FAQ

Ontario Fire Code FAQ for Business Owners and Property and Building Managers 

Important note: This FAQ is general information, not legal advice. Ontario Fire Code obligations depend on the building’s occupancy, height, systems, and use. Your local fire department is the authority having jurisdiction for Fire Code enforcement, and “approved” in the Code generally means approved by the Chief Fire Official. 

Does the Ontario Fire Code only apply when a building is new or renovated?

No. The Fire Code is mainly about the ongoing use, maintenance, testing, inspection, and operation of fire and life safety features in existing buildings. It is not something you check once and forget. The Code requires continuing inspection, testing, maintenance, repairs, records, and operational procedures.

If we hire a contractor, does that shift Fire Code responsibility away from us?

Not entirely. The owner still has important responsibilities under the Code. For example, for fire alarm systems, the owner must ensure that the people doing required annual tests, inspections, repairs, replacements, or alterations meet the Code's qualification requirements. In other words, outsourcing the work does not eliminate the owner's responsibility to ensure it is done properly.

Do we really need to keep inspection and testing records on site?

Yes. Where the Code requires tests, corrective measures, or operational procedures, records must be made showing what was done and when. Those records must be retained at the building premises for examination by the Chief Fire Official, although electronic records are acceptable if they can be made readily available on request. Most required records must be kept for at least two years, with at least the most recent and immediately preceding record retained. Initial verification or test reports for fire protection systems installed after November 21, 2007 must be kept for the life of the system.

Is a fire safety plan just a binder on a shelf?

No. Where required, a fire safety plan must be prepared, approved and implemented. It must include emergency procedures, supervisory staff duties, training, system diagrams, fire drills, fire hazard control, maintenance of safety features, and alternative measures during shutdowns of fire protection equipment or systems. It must be kept in an approved location, reviewed as often as necessary and at least every 12 months, and revised when building use or conditions change.

Which buildings usually need a fire safety plan?

A fire safety plan is required for many occupancies and situations, including buildings containing assembly, care, care and treatment, detention, and hotel occupancies, as well as buildings or premises with 4 storeys or more, certain dangerous goods uses, some high buildings, and other specific cases listed in Section 2.8 of the Fire Code. This is one reason managers should not assume that “ordinary commercial space” means no fire safety plan is needed.

If a sprinkler, standpipe, fire alarm, generator, or other fire protection system is shut down for service, can we just wait until the contractor is done?

No. When tests, repairs, or alterations are made to fire protection installations, a notification procedure must be established, including notifying the fire department and building occupants where necessary for safety. The fire safety plan must also provide for alternative measures during shutdowns of fire protection equipment or systems. In addition, emergency power shutdowns specifically require notification of the fire department, building occupants, and supervisory staff.

Can fire protection or life safety systems simply be taken out of service if they seem unnecessary?

No. Fire protection equipment and life safety systems must not be decommissioned or permanently taken out of service without approval unless the Code specifically says otherwise. That is a common and risky misunderstanding.

How often do portable fire extinguishers need attention?

Portable extinguishers must be maintained and tested in conformance with NFPA 10. They must be inspected monthly. Each extinguisher must have a service tag, unless approved alternative records are kept, and a permanent maintenance record must be maintained for each extinguisher. Extinguishers with defects must be repaired and recharged or replaced after use as required. 

Do sprinkler and water-supply components have to be checked more often than once a year?

Often, yes. For example, most valves controlling water supplies used for fire protection systems must be inspected weekly, unless they are locked open or electrically supervised, in which case monthly inspection is permitted. Fire protection tanks have annual and, in some cases, daily or two-year inspection requirements depending on the component and weather conditions. Fire pumps require regular operation and annual full-flow testing, and hydrants must be maintained, kept clear, and inspected annually. The Code also states that compliance with NFPA 25 for certain water-based systems is deemed to satisfy several Fire Code requirements.

Is the fire alarm annual test the only thing we need to worry about?

No. Fire alarm systems must be inspected and tested in conformance with CAN/ULC-S536, but there are also ongoing operational checks. For example, the central alarm and control facility must be checked daily for trouble indications. Where the system is monitored, the owner must record whether test signals and other events are received by the monitoring station, and those records must be kept in accordance with the Code's recordkeeping rules.

Do emergency lighting and exit signs need regular testing too?

Yes. Self-contained emergency lighting units must be inspected monthly and tested monthly, with a more complete duration test at least every 12 months. Exit signs with battery backup must be inspected monthly and annually; other exit signs must be inspected at least every 12 months. Emergency power systems must also be inspected, tested, and maintained in conformance with CSA C282 (or CSA Z32 in hospitals), with written records maintained as required by that standard.

If our fire alarm system is not directly connected to the fire department, will occupants automatically know to call 911?

Not necessarily. The Code specifically requires a legible notice near each manual pull station where a fire alarm system has no provision to transmit a signal to the fire department. The notice must state that the fire department is to be notified in the event of a fire emergency and must include the relevant emergency phone number.

Does the fire safety plan have to change during construction, renovation, or demolition?

Yes. Before demolition or construction begins, including hot surface applications, the fire safety plan must be revised to include temporary alternative measures for occupant safety and temporary procedures to control fire hazards, including risks to adjacent buildings. The revised plan must then be implemented. 

Is annual review enough if nothing major has changed in the building?

Annual review is the minimum in this part of the Code for the fire safety plan, but the plan must also be reviewed as often as necessary and revised whenever changes in use or other building characteristics make updates necessary. A plan that no longer matches the real building conditions is not a compliant plan.