In my previous life as an Authority Having Jurisdiction, I was often asked for variances from prescriptive requirements for active or passive fire protection. Many times, I was presented with administrative controls as an equivalent means to achieve the same level of safety. I was always apprehensive to approve these alternative approaches, because administrative controls are dependent upon a person(s) to implement and manage them. In one case, I received a request to limit the specific uses of a chemical fume hood to get around the combustible ducting limitations in NFPA 45. In another case, the request was to eliminate an active fire suppression system and replace it with a manual release system. Having investigated numerous fires where administrative controls led to deaths and injuries because of poor management and implementation, I took all administrative control requests very seriously and rarely approved them. In the event of an emergency, I prefer to rely upon an engineered system (properly designed, installed, and maintained), rather than a person, to perform a critical safety function.

There are certain instances, however, where following the prescriptive code can introduce a higher degree of risk to occupants, and in those cases, administrative controls may be the only option. When this occurs, it is incumbent upon the safety professional, whether you are the approver or requester, to ensure the following:

1) The administrative control(s) are well documented within a policy which is overseen by more than one individual.

2) The administrative control(s) are communicated outside of the policy through user training and equipment signage.

3) The policy identifies the individuals responsible for the implementation and management of the administrative control(s) by holding one individual primarily accountable but ensuring secondary accountable is also assigned to others.

3) The policy identifies a succession plan in the event that the responsible individuals are reassigned or leave the company.

4) The policy is reviewed and reconsidered on a recurring basis and has multiple points of oversight.

The most common fatal flaw with administrative controls is that they die when the person responsible for control management and implementation is reassigned or leaves the company. Communication and awareness of administrative controls should not require institutional knowledge. It's like that mystery light switch in your house that doesn't seem to control anything- only the previous owner knows what it does. When it comes to fire safety, there should be no need for a historical perspective, and there should be no questions as to how safety is implemented, monitored, controlled, or ensured!

We are excited to welcome our newest FPE intern, Robert Wachter. Rob is a student in the fire protection engineering program at the University of Maryland, College Park. Since starting with FireTox, Rob has been hard at work expanding his knowledge of fire investigation, fire research, fire toxicity, and fire modeling. We believe that internships are an important part of educational and career development. We strive to expose our interns to hands-on experiences that will help them to connect their academic life with their career aspirations. To learn more about our FPE Internship Program, email

On November 21, 1980, a fire broke out in a non-sprinklered restaurant on the first floor of the 26-story MGM Grand Hotel in Las Vegas, Nevada. The fire quickly spread throughout the first floor of the hotel pushing smoke into the upper floors. In total, 85 people died. The majority of decedents, most of whom where located on the upper floors of the building, died from smoke inhalation. A comprehensive investigation report by the Clark County Fire Department included the toxicological data for the 85 victims. The data showed that the majority of decedents had lethal levels of carbon monoxide and cyanide, either singularly or combined.

Six years later, on December 31, 1986, an incendiary fire broke out in the Dupont Plaza Hotel in Puerto Rico resulting in 96 deaths. The fire started in the hotel ballroom in stacks of corrugated boxes containing furniture. Different from the MGM Grand Fire, however, the majority of decedents in the Dupont Plaza Hotel fire were located on the main floor. In comparing victim blood toxicants from both the MGM Grand and Dupont Plaza Hotel fires, Levin et al found two trends: 1) those intimate with the fire had significant burns but below lethal concentrations of carbon monoxide and cyanide in their blood, and 2) those remote from the fire had non-lethal burns but lethal concentrations of carbon monoxide and cyanide in their blood. Levin's findings are the same as those found by Purser et al in analyzing UK fire victim autopsy data and investigation reports.

The findings from the MGM Grand and Dupont Plaza Hotel fires highlights the correlation between victim location and fire origin as well as first material ignited and blood toxicant concentrations. NFPA 921 requires that the fire investigator test their origin and cause hypotheses against all the known facts and data. In testing a hypothesis, the fire investigator must also consider the victim's autopsy and toxicological data; to often, however, the importance and relevance of this data is overlooked. The origin and cause of the fire must be consistent with the autopsy data. Otherwise said, the fire must be capable of producing the heat and toxicants necessary to cause the victim's burns and blood toxicant concentrations. To learn more about the use of forensic toxicology in fire origin and cause investigation, download our Fire Technology article or contact us.

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