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Author(s): Ron Cote. Published on November 1, 2017.

In Compliance | NFPA 101

Performing a required risk analysis for mass notification systems


Where does compliance with a requirement of NFPA 101®, Life Safety Code®, produce documentation to support recommended, but not mandatory, additional action? One such set of provisions, new to the 2018 edition of the code, addresses performing a required risk analysis for mass notification systems.

The new Section 9.14, Risk Analysis for Mass Notification Systems, offers, like many of the provisions of the non-occupancy-specific core chapters, a menu-like set of requirements that can be mandated by reference elsewhere in the code. Where another code provision mandates compliance with the provisions of Section 9.14, a risk analysis for mass notification systems must be performed and documented in accordance with the requirements of NFPA 72®, National Fire Alarm and Signaling Code, Chapter 24, Emergency Communications Systems (ECS).

For the 2018 edition of NFPA 101, the risk analysis for mass notification systems is required for the following: high-rise buildings with an occupant load of 5,000 or more, or where the occupied floor height is 420 feet (128 m) or more; new assembly occupancies with an occupant load of 500 or more; new educational occupancies; new college or university dormitories with an occupant load of more than 100; and new business occupancies in college or university buildings. Approval of a particular risk assessment method is left to the authority having jurisdiction (AHJ), and advisory annex text in NFPA 72 presents references to credible risk assessment tools.

NFPA 72 also presents a useful risk analysis checklist. Part one of the checklist aids the user in identifying the assets at risk, which can include people, property, operations, environment, and organization. NFPA 101 is concerned with occupant life safety, not property protection or continuity of operations, so where the NFPA 72–based risk assessment is performed for compliance with NFPA 101, the user should focus on the people-related portions of the assessment method. Part two of the NFPA 72 checklist aids the user in determining the facility hazards that would normally be limited by the scope of NFPA 101 to hazards from fire and similar emergencies. However, a purpose statement within the provisions of Section 9.14 establishes that a mass notification system communicates information about emergencies including fire, accidental or intentional human-caused events, other dangerous situations, accidents, and natural disasters—both internal and external to the occupied building. In support of this requirement, the scoping of Chapter 1 of the code was expanded for 2018 to include communications that are provided to occupants under “emergency” conditions.

Where the required risk analysis indicates a need for a mass notification system, the facility emergency action plan must be updated to identify the mass notification system design and performance requirements. The extent of the needed mass notification will vary from building to building and might range from the notification of a few individuals all the way to the notification of the entire nation. The needed notification might end at any of the following intermediate levels: small defined zone; larger defined zone; building floor; multiple floors or zones; entire building; building perimeter; block, campus, or base; city; county; and state.

The risk analysis and the emergency plan comprise the documentation that must be made available to the AHJ showing compliance with the requirement to perform a risk analysis for mass communication systems. The requirement is met without having to provide the mass notification system that is identified as needed by the analysis. The inclusion of Section 9.14 in the 2018 edition of the code will, undoubtedly, generate awareness of mass notification so a requirement, for implementing the systems identified as needed by the required risk analyses, can be added to a subsequent edition of the code.

RON COTÉ, P.E. is NFPA technical services lead for life safety.