Fire Drill Timing
by Brad Keyes, CHSP, on Mar 15, 2021 1:00:00 AM
Q: Has a clarification been issued for what “varying conditions” means in 2012 edition of the NFPA 101 Life Safety Code 126.96.36.199? Our accreditation organization requires fire drills vary by at least one hour from quarter to quarter for each shift, through four consecutive quarters. For example, consecutive first shift drills of 9 a.m., 10:30 a.m. and 9 a.m., although greater than one hour apart, would be considered a pattern. Fire drills should be spread out over the full shift. The question I have is that we are being told this is how it must be done per the accreditor and I’m fine with that, but the code states ‘varying conditions’ and not times. Can you please clarify?
A: Your accreditation organization is one of many authorities having jurisdiction (AHJs) that you have that enforce the Life Safety Code. Section 188.8.131.52 of the 2012 LSC says the AHJ decides whether or not the facility is compliant with the LSC. This means they have the right (and responsibility) to make interpretations on the LSC standards.
You are correct that the LSC does not provide ‘times’ as a varying condition under section 184.108.40.206, but the AHJ has the right to interpret the phrase ‘varying conditions’ in 220.127.116.11 to mean at least 1-hour difference in the start of fire drills on the same shift but different quarters. Actually, your accreditation organization is being rather lenient as most state agencies that survey for CMS require a 2-hour difference in start times of fire drills.
Welcome to the wonderful world of Life Safety compliance. You have just learned that the AHJs keep making new interpretations regarding the same standards. Compliance with the LSC is a moving target, and the interpretations made by the AHJs change. And to make things worse, not all AHJs agree on the interpretations.