Building and Life Safety: Requirements for Emergency Egress Drills
It's back to school time. But, what back to school will look like in 2020 will be unlike anything in the past. Currently, communities are facing unprecedented challenges from the COVID-19 pandemic causing educators, administrators, public health officials and first responders to grapple over the safest decision for how the school year will operate. Some schools may opt for a fully remote learning experience while other may welcome students back to school buildings in person, or possibly a combination of the two. However, regardless of the details of the school day, when students are in the buildings, maintaining a healthy and safe environment cannot be overlooked. This includes continuing to conduct fire drills, among other safety measures.
Educational occupancies, defined in NFPA 1, Fire Code, and NFPA 101, Life Safety Code as "an occupancy used for educational purposes through the twelfth grade by six or more persons for 4 or more hours per day or more than 12 hours per week" include preschools, elementary schools, high schools, and the like. Colleges and Universities fall under a different occupancy classification and are also facing their own unique challenges due to COVID-19. Here we will focus on the emergency egress drill requirements for those facilities classified as educational occupancies.
Why are drills important?
Emergency egress and relocation drills are required as mandated specifically by the occupancy or as deemed necessary by the local AHJ (see Chapter 20 of NFPA 1 or Chapter 14 or 15 of NFPA 101). The purpose of these drills is to educate the participants in the fire safety features of the building, the egress facilities available, and the procedures to be followed. Speed in emptying buildings or relocating occupants, while desirable, is not the only objective, nor is it regulated by the Codes. Students that are returning to school in-person this school year will likely see reconfigured classroom spaces, one way travel throughout the building, and a change in how some traditionally non-classroom space is being used, all due to the overwhelming number of health and safety restrictions in place due to COVID-19. These changes to the building configuration make drilling students especially critical so that in the event of an emergency, students and staff alike are familiar with any changes to the building or their expected course of action for the emergency. Regardless of what changes have been made to the building configuration, free and unobstructed egress must be maintained at all times.
When are drills required?
Generally, egress drills are required by the Code to be conducted at least once every month the educational facility is in session, and sometimes twice within the first 30 days, unless located in a climate with severe weather (cold, heat, etc). All occupants of the building are required to participate in the drill and all emergency drill alarms are to be sounded on the fire alarm system so as to not confuse students and staff as to the required action.
Emergency egress training programs may be substituted on a one-for-one basis for as many as four of the required monthly emergency egress drills. The mixture of training programs and emergency egress drills might elicit student egress behavior that is superior to that instilled by drills alone. However, at least four egress drills need to be conducted prior to the first training program to ensure that the students have walked the egress route and demonstrated other behavior addressed by the emergency plan. The concept behind the requirement that emergency drills be conducted at the start of the school year is that training without the hands-on instruction accomplished by drilling does not guarantee that students will be familiar with the egress routes and able to interact with others during an emergency evacuation or relocation.
Do the codes address drills for non-fire events?
In addition to drilling students and staff on response to a fire emergency, non-fire events such as a targeted-violence event or a natural disaster also require drills. The need to train and drill on multiple scenarios can put a strain on resources, time and patience. Because of this, a new requirement for the 2021 editions of NFPA 1 and NFPA 101 will permit, if approved by the authority having jurisdiction, up to two of the required emergency egress drills to consist of alternative emergency drills for one or both of the following: 1. Targeted violence events 2. Natural hazard events. Additionally, NFPA 1 also addresses frequency, conduct, environment, and documentation for drills.
Fire inspectors play an important role in regulating and managing drills in facilities throughout their jurisdiction, especially in schools. Drills should always be designed and conducted in cooperation with the local authorities as the procedure and details of drills will vary jurisdiction by jurisdiction. Factors such as occupant demographics and location may all impact the details of the drill. Any concerns of those additional restrictions implemented due to COVID-19 safety mandates should be worked through with the local authorities. Above all, fire drills must continue to be conducted, even as modifications around social distancing are established.
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