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The use of administrative controls in place of active or passive fire protection systems

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!


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