NFPA 1: Emergency Action Plans, when are they required and what do I include? #FireCodefridays
No further detail is needed to understand that the events that took place last week in Parkland, Florida were horrific and devastating. It will no doubt have an impact on building and occupant safety going forward and the issues that our Codes face in the future.
As both a mom and fire protection engineer I find myself bouncing back between thoughts…from ”I'll do whatever it takes to keep kids safe” to “I need to be smart and think about fire safety, too”.
How do we keep our children secure in schools (and malls, and movie theaters, and concert venues) but how do we keep them, and all occupants, fire safe, too? It's easy to react and let emotion take over but I can't let the clear need for increased security result in overriding other safety issues that can put occupants at risk, such as fire, and the issues that could arise by not thinking about consequence of emotional reactions. This is a battle we, as fire safety professionals, will continue to address, especially in light of current events, during the upcoming Code development cycle for NFPA 1. How can we further integrate provisions for security while achieving that safe balance with life safety from fire and other emergencies? It's a discussion I wish we didn't have to have, but one that I am looking forward to participating in to make positive and impactful changes in our Codes.
A facility's emergency action plan (EAP) is a critical component to being prepared for a (hopefully unlikely) emergency. A coordinated effort, via the execution of an EAP, can no doubt contribute to a more successful response and outcome during and after an emergency. NFPA 1, Fire Code, requires in Section 10.8.1 that emergency action plans be provided for high-rise, health care, ambulatory health care, residential board and care, assembly, day-care centers, special amusement buildings, hotels and dormitories, detention and correctional occupancies, educational, underground and windowless structures, facilities storing or handling materials addressed in Chapter 60 (hazardous materials), or anywhere required by the local AHJ. The Code is a minimum. Nothing prohibits a building that may not be listed above from developing their own emergency action plan.
The details regarding the emergency action plans are extracted from NFPA 101, Life Safety Code, whose Technical Committee on Fundamentals manages the requirements for what should be included in the emergency action plan in Chapter 4 of that Code. A minimum of (7) items must be addressed in a facility's EAP:
- Procedures for reporting of emergencies
- Occupant and staff response to emergencies
- *Evacuation, relocation and shelter-in-place procedures appropriate to the building, its occupancy, emergencies, and hazards
- Appropriateness of the use of elevators
- Design and conduct of fire drills
- Type and coverage of building fire protection systems
- Other items required by the AHJ
EAPs are to be submitted to the AHJ for review, if required, and must be reviewed and updated also as required by the AHJ. Provided in the Code is lengthy Annex language to supplement the provisions for the emergency action plans. While the Code mandates a minimum of (7) items that every EAP should address, it also provides a list of (18) additional items that should be considered in preparing an EAP (See NFPA 1, A.10.2.8.1). These items include, for example: roles and responsibilities, procedures specific to each type of emergency, assisting people with disabilities, training, documentation, inspection and maintenance of building's life safety features, drills, and post-event planning and review. EAPs will be and should be different for each facility. While fire is one of the prominent emergencies that the Code addresses these EAPs will address any likely emergency that a building may encounter.
In my opinion, one of the most important details of an EAP, and even more so I believe after last week's tragedy, is identifying and describing the appropriate evacuation strategies for each emergency event. Evacuation may be specific to the building, its occupants and occupancy and the types of emergency. The referenced Annex section contains an abundance of information to provide to building owners or inspectors when developing and reviewing EAPs. It is assumed that a majority of buildings will use a total evacuation strategy during a fire, the primary emergency addressed by the Code. But, evacuation from a building could occur for reasons other than a fire, and for those events, careful consideration should be given to evacuation strategies. I encourage all who read this to also read the information in A.10.8.2.1 to further your knowledge and understanding about the types of evacuation strategies, what's appropriate, and how to manage and implement such strategies.
Requiring an EAP is just one piece of the Code that can address both security and safety from fire. NFPA is also furthering its efforts to address security and hostile acts with the development of a new standard, NFPA 3000. For only the second time in NFPA's 121-year history, provisional standard status has been authorized by the NFPA Standards Council for NFPA 3000, Standard for Preparedness and Response to Active Shooter and/or Hostile Events. As part of the standards process, NFPA 3000 is now open for input until February 23, 2018. NFPA 3000 may be available for use as early as this April and will provide the minimum criteria for the level of competence required for responders organizing, managing, and sustaining an active shooter and/or hostile event preparedness and response program based on the authority having jurisdiction's (AHJ) function and assessed level of risk. Please check out the document information page for further information on the scope and development of this important document.
Do you have ideas for how the Code can improve its requirements for emergency action plans? Have you worked with facilities in developing, implementing or reviewing EAPs? Please leave a comment below, your ideas can impact the next edition of the Fire Code. You may also submit any proposed changes online here.
You can follow me on Twitter for more updates and fire safety news @KristinB_NFPA.