Organizational Risk Analysis – Fire Prevention

REPORT

Town of Tillsonburg

DATE:November 3, 2018

TO:David Morris, CAO

FROM:Master Fire Plan Committee

Glen Harrop, Chair

Bob Parsons, Fire Chief

RE:ORGANIZATIONAL RISK ANALYSIS - FIRE PREVENTION

Executive Summary

  • This Report is first of seven such Fire Services Organizational Risk Reports that will assist Council to form a Master Fire Plan.
  • GAP Analysis – The decision of Council to adopt the Recommendations contained in this report will have a direct impact on the other 6 Reports.
  • The report contains statistical information of what the municipality is doing today in the community with respect to legislated requirements for Fire Prevention activities and compares these to Best Practice with reference to Provincial Standards and Guidelines.
  • GAP Analysis – The municipality may not be in compliance currently with the municipal responsibilities for fire protection 2.(1)(a) FPPA.
  • The Report contains analysis of time requirements to complete inspections and enforce the Ontario Fire Code and includes staffing comparatives with municipalities of similar size and demographics.
  • GAP Analysis – There is not sufficient staff resources available to the fire department currently to complete the work.

TOWN OF TILLSONBURG FIRE DEPARTMENT

MASTER FIRE PLAN

ORGANIZATIONAL RISK ANALYSIS

FIRE PREVENTION

Purpose

The purpose of this report is to analyze the current level of service the Tillsonburg Fire Department is currently providing in the area of fire prevention and codeenforcement, to identify any gaps existing between the level of service providedand the level of service that is required. A Master Fire Committee has been appointed by council to study any identified risks, rank them by probability, consequence and impact, develop and consider options to mitigate the risk and finally to make recommendations to the council to implement policy so that its fire department can provide fire protection services to the citizens based on the Town’s needs and circumstances for the next 5 – 10 years. This report is one of seven other fire service organizational risk analysis reports that once prepared and studied will form a comprehensive Master Fire Plan for the Town of Tillsonburg. The other components will include Public Education, Administration, Fire Suppression, Firefighter Training, Communications, Fire Apparatus and Equipment and an analysis of non-core potential fire service options to deliver tiered medical response, water and ice rescue, technical rescue including trench and confined space and hazardous materials response at the operations or technical rescue levels.

The Fire Protection and Prevention Act (FPPA)

This legislation establishes the municipality’s responsibility for fire protection in the community. This is established by Section 2 of the FPPA and it states:

2(1) “Every municipality shall,

(a)establish a program in the municipality which must include public education with respect to fire safety and certain components of fire prevention; and

(b)provide such other fire protection services as it determines may be necessary in accordance with its needs and circumstances.”

To satisfy Section 2(1)(a) every municipality in Ontario is required to provide at a minimum the 4 basic services to its residents as follows:

  • Simplified Risk Assessment
  • A Smoke Alarm Program with home escape planning
  • Fire Safety Education Material distributed to residents/occupants
  • Inspections upon complaint or when requested to assist with code compliance

The Town of Tillsonburg completed a Simplified Risk Assessment and in February, 2004 the Office of the Fire Marshal awarded a Certificate of Compliance too the Town.

To satisfy 2.(1)(b), the best way is to prepare and implement a Master Fire Plan. The Master Fire Plan process will include a comprehensive Risk Assessment.

The Office of the Fire Marshal has identified three “lines of defense” in terms of the overall fire protection for a community:

  • Public fire safety education.
  • Fire prevention inspections and code enforcement.
  • Emergency response.

The philosophy of this strategy is to provide buildings which are as fire safe as possible, to educate residents in fire prevention/fire safety and to provide effective emergency response should the first two strategies fail. While the general public views the fire service as primarily providing emergency response services, the premise of the “three lines of defense” is that the system has failed each time an emergency fire response is required. In support of these lines of defense, the Fire Protection and Prevention Act mandates that municipalities provide specified core services as related to fire prevention-code enforcement and public fire safety education

In support of these requirements, the Tillsonburg Fire Chief who in addition to performing otherassigned responsibilities including management of 37 employees, currently works actively on the ground as a Fire Prevention officer and conducts most of the Fire Prevention duties. The Department is staffed with a full time Deputy Fire Chief who is primarily responsible for supervision of the Fire Suppression, Fire Communications, Training, Apparatus and Maintenance divisions. Both the Fire Chief and Deputy Fire Chief are trained and qualified as Fire Inspectors. Both are Assistants to the Fire Marshal as defined by the Fire Protection and Prevention Act. As well, The Fire Chief has delegated his authorities under the Fire Protection and Prevention Act to the Deputy Fire Chief.

Mission Statement

We will be responsive to the needs of the community through the delivery of a focused fire protection and prevention program based on a continuum of risk assessment, targeted public education and prevention initiatives and in the case of an emergency, promptly respond with highly trained and motivated fire suppression team, ensuring that Tillsonburg will be regarded as a premiere and safe community in Ontario in which to live, work and visit.

Guiding Principles

We believe in

•S urrounding our Customer with Service

•A ccountability through performance measures

•F ostering open communication and collaboration

•E ducating the public to preserve life and wellness

•T he promotion of honesty, integrity and fairness

•Y es, “we are here to serve you.”

The Status of the Fire Prevention Inspection

Program in Tillsonburg Today

Fire Prevention Inspection Policy

The current council approved policy of the fire department is to conduct fire safety inspections upon request or complaint. We are not doing this consistently.

  • We are not able to consistently respond to request or complaint inspections on a reasonable timely basis.
  • We are not able to consistently conduct follow up inspections to ensure that fire code violations have been corrected on a timely basis.
  • We are not consistently able to review and approve Fire Safety Plans which are required by certain property owners in order to be in compliance with the Ontario Fire Code.
  • We are not able to prosecute for contravention of the Fire Code due to consistent work flow.
  • We do not regularly or routinely inspect the Hospital, Nursing Homes, Retirement Homes and homes for special care.
  • We do not regularly or routinely inspect occupancies with large public assembly including schools, churches, restaurants or community centers.
  • We do not regularly or routinely inspect occupancies containing multi-residential dwellings.
  • Other higher risk occupancies including the mall or high, medium hazard industry.

Provincial Review of the Fire Prevention Inspection Program

The municipality is subject to a review by the Office of the Fire Marshal to ensure we are in compliance with the responsibilities established by the FPPA. Based on our current fire inspection practices we may not be able to obtain a Certificate of Compliance as we did in 2004. Should this occur there is some likelihood that the Fire Marshal may come into the community to review all aspects of the Fire Protection services in the community.

Inspections and Code Enforcement

The Office of the Fire Marshal has published standard inspection frequency data based on occupancy use. For purposes of discussion, this report will utilize the Office of the Fire Marshal inspection frequencies as follows for its analysis:

  • Assembly Annual
  • Institutional Annual
  • Multi unit Residential Annual
  • Business/Personal Service Bi-annual
  • Mercantile Bi-annual
  • Industrial Bi-annual

The duties of the fire department in terms of fire prevention/code enforcement include:

  • Enforcement of the Fire Protection and Prevention Act.
  • Inspections and code enforcement as related to the Ontario Fire Code (a regulation under the F.P.P.A.) including inspections due to complaint, and inspections due to request, and retrofit inspections.
  • Business registry inspections.
  • Liquor license application inspections.
  • Provincial ministry license inspections (day care etc.)
  • Commenting, as requested by the Building Department, on Ontario Building Code issues as related to buildings in the municipality.
  • Fire cause determination and investigation.
  • Commenting on site plan issues as requested by the Planning Department.
  • Data compilation and record keeping duties.

The estimated time per inspection is based on the following projected table. Actual times may vary somewhat due to the complexity of the inspection and the number of follow up inspections requiredattaining compliance. Times are shown in minutes.

ACTIVITY / TIME IN MINUTES
TRAVEL TIME / 30
FILE SEARCH / 20
INSPECTION / 30-120
REPORT/RESEARCH / 60-120
FOLLOW-UP / 30-120
FIRE SAFETY PLAN REVIEW / 60-90
FIRE PROTECTION SYSTEM REPORT REVIEW / 30-60
COURT / 5-20 HOURS!

Based on the building stock for the Town of Tillsonburg and utilizing the Office of the Fire Marshal standard inspection frequency data, the following table provides an analysis of the estimated time required to complete inspections based on the frequency data provided by the Office of the Fire Marshal.

BUILDING TYPE / FREQUENCY / HOURS / NO. OF BUILDINGS
** / TOTAL TIME (HR) / TIME PER YR. (HR)
Assembly / Annual / 4.5 / 136 / 612 / 612
Care/Detention / Annual / 6 / 66 / 396 / 396
Multi-Resid.* / Annual / 6 / 196 / 1176 / 1176
Hotel / Motel / Annual / 6 / 4 / 24 / 24
Business / Bi-annual / 4.5 / 295 / 1327.5 / 664
Mercantile / Bi-annual / 4.5 / 266 / 1197 / 599
Industrial / Bi-annual / 4.5 / 75 / 337.5 / 169
Single Family Dwellings / 4484
Residential including Mobile, Co-Op and Condos / 357
Buildings not classified by OBC / 49
Excluding court, the total annual hours required to complete fire prevention inspections / 3640

*Would include additional 2-unit dwellings, once their locations are determined and “retrofit” inspections are complete, which will require an amendment to this table relative to the total time per year.

**Source: County of Oxford, Town of Tillsonburg and the Simplified Assessment November, 2003.

Based on a 40-hour work week, 1 Full-Time Equivalent (FTE)works 1824 hours annually (excluding vacation and statutory holidays) The above table demonstrates that to complete fire safety inspections as per the inspection frequency schedule as recommended by the Office of the Fire Marshal, 2 FTEs are required.

The table analyzing the inspection hours by occupancy does not include complaint or request inspections, inspections required under the Fire Protection and Prevention Act (F.P.P.A.), inspections in conjunction with the Building Department or retrofit inspections under the Ontario Fire Code. Follow-up inspectionsare often not completed in a timely fashion or not completed at all. This is a critical liability exposure. We are still not meeting the O.F.M. frequency which is a best practice recommendation. The table does not consider the time it takes to complete other fire prevention activities including review and attendance at meetings relative to building permits, building occupancy approvals, site plan and work associated with our participation on the Development Coordinating Committee, zoning applications, prosecution for offences under the FPPA and fire scene investigation to determine the origin and cause of fire as required by the FPPA.

Currently 2 FTEs at the Fire Department commit a cumulative total of approximately 450 hours on average annually to conducting Fire Prevention inspections or approximately 25% of 1 FTE. A greater amount of staff resource time is required to work operationally, supervise and manage other divisions and responsibilities of the Fire Department and other assigned duties including, Administration, Public Education, Suppression, Training, Fire Communications, Mechanical, Building, Recruitment, Health & Safety, and Community Emergency Management. The FTE analysis for each of these divisions and activities will be reported in forthcoming Organizational Risk Analysis Reports.

A summary of the inspections completed from 2004-2008 is provided in the tables that follow.

Inspection Comparison 2004-2008
Listed by Summary Activity / 2005 / 2006 / 2007 / 2008
Assembly / 19 / 17 / 4 / 4
Residential / 321 / 481 / 323 / 323
Commercial / 19 / 9 / 12 / 12
Institutional / 9 / 13 / 8 / 8
Industrial / 13 / 16 / 5 / 5
TOTAL ACTIVITY / 391 / 542 / 357 / 358
Fire Safety Plan Review / 5 / 7 / 3 / 4
Fire Investigation / 14 / 9 / 5 / 4
Zoning, Building and Site Plans / 39 / 12 / 23 / 20
2005 Inspection Summary
Fire Safety Inspection / Follow-up / Occupant Load / Consultation / Other / TOTAL
Assembly / 8 / 7 / 1 / 2 / 1 / 19
Residential / 18 (254) / 27 / 0 / 7 / 15 / 321
Commercial / 9 / 6 / 0 / 2 / 2 / 19
Institutional / 3 / 3 / 0 / 2 / 1 / 9
Industrial / 4 / 4 / 0 / 4 / 1 / 13
TOTAL / 42 (254) / 47 / 1 / 17 / 20 / 381
Fire Safety Plan Review / 5
Fire Investigation / 14
Zoning, Building and Site Plan Review / 39
2006 Inspection Summary
Fire Safety
Inspection / Follow
Up / Occupant
Load / Consultation / Other / TOTAL
Assembly / 7 / 6 / 2 / 1 / 1 / 17
Residential / 25 (385) / 41 / 0 / 13 / 17 / 481
Commercial / 5 / 2 / 0 / 2 / 0 / 9
Institutional / 4 / 6 / 0 / 2 / 1 / 13
Industrial / 3 / 5 / 0 / 4 / 4 / 16
TOTAL / 44 (385) / 60 / 2 / 22 / 23 / 536
Fire Safety Plan Review / 7
Fire Investigation / 9
Zoning, Building and Site Plan Review / 12
2007 Inspection Summary
Fire Safety Inspection / Follow Up / Occupant Load / Consultation / Other / TOTAL
Assembly / 2 / 4 / 2 / 1 / 0 / 9
Residential / 29 (408) / 36 / 0 / 16 / 22 / 511
Commercial / 19 / 12 / 0 / 3 / 0 / 34
Institutional / 3 / 3 / 0 / 2 / 0 / 8
Industrial / 2 / 4 / 0 / 1 / 0 / 7
TOTAL / 55 (408) / 59 / 2 / 23 / 22 / 569
Fire Safety Plan Review / 3
Fire Investigation / 5
Zoning, Building and Site Plan Review / 23
2008 Inspection Summary
Fire Safety Inspection / Follow Up / Occupant Load / Consultation / Other / TOTAL
Assembly / 2 / 1 / 1 / 0 / 0 / 4
Residential / 17 (262) / 26 / 0 / 8 / 10 / 323
Commercial / 7 / 3 / 0 / 2 / 0 / 12
Institutional / 1 / 4 / 0 / 1 / 2 / 8
Industrial / 2 / 1 / 0 / 1 / 1 / 5
TOTAL / 29 (262) / 35 / 1 / 12 / 13 / 352
Fire Safety Plan Review / 4
Fire Investigation / 4
Zoning, Building and Site Plan Review / 20

Source: Tillsonburg Fire Department inspection data.

For information purposes the following outline is provided as to what a “typical” inspection involves. Depending on the occupancy, other measures may also need to be assessed:

Fire Safety Inspection Procedure

-Determine the property to be inspected by correct verified municipal address onthe department’s Records Management System, Fire Pro.

-Determine the type of occupancy to be inspected as per the OntarioBuilding Code.

-Review the current record for previous building information including fire prevention or fire loss data, if available.

-Review applicable sections of the Ontario Fire Code and Ontario Building Code if required.

-Upon arrival, meet with the owner or owner’s representative prior to conducting the inspection:

  • Discuss any changes to the building since the last fire safety inspection.
  • Find out what types of fire safety systems the building has (e.g. sprinkler system, fire alarm system, fixed fire protection, etc).
  • Obtain copies of the fire safety system’s inspection/testing reports as required under the Ontario Fire Code.
  • Ask to see the building’s fire safety plan (if required) and determine if updates are required.
  • Ask to see the records of the checks, tests and inspections that are required under the Ontario Fire Code that pertain to the building being inspected.
  • Have the owner or owner’s representative attend the inspection so that they can be educated on any violations found as well to provide access to secured areas of the building.

During the inspection process,Ontario Fire Code Division B Part 2 (Fire Safety) & Part 6 (Fire Protection Equipment) are utilized. Other areas of the Ontario Fire Code may be utilized depending on the type of the building and what the building is being used for. Other areas of the Ontario Fire Code that may be utilized are the following:

Division B, Part 3 – Fire Safety For Industrial and Commercial Uses

Division B, Part 4 – Flammable and Combustible Liquids

Division B, Part 5 – Hazardous Materials, Processes and Operations

Division B, Part 8 – Demolition

Division B, Part 9 – Retrofit

The inspection process becomes more involved when the above noted parts of the Ontario Fire Code are utilized as these parts are highly technical and require a thorough knowledge of not only the Ontario Fire Code, but also the OntarioBuilding Code. For the purpose of discussion, this report will reflect a general fire safety inspection only involving Division B, Parts 2 & 6. The following is what an inspector is looking for during the inspection process:

Division B, Part 2

2.2.1.1. – Is the fire separation between major occupancies damaged (e.g. between two different stores in one building)?

2.2.1.1. – Are there any damaged fire separations (e.g. furnace room, storage room, etc)?

2.2.3.1. – Are closing devices intact and operating properly?

2.3.2.1. – Is flame resistance of textiles required and when was the last time it was treated (e.g. flame retardant applied to curtains in a school gym)?

2.4.1.1. – Is there an accumulation of combustible materials that poses a fire hazard?

2.4.1.5. – Are dryer lint traps being cleaned out?

2.4.4.1. – Are open flames being used?

2.4.4.1. – Are extension cords being used as permanent wiring; are there any other electrical issues?

2.5.1.2. – Are fire access routes unobstructed?

2.5.1.4. – Are fire access routes properly marked as per the Town of TillsonburgTraffic By-law.

2.6.1.12. – Is commercial cooking equipment provided with exhaust and fire protection systems in conformance with NFPA 96 (2001 Edition).

2.6.1.13. – Are commercial cooking equipment exhaust and fire protection systems being properly maintained in conformance with NFPA 96 (2001 Edition).

2.7.1.4. – Is the occupant load posted in a conspicuous location and is the occupant load correct for this building?

2.7.1.7. – Are the exits properly lit and are they obstructed?

2.7.1.8. – Is the fire escape being properly maintained?

2.7.2.1. – Is the door release hardware functioning properly and installed in the proper locations?

2.7.3.1. – Is the exit signage visible and illuminated?

2.7.3.3. – Is the emergency lighting being tested monthly and annually? Are there records to prove this?

2.8.1.1. – Does this building require a fire safety plan? Is there a fire safety plan on site? Has the plan been approved by the Chief Fire Official? Has the plan been reviewed in the past 12 months?