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

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.