U.S. Department of
Housing and Urban Development
Milwaukee Field Office
Suite 1380
Henry S. Reuss Federal Plaza
310 West Wisconsin Avenue
Milwaukee, WI 53203-2289
http://www.hud.gov/local/mil/
MEMORANDUM FOR:
Executive Directors and Staff,
Housing
Authorities of Wisconsin
(Note:
Message BCC'd to all WI PHAs and All MI UP PHAs)
FROM: Larry Wood,
General Engineer, Wisconsin Public Housing Program
Center
SUBJECT: Important
Information about Fire Safety
Smoke detectors
are important. They absolutely save lives. Since the
installation of residential smoke detectors became a
code requirement, the death rate in home fires has been
reduced by half. Ensuring adequate smoke detection
protection is an important responsibility for all
housing authorities.
The following
summarizes the requirements for smoke alarms and smoke
detectors* that Housing Authorities need to comply with.
It is our hope that this information will be of use to
PHAs in ensuring that its properties are compliant and
its residents will not be harmed by the effects of fire
and smoke. Please note that although the REAC inspects
smoke detectors in Public Housing units as part of its
physical inspections, in general REAC is only checking
some of the minimum requirements, but not all of them.
Therefore, if recent REAC inspections have not uncovered
any smoke detector deficiencies, a PHA could still not
be in compliance with the requirements concerning these
important life safety devices. HQS inspections also do
not address all of the required smoke detector
protection issues in units participating in the Housing
Choice Voucher Program. Generally, UPCS and HQS
inspections do not address the requirements of local
codes and of the Federal Fire Safety Act (Public Law
102-522). The local codes and the Federal Fire Safety
Act require compliance with NFPA 72, the National Fire
Alarm Code. There are also requirements specified in 24
CFR 965.805. Therefore, our office has developed this
guide for PHAs to give more information regarding the
relevant smoke detector requirements.
Please note that
your local fire official, smoke detector manufacturer,
and fire protection engineer should always be consulted
for the exact requirements for your particular area,
building type, and specific fire protection system. This
guide is not meant to take the place of or be used in
lieu of their expertise for your specific situations.
Listed in the Appendix of this letter are synopses of
the specific codes, standards, laws and regulations.
*The term “smoke
detector” will be used throughout to mean both smoke
detectors and smoke alarms
Summary of the
Minimum Installation Requirements:
For new
construction:
·
Hardwired
(interconnected required and battery backup
recommended**)
·
In every sleeping
room
·
Outside and in
close proximity to every sleeping room
·
On every level
·
For Public
Housing, in public areas, such as stairways, laundry
rooms, common areas
For existing
construction:
·
Hardwired
(interconnected and battery backup recommended**);
battery-operated are allowed as a “temporary measure”
and “must be replaced with hard-wired…in the normal
course of a PHA’s planned…CGP program.”
·
Outside and in
close proximity to every sleeping room
·
On every level
·
For Public
Housing, in public areas, such as stairways, laundry
rooms, common areas
For units for the
hearing-impaired, detectors must be hardwired. In
addition to the installation of smoke detectors with
built-in notification strobes, fire alarm strobes are
required in areas where smoke detectors cannot be
installed, such as bathrooms. The strobes must be placed
in every room with a door and at least one strobe must
visible from every room such that hearing impaired
persons can be notified regardless of where they are
located in the residence. The strobes are connected to a
fire alarm system, such that the strobes will activate
when any of the smoke detectors detect smoke. Therefore,
in units for the hearing impaired, a more complicated
system of detectors and strobes is required. NFPA 72,
the Fire Alarm Code, specifies the requirements for this
type of system. One of the requirements is that strobes
in bedrooms must be located within 16 feet of the pillow
and must have an output of at least 177 candela when the
distance from the ceiling to the top of the lens is less
than 24 inches (Table 7.5.4.4.2). The intense light
output requirements of the strobe are to ensure the
strobe is able to wake up a sleeping person.
However, even in
units for the hearing-impaired, one must also ensure
proper sound output levels. Because persons without
hearing problems can also occupy units for the
hearing-impaired, alarms installed must also meet the
audible alarm requirements in NFPA 72. The Fire Alarm
Code requires that an alarm sound is audible in all
occupiable areas. Please keep in mind that the audible
sound should be very loud, especially in bedrooms, where
the sound must be sufficient to waken a sleeping person
above ambient noises such as radios, televisions and air
conditioners.
** The
Guide for
Implementation of PL102-522 for Fire Alarm and Automatic
Sprinkler Installations
explains that “several court cases have held landlords
liable for detectors not working during power failures
because detectors with backup power are readily
available...”
Specific Common
Deficiencies:
The following are
common deficiencies we have observed in Public Housing
and Housing Choice Voucher units. Please note that you
should always follow the installation instructions of
your specific smoke detectors to ensure they are covered
under the manufacturer’s warranty. All of the NFPA 72
references cited below are from the 2002 edition, the
current latest edition.
Placement:
Kitchens:
Section 11.8.3.5 of NFPA 72, The Fire Alarm Code,
requires smoke detectors located within a 20-foot
horizontal path from a cooking appliance to be equipped
with an alarm- silencing means or to be of the
photoelectric type. Cooking vapors could cause many
nuisance alarms in ionization type smoke detectors, but
are less likely to cause them in photoelectric type
detectors because of its different way of sensing smoke.
A leading reason for the removal of batteries or
otherwise disabling the detector by residents are
repeated nuisance alarms. Also, PHAs should consider who
might be occupying the unit. If a detector with a
silence-button is installed on the kitchen ceiling, a
person confined to a wheelchair would be unable to press
the button.
Bathrooms and
Kitchens:
Section 11.8.3.5 of NFPA 72, The Fire Alarm Code, states
that smoke detectors shall not be installed within a
36-inch horizontal path from a door to a kitchen or a
bathroom containing a shower or tub. The water vapors
from cooking or from a shower or tub are a common cause
of nuisance alarms. Note that this requirement does not
allow any detectors of any type, either photoelectric or
ionization, to be installed in the 36-inch horizontal
path.
Supply
Registers:
Section 11.8.3.5 of NFPA 72, The Fire Alarm Code, states
that smoke detectors shall not be installed within a
36-inch horizontal path from the supply registers of a
forced air heating or cooling system. It also states
that detectors should not be installed within a 36-inch
horizontal path from the tip of a ceiling fan. The
airflow in these locations could prevent the products of
combustion from effectively reaching the smoke detector.
Wall/Ceiling:
Most smoke
detectors can either be installed on a wall and on a
ceiling. However, Section 5.7.3.2.1 requires when a
detector is installed on a wall, it must be placed no
lower than 12 inches but no higher than 4 inches from
the wall/ceiling line. When detectors are installed on
ceilings, they cannot be placed less than 4 inches from
a sidewall. Improper placement might render the detector
ineffective at providing early warning in a fire.
Other
requirements:
The following
lists some of the manufacturer’s instructions for
typical residential smoke detectors regarding where NOT
to install smoke detectors:
·
Do not install
less than 12 inches from fluorescent lights; electrical
“noise” can cause interference.
·
Do not install
where temperatures are regularly below 40 degrees, such
as garages or unfinished attics.
·
Do not install
within 20 feet from furnaces, water heaters and space
heaters, and all other sources of combustion products.
·
Do not install in
insect infected areas. Insects can clog the sensing
chambers. However, there are smoke detectors available
with special screens to prevent insects from entering.
The above list and
previous descriptions include only the most frequently
seen problems by this office. Refer to the
manufacturer’s instructions for your particular smoke
detector model to see its entire set of installation
requirements.
Age:
Section 10.4.6 of NFPA 72 requires that, unless
otherwise recommended by the manufacturer, smoke
detectors in one- and two-family dwellings shall be
replaced when they fail to operate during testing, but
shall not remain in service longer than 10 years from
the date of manufacture. Therefore, it is important to
keep the manufacturing data and to plan for replacement
of those detectors more than 10 years old. According to
NFPA, smoke detectors have a 3% per year failure rate.
Therefore, after 10 years, 30% of detectors will not
work effectively. After 15 years, only half will work as
designed. Even if the detector is operational on the day
it is tested, there is no way of knowing if it will be
operational the following day or until the next time it
is tested. See also the section below regarding the
reliability of testing. Of course, when batteries are
used as a power source, they should be replaced in
accordance with the detector’s manufacturer
recommendations.
Maintenance:
The
manufacturer’s recommendations and procedures for
maintenance should always be followed. Manufacturers
often specify that detectors should be cleaned once a
month by gently dusting or vacuuming the outside with a
soft brush attachment. If regular cleaning is not done,
a build-up of dust could prevent the detector from
working properly.
Testing:
Testing requirements depend on the manufacturer’s
requirements, and Fire Alarm Code requirements differ
depending on if the detectors protect one- and
two-family dwellings or multiple-family dwellings.
Always consult the manufacturers for their
recommendations and requirements. Note that
manufacturers recommend testing of detectors in one- and
two-family dwellings by pressing the detector’s test
button. Although this is the preferred method of
testing, this method does not actually confirm that
smoke is able to enter the chamber and activate the
detector. So, it is possible that pushing the test
button could indicate that a smoke detector is in
working condition, but the smoke detector actually has a
clogged screen or another defect such that it will not
signal an alarm during a fire condition.
There are other
test methods that might be recommended by the
manufacturer of your smoke detectors. The use of canned
“smoke” or an Underwriters Laboratory (UL) listed or
other independent laboratory labeled aerosol product for
testing smoke detectors is sometimes recommended.
However, there are sometimes problems associated with a
build-up of the aerosol product, when used improperly,
causing damage to the detector. As stated above, always
be careful to follow the manufacturer’s requirements,
but be aware of the limitations of each of the testing
methods.
In apartment
buildings, other multi-family dwellings, and other
public buildings such as community centers, childcare
centers, and offices, NFPA 72 requires smoke detectors
to be tested to ensure smoke entry into the sensing
chamber and an alarm response, such as by testing with
smoke or listed aerosol approved by the manufacturer.
Simply pushing test buttons, however, is not acceptable.
While it is the
PHA’s responsibility to ensure that smoke detectors are
in working order, tenants of public housing as well as
any other leased housing can also be assigned specific
responsibilities to help maintain the smoke detectors in
working order. In such cases, the lease should state the
tenant’s responsibility, such as maintaining and testing
smoke detectors between the PHA’s regular inspections in
accordance with the manufacturer’s requirements, as well
as any consequences if the tenant does not meet their
responsibilities as outlined in the lease. PHAs should
ensure that a copy of the manufacturer’s requirements is
provided to the tenant, and that it keeps a record that
they were provided to the tenant.
The lease should
also state that the tenant is required to immediately
notify the PHA if any detectors are broken or
malfunctioning. It should also be clearly stated that
tenants who fail to maintain the detector in proper
working condition (i.e. batteries are removed or the
detector is otherwise prevented from working properly)
could be found to be in breach of the lease. Resulting
actions by the PHA, such as eviction or fines, should
also be described. Please discuss this issue with your
legal counsel to ensure the leases clarify the PHA’s and
tenant’s responsibilities and the consequences if
tenants are proven to violate the lease.
If a person with
mobility impairments occupies the unit, the PHA has
greater responsibilities. For example, a person in a
wheelchair is probably unable to test the detectors.
Therefore, it is the PHA’s responsibility to do so
instead of the tenant. Likewise, a tenant with other
types of disabilities might be unable to perform the
testing requirements.
We hope that this
information will aid your Housing Authority in providing
the required smoke detection to its residents and
visitors. Although many topics were covered here, this
should not be considered comprehensive guidance on the
subject. We recommend consulting with the manufacturers
of the smoke detectors at your properties, as well as
with the local fire marshal and/or a registered fire
protection engineer. Your insurance carrier can also
provide information, including information on how
insurance costs may be reduced when additional
protection (i.e. automatic sprinkler protection) is
provided. Also, please note that this addressed smoke
detection only. The requirements for automatic sprinkler
systems and other life safety systems such as carbon
monoxide detectors were not covered here.
If you have
further questions, please contact Larry Wood, General
Engineer, at 414-297-3214 ext 8226 or on the Internet at
Larry_A._Wood@hud.gov
.
APPENDIX
Summary of
Laws, Codes, Standards, and Regulations:
Public Law
102-522,
Federal Administration Authorization Act of 1992, also
known as the Federal Fire Safety Act, includes
provisions that directly affect HUD-assisted housing.
The Act specifies where automatic sprinkler protection
is needed, but it also describes required levels of fire
alarm protection for all dwelling units, both PHA-owned
and those receiving Section 8 assistance. The Act’s
requirements differ based on if the units are newly
constructed, rebuilt, or existing. For new construction
and renovated units, the requirements also depend on the
height of the structure. For existing buildings, the
minimum fire alarm requirements are single/multiple
station smoke detectors, located outside of all sleeping
areas, on each level, battery or hard-wired, clearly
audible or interconnected.
24 CFR 965.805:
This describes the basic requirements for PHA–owned or
leased properties. It states that, “at least one
battery-operated or hard-wired smoke detector or the
greater number required by state or local codes, in
working condition, on each level.” There are hard-wiring
requirements for detectors in units occupied by
hearing-impaired residents. This section also states
that smoke detectors are required in the public areas,
including but not limited to laundry rooms, community
rooms, day care centers, hallways, stairwells, and other
common areas, of all PHA–owned or leased housing.
Local Codes:
Local codes might have slightly different requirements
for where smoke detectors are needed. However, all local
codes reference NFPA 72, or the National Fire Alarm
Code, as the standard for how to install the detectors
to ensure they work properly. Consult your local code
authority for more specifics about what the requirements
are for your jurisdiction. Keep in mind that codes
present MINIMUM requirements. A PHA can always provide
greater protection than the minimum allowable in the
code, but it must not provide less.
NFPA 72:
The National Fire Alarm Code covers basically everything
about smoke detection requirements including correct
placement, maintenance and testing requirements. The
local code officials are usually familiar with the
requirements of NPFA 72, which is updated every three
years. However, local code officials generally do not
inspect to ensure EVERY requirement of the code is met.
The officials might be inspecting for compliance to some
of the basic requirements only. The Code clearly states
that it is always the property owner’s responsibility to
ensure compliance at all times.
UPCS:
The REAC Compilation bulletin summarizes the
requirements for inspection. It states, “smoke detectors
within a unit must be operable and located on each
living level.”
PHAS:
PHAs are required to analyze local code and include
these local code requirements that are more stringent
than UPCS as part of its inspections. This is explained
in the
Instruction Guidebook for Completing Public Housing
Assessment System Management Operations Certification
Form HUD-50072
for the Management Operations Assessment Sub-System
(MASS). While this office might ask for this
documentation during a PHAS review, REAC inspectors will
only cite any non-working smoke detector or missing
smoke detector. This inspection deficiency is
categorized as an Exigent Health and Safety (EH&S)
deficiency requiring immediate correction.
HQS:
The inspection form asks the following: 1) Is there is a
working smoke detector on each level?; 2) Do the smoke
detectors meet the requirements of NFPA 74 and its
successor standards (NFPA 74 has been succeeded by NFPA
72)?; and 3) In a unit occupied by the hearing impaired,
is there an alarm system connected to the smoke
detector?
Additional HUD
guidance:
Notice PIH 99-11
(HA) – Fire Safety, issued Feb 17, 1999, also contains
helpful information regarding fire safety topics.
The Guide for
the Implementation of PL102-522 for Fire Alarm and
Automatic Sprinkler Installations,
contains detailed guidance on smoke detection and
automatic sprinkler issues such as how to choose a
qualified contractor. The guide is available at the
following website,
http://www.huduser.org/publications/destech/hudguide.html.
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