Sprinkler and Fire Protection Installer Trade: Clarifications

Communiqué du commissaire des incendies

Sprinkler and Fire Protection Installer Trade: CLARIFICATIONS

Communiqué 2017-03

February 8, 2017

The present communiqué supplements Fire Marshal’s Communiqué 2017-02, Sprinkler and Fire Protection Installer Trade, issued on February 2, 2017.

The Ontario College of Trades (College) has been hosting discussions with the Sprinkler and Fire Protection Installer Trade Board (SFPI TB), the Canadian Fire Alarm Association (CFAA) and the Office of the Fire Marshal and Emergency Management (OFMEM) to clarify a number of points related to the application of new compulsory qualification requirements for the sprinkler and fire protection installer trade.  The purpose of this communiqué is to advise the fire service of a number of interpretations respecting Ontario Regulation 275/11 on which all parties (i.e. the College, SFPI TB, CFAA, and OFMEM) have recently agreed.

The scope of practice for the trade of sprinkler and fire protection installer, as set out in subsection 41. (1) of Ontario Regulation 275/11, Scope of Practice - Trades in the Construction Sector, is as follows:

"...

  1. Planning proposed installations from blueprints, sketches, specifications, standards and codes.
  2. Laying out, assembling, installing, testing and maintaining high and low pressure pipeline systems for supplying water, air, foam, carbon dioxide or other materials to or for fire protection purposes.
  3. Measuring, cutting, reaming, threading, soldering, bolting, screwing, welding or joining all types of piping, fittings or equipment for fire protection of a building or structure.
  4. Installing clamps, brackets and hangers to support piping, fittings and equipment used in fire protection systems.
  5. Testing, adjusting and maintaining pipe lines and all other equipment used in sprinkler and fire protection systems.
  6. Operating and utilizing necessary tools and equipment for the installation of sprinkler and fire protection systems.”

Recent discussions by the parties named above have centered on clarification of the term “fire protection installer”, the trades encompassed by this term, and the qualification requirements that apply to these trades.  Although a number of questions remain pending, to date, all parties have agreed on the following interpretations: 

  • The term “fire protection system” encompasses various types of systems relating to fire protection, including fire suppression systems and fire alarm systems.
  • There is a distinction between fire suppression systems (including automatic sprinkler systems, special fire suppression systems, on-site fire protection water supply systems, and hose and standpipe systems) and fire alarm systems.
  • In light of this distinction, qualification requirements of persons inspecting, testing and maintaining (includes repairing, replacing and altering) components of a fire protection system apply as follows:
  • Persons who perform annual tests or annual inspections, and persons who repair, replace or alter components of a fire alarm system shall comply with qualification requirements outlined in Section 1.2 of Division C of the Fire Code (Ontario Regulation 213/07, as amended) and shall perform the work in accordance with relevant requirements included in Section 6.3 of Division B of the Fire Code.  These Fire Code requirements are unchanged and continue to be in effect.
  • Persons inspecting, testing and maintaining components that are specific to a fire suppression system fall within the scope of practice provided in section 41 of Ontario Regulation 275/11.  As such, they shall comply with qualification requirements stemming from the compulsory trade1 designation under Ontario Regulation 20/15 and shall perform the work in accordance with relevant requirements, including requirements in Part 6 of Division B of the Fire Code.
  • With respect to inspecting, testing and maintaining components that are both part of a fire alarm system and part of a fire suppression system, the purpose of the particular activity being conducted shall dictate who is permitted to complete the work as per the statements above.  This means that persons in either of the categories of qualified persons mentioned above are permitted to test those components of the system that they deem relevant for complying with Part 6 of Division B of the Fire Code.  

Although interconnected smoke alarms were not specifically mentioned above as a fire protection system, persons who perform annual tests or maintain interconnected smoke alarm systems also need to comply with qualification requirements outlined in Section 1.2 of Division C of the Fire Code and shall perform the work in accordance with relevant requirements included in Article 6.3.2.6. of Division B of the Fire Code. These Fire Code requirements are unchanged and continue to be in effect.

Notwithstanding the new qualification provisions for the sprinkler and fire protection installer trade introduced by the College, the only qualification requirements enforceable by the fire service continue to be those referenced under Section 1.2 of Division C of the Fire Code.  The Chief Fire Official continues to have discretion over the extent of enforcement of these requirements when concerns are noted respecting the qualification of persons performing work on fire alarm systems.  Any concerns with the qualification of persons performing work on sprinklers or other fire suppression systems may be discussed with the building owner and/or reported to the College at the discretion of the Chief Fire Official.

With the exception noted below, the qualification of persons in the sprinkler and fire protection installer trade may be ascertained by searching the College’s Public Register.

The qualification of persons performing annual tests and inspections, or repairing, replacing or altering components of a fire alarm system may be ascertained by searching the following:

Discussions between all parties remain ongoing.  Additional clarifications regarding the application of the new sprinkler and fire protection installer compulsory qualification requirements will be communicated to the fire service by the OFMEM in the future, as they become available.  Some matters currently under discussion are as follows:

  • the extent to which non-tradespersons may perform daily/weekly/monthly checks, tests and inspections of fire suppression systems required by Part 6 of Division B of the Fire Code;
  • persons that may perform testing required for the commissioning of fire suppression systems under the Building Code;
  • qualifications of persons installing and verifying new fire alarm systems; and
  • qualifications of persons installing special fire suppression systems (e.g., dry chemical agent, gas extinguishing agent, etc.). 

Questions regarding matters explained above should be directed to the College; staff members can be reached by telephone at (647) 847-3000 or 1-855-299-0028 (toll free), or by using the e-mail form on the College’s Web site.

 

1 A compulsory trade, as defined by the Ontario College of Trades, is a trade in which registration as an apprentice or journeyperson candidate, or certification as a journeyperson, is mandatory.