Code Enforcement Without the Code

Code enforcement has become extremely technical and requires code officials to have many skills. These skills include the understanding of codes and standards, communication, interpersonal, time management, and the knowledge of the general intent of codes. Although there is a range of requirements for every type of system, component, design, or building, the basics for the enforcement will remain constant. As code officials develop in their profession, they begin to understand the intent of the adopted code or standard which is based on the principles of life safety.

This article is not intended to replace sound code enforcement. Fire marshals, fire inspectors, plan reviewers, and building owners should study, learn, and understand the adopted fire code. In many cases as fire inspectors begin in the profession, they can follow some basic principles in fire prevention.

When students in a Fire Inspector I course are asked "why is there a need for fire inspections" there are many answers. The first answer is typically life safety. Students will follow up with answers about requirements of the code, fire prevention, education, or even to reduce the number of fires. The answer has expanded over the years and may include firefighter safety or an improved awareness toward fire safety. Looking toward the first answer, the model fire and building codes are dominated by code requirements that relate to "life safety."

Initial Inspection Efforts

The initial concept of a fire prevention bureau is to prevent fire. Inspection efforts can be based on fire prevention (limiting the fire) and proper construction of a building or sound practices once a fire occurs. Fire prevention, in its basic concepts, is to limit fires from starting. This can be accomplished by separating combustible materials from ignition sources or limiting open flame devices. Many of our fire fighters are taught this basic concept when conducting a home fire survey. Clothes, storage, and other materials should not be stored adjacent to a heat producing appliance such as a water heater or furnace. The same theory is present in commercial buildings. Under fire prevention is the ability to limit unsafe activities such as open flames, cooking, industrial process, or even incompatible material use and storage.

As the inspection continues, the inspector should be evaluating the building based on its sustainability during a fire event. Ask yourself "If a fire occurs, will the system (building) limit the spread of fire and will people get out of the building?" Let's look at this as a matter of "life safety." Life safety can be defined as the means of egress and its protection. Means of egress is any space in the building up to the "public right of way" (outside of the building). The following questions can be asked when evaluating the components of an egress system:

  • Are exit signs visible?
  • Do doors swing out or with the flow of egress?
  • Are doors readily operable?
  • Do lighting systems operate under loss of power?
  • Are exit stairwells in working order and do they direct people out of the structure?
  • Is there proper capacity of exits based on the occupant load?

Evacuation Efforts

In order to begin the process of evacuation, the occupants must be notified that a fire exists. This is typically accomplished by notification devices (horns, strobes, or speakers) connected to a fire alarm system. Fire alarm requirements are based on the adopted building, life safety, or fire code. In a residential setting, notification is provided through smoke alarms. The alarm system must be properly maintained by the business owner who typically contracts with an approved alarm company to test and maintain the system.

Evacuation can be accomplished by a trained staff that alerts occupants in the event of a fire. In addition to a fire alarm system, the staff of a building must be trained in evacuation procedures and this is usually tested by a "fire drill." Staff must also be trained in fire prevention and general safety. Training requirements and frequency of the training is outlined in the adopted fire code.

If a fire does occur, the building is expected to perform based on its design and keep the fire limited in size. A common approach is the installation of a maintained and approved automatic sprinkler system. A sprinkler system is not a one-size fits all solution. Sprinkler systems are designed based on the occupancy hazard or storage arrangement. The design of the sprinkler system is based on the National Fire Protection Association (NFPA) Standard 13: Installation Standard of Automatic Sprinkler Systems. This standard outlines proper sprinkler placement, system requirements, system design, and proper system installation.

Automatic sprinkler systems require regular maintenance and testing. The proper frequency and procedure is given in NFPA 25: Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. The owner or occupant of a building must be able to demonstrate that a system has been tested in accordance with NFPA 25. This may be accomplished in-house or by an approved sprinkler system contractor.

Sprinklers are only one type of extinguishing system. There are other types of alternative suppression systems. Many times these systems are installed to protect a process that may have inherent dangers. For instance the spraying of flammable liquids is typically conducted in a paint spray booth. The paint spray booth will include the plenum and exhaust system which would be protected with an approved sprinkler system or dry-chemical fire suppression system. In the case of the later, the suppression system would have required maintenance in accordance with the installation documents.

The most common form of alternative suppression system is a UL300 commercial cooking restaurant suppression systems. These systems are installed and maintained per NFPA 17A: Wet-Chemical Extinguishing Systems. This alternative suppression system must be maintained along with the cooking system. This would include good house keeping, cleaning of the appliances and the hood including the associated duct work.

Another factor in limiting the size of the fire is the proper maintenance of fire walls, barriers, and similar built-in features. For these systems to work properly, the wall must be constructed appropriately and maintained. This includes doors that close properly, penetrations that are sealed, and a continuity of the "system". Fire walls are typically referred to as a "system" which is constructed based on a set of UL design criteria. The International Building Code provides references to the UL design criteria (related to the type and duration of the assembly) on the type of fire wall to be constructed. These assemblies must be maintained and kept intact at all times.

This basic approach to code enforcement is built on many experiences with an adopted fire or building codes. Code enforcement requires training and extensive study of the codes in order to properly enforce them in your community. Remember that the codes strive to protect the people who use a building, which includes the fire service. Buildings and structures require regular maintenance to continue to meet the initial design and installation.


Michael O'Brian has a varied career in the public and private sectors with an emphasis on code administration and enforcement for the last 10 years. Currently he is working for Farmington Hills, MI, Fire Department as a Staff Lieutenant and is the president of Code Savvy Consultants, a municipal plan review and consulting company.

He is the creator of a dynamic web page called www.inspector911.com which is designed to assist local inspectors by providing resources, information, checklists and up to date news. He has a bachelor of science degree in public safety administration from Eastern Michigan University and can be reached via email at mobrian@inspector911.com

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