(Posting Date: 06/05/20)

May 5, 2020

CFAA’s mission is to “maximize the effectiveness and use of fire alarm systems in the protection of life and property in Canada.”

This Bulletin, in addition to previous Bulletins, is intended to provide assistance to members and technicians to address Codes, Standards and Bylaws compliance issues as we go forward under the constraints imposed by the COVID-19 pandemic. 
CFAA and most government agencies consider the inspection, testing and repair work provided by our members to be an “essential service” when buildings are either empty or fully occupied.  These are both conditions that cause buildings to be operated outside their normal design and operating parameters. Manufacturing and installation of new fire safety systems are also considered essential services in many Provincial jurisdictions where construction is underway and new equipment is needed.
We recognize and fully endorse the need to keep you, your clients and the public safe from the spread of the virus, while ensuring that there is complete adherence with federal, provincial and municipal government directions regarding COVID-19. CFAA members need to work with the fire services, building owners, managers and occupants to develop safe processes for conducting fire testing and inspections during this period.
Compliance with applicable Building and Fire Codes is required by law. It is important that you document any deviations related to compliance requirements. This includes meetings with building owner/operators and/or Authorities Having Jurisdiction (AHJ) where there has been an agreement to reduce the normally required level and frequency of fire alarm testing and inspection services. 
In the case of a residential building, for example, where entry to suites is disallowed by agreement with the AHJ there should be a record of this-agreement. If a building owner, property manager or occupant is refusing entry then that should be documented. In addition, you should document if you are asked to perform work in an unsafe environment and cannot complete all or part of the contracted work.

Please refer to the template that you may wish to use to record any agreement or refusal and attach it to your inspection report. A copy should be sent to those named in the agreement regardless of whether they signed it or not.

Template Form:

Authorities Having Jurisdiction (AHJs) rely on the requirements in ULC Standard S536: Inspection and Testing of Fire Alarm Systems, along with other National Standards to help determine compliance with Building and Fire Codes.  The ULC 536 Standard includes requirements that recognize some devices may not be accessible and makes provisions for identifying and documenting the particular condition. Where a satisfactory and safe approach to testing a device cannot be achieved, that device should qualify as an inaccessible device during an inspection, under COVID-19 conditions.
Your inspection report should specifically indicate the inaccessible device(s) as per the Standard.  This should further be acknowledged by signature from the AHJ or building owner or operator.
We feel it is important to continue to provide our essential services without delay where fire alarm testing and inspections can be conducted safely, while also ensuring complete adherence to applicable Codes, Standards, Bylaws and emergency public health orders regarding COVID-19.
It is therefore important that fire service companies work with the building owner/operators and AHJs to determine how best to proceed with testing and inspection under the restraints of COVID-19 procedures.  If you are denied access to a building by a building owner or manager, it is recommended that you contact the local fire services for further direction and agreement to the proposed testing regimen. Again, we suggest that you attach a record of the discussion and agreement to your test report with a copy to those referenced in the report.
For ongoing updates related to COVID-19 situation please refer to the CFAA website at