certified fire safety/emergency action director or deputy with the same qualifications must be on duty at all times during regular business hours. These personnel are responsible for ensuring that all building occupants participate in regular drills, are familiar with the building's egress components and shelter in place locations. They are responsible for the proper training of the building's fire safety and emergency action staff members as well as the effective implementation of the actual plan.
Training and recordkeeping are a significant part of an effective plan and requires ongoing and continual compliance in accordance with Fire Code section 404 which mandates a frequency depending on the occupancy group.
It is no longer acceptable to secure an approved plan and file it in a drawer. As expected, FDNY has ramped up enforcement by conducting inspections of buildings and issuing a notice of violation for non-compliance.
Tailor-made inspectorial routes have been created from a database of previously approved plans to ensure plan compliance, training and recordkeeping requirements have been met.
Previously approved plans for buildings where certified staffing changes have occurred are no longer able to file amendments to their plans. Buildings that have undergone alterations and changed egress or occupancies cannot file amendments. In these cases, new plans must be filed in the new comprehensive format.
While there is an obvious need to comply from a legal and enforcement perspective, there are other benefits to a well prepared and implemented fire safety and emergency action plan.
A building's staff and its occupants that are familiar with the plan, its directions and the emergency components of the building they work in, are more likely to effectively respond to an emergency and reduce the risk to the occupants and damage to the building.
The legal liability of a building's owners may be reduced with a compliant and effective emergency action plan and in some cases the insurance companies may issue discounts for buildings that fulfill the requirements of these new rules.
So, while it is sometimes a tedious and cumbersome process, an approved fire safety and emergency action plan can, if administered properly, reap benefits far greater than its cost.
Paul D'Alessio is senior technical consultant for Total Safety Consulting LLC, New York, N.Y. Tags: