U.  S. Department of Housing and Urban Development

Office of Public and Indian Housing

:

Special Attention of: NOTICE PIH 99-11 (HA)

Secretary's Representatives;

State and Area Coordinators; Issued: February 17, 1999

Public Housing Hub Directors, Program

Center Coordinators, Troubled Agency Expires: February 28, 2000

Recovery Center Directors and Special
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Applications Center Director; Administrators,

Offices of Native American Programs;

Public Housing Agencies; Section 8 PHAs,

Tribally Designated Housing Entities (TDHEs);

Resident Management Corporations

Subject: Fire Safety

1.  [Purpose:]{.underline} The purpose of this Notice is to prevent loss
    of life and injury in public and Indian housing developments due to
    fire.

2.  [Applicability:]{.underline} This Notice applies to the following
    housing programs under the jurisdiction of the Office of Public and
    Indian Housing:

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a.  Existing public and Indian housing projects

b.  Public and Indian Housing Development

c.  Public and Indian Housing Modernization

d.  Section 8

-   Tenant-Based Rental Certificates/Vouchers

-   Project-Based Rental Certificates

-   Moderate Rehabilitation

e.  HOPE Programs for Public and Indian Housing

f.  Indian Housing Units Assisted Under the Native

> American Housing Assistance and Self Determination Act

3.  [Background:]{.underline} In an effort to maximize the safety of
    residents, housing authority staff and fire and rescue personnel,
    particularly in high-rise buildings, it is imperative that all
    public housing agencies, Tribes and Tribally Designated Housing
    Entities (hereafter collectively referred to as HAs) and Section 8
    owners comply with the provisions of the Fire Administration
    Authorization Act of 1992 (the Act). In September 1995, the
    Department issued a "Guide for the Implementation of PL 102-522 for
    Fire Alarm and Automatic Sprinkler Installations." This publication
    addresses three provisions of the Act affecting HUD-assisted
    housing: (1) four-story or higher multifamily buildings that are
    newly constructed after October 26, 1992, and for which: (i) housing
    assistance is used for the construction or (ii) a binding commitment
    is made, before construction begins, to provide housing assistance
    for the newly constructed property must be protected with an
    automatic sprinkler system and hard-wired smoke detectors both of
    which must be installed in accordance with NFPA requirements; (2)
    rebuilt, four-story or higher multifamily buildings that are rebuilt
    after October 1, 1994 and for which housing assistance is used to
    (i.) rebuild the property or (ii) a binding commitment is made
    before rebuilding begins, to provide housing assistance for the
    rebuilt property must be in compliance with Chapter 19 of National
    Fire Protection Association (NFPA) 101, the "Life Safety Code" which
    includes requirements such as hard-wired smoke detectors, automatic
    sprinkler systems, egress systems, emergency lighting, etc. and (3)
    **[all]{.underline}** other dwelling units receiving housing
    assistance must be protected by hard-wired or battery-operated smoke
    detectors installed in compliance with NFPA 72. The Guide can be
    obtained from HUD User by calling 1 800 245-2691.

4.  [Sprinkler Systems Inspections:]{.underline} For their respective
    properties, HAs and Section 8 owners should ensure that sprinkler
    systems are designed, installed, maintained and inspected to assure
    proper operation on **[all floors]{.underline}** and in all spaces;
    require management follow-up on all properties to ensure that
    inspections are conducted , identified corrections needed are
    completed and that required record keeping is maintained. Local Fire
    Department Officials should be invited and encouraged to conduct
    pre-plan tours of all properties to become familiar with the
    properties' layout, operation and specific occupant mix (see #5
    below). Particular care should be taken by HAs and Section 8 owners
    to ensure that subsequent maintenance work such as painting,
    plastering or other work by their staff or contractors does not
    inadvertently cover up or hide access to sprinkler system or
    standpipe building connections.

5.  [Preplanning Visits:]{.underline} HAs and Section 8 owners, for
    their respective properties, should invite and coordinate
    preplanning tours/visits with local fire department(s) to ensure
    that responding emergency fire services are familiar with:

-   the structure

-   built-in fire and emergency equipment

-   operational issues that could affect fire fighting

-   occupant mix of the facility having impact on fire fighting

-   overall size and design of structures

-   key building personnel and procedures for contacting them during an
    emergency.

Of specific interest to fire service personnel will be their
coordination of local

fire fighting standard operational procedures as related to the tactics
likely to be

used during an emergency in the facility. Issues like the size of hose
connections

and points of supply for fire fighting hose can vary with local fire
departments.

Issues such as the diameter of the hose, minimum amount of fire hose
needed to

reach a given area and locations of water supply connections can become
critical

for fire incident commanders, therefore, pre-planning visits and
coordination are

essential **[before]{.underline}** a fire occurs.

Although fire fighting tactics may vary from fire to fire, fires in
high-rise

structures are extremely dangerous and require a very precise delivery
of

resources, coordinated attack, sufficient water supply and evacuation of

residents. Therefore, it is essential that local fire departments visit
properties and

pre-plan their probable response to future emergencies likely to be
encountered.

6.  [Self-Closing Doors]{.underline}: Self-closing doors are an
    effective method for slowing down the spread of a fire providing
    sometimes critical, life-saving time for fire and rescue personnel
    to do their job and allow individuals to escape the fire or be
    rescued. It is imperative that where such doors are in place or
    required that they are unobstructed and that the self-closing
    mechanisms are fully operational at all times. In some situations,
    particularly in high-rise residential (elderly and family)
    buildings, residents may disable such self-closing mechanisms to
    avoid accidental lock-outs when temporarily stepping into a hallway
    or visiting a nearby neighbor. Such self-closing mechanisms should
    be included as a routine inspection item to ensure proper operation
    of the mechanism. In situations where the mechanism is not
    functioning due to resident action, management should treat this as
    a violation of the lease and take appropriate action on a case by
    case basis. The importance of the proper functioning of self-closing
    doors should be addressed during regular, on-going resident
    education programs on fire safety arranged by the HA and Section 8
    owners for their respective properties and conducted by local/State
    Fire Department officials. Additionally, emergency egress doors in
    residential properties should never be locked from the inside
    barring emergency egress. There are some exceptions to this in
    certain types of facilities, however, where this is necessary there
    are specific procedures that must be followed in accordance with
    local/State requirements.

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7.  [Smoke Detectors:]{.underline} Where battery operated smoke
    detectors are permitted, the removal of batteries from smoke
    detectors by residents is a serious problem which should to the
    extent authorized under the lease, be considered a lease violation
    and appropriate action taken on a case by case basis. Due to
    extensive problems with residents removing batteries, consideration
    should be given to replace battery operated smoke detectors in
    existing units with hard-wired detectors (with battery back-up)
    whenever possible - for example, when other wiring upgrades occur in
    a unit(s) or if wall finishes are being replaced in unit(s). Since a
    missing battery in a battery operated smoke detector will fail a
    unit during the Public Housing Assessment System (PHAS) inspection,
    the use of hard-wired smoke detectors should improve PHAS scores.
    Even though there may still be a problem with resident removal of
    back-up batteries, hard-wired detectors will increase protection
    even with back-up batteries removed except in situations where power
    failure occurs.

8\. [Fire Safety Inspections:]{.underline} Most model and local codes
require that facilities be inspected periodically by appropriate
local/State officials having jurisdiction over the property (for
example: local/State fire officials and/or local building officials).
HAs and Section 8 owners, for their respective properties, should ensure
that appropriate local officials who are responsible, are conducting
required inspections, ensuring that code violations (or suggested
improvements) are being appropriately addressed, and that local fire
department(s) are encouraged to conduct pre-plan visits to properties.
For instance, some of the primary standards affecting the fire safety,
maintenance and operation of properties are found in National Fire
Protection Association documents as follows:

o Sprinkler Systems NFPA 25

o Standpipe Systems NFPA 14

o Fire Alarm Systems NFPA 72

o Fire Extinguishers NFPA 10

o Emergency Exits/Lighting NFPA 101

To obtain these standards, contact the NFPA at 1 800 344-3555.

(Note: Property owners are responsible for ensuring that all fire
protection

systems and features are always in operating order in accordance with
local/State

codes which typically reference the NFPA standards and there are
inspection

protocols and records maintenance to be followed by HAs and property
owners

that are included in these standards.)

9.  [Evacuation Plan:]{.underline} HAs and Section 8 owners, for their
    respective properties, should ensure that there is a viable
    evacuation plan in effect that has been developed in consultation
    with local/State Fire Officials and ensure that residents, staff and
    the Fire Department are aware of the evacuation plan through ongoing
    Fire Safety education programs. HAs and Section 8 owners should
    confer with local/State Fire Officials to plan and schedule
    recommended fire drills for their properties to test the
    effectiveness of evacuation plans and ensure that all involved are
    familiar with evacuation procedures. Such procedures should address
    a variety of occupancy types and buildings. For example, special
    procedures and training will need to be developed, in conjunction
    with local/State fire officials, for buildings that house primarily
    elderly persons including those with mobility problems, disabled
    persons and or families with children.

10\. [Fire Safety Training:]{.underline} HAs and Section 8 owners, for
their respective properties, should ensure that residents are provided
information and training on how to prevent fires and what to do in the
event of a fire including information for residents of high-rise
buildings on what to do when a fire occurs and techniques for surviving
a fire. Such information should be provided to all new residents upon
leasing an apartment. This information and training can be provided by
local/State Fire Officials. Training for residents and staff should be
conducted on a regular, recurring basis - at least once each year. It is
recommended that a "Fire Safety Awareness Day" coinciding with National
Fire Prevention Week be held by owners each year for their properties.
Also, a hot-line for reporting fire safety violations could be
established either in conjunction with the locality or property
management.

(Note: Where HAs are conducting inspections of Section 8 or other
assisted housing - such inspections should, at a minimum, address
numbers 3, 4, 6, 7 and 8 above)

HAs are responsible for disseminating this Notice to current and future
property owners involved in their programs whose units are receiving
assistance under 2d, e and f above.

Resources/Publications:

U. S. Fire Administration

Federal Emergency Management Agency

16825 South Seaton Avenue

Emmitsburg, Maryland 21727

Telephone: (301) 447-1000

Guide for Implementation of PL 102-522 for Fire

Alarm and Automatic Sprinkler Installations

HUD User - Telephone 1 (800) 245-2691

National Fire Protection Association

1 Batterymarch Park

Quincy, MA 02269-9101

Telephone: (617) 770-3000

(Note: For NFPA Standards Publications and

technical assistance)

/s/ Harold Lucas

Assistant Secretary for Public and Indian Housing