For many commercial real estate professionals, keeping up with new codes and standards, especially the wide-ranging international, state and local codes and standards as written by the International Code Council, equates to a second full-time job. The ICC is a professional member association with a mission to provide the highest-quality codes, standards, products and services for all concerned with the safety and performance of the built environment. Its codes and standards are widely used within the United States to design, build and ensure operating compliance.
We rely on field experts, architects, professional engineers and other specialists we hire for the design and construction of various projects to maintain a working knowledge of current codes. However, practical operating subtleties within mandates and requirements can sometimes be overlooked considering the vast amount of information in the International Code. Nuances in the best-intentioned code or standard can inadvertently result in operational challenges.
A year ago, I was visited by a group promoting a newly created training program in response to the recently adopted 2016 Denver amendments to the 2015 Fire Code. Citing Section 403.13 below, entitled Facility Manager Certification, they could deliver the appropriate training, for a fee, to all affected persons to ensure compliance with the following: “All personnel responsible for facility maintenance, fire safety, emergency procedures, evacuation plans, evacuation drills, employee training and response procedures, hazard communication, resident training, tenant identification, emergency response team formulation and training, hazardous materials management plans, hazardous materials inventory statement, etc., shall complete a Denver Fire Department training course and shall have a current certification by the Denver Fire Department.”
The broad and all-inclusive language attempts to provide a standard in the development and operation of fire and life-safety training and systems maintenance and operations. The code’s language is ambiguous and could apply to any and all property management staff, as it contains facility maintenance, hazard communications and tenant identification within its scope.
From a property management perspective, how feasible is compliance in its broadest sense based on the requirements? If you manage a 24/7 high-rise office tower, as a matter of routine operation, appropriate training and certification should reasonably be considered for building engineers or those individuals in charge of the tower’s life-safety systems. Individuals who write, prepare and deliver fire and life-safety training programs also could fall under the requirement.
But, do you operate with teams of lobby attendants or security personnel who, at the direction of senior engineering or management staff, communicate with fire dispatchers during the routine course of various systems maintenance or construction projects? Do they ever utilize a general hazard communications public address system for announcing fire drills, alarms or weather events? The requirement would necessarily include any and all “floating” attendants who are temporarily filling shifts, often at the last minute, during absences.
The language also would extend to vendors and/or contractors performing repair or maintenance to various systems throughout a typical operating year – think fire pumps, wet and dry fire suppression systems, etc. What about your friendly fuel delivery service for your emergency generator? Tenant-specific life-safety systems and their corresponding maintenance vendors, tenant floor wardens, searchers and other volunteer training and emergency response teams would be included in the requirement.
Is recertification required after a period of time? Depending on your specific operation, the extent of the requirement may be extensive and onerous.
The good news? The Denver Fire Department invited members of Denver’s Metro Building Owners and Managers Association to participate in an ongoing conversation to address these and other concerns regarding the code. To date, implementation of the program is on hold, or is voluntary if you choose to implement the program, for which there are various training options. Stay tuned!