36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

215 Fire Alarm Systems

Section 215 covers fire alarms, which are required to comply where audible fire alarms are provided. Provisions are included that are specific to public use and common use areas (215.2), work areas (215.3), transient lodging guest rooms (215.4), and residential dwelling units (215.5).

Substantive changes made in the final rule concern existing facilities, work areas, and other types of emergency alarm systems. Editorial changes include the addition of references to transient lodging facilities and residential dwelling units, which are subject to specific requirements for fire alarms in other scoping provisions in sections 224 and 233, respectively.

Fire alarm systems required to be accessible must have visual appliances which serve people who are deaf or hard of hearing. The advisory committee had recommended an exception that would require visual appliances in alterations only where a fire alarm system is upgraded or replaced or a new system installed. Such an exception would recognize that fire alarms are often complex building-wide systems that cannot necessarily be brought into compliance with requirements for visual appliances on a piecemeal basis. The Board had not included this exception in the proposed rule because it considered the basic application provisions for alterations in section 202.3 to be sufficient. In general, these provisions apply requirements of the guidelines according to the scope of an alteration to the degree that compliance is "technically feasible." The Board has reconsidered this decision and has included an exception in the final rule for consistency with the International Building Code and the National Fire Protection Association code (NFPA 72). The exception clarifies that alterations affecting fire alarm systems partially, or in a limited manner, do not trigger requirements for visual appliances (215.1, Exception). However, alterations that involve the upgrade or replacement of an existing alarm system or the installation of a new system are subject to the requirements for visual alarms.

The Board intends the exception at 215.1 to be applied in the same manner and to have the same meaning as is common practice in a similar exception provided in the model codes upon which this exception is based. Upgrades to the fire alarm system are changes to the system infrastructure and are not changes to individual system components. For example, replacing the main fire alarm control panel which permits fire alarms to be better integrated with other building systems or with off-site monitoring services would be considered an upgrade to the fire alarm system. In addition, replacing or increasing the main power supply to the fire alarms would be an upgrade to the fire alarm system. However, adding or relocating individual visible or audible notification devices is not an upgrade to the system.

Comment. The proposed rule included a requirement for visual alarms in employee work areas that are served by audible alarms (203.3). Employee work areas are exempt from most other requirements in the guidelines under an exception at 203.9. In order to gauge the impact of this requirement, the Board posed several questions that sought comment on: how frequently alarm systems are typically replaced or upgraded in such a manner that the requirement would be triggered in existing facilities (Question 5), other alternatives that would provide a comparable level of life safety for employees who are deaf or hard of hearing (Question 6), and limiting the number of visual appliances for the benefit of people who have photosensitive epilepsy (Question 7). Comments indicated that alarm systems are typically replaced on a 10 - 15 year cycle. However, some indicated that the electrical service supporting the alarms is not necessarily replaced or upgraded when alarms systems are, which may preclude opportunities to easily add more appliances to the system as part of the work. Responses on alternative methods included low tech suggestions such as pagers, a buddy system, and other solutions that involve non-fixed elements or operational methods and are thus outside the scope of these guidelines. Many people who have photosensitive epilepsy and organizations representing them acknowledged that visual alarms are necessary in public use and common use areas but urged the Board to treat employee work areas differently. These commenters expressed concern that visual appliances in employee work areas could pose barriers to the employment of people who have photosensitive epilepsy. Activation of visual appliances in work areas on an as-needed basis does not provide a practicable solution as most codes, standards, and local laws prohibit deactivation of fire alarm appliances.

Response. The Board has removed the requirement for visual alarms in employee work areas. Instead, the final rule only requires that work areas be designed so that compliant visual appliances can be integrated into the alarm system (215.3). This provision, which applies only where work areas have audible alarm coverage, will facilitate accommodation of employees who are deaf or hard of hearing as required under title I of the ADA. The specification does not require electrical service to support wiring for visual appliances throughout all employee work areas. The specification merely requires that the wiring be placed so that it can be tapped into from the location of employee work areas. The Board believes that the surplus electrical service typically provided should be sufficient for the incidental installation of visual alarms.

Comment. The Board proposed covering facility alarm systems (other than fire alarm systems) that do not instruct occupants to evacuate the facility but provide other warning information, such as those used for tornado warnings and other emergencies. The proposed requirement (215.2 in the proposed rule) specified audible and visible signals but did not reference any specific technical criteria, including any addressing placement or photometric characteristics. Instead, the Board sought comment on what these characteristics should be, particularly where differentiation from fire alarm system signals is important (Question 9). Many commenters supported ensuring that such alarm systems are accessible to people who are deaf or hard of hearing, but no information was received on appropriate technical specifications for guidelines that are national in scope.

Response. The scoping requirement for other types of alarms has been removed in the final rule. The Board did not want to scope an element absent reliable technical specifications. The Board will consider bringing this matter to the attention of international model codes and standards organizations in the future.