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HomeMy WebLinkAboutIndustry Bulletin 2023-002 Making Work Available for Inspection BILLY P. ALCORN INTERIM FIRE CHIEF Jonathan Chew, Deputy Fire Chief Prevention and Support Services Division (559) 621-4101  FAX (559) 457-1279 Fresno Fire Department  911 H Street  Fresno, CA 93721-3082 “To protect and put service above all else.” FIRE INDUSTRY BULLETIN 2023-002 SCOPE Information for all permit applicants and associated contractor’s, etc. engaged in permit construction (including new installations of all types, tenant improvements, alterations, etc.) and making all work available for Fresno Fire Department (FFD or Department) inspection. PURPOSE The purpose of this industry bulletin is to notify applicable stakeholders of requirements related to the inspection of, and access to, work which is required to be made available for inspection. These requirements are clearly noted in California Fire Code (CFC) §108 (et. al.). BACKGROUND On several occasions, permit applicants engaged in construction activities have regularly (and illegally) covered work in violation of the requirements found in the CFC and FFD permit requirements. To prevent these violations from occurring, FFD staff have routinely required a standard note be applied to many types of construction documents. This note explicitly states that it is the “contractor’s” obligation to make all work available for inspection. The note does not however, explicitly state which contractor is responsible to make the work available for inspection, since this issue is clearly addressed in the CFC (see below). For reference, the text of 2022 CFC §108.3 Concealed work, is quoted here: “It shall be the duty of the permit applicant to cause the work to remain visible and able to be accessed for inspection purposes. Where any installation subject to inspection prior to use is covered or concealed without having first been inspected, the fire code official shall have the authority to require that such work be made visible and able to be accessed for inspection. Neither the fire code official nor the jurisdiction shall be liable for expense entailed in the removal or replacement of any material required to allow inspection.” Fire Industry Bulletin 2023-002 July 17, 2023 Page 2 As noted in the International Code Council (ICC) code commentary for this section, “The section requires that any work to be concealed upon completion must remain exposed until an inspection is made. If the work requiring inspection is covered up before the inspection takes place, the fire code official has the authority to require removal of the concealing construction. The section also makes it clear that any expense incurred in removing or replacing material that conceals an item to be inspected is not the responsibility of either the fire code official or the jurisdiction. Obviously, this can be a time-consuming and expensive procedure that can be eliminated by good communication and cooperation between the contractor or permit holder and the fire code official.” FFD’s position on this issue is clear: Concealed work which is not made available for inspection by the permit applicant will not be approved, and no permit sign off will occur. INFORMATION FFD has now been requested to define the scope and terms of CFC §108.3 and “making work available for inspection”. To be helpful, it is perhaps better to define what “making work available for inspection” is not. Any inspection which requires the use of a visual aid (inspection camera, photographs, videos, etc.) does not meet the intent of CFC §108.3 or “making work available for inspection”, and as such is prohibited. This prohibition does not include Remote Video Inspections (RVI) which are covered by separate FFD policies. Similarly, cutting access holes in ceilings for FFD staff to put their head through (with or without the need for an additional aid such as a ladder), opening holes in drywall along piping or wiring routes (while leaving the remainder of the ceiling, floor or wall enclosed), also does not meet the intent of CFC §108.3 or “making work available for inspection”, and as such, is prohibited. Finally, leaving sections of adjacent construction elements open, including, but not limited to, ceilings, floors, walls, etc., so that FFD staff are required to inspect the work at an oblique, side facing, or turned angle (with or without the need for an additional aid such as a ladder) also does not meet the intent of CFC §108.3 or “making work available for inspection”, and as such is prohibited. All items related to the permitted work which is to be inspected by FFD must be afforded access for inspection, and a key specification for all overhead inspections is that they are intended to be conducted from the floor level. Generally, this means that there should be no special equipment needed for these inspections, such as ladders or lifts. Fire Industry Bulletin 2023-002 July 17, 2023 Page 3 However, to ensure that FFD staff are able to meet the ethical and legal requirements for completing an inspection, permit applicants must have properly maintained and serviced equipment like ladders, lifts, etc. (in good condition) available as conditions warrant (i.e., high ceiling buildings, etc.). This equipment may be used so an FFD staff member can verify installations or components that cannot be visually verified from the floor level. Examples of installations or components that may require additional (physically closer) scrutiny, may include, but are not limited to, fire sprinkler hanger screws, seismic sway brace attachments and fasteners, candela ratings on fire alarm notification appliances, support of wiring or cabling, etc. Conditions where work is considered “not available for inspection” and not in compliance with CFC §108.3 includes, but is not limited to, any of the conditions noted above, and similar conditions that are not specifically articulated in this bulletin. Additionally, the provision of unsafe equipment (i.e., ladders, lifts, etc.) that are made available at a construction site for FFD staff use, but which are deemed by the affected FFD staff member to be deficient, is also considered a sufficient condition to discontinue an inspection, and to institute an associated reinspection fee. When, in the opinion of the Fire Marshal (or designee), any work is considered not in compliance with the intent of CFC §108.3 or is “not available for inspection”, the inspection may be discontinued, and a reinspection fee assessed for the inspection. NOTE It is the permit applicant’s obligation to make the work available for inspection in accordance with the minimum requirements noted in the CFC. It is also the permit applicant’s obligation to coordinate construction schedules, trades, etc. as necessary to ensure work remains available for inspection in accordance with the minimum requirements noted in the CFC. Construction schedules, opening dates, etc. are completed without FFD input, and as such are the obligation of the permit applicant to provide sufficient time for the work to remain available for inspection based on FFD’s current inspection schedule. All permit applicants should routinely inquire as to FFD’s current inspection schedule as a project progresses. This notice is effective July 17, 2023.