This Total Cost of Ownership (TCO) model uses the following assumptions:
•The base system is for a single site with 16 card readers and a requirement for ID badges, wireless locks, and video surveillance.
•The initial capital and installation costs for the IT hardware and software licenses have been included.
•Items common to all systems such as card readers, locks, wiring, cameras and recording devices have not been included.
•We have assumed that the customer purchases the software maintenance that allows them to remain on a supported version of the application and database for the entire five years.
•In the on-premise model, we have assumed a one-time refresh in the computing hardware and operating system.
•We have assumed a data center infrastructure cost of $75 per month for the on-premise solutions. This cost includes rack space for a 1U server along with a 2 Amp power budget and 5 Mbps bandwidth allocation.2
•We have used either the competitors’ hardware/software bundle or a direct quote from a prominent computer hardware provider based on the datasheet specifications to estimate the cost of computing hardware for the on-premise solutions.
•For the on-premise solutions, we have estimated IT management and database administration costs basis at $800 per year. This includes 16 hours of IT services for general administration, monitoring, patch management, system back-ups and database administration at $50 per hour.Many additional factors are often included in a complete TCO analysis, but we found that these vary so widely from organization to organization that they could not be included in a meaningful generic model. Thus, we excluded such considerations as:
•Organizational cost of server downtime, including lost productivity and explicit cost of IT and security staff time to remediate failed systems.
•Business risk cost of system unavailability, including lost revenues, liabilities due to service level agreements, and loss of good will.
•The costs for continuous threat monitoring, intrusion prevention, data security audits, and data privacy protections.1All systems were configured to be “feature equivalent”. For example, any required software options to support video integration, wireless locks and ID badging, were included but not the actual hardware. These figures are derived from actual quotes received from a co-location service in December of 2015. The Gartner IT Key Metrics Data study estimates the total cost of ownership for a physical WINTEL server is $8,260 per year.
Annual Cost Comparison With Redundant On-Premise Solutions As should be expected, the charts below depict a wide variation in the distribution of costs between the various solutions. The majority of the expenses (54%) for the Brivo cloud solution are associated with the monthly subscriptions. These subscriptions incorporate the software and hardware expenses as well as operational costs for the overall platform. By comparison, 78% of the cost for the on-premise solution is tied up in on-premise and IT infrastructure. The total expenses over five years for the 16 door systems were calculated with the following results:Comparison Of Cost Distribution With Non-Redundant On-Premise Solutions Brivo Onair Total Cost Of Ownership (TCO)
Comparison Of Cost Distribution With Redundant On-Premise summary clearly shows that the SaaS solution is the most cost efficient option. SaaS solutions, owing mainly to the reduced operational and IT expenses, are generally able to provide a much greater variety of functions than server based solutions, which often charge additional fees for high availability and each piece of added functionality.The cost savings of using a SaaS solution for access control are clear. Extending the cost savings of a SaaS solution even further, the above example does not factor in less visible, yet just as important functionality such as automatic upgrades to applications and system software, active data protection measures and unlimited linear scalability. If this additional functionality were costed out, the SaaS solution takes an even greater leap forward in cost savings over the server-based solutions.Brivo Onair Total Cost Of Ownership (TCO)
Added Benefits Of The Brivo Onair SaaS Solution ..In addition to the direct cost advantage of the SaaS solution, there are a number of additional benefits, which have not been quantified in this study. The chart below provides a quick summary of the additional values inherent in the SaaS solution.The data represented thus far have primarily addressed the single-site case with 16 doors. Qualitatively, the SaaS solution fares even better in a multi-site application, primarily due to additional cost penalties that the server-based solution must pay during the initial setup, along with higher ongoing IT expenses due to the complexity of managing the security management applications over a far-flung network. The SaaS solution is particularly beneficial in this environment because, as a web application, it is intrinsically multi-site from the inception.Another major advantage to SaaS solutions over server-based solutions is scalability. Our analysis did not include the often-significant costs to enlarge on-premise solutions in terms of door capacity and administrative clients. Many server-based solutions require fixed client installations for each site, increasing the cost of acquisition and the on-going expense to manage remote client software. As mentioned with the case study example above, initial setup costs along with higher IT expenses during installation prove out the superiority of the SaaS model over server-based options.Brivo Onair Total Cost Of Ownership (TCO)
Conclusions: As we have shown, our study indicates that using a SaaS solution for a security management platform –specifically electronic access control, ID badging and video –provides major, demonstrable cost savings. In addition to ease of installation and ease of use, the market’s increasing awareness of the cost benefits of the cloud are driving the substantial growth in the installation of such systems.These findings have several implications for system integrators and end users. The first is that –other things being equal –both groups would be well advised to calculate the relative cost of any proposed physical security solutions before making a decision on what to offer a customer (in the case of integrators), or what to ultimately buy (in the case of end users). The second implication is that the savings provided by SaaS can also be extended to other security services, such as hosted video, intrusion detection, remote monitoring, and many others. This is an important implication for the vast majority of business owners, as most businesses are not large enough to be able to absorb the cost of dedicated server solutions into a larger IT infrastructure. What this means is that such business owners can expect to enjoy enterprise-grade service levels at lower TCO points than at any time in the history of electronic security.Brivo Onair Total Cost Of Ownership (TCO)
CONTACT AAA ALARMS TODAY FOR EXPERTISE IN ELECTRONIC SYSTEMS FOR DETECTION, LOCKDOWN, ALERT, AND RESPONSE WITH LIVE VIDEO SURVEILLANCE/SECURITY CAMERAS AND GUN SHOT SOUND DETECTION ELECTRONICS
ACTIVE SHOOTER Contents Acknowledgments.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii Introduction to Active Shooter Programs, by Jason Thomas Destein. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 The Six Phases of the Attack, by Linda Watson, CPP. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Using Situational Awareness to Observe Pre-Attack INdicators, by Brad Spicer.. . . . . . . . . . . . . . . . . . . . . . . . . . 11 Proactively Preventing Active Shooter—Post-Incident Data, by Rick Shaw.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Lessons Learned, by Lawrence J. Fennelly.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 Public Safety and School-Sponsored Onsite Training Programs for Emergency Responders, by Jim McLain, CPP, FMP .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Behavioral Threat Assessment Teams, An Ounce of Prevention, by Jason Stone.. . . . . . . . . . . . . . . . . . . . . . . . . 25 Preventing an Active Shooter Incident, by Paul Timm, PSP.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Buying Time—Realistic Hardening of the Target at the Classroom Door, by Jim McLain, CPP, FMP.. . . . . . . . 30 K-12 as Soft Targets, by Dr. Jennifer L. Hesterman, EdD. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 When EMS Arrives on the Scene, by Michael J. Fagel, PhD, CEM.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 Behaviorial Cues, by Inge Sebyan-Black, CPP.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 To Arm or Not to Arm…Teachers, by Jason Thomas Destein.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 Appendix A: Tabletop Exercise, by Victor Cooper CPP.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 Appendix B: Shootings on the Rise, by Mark Tarallo.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 Appendix C: The Best Defense, by Laura Spadanuta.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 Appendix D: Early Warning, Timely Respone: A Guide to Safe Schools, U.S. Department of Education.. . . . . 57 Appendix E: Conclusion from ASIS Workplace Violence Prevention and Response Guideline, ASIS International Standards and Guidelines.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 Active Shooter ii ASIS School Safety & Security Council According to the FBI, the frequency and lethality of active shooter incidents in America is increasing. More than one in four (29%) of these tragedies has occurred at educational institutions. Schools and universities must be prepared to not only respond to these incidents, but to also prevent them. Fortunately, when campuses properly prepare in advance to these emergencies, those prevention efforts also address many other vulnerabilities, such as workplace violence, bullying, individuals with mental health and addiction challenges, harrassment, emergency management (natural disaster as well as man-made), and even public health crises. Robin Hattersley, Executive Editor, Campus Safety A good friend of ours is a retired school teacher who has dedicated thirty-seven hardworking years to the profession. Proud of what he had achieved, he took us over to his school for a tour and see the flower garden he had planted. Before we got to his garden, we observed four doors propped open. Embarrassed, “It wasn’t called for. They would have been secured if I was still here,” he said. This white paper is a part of a series prepared by the members of the School Safety & Security Council. We are an active council. Our members are from colleges and universities, K to 12, and consultants. This group has a deep passion for the safety of children. This paper address different approaches to Active Shooter situations, but ultimately we must think proactively and take some action to protect individuals if the unthinkable does happen. Do not be complacent and take the approach of, “it can’t happen here.” We are all vulnerable. The frequency as well as the effect of Active Shooter appears to be increasing in this country. Being prepared is the key to survival and saving lives. In this paper, Jennifer Hesterman will make a great point when she ask what the cost is of not securing your school. We ask you to carefully think about these words. Take some action. Get prepared. Research your industry and determine what works best in your particular situation. The response will not be the same for everyone. Different environments require different responses. For example, the response for an elementary school during an Active Shooter situation will not be the same as that for a university campus or a high-rise office building. Develop emergency procedures and conduct active drills with local emergency responders. Above all, train everyone—employees, security personnel, students, faculty and staff. You will need them to know the appropriate response and what actions they should take. My sincere thanks goes out to all the members of the School Safety & Security Council for their hard work in putting this paper together and to our CVP, J. Kelly Stewart, CPP for his kind words of support. Lawrence J. Fennelly, School Safety & Security Council (Past Chair and Current Member) Loss Prevention & Crime Prevention Council (Past Chair and Current Member) Active Shooter 1 ASIS School Safety & Security Council Introduction to Active Shooter Programs by Jason Thomas Destein How many Active Shooter programs are out there today? Reportedly “Run-Hide-Fight” has been lowering the number of workplace violence fatalities over the years and would be a good model to follow except K-12 children cannot comply with the “Fight” component of the program. There is ALICE, which is available at a national level. “Lock out, Get out, and Take out” and ONE are yet others. These are all great programs in their own way, and ultimately there is really no wrong program since their true intent is using them to save lives. But let’s face it, each person has their own style and way they react to situations during stressful events, and an active shooter event is certainly very stressful. To be clear, there is no perfect program out there. You find a program that fits your needs, your style, so when you have to use it, you know instinctively what to do. This section lists these programs to discuss the pros and cons of each to help you reach your decision or to explore further options. Run, Hide, Fight Run, Hide, Fight is based on the premise that during an active shooter situation there are steps that you follow when you hear gunshots fired. Run • Find a path and attempt to evacuate • Evacuate whether others agree or not • Leave your belongings • Help others Evacuate • Prevent others from entering • Call 911 If you are not able to run, then you are encouraged to: Hide • Lock or block door • Silence cell phone • Hide behind large objects • Remain quiet • Stay out of shooters view • Provide protection if shots fired in your direction • Not to trap or restrict your options or movement Active Shooter 2 ASIS School Safety & Security Council If you do not have the ability to hide, then the last option is to: Fight • Attempt to incapacitate the shooter • Act with physical aggression • Improvise weapons • Commit to your actions It should be noted that “Run. Hide. Fight: Surviving an Active Shooter Event” is a U.S. Department of Homeland Security Grant Funded Project of the Regional Catastrophic Planning Initiative. It was produced by the City of Houston Mayor’s Office of Public Safety and Homeland Security.1 Lock Out, Get Out, Take Out Lock Out • By adding locks to all classroom doors and keeping them locked while in class. Also adding a lock and video entry system to the main entrance for all visitors to use. • Barricade all doors during a situation. Get Out • Anything goes when you are in harm’s way, like breaking windows to use as the nearest exit. Take Out • Anything goes, once again. When confronted and no other option is available, you do what you have to do. Whether teaching how to respond to workplace violence in an office, factory/retail setting or college campus, our consulting firm uses the “Run, Hide, Fight” video as part of our curriculum. The only additional information we add is a reminder that “Run, Hide, Fight” is not linear. You may be in a situation when confronted by an active shooter, and the only logical choice is to fight before you can run or hide. After a discussion about the video, people often ask if “Run, Hide, Fight” should be taught in the K-12 setting. The short answer to this question is “no.” The long answer is much more complicated. 1 Ready Houston, www.readyhoustontx.gov. http://www.youtube.com/watch?v=5VcSwejU2D0 Active Shooter 3 ASIS School Safety & Security Council Schools Must Keep ‘In Loco Parentis’ in Mind It is important to remember, “Run, Hide, Fight” is shown in an office setting and not a school. Everyone depicted in the video is an adult responsible for themselves and their own decisions. At 1:45 p.m. in the video, viewers are instructed to: “First and foremost, if you can get out, do. Always attempt to escape and evacuate, even when others insist on staying. Encourage others to leave with you, but don’t let them slow you down with indecision.” K-12 schools operate under a different set of rules than business. Businesses must provide training for their employees to meet OSHA regulations for safety, but the adults are expected to use that training and act as, well, adults. Courts have ruled that schools and school personnel are in loco parentis, or in the place of a parent. This gives the schools both responsibilities and, consequently, liability in regards to their actions for keeping students safe. Not only are schools responsible for training students for an emergency, but also for leading the students in an emergency. Therefore, in the event of an active shooter, a teacher cannot instruct their students to run for the nearest exit, yet not make sure the students are actually trying to exit. Nor should a teacher leave behind a student who is too frightened to leave an area, especially when the child is very young. Barricades Compensate for Weak Locks, Doors and Windows Hide is currently taught in schools under the term “lockdown.” When an active shooter is inside a school, staff members are generally instructed to lock their classroom door, cover the window if possible, turn out the lights and move the students to an area in the room where they are less likely to be hit with gun fire if the shooter fires through the door. Although this has been shown to be an effective method for keeping students out of harm’s way, many feel simply locking the door is not enough. Teachers are now being taught to barricade the room using existing furniture, extension cords or commercial products designed specifically to keep a room secure during an active shooter event. This enhanced technique of barricading overcomes weaknesses in doors such as large windows to the side of the doorframe or large windows in the door itself. Don’t Teach Children the ‘Fight’ Component Fight is viewed as a last option when in direct contact with the shooter or if you do not have the option to run or hide. Should we be teaching children to fight a person with a gun? NO! There are several good reasons why this shouldn’t be taught to them. First, the active shooter event in school is rare. Depending on the age of the child, we could be causing them unnecessary fear by preparing them for something that is unlikely to affect them. Although we could have age appropriate conversations with older students about what their choices could be, parents may not agree with the message we give their child. It is better to give the parents talking points so they can have the discussion with their children. Active Shooter 4 ASIS School Safety & Security Council When my children were still in school, I gave them specific training on what to do in an emergency at school, church, the mall, etc. As a police officer, I have a different perspective and skill set than most parents. I could see some parents being extremely angry if I told their children what I told mine. However, I was exercising my responsibility as a parent, not a school employee. What About Teachers and Administrators? Q: Should we teach staff members to fight? A: Maybe. First, we must let them know it is their choice whether or not to attack the shooter. For example, post 9-11, if anyone gets the least bit out of order on a plane, they are usually beaten by fellow passengers and duct taped to a chair. Q: Do all the passengers attack? A: No. Some choose to attack, and others choose not to attack. This is what we need to teach our staff; they have a choice. If they want to learn techniques for fighting, we should use our relationship with our local law enforcement to provide the training to attack a shooter. How ‘Lock Out, Get Out, Take Out’ Works Q: So what do we teach in schools? A: There are many programs and many “experts” willing to sell their sure-fire strategy for keeping students and staff safe. Almost all are time consuming, and many are expensive. Two things schools are short of are time and money. There is little time for training and almost no budget. Strategies must be easy to learn, easy to remember, and easy to use. These strategies must give staff choices and allow them to make choices based on their training and the situation. Lock Out Since Sandy Hook, many schools are securing the perimeter of the buildings and using a camera and buzzer system to control entry to the building after the start of the school day. This is not a foolproof method of keeping bad people out of the building, as we saw in the fall of 2013 at the McNair Discovery Learning Center when the gunman entered the building behind a parent who had been buzzed in. However, this does add one more layer to a school’s plan to keep their building secure. It is recommended that all classroom doors be locked at all times, even when class is in session and even if the door is kept open. In the event of a threat inside the building, the door is already secured and just needs to be pulled shut. The teacher does not need to find their keys, step outside of their room into the hallway, and attempt to engage fine motor skills while potentially facing a shooter. Steps can now be taken to barricade the door. Active Shooter 5 ASIS School Safety & Security Council Should the teacher attempt to lead their students out of the building at the onset of the event? Are they in direct contact with the shooter? Do they know the exact location of the shooter and where the shooter is heading? Do they know they have safe passage to get outside? Can they move all of their students quickly and at once? Do they have enough information to make a good decision to leave a place where they are safe and move to an area where they may not be safe? With so many questions, it reinforces the need to train our staff and allow them to decide a course of action based on their training and the circumstances. Get Out When in direct contact with an active shooter, you should do everything possible to get your students and yourself out of harm’s way as quickly as possible. This means everything from heading to the nearest exit to using a chair to break a classroom window and tossing students out the window. Or, you may be in a barricaded room and no longer feel the room is safe. Get out anyway possible. Take Out A teacher is with their class on the third floor of an old school. They have successfully barricaded their classroom and did not attempt to leave because they had limited information on the location of the shooter. But, this is not an active shooter event. A noncustodial parent has already killed his ex-wife and is at the school to murder his child and commit suicide. He knows the police are on the way and has not wasted any time getting to his child’s classroom. He has brought the tools necessary to breach the door. It is unlikely that you or your students can survive unharmed by jumping from the third story. If that teacher chooses to take out the shooter, there are no rules. They may use anything in their room as a weapon and do whatever it takes to keep their students safe. However, if they choose to remain passive, that is also their choice. Just as “Run, Hide, Fight” is not linear, neither is “Lock Out, Get Out, Take Out.” Staff members are trained in their choices and allowed to make their choice based on that training and the current situation. However, it should be stressed that when in contact with the active shooter, lockout is not a choice. Staff and students should put as much distance between them and the gunman, or the staff member should do whatever is necessary to take out the shooter. “Run, Hide, Fight” is an excellent training tool when working in colleges, office settings, and factories. However, with the responsibility schools have for their students and range of ages of the students in schools, “Run, Hide, Fight” should not be the model used for school safety.2 2 Gary L. Sigrist Jr. is the CEO and President of Safeguard Risk Solutions. He previously served as the Readiness and Emergency Management in Schools (REMS) Project Director for the South-Western City School District in Grove City, Ohio. Active Shooter 6 ASIS School Safety & Security Council ALICE ALICE training is a strategy designed to increase survival during an armed intruder event. ALERT: Inform as many people as possible within the danger zone of life threaten situation. Use plain and specific language. LOCKDOWN: Barricade the room. Silence phones. Prepare to evacuate or counter if needed. INFORM: Communicate shooters location in real time if possible. 98% of the time the shooter works alone. COUNTER: Create noise, movement, distance & distraction with intent of reducing shooters ability to shoot accurately. The focus here really is to disrupt the shooter by distractions. COUNTER is about survival. EVACUATE: When safe do so, remove yourself from the danger zone. Observe, Navigate, Escape (ONE) The O.N.E concept was created mostly for the K-12 environment, as there are some schools that have not embraced the Run, Hide, Fight concept or other programs for evacuation. The O.N.E concept is based on using your senses to help you survive an Active Shooter situation. This concept does not encourage students to Run or Fight their way out of a situation. There may be a point in which one of those action may be necessary, but O.N.E does not encourage you to do either of those. Instead, O.N.E uses your natural instincts and senses that you have been using all of your life. For children, especially in elementary school, learning using their senses is the most common way they learn and understand. It only makes sense that we would teach them to evacuate using their senses so that they understand what they are doing and remain calm. O.N.E was created by Securable Consulting, LLC and inspired by the children of a local school district. Below is an overview of the O.N.E concept. OBSERVE. This is the most important step in plan, as you will continue to OBSERVE at every step of the plan. Simply stated, OBSERVE is meant for you to know what is around you. What is the environment you are in (classroom, office, retail, coffee shop, etc.) • OBSERVE with your senses (eyes, ears, nose, and touch.) You can gain valuable insight of your surroundings just by trusting your natural instincts that we all have. • LOOK to see if the shooter is near. Look to see if there are any signs of victims in your possible path. Look to see if there are any possible items that you could use as a weapon if needed. • LISTEN for any screams, further gunshots, footsteps, voices, sirens or any other sound that could indicate some type of action. Try to ascertain distance and direction of the sound. • SMELL the air. Is there anything different? Do you smell smoke, gun smoke or powder? Is the smell strong or weak? This could tell you if you are close or far from the situation. • TOUCH the walls, doors, windows and the floor. Feel for any vibrations or temperature changes. Again, the intensity of the vibration of temperature changes can tell you how close or how far you are from potential harm. Active Shooter 7 ASIS School Safety & Security Council Your surroundings can save your life if you are able to observe what is around you. We are in these environments everyday and we should know them better than anybody else. Don’t get complacent with your surroundings and take for granted what is around you. Escaping from harm is not as simple as running out. It can be an obstacle course, and knowing your surroundings can be all the difference. USE YOUR SENSES AND OBSERVE YOUR SURROUNDINGS! If your observations indicate that harm is not far, then certainly shelter and hide as best you can. Remember this: You have been developing your senses since you were born! Children are learning every day using their senses, and they are understanding more than anything else at this point in their lives. Most people trust their senses more than anything else, and rightfully so. It is basic human instinct to rely on our senses when danger is present. It is only when we see others in panic mode do we lose sight of using our senses to our advantage. We must remain calm in the presence of danger. From there: NAVIGATE. As you continue to OBSERVE your surroundings and feel that it is now the right time for you to NAVIGATE out of your initial location to that of a location of safety, keep the following in mind: • Always OBSERVE your surroundings and adapt to any changes. • NAVIGATE a path based on: ——What your senses indicate to you. ——Who you are navigating with (students, co-workers, small children, strangers) • Your ability to move, quickly, quietly, effectively and as calmly as you can is going to be of the utmost importance. You do not need all of your belongings; technology to communicate with is the most important item to have. • Assign children a “buddy friend” to navigate with, and also assign each of them a role in the process. Whether it is one child is listening and one child is looking for other signs of possible danger. Give them something to do to keep them focused. ESCAPE. As soon as you feel you have the opportunity to do so safely, escape. The average duration of an active shooter event is just short of 10 minutes. It takes on average 12-15 minutes for law enforcement to arrive on scene, according to Jim Schwartz, Chief Arlington County Fire Department. • Follow your teacher who should be leading the way. • Listen for sirens and try to move in that direction if safe to do so. • Always account for the children you are leading, talk to them to keep them calm and quiet. If you are leading out 15 children, keep counting them on the way out. This is also a good way to keep you as the teacher focused and calm as well. Active Shooter 8 ASIS School Safety & Security Council The Six Phases of the Attack by Linda Watson, CPP We hear the words “active shooter” on a more frequent basis every time we turn on the radio or television. It seems like the more it is happening, the more our society becomes de-sensitized to this type of violence. When an active shooter is in the “implementation phase”, a series of events has already happened for the “actor” to arrive at this tragic point. Experts agree there is no accurate or useful “profile” of an active shooter. According to Dr. Joshua Sinai, Ph.D., there are six phases to any active shooter incident.3 Phase I Cognitive Opening: The “Mindset” Phase II Planning Phase III Preparation Phase IV Approach Phase V Implementation Phase VI Post-Incident Mitigation Given these six phases of the attack, we can look at incidents where the attacker went from thinking about an attack to directly the attack phase with little or no planning steps in between. Contrary to much media “hype,” most attacks are methodically planned and executed by the attacker. Much consideration is given as to whom to target, where the incident will take place, and by what means the attack is carried out. In most incidents a firearm is used as the weapon of choice. Active shooters have evolved over the years. They are doing research to find how past attacks have been carried out. They are seeing the police response and the tactics used to respond to those attacks. As a result, the active shooters have changed some of the ways in which they plan and attack their victims. Two recent attacks that illustrate this come to mind: the Virginia Tech attack—where the doors were chained on the inside to prevent victims from escaping; and the Sandy Hook Elementary School attack—where the windows adjacent to the main door were shot out by the “actor” to gain access into the school. The Federal Bureau of Investigation published a study of recent U.S. active shooter incidents.4 A snapshot of its findings summarizes: • 160 incidents occurred between 2000 to 2013 • An average of 11.4 incidents occurred annually, with an increasing trend from 2000 to 2013 • 1,043 casualties, including killed and wounded (shooters were not included in this total) • 486 were killed in 160 incidents • 557 were wounded in 160 incidents 3 Active Shooter, A Handbook on Prevention. Joshua Sinai, Ph.D. Published by ASIS International. (2013.) 4 “A Study of Active Shooter Incidents, 2000-2013.” Texas State University and Federal Bureau of Investigation, U.S. Department of Justice, Washington, D.C. (2014.) Active Shooter 9 ASIS School Safety & Security Council Cinemark Century 16 Theater in Aurora, Colorado: 70 (12 killed, 58 wounded), July 20, 2012. Virginia Polytechnic Institute and State University in Blacksburg, Virginia: 49 (32 killed, 17 wounded), April 16, 2007. Ft. Hood Soldier Readiness Processing Center in Ft. Hood, Texas: 45 (13 killed, 32 wounded), November 5, 2009. Sandy Hook Elementary School and residence in Newtown, Connecticut: 29 (27 killed, 2 wounded), December 14, 2012. Active Shooter Incidents with Highest Casualty Counts (2000-2013) 193 (84 killed, 109 wounded) killed wounded Active Shooter 10 ASIS School Safety & Security Council The findings reflect the damage that can occur in a matter of minutes. In 64 incidents where the duration of the incident could be ascertained, 44 of the 64 incidents ended in 5 minutes or less, with 23 ending in 2 minutes or less. After seeing the FBI’s statistics, the yet unanswered question has become how to interrupt the “phases of the attack” to stop the carnage. In the first phase, the “actor” is thinking about the attack but has not yet shared those thoughts with anyone. When those thoughts combine with an action plan, the attack becomes real. Next, the acquiring of weapons and materials begins with logistical planning. Information about the attack is usually shared in some way during the planning phase with someone who knows the attacker. This is the period where the most opportunity to stop the attack can take place. The first three phases of the attack can take days, months, and years. When the actor is in the approach phase, he or she has acquired all their weapons and is deploying to the site. The final phase, which is the implementation and execution of the attack, ends within 5 minutes usually. The conclusion to the active shooter incident is either by a self-inflicted gunshot or by the responding law enforcement. Frequently information that has been shared by the attacker with people before the incident does not make sense to the person(s) it is shared with. After the tragedy has occurred, people who knew the actor will come forward with remembering odd things or behavior from that person. This echoes Secret Service statements that, “Prior to most incidents, other people knew about the attacker’s idea and/or plan to attack.”5 In conclusion, active shooter incidents are increasing across the United States. If someone is sharing information that is bothering you or making you nervous, find a way to tell someone who can analyze it and determine if it is relevant or not. Lessons learned since Columbine have changed the way law enforcement agencies respond to active shooters across the nation. Law enforcement personnel must constantly adapt and readjust to the everchanging active shooter. More recently, incidents have occurred where the active shooter involved more than one location. Situational awareness is key to staying alive during an active shooter event. 5 “The Final Report and Findings of the Safe School Initiative: Implications for the Prevention of School Attacks in the United States.” Washington, D.C. (May 2002.) Active Shooter 11 ASIS School Safety & Security Council Using Situational Awareness to Observe Pre-Attack INdicators by Brad Spicer If a killer was on your campus, when would you want to know about him (or her)? Do you want to know that he is at the parking lot? At the main entrance? Or if he has already entered the lobby, hallway, and classrooms? Situational awareness is what allows us to recognize the early signs of danger in order to prevent violence. If prevention fails, situational awareness can still mitigate the attack. More of an attitude than a hard skill, situational awareness is the ability to identify and process information about what is happening around us. We all have it some of the time, but it is also something none of us can have at all times. As is the case with most abilities, there are varying levels of situational awareness. Jeff Cooper, a Marine and innovator of tactical training, pioneered the concept of levels of awareness. His system, “Cooper’s Color Codes” illustrated below, has been used to train military and law enforcement for decades. Cooper’s Color Codes have nothing to do with warning code phrases or an outdated Homeland Security alert system. They simply assign a color to describe a level of awareness. Yellow is the goal for optimum situational awareness. You are best able to observe your environment and notice changes that may pose a risk by being prepared, alert, and relaxed. Sometimes these observations are subtle and identified by intuition. Intuition is not magical; it is an educated hunch based on your knowledge and experience. Nothing interests us more than our own survival, and intuition can help us perceive threats. WHITE Unprepared and unready to take action. YELLOW Prepared, alert, and relaxed. Good situational awareness. ORANGE Alert to probable danger. Ready to take action. RED Action Mode. Focused on the emergency at hand. BLACK Panic. Breakdown of physical and mental performance. Cooper’s Color Codes Active Shooter 12 ASIS School Safety & Security Council Prevention Prediction can seem daunting when a mass killing is framed only within the context of the shooting. Returning to the hypothetical killer we began with, and instead of him roaming a parking lot, imagine you are observing his intention in the form of posts on social media days to months before the first shot was fired. Despite how they are portrayed by the media, these shootings do not start with the first shot. The shooting did not began when “…all of the sudden, he took out a gun and started shooting everyone.” Generally, intentions were hardened long ago. The length and observability of these precursor incidents increase the possibility of prevention. The challenge is having the situational awareness to observe a potential threat and then direct the appropriate resources towards the person in question before it becomes too late. On April 20, 1999, 13 people were murdered at Columbine High School. While not the first mass killing in a school (there were five in 1997 alone), Columbine was the event that coined the term “Active Shooter,” which certainly described the situation as the murders occurred. But the Columbine attack did not start on April 20. • The attack did not start at 11:19 a.m. when, according to a witness, one of the two killers yelled, “Go! Go!” as they pulled guns from beneath their trench coats and began shooting. • It did not start at 11:18 a.m. when the two assailants left their vehicles in the Juniors’ parking lot after their explosive devices failed to detonate. • It did not start earlier that morning when they were carrying into the school explosive devices set to detonate at 11:15 a.m. during a busy lunch shift. It did not start April 20 with the two loading their weapons in the morning hours. It didn’t even start that year when they rehearsed their attack. While we will never know the exact date, we think the attack probably was motivated in 1996 when a blog associated with an online gaming site took a violent turn. From that point forward, warning signs were exhibited. Those warning were missed chances at intervention and thus preventing the attack from occurring. Active Shooter 13 ASIS School Safety & Security Council Pre-Attack INdicators Few mass killings are preceded by a direct threat. While threats should never be ignored, they should be viewed more as a promise than a guarantee. Some threats can actually be viewed as psychological motivators used to de-escalate, not escalate, confrontations. Threats are typically issued to obtain a desired response (such as fear) rather than to forecast imminent danger. Preventing an attack requires the observation of subtle Pre-Attack INdicators (PAINs); not just waiting for the direct threat. Listed below are actions that may be associated with PAINs and warrant closer attention. • Threat of suicide or self-harm • Threat of violence (directly or implied) • Fascination with/asserting ownership of firearms • History of violence; behavior obviously insensitive to others • Preoccupation with themes of violence • Intimidating others; frequently confrontational • Crossing boundaries (e.g., excessive calls, emails, etc.) • Marked academic performance decline • Notable changes in personality, mood, or behavior • Give away personal possessions • Shows noticeable decline in personal hygiene • Substance abuse When PAINs are observed, caution must be taken to consider the context of the warning signs to determine if a threat assessment is needed. The focus of a threat assessment is not if a person makes a threat, but if they pose a threat. Simply put, threat assessment is the process to determine dangerousness. In his book, The Gift of Fear, Gavin de Becker outlines a powerful way to efficiently define dangerousness. JACA is an acronym for Justification, Alternatives, Consequences, and Ability. Apply JACA from the viewpoint of the person you are assessing, not your own, and answer the following questions. —— Does the person feel Justified in taking violent action? —— Does the person feel there are Alternatives to violence? —— Is the person concerned about the Consequences of a violent action? —— Does the person have the Ability to carry out an attack? If one or more elements of JACA are present, a formal threat assessment is likely needed. JACA is simply a snapshot and does not replace the need for a formal and comprehensive threat assessment and case management program. Active Shooter 14 ASIS School Safety & Security Council Threat assessment programs take advantage of early warning signs. When these are missed and the situation escalates to imminent violence, PAINs are still present though more often associated with attack-related behavior. Recognizing PAINs immediately prior to an attack may not enable prevention, but it can mitigate the casaulties. First Timer’s Syndrome Mass killers rarely have an exit strategy. They expect to die (by suicide or suicide by cop) or be captured. Because the attack will be their first and last act of extreme violence, they will exhibit behavior and physical PAINs immediately before the attack. An apt description of these PAINs is First Timer’s Syndrome. Working in code yellow (prepared, alert, and relaxed) of Cooper’s Color Codes allows you to observe PAINs that slightly deviate from baseline operations and pose danger. Physical PAINs include appearance and dress. Behavioral PAINs include overt actions and more subtle gestures. Obviously these PAINs are almost always consistent with perfectly innocent explanations and do not automatically indicate danger. When the behavior is carefully and prudently explored (and the person is determined not to be a danger to himself or to others), our intuition learns how to better distinguish future threats. It is your intuition, training, and experience that help you determine if the situation poses no threat, if further investigation is needed, or if immediate action response is required. In the very rare instances when immediate action is required, your mindset (Cooper’s Color Code Red) can improve your response. Situational Awareness and Response Try to avoid code white (unaware) when you are at work or in public places. Make condition code yellow a habit. When you observe potential PAINs, quickly analyze the situation. A valuable system to make rapid decisions under pressure is the Observe-Orient-Decide-Act (OODA) Loop, which is sometimes referred to as Boyd’s Cycle after its creator, retired U.S. Air Force Col. John Boyd. The process begins by observing the situation. Orientation, next, is critical because most emergencies happen too quickly to process information as it is observed. Think of orientation as gaining perspective. Once orientation is gained, it is time to decide. The decision considers factors in information from orientation and your training and experience. The last step is to act on the decision. The “loop” occurs when situation changes. This cycle continues throughout an incident. Thoughout the day, strive to have good situational awareness. If you identify potential dangers, switch to code orange and apply the OODA Loop. In the very rare instances that require immediate response, move to code red; however, you switch back to code yellow if no threat exists. Repeat this exercise and situational awareness will become habit. Active Shooter 15 ASIS School Safety & Security Council Be Aware—But Stop Looking for Mass Killers In “Just 2 Seconds”, a resource guide for those charged with protecting public and high profile people, authors de Becker, Marquart, and Taylor point out it is futile to “look for assassins.” Trying to look for someone who could be an attacker in a crowd is like looking for a needle in a stack of needles. What student does not have a backpack? Are any shirts actually tucked in? Rather than trying to imagine how each and every person could be a threat, maintain good situational awareness and allow yourself to recognize physical and behavioral activities that differ from the baseline. Whenever possible, observe persons as they exit vehicles or move to enter buildings or buses. Watch for physical and behavioral indicators from people who approach new areas such as a school or bus. About PAINs If you wait for a guarantee of danger, then you are eliminating the opportunity to prevent the violence or seriously limiting your ability to mitigate casualties. PAINs are warning signs that almost deserve some attention though rarely warrant immediate action. When you observe PAINs, you should either:
Eliminate the person as a threat and move back to Cooper’s Code Yellow;
Continue to investigate and remain in Cooper’s Code Orange; or
Act and implement emergency response plans. (Cooper’s Code Red)
The decision is based on your observations, circumstances, and experience. If you cannot eliminate the situation
as a threat and are unsure if the situation is dangerous, remain focused (Cooper’s Code Orange) and investigate.
How you investigate is situational. While interacting with a potential threat may seem counterintuitive, it may
be necessary if it is your responsibility to guard the safety of others around.
Protecting schools can be incredibly difficult and tragically imperfect. However, situational awareness and
PAINs are strategies that can help make campuses a little safer from a personnel standpoint. When contemplating
the implementations of preparedness programs, leaders should consider the following decision-making
possibilities:
• Do nothing and hope nothing happens
• Do nothing and it does happens
• Do something and nothing happens?
• Do something and it happens
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Proactively Preventing Active Shooters—Post-Incident Data
by Rick Shaw
Given the choice, would you rather prevent an active shooting or react to an active shooter? Given the choice,
would you rather prevent the lawsuits, damaging headlines, and invasive media grilling related to an active
shooter tragedy, or would you react to all of the above? Of course prevention is the better option, but is prevention
possible?
The short answer is YES! Prevention is possible. The steps in the Pathway to Prevention are well documented by
hundreds of post-incident reports revealing that most, if not all, were preventable. Post-incident reports reveal
that pre-incident indicators, concerning behaviors, suspicious activities, and warning signs were almost always,
if not always, observed and even reported BEFORE the shooting tragedies occurred.
So if pre-incident indicators are almost always observed and/or reported before incidents and tragedies occur,
why are so many preventable incidents and tragedies not being prevented?
Reacting versus Preventing
In response to school tragedies at Columbine, Sandy Hook, and numerous others, most school administrators
reacted by scheduling security assessments with a security expert who would visit the school to assess the
school’s security preparedness. Security assessment reports usually deliver numerous recommendations for
schools to add more security cameras, more security alarms, more physical security access products (locks,
security windows, access management, etc.), more mass notification and communications systems, more
active shooter trainings, more emergency and crisis response planning, more emergency and crisis policies/
procedures, more crisis communications and social media guidelines, and more of the same.
Security assessments can absolutely be helpful to ensure reactive and response efforts are in place. Security
cameras record forensic evidence of what happened, security alarms go off when the threat is at your door, security
access products will hopefully keep the threat out of your school, active shooter responses kick in when
a shooter is at your school, and crisis responses take place during and after a crisis has taken place. Most of the
security assessment “recommendations and solutions” are designed to improve reaction and response time to
a threat that is on your campus or an emergency/crisis that has already happened.
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Prevention and Prevention Assessments Offer Numerous Benefits
The benefits of proactive prevention are impressive and even life-saving, and successful prevention begins with
a Prevention Assessment, which is much different than a Security Assessment. Prevention Assessments focus
on a school or district’s capabilities to proactively prevent threats and proactively prevent at-risk individuals
from escalating on a “path to violence” that can lead to incidents, lawsuits, tragedies and soaring liabilities and
other challenges.
The “Path to Prevention” Involves 6 Essential Steps:
• Awareness at the individual level
• Collecting the Dots
• Assessing the Dots
• Connecting the Dots
• Intervention and Monitoring
• Prevention (Pro-Active and Pre-Active)
Each of the six essential steps in the Path to Prevention are critical and necessary for schools/colleges to proactively
intervene with at-risk individuals and incidents on campus, off campus and on Social Media BEFORE they
escalate towards something more serious, more dangerous, more expensive or more tragic.
A Prevention Assessment will review:
How schools are ensuring situational and ongoing awareness at the individual level—including but not limited
to what concerning behaviors look like, how to make incident reports (confidential and/or truly anonymous),
situational awareness, updates on new and viral social media risks, policies, procedures, plans (including individual
roles and responsibilities) related to preventing as well as ensuring all individuals are aware of emergency
and crisis response plans from security assessments.
How schools are collecting the dots—including but not limited to how schools are collecting incident reports,
investigations, interventions, social media behaviors and comments, etc. from individuals in their school and
“community-wide” who almost always see pre-incident indicators. And making sure all of the “dots” are collected
in a central, secure records management platform that is separate from Student Record Systems to eliminate
potential liabilities due to disclosures (unauthorized and authorized) outlined in multiple guidelines including
FERPA, state laws and national standards guidelines. Too many schools are using outdated approaches (paperbased,
spreadsheet-based and other silo-based approaches) that lead to gaps and information falling through
the cracks.
How schools are assessing the dots—including but not limited to the school/college threat assessment team and
“community-based” threat assessment and safety teams. How threat assessment team members are assessing
and measuring an at-risk individual’s potential of aggression and violence, how teams (school and communitywide)
are securely sharing information to meet privacy and security obligations, how teams ensure real-time
collaboration rather than weekly meetings, how teams include third-party and community resources such as
mental health services, law enforcement and numerous other assessing the dots efforts.
Active Shooter 18 ASIS School Safety & Security Council
How schools are connecting the dots — including but not limited to how teams are connecting all related incident
reports, investigations, witnesses, updates, legal obligations, internal resources, community-wide resources
and numerous other connecting the dots efforts. Post-incident data and comments almost always refer to
“the failure to prevent was due to not connecting the dots” and the Prevention Assessment will help your school,
college and community to identify gaps, silos and disconnects BEFORE they lead to a failure to prevent.
How intervention efforts are working with at-risk individuals, how intervention efforts are communicated and
documented across the school or district, how intervention related monitoring is working, what intervention
programs are being utilized, are intervention efforts consistent and how numerous other intervention efforts
are being utilized.
How prevention efforts are working in the school and across the district to prevent and eliminate liabilities and
incidents associated with violence, sexual assaults, bullying, cyber bullying, gangs, drugs, weapons, sexting,
social media drama, diversity/inclusion, suicides, cutting, depression, isolation, truancy, and numerous other
threats, incidents, tragedies, and soaring liabilities.
Prevention Gaps Exposed In Student Surveys
To better understand what students are experiencing, Awareity conducted Student Safety Surveys in 2013 (nearly
4500 students across 16 states) and 2014 (nearly 6500 students across 14 states) and the students’ responses
exposed several serious gaps and prevention disconnects in their schools. For example:
• 79 percent of students have been impacted by bullying in their school
• 46 percent of students have been impacted by cyberbullying
• 49 percent of students are witnessing another student being bullied at least once a week
• Only 17 percent of students said things got better when they reported a bullying incident
• 39 percent reported bullying incidents to teachers
• 36 percent reported bullying incidents to parents
• 17 percent reported bullying incidents to school office personnel
Many Students are still not reporting incidents because:
• 28 percent are scared to make the situation worse
• 26 percent don’t want to be involved
• 23 percent don’t want to be a snitch
• 20 percent don’t believe it will help
If schools are not receiving incident reports, it is not because incidents are not occurring, it could be because
students have lost trust in adults and their school’s prevention capabilities. Lost trust and lack of taking action
is a dangerous problem, because when human beings ask for help and nothing happen, human beings tend to
take matters into their own hands.
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Why is survey data about bullying important? Many previous active shooters have left messages and manifestos
that cited their grievances with being a victim of bullying. When you combine the survey data about bullying
with the survey data that when students report bullying and things get better ONLY 17 percent of the time, human
beings (students) may decide to take matters into their own hands — some will become violent, some will
bully others, some will become depressed, some will resort to suicidal ideations, some will turn to self-harm and
cutting and some will turn to drugs and alcohol to get away from the pain…and some have and could become
SHOOTERS.
The student survey also provides insight on what students hear other students talking about:
• 34 percent are aware of someone who may pose a risk to students and their school.
• 34 percent are aware of a fellow student who has talked about or contemplated suicide.
• 34 percent are aware of students who have brought drugs or alcohol to school.
• 90 percent said they would report weapons, online threats, and suicidal students if they had an anonymous
incident reporting option.
• 98 percent said they are willing to be a hero for somebody, BUT school administrators need to equip
students (faculty, staff, and community members) with the web-based and anonymous incident reporting
tools so they can share their observations of concerning behaviors and pre-incident indicators.
The evidence from post-incident data, from lessons learned, and from student surveys is overwhelming and the
data exposes numerous liabilities and dangerous gaps with current and community-wide prevention capabilities
in schools and communities.
School Administrators should take immediate action to learn more about their school-wide and their community-
wide prevention capabilities before the next incident or tragedy occur. All schools should conduct a
Prevention Assessment to learn how they compare to leading schools who are proactively preventing active
shooters, violence, and numerous other incidents and liabilities while also improving their school climate for
all students, all school personnel, and their entire community.
Rick Shaw is President and founder of Awareity. For more information, please visit www.awareity.com
Active Shooter 20 ASIS School Safety & Security Council
Lessons Learned
by Lawrence J. Fennelly
After every active shooter incident, there are questions from victims and their families, as well as mental health
professionals. They want to know why the shooting happened. They want to know what could have been done
to prevent the attack and what caused this particular person to kill or injure innocent people. People start looking
for missed warning signs. Most importantly, everyone wants to know what can be done to prevent the next
incident from happening.
In addition to those questions, law enforcement and other first responders evaluate their response and seek
answers to their own set of questions after each and every new active shooter incident:
• What strategies worked well and what did we do “right” during the response?
• What could we have done better?
• What systems and procedures worked well and what needs to be re-evaluated or changed?
• What additional equipment or training would have made the response better?
Evaluating first responder actions are an important part of improving how active shooter incidents are handled.
We learn from mistakes that have been made in the past. For instance, when two students conducted their
attack at Columbine High School in Littleton, CO, law enforcement officers as well as first responders outside
the building were hearing shots as innocent victims were killed or injured. In the past, first responders gathered
outside the building or area, waited for additional responders, planned their strategy, and then entered the
building to neutralize the threat. Research has shown that in almost every case, once shooters are confronted
by an armed response, no other innocent victims will be killed or injured.6 Because of this the initial or sole first
responder on the scene now enters that building as quickly as possible to gain control of the situation.
Traditional law enforcement response to an active shooter event was to secure the perimeter, gather information,
and wait for additional officers to arrive. Unfortunately, the shooting at Columbine High School proved
this approach failed. Since that time, law enforcement officers now use rapid deployment to an active shooter
event by entering the building or the area as fast as possible with the goal of neutralizing the hostile threat with
the least amount of force.7 What we have learned is that even a sole first responder on the scene must communicate
with other responders who are en route and then enter the building or area to prevent further injuries or
loss of life. A law enforcement officer on the scene of an active shooter incident, who enters a building or area
alone before other first responders arrive, does so because of their sworn duty to protect. This strategy is an effort
to prevent the death toll from rising.
Past incidents have shown that an incident command post must be established as soon as possible to coordinate
the response of multiple agencies. Also, a perimeter has to be identified quickly so responding agencies will
know where to gather and what to do.
6 http://www.policemag.com/channel/careers-training/articles/2013/02/rethinking-active-shooter-response.aspx
7 https://info.publicintelligence.net/LAactiveshootertactics.pdf
Active Shooter 21 ASIS School Safety & Security Council
Ideally, the resources of many agencies should be utilized to effectively respond to an active shooter situation.
Responders must have the needed equipment so they can prepare and effectively respond. Agencies should
work together to provide and support each other’s training so they are all aware of how they will respond and
work together as a team. The shooting at Sandy Hook Elementary School made first responders aware of how
important it is to have a plan in place to allow multi-jurisdictional agencies to communicate, and that there
must be adequate communication operators (dispatchers) available to handle the influx of calls.8 It is vital that
that communication is maintained with the community, as well as the first responders, throughout the entire
incident.
The shooting at Virginia Tech caused the university to re-evaluate their emergency communication and warning
systems. Even though there were multiple layers in their communication process, not all of them worked
well. One lesson learned was redundant modes of internal emergency communications and notifications with
overlapping layers of communication were needed. Numerous modes of communication are available such as
text alerts, audible sirens, social networks, e-mail, web pages, local university cable television stations, computer
pop-up alerts, and constant updates to local and national media. The messages provided information on
what was happening with the police response and instructions on what individuals on campus should do.
Virginia Tech also learned that some words (such as “shelter-in-place” and “lockdown”) were confusing and
many people did not understand exactly what they meant. The term “clear” caused confusion to some of the responding
agencies. They were unsure whether “clear” meant evacuate the building or “clear” the building of any
potential suspects. Even when we speak the same language, we find these words that have different meanings.
The shooting at Northern Illinois University in 2008 demonstrated the need for National Incident Management
System (NIMS) for all campus law enforcement as well as training and drills for students, faculty, and staff so
they know their roles and responsibilities during an active shooter incident. All-hazards planning and response
with comprehensive training, drills, and exercises are a critical part of emergency preparedness.
The response to the 2012 shooting at the Century 16 Theater in Aurora, Colorado, emphasized the need to have
access to an area crowded with vehicles and people. Before even arriving at the theater, first responders were
inundated by moviegoers covered in blood and carrying victims.
Although local and state first responders are almost always the first ones on the scene of an active shooter incident,
the FBI plays a large role in supporting the response to every major incident in recent years. The FBI has
training and resources which can be utilized before and after an incident occurs.9 Shooters plan their actions,
so it is reasonable that first responders also have a plan for how to best handle the situation. The lessons learned
from previous active shooter incidents are invaluable to first responders and this knowledge will help save the
lives of innocent victims who are simply in the wrong place at the wrong time.
8 www.dhs.gov/active-shooter-preparedness
9 http://www.fbi.gov/about-us/office-of-partner-engagement/active-shooter-incidents
Active Shooter 22 ASIS School Safety & Security Council
Public Safety and School-Sponsored Onsite Training Programs
for Emergency Responders
by Jim McLain, CPP, FMP
Many public K-12 school systems in America have emergency plans that include measures for active shooter
situations. This is typically in accordance with their state laws or regulations. But without proper and periodic
training, these emergency plans are merely a list of instructions that may or may not be carried out in actual
emergency situations.
In addition to mandatory training drills (e.g., fire, lockdown, and bus evacuation), school administrators should
regularly engage with their crisis management teams in practical or tabletop exercises to train on how to execute
their plans in the event a critical incident arises. As with plans that require update, the exercises should be
modified to address different incidents. The training should be placed in a mandatory cycle to ensure the most
effective response when needed. Public safety officials must be involved in each of these tabletop exercises.
Having key stakeholders together is needed in order to educate school staff on expectations during a response,
and to evaluate and provide input on the actions taken by crisis teams.
Active Shooter 23 ASIS School Safety & Security Council
At my school district, the crisis and security plans require updating each year. All schools within the school division
are required to conduct tabletop exercises in a mandatory cycle. Secondary, high, and middle schools are
provided tabletops every other year. Elementary schools receive these exercises every three years. Schools may
request out-of-cycle tabletop exercises, and typically do this when staff changes occur or when shortcomings
are identified.
This continual and cyclical timeline was planned with consideration for other drills, instructional time, the
number of schools, and the resources available to provide the training. A two-member security planning team
assigned to the central safety and security office reviews and approves plans every year. The team also conduct
tabletop exercises. The exercises are formulated and routinely modified under the supervision of a dedicated
security specialist. Approximately 85 tabletops that take about 90 minutes each are conducted each year. Supervisors
from the local police and fire departments attend every exercise.
From the school district’s perspective, this is an effective method in preparing school teams to respond to
emergencies when coupled with the multitude of other drills the teams conduct with students and staff. What
can school systems then do to facilitate public safety agencies’ abilities to respond to their school emergencies?
Coming from a law enforcement background that include years assigned to a tactical unit, it is understood
there are three basic needs in any strategy to address and resolve active shooter and other violent incidents:
Communications. Intelligence. And training.
Once schools understand and embrace this, it becomes highly effective in enhancing school safety to assist
public safety with their training needs relative to school emergencies. By providing school facilities as training
venues, administrators inherently allow emergency response groups to address each need.
Interactive training inside the school buildings provides public safety operators the opportunity to assess communications
capabilities or limitations inside particular sites, valuable real-life intelligence on the structure
itself, and an excellent training environment. Although it improves the ability of emergency responders to respond
in active shooter and mass casualty scenarios, training opportunities for the utilization of schools should
not be limited. Practically speaking, the more responders become familiar with school layouts by actually being
in them as opposed to just viewing the floor and site plans, the better off school communities are.
Since actively engaging public safety in utilization of our facilities within reasonable expectations, needed improvements
by the schools are regularly identified and addressed, response on day-to-day calls for service are
enhanced as well as emergency response.
Public safety concerns regarding their difficulty to communicate in some of our schools during training created
a need by our central office to assess each school for in building penetration of the public safety radio frequencies.
Working in conjunction with two way communications specialists in our county a number of facilities were
tested and bi-directional public safety antenna systems were installed. This program is ongoing and has the side
benefit of helping schools improve school based portable radio communications through the addition of radio
repeaters in their facilities subsequent to the onsite assessments.
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For pre-incident intelligence and to enhance emergency response all schools have an exterior and interior
numbering system at all primary entrances. Public safety departments are provided electronic site, floor plans
and aerials accessible from their computer aided dispatch terminals in their cruisers or apparatus. Large scale
paper versions of this for all schools are carried by school security supervisors for command post deployment
when emergency responders are on scene. The onsite training opportunities we have afforded to public safety
educated us the items we provide are useful but by comparison physical knowledge gained through training use
has been exceptionally beneficial.
Our local police SWAT group oversees active shooter training. Every summer all sworn members of the police
department, sheriff’s department, and the area state troopers go through onsite active shooter training at two
of our high schools. Recently due to the large presence of federal law enforcement agencies in our area, many
agents as well as military police have been included in training efforts as they may be in the area should an incident
occur. The base and military police are provided training at our large elementary school located on the
installation. The fire department also conducts mass casualty and multiple unit response functional exercises
during the summer months at our high schools.
Additionally, a variety of our schools are regularly used for squad-level training for our district level police
and fire stations. The training ranges from K-9 searches, building searches and room clearing, officer safety to
hazmat response.
Important consideration must be given to the use availability of the individual school itself. Like many school
divisions, our facilities are often in use after hours and on weekends for community activities that generate
needed income for the school system. Since public safety training does not occur during regular school hours,
community usage or extracurricular school activity can limit training availability. Coordination is the key.
Our school division requires all requests for training come through the office of safety and security. Once the
request is made, an office staff member coordinates with the office of community use and the school administration
of the affected location. If a particular site is not available for the requested date, a proximate school is
offered as an alternative.
Once the training is scheduled, uniformed school security responds to grant access on the date of the training.
While many of the police entities have emergency key access for schools, security is necessary to disarm the
security system and make sure no unscheduled activities are taking place that might interfere with the planned
training session. 30 minutes prior to the end of training, school security responds back to secure the site at the
conclusion. Large scale exercises or training resulting in a number of emergency vehicles onsite necessitates the
coordination with public information offices for the school division, the police, and fire departments.
There is an old police or sports adage that is very fitting. “You play how you train.” It aptly describes the many
advantages for school systems facilitating use of their buildings for public safety.
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Behavioral Threat Assessment Teams,
An Ounce of Prevention
by Jason Stone
Columbine High School. Virginia Tech. Sandy Hook Elementary. What were once names of safe educational
institutions are now synonymous with fear, pain, death, and tragic loss of innocent lives. The horrific gunning
down of men and women, boys and girls, that took place on these campuses have helped coin new phrases like
“active shooter”, “lock & hide” and “run, hide, fight”. These catchphrases describe response procedures that do
just that—respond. But in order to respond to an event, it must be situation that is in progress.
When it comes time for the responding team to arrive, unfortunately there will be people that are already injured,
some possibly killed. Wouldn’t it be great if there was a tool available that can stop active shootings from happening?
What if schools could have a well-trained team that gather at a moment’s notice, evaluate the potential for
threat, and set a plan to action? This is not a dream. These teams do exist and they prevent disasters nationwide
almost daily. They are called Threat Assessment Teams (TATs), and have become an effective tool to help prevent
(that’s right, I said prevent) horrific events similar to the ones we have seen occur all too often in recent years.
Did Not See It Coming
Immediately after an attack, the news is filled with reports of shock and disbelief. We sometimes hear, “He just
snapped” or “She was such a good kid. I would never have thought she would do something like that.” Then once
the dust settles, a different truth emerges—how the person who just committed inexplicable murder wasn’t
himself lately, or how she joked about shooting up the school. More time passes and the media uncovers how
the assailant turned in dark writing assignments with shocking focus on killing, torture, or suicide that was just
“not like his normal work.” Or maybe we are told that she posted online about how hopeless it all was and want
everything to end. Thus countless investigators think about how helpful it would be to have this information
prior to resulting tragedy rather than after. We imagine how many lives could have been saved, how many
families would be spared these tragedies, if we had ‘the big picture’ before the first shot was fired.
The Secret Service conducted an in-depth study of 37 incidents that took place between January 1974 and May
This report, called the Safe School Initiative, showed 93% of assailants in the study displayed troublesome
behavior prior to their attack. The study showed that at least one other person knew there was a very high potential
the subject would attack in 81% of the incidents studied; more than one person knew the likelihood for
violence in 59% of the cases. This information is alarming especially since 93% of those individuals with knowledge
that an attack would occur were other students or friends of the assailant.
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This information tells us unabashedly that people knew there was potential for violence … and said nothing. Or
if had they said something, perhaps the reporting system was fragmented, and the potential life saving information
did not reach the proper person who could have done something about it. The bottom line is nobody had
the opportunity to see the big picture. A properly functioning TAT not only gets to see the big picture, it has an
opportunity to intervene, and that makes a world of difference.
Purpose of the Team
A TAT’s main purpose is to provide a thorough and unbiased investigation into all reported potential threats.
Investigations are handled tactfully and confidentially. The team acts with the safety of all parties involved as a
primary concern at all times. Since many TAT investigations involve suicidal behavior, it is important that TAT
members do not lose focus on the fact they must consider the protection of the individuals under investigation
as well as potential targets. The team must be prepared to calmly RESPOND to the facts of a concern, and not
REACT out of fear. How the team handles the investigation does not only affect the outcome of the current investigation,
but it will also affect future ones. Teams that rely solely on punishing the subject of the investigation
rather than a course of action that helps keep the community as safe as possible will wind up alienating themselves.
If the TAT can show it performs its functions with the best interest of all involved, at all times, it will earn
the trust of the community it serves. When the trust of the community is earned, concerned peers will be more
likely to seek the team’s help. If a team is heavy handed and becomes known for acting out of fear, it will not only
lose the trust of the community, and therefore risk future operations, but it could open itself and its organization
up to lawsuits.
The Team (experienced counselors, instructors, administrators, security & safety, law enforcement)
The team should select a leader; a chairperson if you will. The chairperson should have a level head, an excellent
working knowledge of the threat assessment process, and should be very familiar with the school culture. It is
important to point out that the person selected to head the team does not have to be in a leadership position at
the school—the selected chairperson could very well be a counselor or faculty member. What is important is
that they meet the above criteria. In a group such as this, all members must be allowed to speak their mind and
not be influenced by the position any team member holds. It may take you a few tries to form a team in which
everyone works well together, but you should start with the following individuals:
• experienced counselors
• teachers
• school administration
• campus security representative
• law enforcement representative
** It is very important to mention parents and students should not be a member of the TAT due to the
confidentiality of the discussion the teams will be having
Active Shooter 27 ASIS School Safety & Security Council
Training the Team
Training is one of the major keys to a TAT’s success. Proper training matched with proper staffing will make a
TAT a very effective tool to help those that may need it in your school system. It may save a life or prevent injuries
on or off campus.
All team members should be trained in basic threat assessment at minimum. It is preferred that all members
receive advanced threat assessment training at the educational level of your institution (higher education vs.
K-12).
Opportunities for the team to train together under the processes put in place by your organization should be
made available whenever possible. The more the team works together, the more proficient they will become. In
some school systems, the team meets on a weekly or monthly basis to discuss legitimate cases. In other school
systems, the demand might not be as high and so the team may only be called upon once or twice a year. In the
latter cases it is very important that the team still meets regularly to discuss procedure and do tabletop exercises
to keep everyone’s skills up to date.
This section was intended to give the reader a brief summary of how a Threat Assessment Team works, a basic
outline on how to form one, and how it is trained. It is by no means an all-inclusive training document. But
hopefully this document has provided enough material for the reader consider and realize that Threat Assessment
Teams are another deployable, and in fact effective, tool in targeted violence and suicide prevention.
Active Shooter 28 ASIS School Safety & Security Council
Preventing an Active Shooter Incident
Paul Timm, PSP
Active shooter events, despite their relative rarity, are an important security concern for entities such as educational
institutions, businesses, and government buildings. The frequency of these deadly incidents is on the rise
in America, and the intense media spotlight is frequently focused on them. As a result, today, more than ever,
is the best time to implement measures and practices that are focused on training, preparing for and,perhaps
most importantly, preventing these difficult situations.
Between 2000 and 2013, 486 people were killed in active shooter events. An additional 557 were wounded.10
During the first half of this time period, there were approximately six active shooter situations per year. The
average of the second half of the 13-year study rose significantly to 16 per year. This rise in active shooter events
is an alarming trend that hs caused society take note. Regardless of the number of shootings that actually occur
each year, just the possibility of an active shooter incident must cause us to take precautions to reduce the risk.
There are several ways educational institutions, from K-12 to universities, can assist in the prevention of the
event from starting. First and possibly most importantly, provide training to your stakeholders. Training can
take many different forms, but experts should always conduct it. Vital instructional topics include:
• Heightened Awareness. Make stakeholders aware of their surroundings, potential threats, and the security
measures that are in place. Encourage them to report all legitimate issues.
• Diffusing Potentially Volatile Situations. From handling disgruntled persons to appropriately addressing
escalating or destructive behaviors, provide people with effective direction and methods.
• Personal Crime Prevention. Equip your stakeholders with good safety practices, such as utilizing a “two
person rule” for accountability purposes,intentionally moving about the campus in well-lit areas, and
avoidingthe display of money and valuable devices.
Another important way to discourage shooters from targeting educational institutions involves “hardening the
target.” The concept of target hardening centers on the idea people who contemplate executing malevolent acts
are more interested in choosing the easy target than an intimidating one. How can you make your campus and
individual facilities appear to be difficult to victimize? Security measures that aid in these efforts include strategic
placement of video surveillance cameras, noticeable presence of security personnel, and implementation
of Crime Prevention Through Environmental Design (CPTED) principles such as “natural surveillance” and
“natural access control.” These measures serve to discourage, if not warn, would-be bad guys that criminal actions
will be more difficult to carry out than not. Building design from new construction to renovations can also
significantly impact prevention. Effective design features include secured vestibules, classroom security locks,
10 A Study of Active Shooter Incidents in the United States. Federal Bureau of Investigations, U.S. Department of Justice.
Active Shooter 29 ASIS School Safety & Security Council
vehicle barriers, bullet resistant glass, and other delay measures. These features can help not only in limiting the
damage of an in-progress active shooter but also in stopping shooters before they start by making it difficult to
enter a building or gain access to classrooms or gathering areas.
Other prevention techniques focus on policies and procedures that deal with everything from visitor management
practices to social media risks. For example, policies that involve suspension, expulsion, and termination
should be drafted to address the possibility that the person being reprimanded or fired might grow upset or angry
and react violently. These policies assist administrators and those in authority in making safe decisions regarding
termination, suspension, and expulsion. Effective policies should include mandatory cool-off periods
for terminated workers. In other words, these individuals are not permitted back on campus for a certain period
of time after the termination. Monitored exit interviews and notice of termination practices allow administrators
to foster an environment where the terminated employees grievances or issues with the institution are aired
and potentially resolved before they develop into something more threatening down the line.
Today is the day to place importance on prevention efforts. Be proactive. Stopping the active shooter before he
or she has a chance to carry out their mission is obviously invaluable. According to an FBI study, most active
shooter events begin and end within five minutes. This means that if prevention failed, we may not be able to
immediately rely on the response of law enforcement officials to neutralize the threat. Instead, make a commitment
to instruct your stakeholders, discourage criminal behaviors, implement design features, and craft
relevant policies that will significantly reduce your risk.
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Buying Time—Realistic Hardening of the Target at the Classroom Door
by Jim McLain, CPP, FMP
The rare but devastatingly tragic incidents of targeted violence involving school shootings from external actors call
to attention the need to review and improve, where possible, the physical security of our academic institutions
nationwide. After the incident at Sandy Hook Elementary School in 2012, once again a need was identified to
provide better physical security if the outer perimeter was breached. Taking a corporate approach of layering
security in order to buy time for the arrival of emergency responders to resolve the threat, there was a renewed
focus on the construction of the classroom door.
How do you buy time at a door that is closed and already has a lock? To answer the question, school and physical
security officials evaluated standard classroom doors, their construction, and configuration to ask:
• Is the door solid or hollow core?
• Is the door wood or metal?
• Does the door have a vision kit or panel?
• Is there a sidelight next to the door?
• Does the door have a lock that can be easily engaged in an emergency with a strike and frame sturdy
enough to mitigate rapid breach?
Hollow core doors provide a privacy barrier, but they are ineffective for physical security and allow for easy
noise detection. Wood or metal solid core doors are adequate for security so long as the hinges, strikes frame,
and locking mechanism are strong enough.
The major vulnerabilities inherent in classroom doors are: 1) glass within or adjacent to the door that, when
broken, would allow access to the handle; and 2) a locking configuration that prevents easy engagement in an
emergency.
The fire codes in most states require classroom interior door latches to open in case of fire, even when locked
from the outside. Unfortunately this creates a situation whereby an assailant can break the vision panel or sidelight,
and reach in to open the locked door from the inside. While it would seem obvious to simply eliminate
the glass, it is not practicable in today’s school building design. Natural light penetration is considered desirable
and even advantageous in creating optimum learning environments. This tends to make security professionals’
physical security goals more challenging in educational facilities when it comes to the layered approach.
In locking configurations on classroom doors, there has been a longstanding philosophy in many school communities
that the door should only be lockable from the outside to prevent kids from locking the teacher out.
With that we have many schools with cylinders on the outside and no means to lock the door from the inside.
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31 ASIS School Safety & Security Council
In routine day to day activity, this is of course fine. In the chaos of an
emergency, however, teachers opening the door to lock it from the
outside not only exposes them to the gunman, but in some cases,
the teacher inadvertently unlocks it by pushing down on the interior
handle as they close the door under duress. The worst case scenario
that plays out being the teacher cannot find her/his keys in an emergency,
or a substitute teacher has no key to begin with.
To address this, all that many schools can do is to try locking the door
at the beginning of the day while it stands open. Should an emergency
arise where lockdown procedures are appropriate, the teacher or
substitute simply closes the door. Naturally the issue with this procedure
is under certain situations a student can close the door and the
teacher would effectively be locked out. The double cylinder locks
are effective but the dilemma of no readily accessible keys may exist.
Post Sandy Hook, the one cost-effective and seemingly ready fix that
overcame the door issues aforementioned is the portable and rapidly
deployable barricade or barring device that prevents unlocked doors
from being easily breached. The market was flooded with a plethora
of different concepts of the same tool. The school division I manage
security for even put our design engineers to work. A prototype of a
spring-loaded floor device was created. Our design, along with some
door devices we purchased from legitimate vendors, was presented
for approval.
All devices were ruled as being against fire code in our state. They
were therefore rejected by the fire marshal. Research into codes and
regulations revealed that there are a great many states where the fire
code prohibits the use of any type of door barricade implement as it
may impede fire evacuation.
A two pronged approach to resolve this buying time strategy was
taken. Finding the optimum type classroom lock and taking steps to
prevent access by breaking the glass. Primary considerations have to
be considered for a cost-effective solution that works and does not
over institutionalize the facility.
Aesthetics also plays an important role in the public education culture
and must be considered by security professionals. This presents
Active Shooter 32 ASIS School Safety & Security Council
11 The single bore cylinder is commonly used because of its ease of installation and costs. Commercially, mortise type locks are popular because of its durability
and built in deadbolt type secondary lock, depending on the model you procure.
challenges in trying to address physical security needs. Both educators and school community members shun
the idea of their schools looking like prisons or defense facilities.
The preferred type of door hardware is equipment that can be locked from the inside with a single lever handle
that, when pulled down, will unlock the door from the inside. The door, frame, and hinges must be sturdy to
begin with. Consideration has to be given to the type of lock: single bore cylinder or mortise lock.11
Thumb turn (or a button on the inside lever or on the back plate) can work to lock the door from the inside;
however in a panic, the button lock can be disengaged by a teacher who pushes the button to lock the door but
then as he/she endeavors to close the door unintentionally pushes down on the lever.
We had a manufacturer fabricate a heavy duty mortise lock with an incorporated secondary locking device. A
thumb turn lock mounted on the escutcheon (or back plate) with an indicator window was used. The indicator
displays for the interior user when the door is locked in white lettering on a red background and unlocked with
black lettering on a white background. The front of the lock set has a keyed cylinder with a vandal-proof lever.
If the lever is forced down in an effort to force it open, an interior ratcheting simply breaks the lever free and it
goes back into functioning battery. Staff is currently testing the lock to ascertain if it meets our need for buying
time at the door.
Because of the desire for natural lighting and the need for administrators and teachers to monitor what’s on the
other side of the door without disrupting instructional sessions, all of my school division’s classroom doors have
vision kits/panels installed. Many school divisions throughout the nation face this same challenge. A violent
intruder need only break out the glass to reach in and defeat the lock.
There are several options in approaching this. The old established method of reinforcing the glass with wire
mesh on the inside (like the way they were when we were in school many years ago) is no longer an option in our
organization. Approximately a decade ago, it was decided to do away with utilization of this type of glass due to
a potential for a child to injure themselves if they accidently broke the glass. (Although I suspect that costs also
may have played a factor in the decision.)
There are some highly effective screens available with ballistic capabilities that are cost-effective. Bars and
heavy-duty meshes were also reviewed. These were not acceptable in the school environment here because of
the institutionalized perception. Plexiglas-type material was considered as well but the mounting and yellowing
over time concerns were raised.
The second prong of the approach came down to clear and not tinted security films. The film manufacturers
provide excellent demonstration videos, but staff and I decided to conduct field and performance testing on
our own due to concerns of door framing, mounting, and the small size of the vision panels. With over twenty
thousand classroom doors in our organization, finding a solid solution in a cost effective manner is paramount.
Active Shooter 33 ASIS School Safety & Security Council
Does security film applications work? To answer the question, our first round of testing consisted of security film
mounted to the inside and outside of existing window glass. The optional security adhesion kit to strengthen the
frame area where it meets the glass was also used.
The film and kit were installed on a four by four feet library entrance and two classroom vision kits. The optimum
cure time of ninety days was allowed. The testing was conducted in the wing of a school under renovation
after school hours so there would be no disruption to the primary mission of educating the children. The area
was cordoned off with safety personnel posted to prevent unwanted access and unintentional injury.
The local police department special weapons and tactics team performed the field testing on the glass. Three
methods of breach that might be readily available to a school shooter were deployed: the butt of a rifle, a fire
extinguisher, and finally a breaching round fired from a shotgun.
On the larger library window the film performed remarkably. Repeated and numerous strikes with the rifle butt
and fire extinguisher failed to even crack the window. The breaching round put a slug sized hole in the window
but it held together and subsequent strikes failed to breach the window even after being shot. While ballistic
capabilities are not inherent in the security films they still maintained considerable strength after being penetrated
by the round fired from a gun.
The small classroom window glass panels were tested on doors mounted in their standard frames with standard
wooden window frames. In both cases the windows remained intact but the frame surrounding the vision kit
gave way causing the entire panel to fall out thus defeating the purpose.
A second round of testing was needed so installations were done on three doors in the same building with metal
framing being installed with each vision kit. One door window installed with a single side film and adhesion kit
inside a metal frame withstood all breach attempts. The door itself was locked. The swat team member did not
shoot this door window.
The second application was identical to the first but the door was unlocked with play in it. The application failed
after several attempts. We did not shoot this panel either.
The third and final door had film installed on both sides with an adhesion kit install on the metal frame and
window seam. This door withstood all attempts, including breach by shooting.
While double-sided application with a metal frame appears to provide the solution, our team of staff elected to
perform one more round of testing so we can incorporate variables that might be considered by other school
districts and could present cost savings. For example, how do single-side installation and double-side installation
without the optional adhesion kit perform?
Active Shooter 34 ASIS School Safety & Security Council
For the second round and forthcoming third round, we invited the assistance of Underwriters Laboratories to
observe and provide their expertise in reaching a successful solution with the versatility to work on a variety
of door vision panels. The one definite reached at this junction is the necessity for an attachable metal frame
around the treated window.
The third round of testing also includes the aforementioned lockset developed for our purposes. A similar configuration
with the indicator window and thumb turn was developed for the larger doors with interior panic
hardware as well.
One final point, any testing and evaluation team should be multi-disciplinary so that all variables are considered.
The staff team mentioned in this document was comprised of school security, school design engineers,
and facilities management personnel, along with police and fire representation. Present also in prior and any
subsequent testing is a life safety development manager with Underwriters Laboratories.
We are confident the simple strategy of buying time at the classroom entrance door will be an effective layered
security solution. As to what else school divisions security officials decide to include as part of their physical
security program to mitigate the school shooter, proper consideration for what is acceptable to the organization,
costs, and how the material(s) will perform in the actual environment should be considered.
Active Shooter 35 ASIS School Safety & Security Council
K-12 as Soft Targets*
by Dr. Jennifer L. Hesterman, EdD
Based on concepts covered in
Soft Target Hardening:
Protecting People from Attack
CRC Press, 2014
Every day, somewhere in the world, another school wakes up from
the aftermath of another violent attack possibly caused by a terrorist
or an insurgent group that threatens the United States or its citizens
abroad. In some cases, they were bombed by their own government
as a consequence of civil war or as part of a warfighting strategy that
is impossible for us to comprehend. Who could have predicted, even
ten years ago, that schools, as well as churches and hospitals, would
be considered routine and legitimate targets for terrorist groups? The
actors have redrawn the battlefield lines around sanctuaries that civilians
once held confidence in of shelter and safety. Schools for children
are legitimate and penetrable targets scoped by those who wish
to do harm, from international terrorist organizations to lone wolves
to those merely disgruntled or mentally incapacitated and have the
urge to “act out.”
A school is a soft target, meaning it is:
• A civilian-centric place
• Not typically “fortified,” meaning vulnerable, unprotected, and undefended
• Security not a primary mission
• Possibly co-located with or near a hard target
If lacking a specific agenda, terrorist criminals may choose to target a school for the ability to inflict the most
damage in terms of casualty count. Also, soft target attacks generate a long press cycle, serving any “fame,” recruiting,
or legitimacy goals of the actor. Another consideration for the tactic, soft target attacks generate more
fear and psychological “pain” than hitting a government building or installation.
Perhaps nothing more deeply affects the American public than an attack on a school. We never expect that
innocent children would be targeted by anyone, be it their fellow student, a member of the community with a
mental illness, a criminal, or a terrorist. Therefore we are wholly unprepared, shocked, and deeply saddened
when we learn of its occurrence. The ripple effect of school attacks is also immense—traumatizing students,
teachers, and first responders who view the scene; inducing post-traumatic stress and panic disorder in many.
So, a school attack persists in people’s minds and on society’s conscious long after the shooting stops, long after
the walls are repaired and the students’ return, which makes it the perfect target in the eyes of a motivated killer.
Active Shooter 36 ASIS School Safety & Security Council
Psychology of Soft Targeting
We can easily slip into a false sense of security and become complacent about safety inside our schools’ halls
and classrooms. Security, however, is not the primary mission of schools, which typically are constrained of the
resources needed to fund recommended security measures or hire additional guards. Also, schools are typically
“gun free” zones so the only resistance a violent actor will meet is a typically unarmed security guard or two.
In addition to physical security factors, we need to look inward and fight our psychological “blind spot” regarding
the issue of school security. I often speak with college presidents and high school principals about the possibility
of a terrorist attack or an active shooter event on their property, and I’ve met certain mindsets that prove
problematic. They may convey a feeling of hopelessness (there is not much we can do to prevent or mitigate the
threat); infallibility (it will never happen here); or inescapability (its destiny or unavoidable, so why even try).
Some block out the thought at a personal level by thinking “it can’t happen to me,” indicating a sense of invulnerability.
Even worse, others may believe that “if it’s going to happen, there is nothing I can do about anyway,”
expressing inevitability.
Persons with these types of mindsets are a detriment to your organization in a crisis as they exhibit a lack of
awareness to the threat, mental preparation, or lack the sense of determination to engage and command the
situation. In an emergency, those without a plan or resolve may wait for first responders and law enforcement to
arrive and rescue them before taking steps to save their lives or the lives of others. The Sandy Hook shooting lasted
6 minutes and ended with 26 people dead. There is no time to wait for help when the attacker is determined
and brings heavy firepower to the fight. In an active shooter event, everyone is a first responder.
Escalation of School Attacks Worldwide
On April 7, 2011, a 24-year-old man named Wellington Oliveira traveled to the Tasso da Silveira Municipal
School in Rio de Janeiro where he was a former student and subject of classmate bullying. He methodically
killed 12 students. A firefighter who responded to the scene told newspapers, “There is blood on the walls,
blood on the chairs. I’ve never seen anything like this. It’s like something in the United States.”12 His statement
illustrates the prevailing worldview towards the escalation of school violence in our country, especially with the
recent epidemic of shootings and stabbings. As part of a larger society which is increasingly violent, there is an
inevitable ripple effect on the safety and security of our schools.
At any given time, there are at least 75 million Americans attending some type of school from Kindergarten
through doctorate level courses. Overseeing them are 5 million teachers, administrative, and support staff on
campuses.13 Many schools also serve community needs, used as places for meeting, polling, or shelters in times
of emergency—introducing other potential bad actors to the installation. Even if schools are not the intended
12 Bryan Johnson, “Top 10 Chilling Quotes During School Shootings.”
http://listverse.com/2012/05/09/top-10-chilling-quotes-during-school-shootings/
13 Department of Homeland Security, “FEMA 428, Primer to Design Safe School Projects in Case of Terrorist Attacks.” (2012.)
Active Shooter 37 ASIS School Safety & Security Council
target, children must be protected from the physical and emotional side effects of being in the proximity to horrific
violence. For example, there were four elementary schools and three high schools located within six blocks
of the World Trade Center on 9/11. Children in at least three states had parents working in or around the World
Trade Center that day. Thousands of children were exposed to the toxic dust clouds from the collapsing buildings.
In the Washington DC area, schoolchildren faced similar stress when the Pentagon was attacked.14 Schools
have also been pulled into active shooter events where a gunman is on the loose and part of a manhunt on the
school property but they weren’t the primary target.
The top two deadliest mass shootings by a single person in U.S. history both occurred on school campuses. On
April 16, 2007, 23-year-old Seung-Hui Cho killed two students in his Virginia Tech dormitory. Cho then went to
a classroom building, barricaded himself inside, and shot 53 students and teachers, killing 30 in just nine minutes.
On December 14, 2012, Adam Lanza killed his mother in their home. Lanza then went to the Sandy Hook
Elementary School in Newtown, Connecticut. There, he bypassed the security door and shot through a plate
glass window to gain entrance to the building. He killed 20 first graders and 6 staff members in only six minutes.
Since the 1999 Columbine attack, there have been at least 30 other major school shootings in our country. Certainly,
terrorists and others with nefarious intention watch and see the relative ease with which school attacks
are accomplished.
K-12: Vulnerable in the Crosshairs
Kindergarten through 12th grade vulnerabilities differ from those on college campuses. First of all, physically not
matured the younger populace cannot defend themselves as readily and are more likely to slip into suspended
disbelief as the situation unfolds than engage a “flight or fight” response. Examining the unique vulnerabilities
found from shooting attacks associated with K-12 helps to better understand trends, the risk of attack, and
mitigation challenges.
The first K-12 school attack in the United States was the Enoch Brown School Massacre, which occurred July
26, 1764. On this date, four American Indian warriors entered a white settler’s log cabin school in Greencastle,
Pennsylvania, and used a tomahawk to kill and scalp the teacher and ten students. Throughout the years,
primary and secondary schools have been the site of revenge murders, racial attacks, gang violence, suicides,
workplace violence, and lovers’ quarrels. They have been used by domestic terrorists as a way to express rage
and garner attention to their cause. For example, on May 18, 1927, the Bath Consolidated School was the scene
of the deadliest act of mass murder in a school in U.S. history in a lone wolf, anti-government attack. Andrew
Kehoe, upset with policies and tax law he believed led to his farm’s foreclosure, murdered his wife at home, and
then detonated three dynamite bombs at the Maine school where he worked as the accountant. Kehoe spent
months planting explosive material throughout the building in a premeditated act that stunned the country.
When confronted at the scene by law enforcement, he detonated a vehicle bomb, killing himself and the school
superintendent. In all, the attack killed 38 school children and five adults.
14 Centers for Deisease Control, “Schools and Terrorism: A Supplement to the National Advisory Committee on Children and Terrorism Recommendations
to the Secretary.” Atlanta, GA. (2003.)
Active Shooter 38 ASIS School Safety & Security Council
International terrorist groups and embattled governments use modern day schools as political targets. Students
have been the victims of bombings, shootings, kidnappings, and hostage situations. In the past 40 years, there
have been massacres at the Ma’a lot school in Israel, the Bahr el-Baqar school in Egypt, the Beslan school in
Russia, the Nagerkovil school in Sri Lanka, and more recently, the Army School in Peshawar. Schools in the Gaza
strip, Iraq, and Afghanistan are routinely attacked. Mass student kidnappings became a new fear when terrorists
from the al Qaeda-linked group Boko Haram, who posed as soldiers to gain trust, kidnapped more than 500
girls from their boarding school in Nigeria on April 16th, 2014. The girls literally disappeared into thin air, with
Boko Haram leaders threatening to sell them into marriage and the sex trade for $12 a person to raise money for
the group. They next attacked the village where the girls were from, killing 150 family members and search and
rescue team personnel.
Why are K-12 schools more vulnerable to attack? First of all, the student populace is made up of children and
young adults. Having not reached mental or physical maturation, obviously they are easier to overpower. Second,
security measures are typically in place but done inconsistently. For example, as violence in our country
began to rise in the 1980s, many schools began installing metal detectors at entryways. Although metal detectors
work extremely well to catch weapons, school administrators found this type of screening time-consuming;
especially when considering the rushed movement of hundreds of students to their classrooms each and every
morning. Operating detectors or individual wands is extremely manpower intensive, and so many schools
abandoned the idea.
The concept of school resource officers (SROs) took hold in the 1970s when protests and unrest related to the
Vietnam War spilled over into school systems. SROs are sworn law enforcement officers who are detailed to
the school system and work to enhance security at their institution. They may be armed and can make arrests.
However, SROs can also be of limited help when facing a determined gunman/gunmen with a practiced, solid
plan and heavy firepower, as the following cases illustrate.
In the Columbine High School attack, Eric Harris and Dylan Klebold managed to kill 15 people and injure 24
despite the presence of an onsite SRO. Jefferson County Sheriff’s Deputy Neil Gardner, a 15-year veteran of the
Sheriff’s Office, usually ate his lunch with the students in the cafeteria. His car parked in front of the cafeteria
doors between the Junior and Senior parking lots. On the day of the attacks, Deputy Gardner was eating elsewhere
on campus, watching an area frequented by smokers. When shots were fired inside of the school, he
pulled up to the indoor/outdoor cafeteria area where Harris and Klebold had tried to set off two bombs and
had already started killing students. Gardner engaged them in a gun battle; however, he was unable to hit the
perpetrators. One injured teacher and a student were able to escape during the chaos, and Gardner was responsible
for later saving other students as he protected them when they were fleeing. He exchanged gunfire
with the shooters when they were killing students in the library before they committed suicide. He likely saved
lives in the end, but Gardner’s daily presence on the school grounds obviously didn’t deter the shooters from
their operation. In fact, investigators believe the shooters purposely chose the area where Gardner typically had
lunch to start the operation with the likely intention to kill him first and remove their only obstacle to success.
Active Shooter 39 ASIS School Safety & Security Council
The Red Lake School Massacre occurred on March 21, 2005. That morning, 16-year-old Jeffrey Weise killed his
grandfather, a tribal police officer, and his girlfriend at their home. Weise then took his grandfather’s police
weapons, vest, and vehicle, and drove to Red Lake Senior High School, where he had been a student some
months before. Weise first shot and killed the unarmed security guard at the entrance of the school, then targeted
a teacher and five students. After the police arrived, Weise was undaunted and exchanged gunfire with them;
he was wounded and then committed suicide in a vacant classroom.
In May of 2014, police in Waseca, Minnesota arrested seventeen-year-old John David LaDue on charges related
to an elaborate plan to carry out a massacre at a nearby school. According to his 180-page diary that police found
in his bedroom, LaDue plotted to kill his family members, start a diversionary fire to distract first responders,
and then go to a nearby school. He was first going to kill the SRO, set off bombs, and shoot students and staff.
A resident living next to a storage facility worker tipped off police to the suspicious teen. Contents of his locker
revealed a pressure cooker, pyrotechnic chemicals, steel ball bearings, and gunpowder. He had also been able to
stockpile three completed bombs, an SKS assault rifle, a Beretta 9 mm handgun, hundreds of rounds of ammo,
and several other guns inside a safe at his home. LaDue had been testing his devices at a local elementary school
playground and intended to attack the school on the anniversary of Columbine. However, the date of the anniversary
fell on Easter Sunday and school was not in session. Locals described LaDue as a polite boy who did well
in school and had plenty of friends.15
Religious elementary schools in the U.S. have also been the target of terrorists. In August of 2011, Federal law enforcement
officers arrested Emerson Winfield Begolly in New Bethlehem, Pa. Begolly was a moderator and supporter
for the internationally known Islamic extremist Web forum Ansar al-Mujahideen English Forum (AMEF).
Begolly produced and distributed a 101-page document with instructions for constructing chemical-based explosives
and a target list that included Jewish schools.16 Secular schools must be especially vigilant since religious
terrorism is the most dangerous, with actors believing their violent actions are sanctioned and just.
Often, the perpetrators of K-12 violence are known—either current or former students, staff, or teachers. They
know the school layout, class schedule, and become familarized with the SRO’s habits. They know when and
where to strike with least resistance for the most effect. Deterring school violence under these circumstances is
very difficult.
Emergent Threat: Stabbing Attacks
Gun attacks are obviously the most feared weapons assault since mass casualties are inflicted in a shorter period
of time and the mortality fears it conjures. However, we confiscate more knives in schools across the country
than guns annually, and knifing incidents are on the rise as well. Between April 2013 and April 2015, there were
at least 15 reported stabbings at schools across the country. Knife attacks are fast, unexpected, and devastating
in terms of injuries. For example, on April 9, 2014, 16-year-old Alex Hribal used two kitchen knives to stab 22
15 Dana Ford and Ben Brumfeld. “Police: Minnesota Teen Planned School Massacre.” May 2, 2014.
16 The Investigative Project on Terrorism. “USA vs. Begolly, Emerson.” 2011.
Active Shooter 40 ASIS School Safety & Security Council
victims in their stomachs and lower backs at Franklin Regional High School outside of Pittsburgh, Pa. The devastating
attack lasted over 4 minutes until the assailant was subdued by brave students.
In stabbings, victims often do not feel pain from the inital wounding. Rather, it is a cold, icy feeling at the stabbing
site since the body goes into shock. Victims often do not realize what has happened until they start bleeding, which
delays the “fight or flight” response and allows the attacker more time to further engage and inflict wounds.
Reviewing stabbing case studies, it appears people may be more willing to engage and subdue an attacker wielding
a knife than choosing to run and/or hide from a gunman. However, engaging an enraged assailant wielding
large knives is very difficult, and those who approach will be likely injured. The U.S. is not the only country faced
with this emergent issue. Mass stabbing attacks have also occurred in K-12 schools around the world, with mass
casualty attacks in Ireland, China, and Germany.
Response to the Threat
In conclusion, protecting our schools and their occupants from any type of attack—whether by terrorist, lone
wolf, student, or faculty member with a vendetta—is extraordinarily difficult. We naturally don’t want to turn
our schools into fortresses, although as I illustrate in my book, Soft Target Hardening, the goal is to present your
facility as impenetrable so the bad guys move on. There are best practices for hardening your school and there
may be some inconvenience to faculty, students, and parents, but once inside, the feeling of safety and security
leads to a richer learning environment.
There are other steps we must immediately take such as identifying and eliminating our psychological blind
spot that prevents us from understanding that our school is vulnerable. A quick look at active shooting events
in K-12 schools in the U.S. proves geographic location, the type of school, and economic class of its student are
absolutely not factors. We should therefore focus on vulnerability, not probability. We also need to get out of
the business of prediction and into that of preparedness. Finally, we have to come to terms with the fact the
threat may be an insider—a disgruntled teacher or a bullied student. The identification of actors who have the
propensity to carry out a school attack, or who could bring outside danger to our doorstep, is another area ripe
for exploration.
Although it is more comfortable to bury our heads in the sand on this topic and spend our precious resources
on gym climbing walls or more smart boards, in the end only you can answer—what is the cost of not securing
your school?
Active Shooter 41 ASIS School Safety & Security Council
When EMS Arrives on the Scene
by Michael J. Fagel, PhD, CEM
Law enforcement, as well as fire/EMS rescue, oftentimes converge at the scene of an emergent situation from
several departments at different times and from different locations. In Active Shooter situations, there is no time
to wait for standardized SWAT protocols. Rather, convergent initial contact teams that form up to neutralize the
threat may be approaching the area from varying locations to address the situation. Additionally, other emergency
medical, fire, and rescue personnel will be arriving but (based on predetermined protocols that should
be practiced well in advance) they may stage offsite, away from the scene or out of the hot zone awaiting entry
permissions. A strong command presence and discipline from all responding agencies is needed to manage
various responding resources and to coordinate the treatment and transfer of victims.
Individuals involved in the incident may be required to provide immediate lifesaving care to treat life threatening
injuries of injured casualties. Normal EMS protocols may be suspended and the normal standard of care
we enjoy throughout the U.S. is generally diminished since MS treatment will be focused primarily at triage
and care of life threatening injuries. Initial EMS activities may occur in warm zones with further treatment and
transport in a cold zone. Law enforcement security in both warm and cold zones will be critical to supporting
effective triage, treatment, and transport of victims.
As television coverage has often shown, injuries sustained during an Active Shooter situation may be catastrophic.
EMS does not operate in a routine environment or provide normal response during this kind of operation.
To assist, all persons involved must be able to adapt and overcome the events as they unfold. This cannot
be accomplished without adequate preparations, preplanning, response drills, and similar activities. Failure to
do so may well likely lead to repeated tragic results. Fire/EMS, law enforcement, and dispatch agencies’ active
participation in planning and exercises will help to successfully adapt in a chaotic situation.
Active Shooter 42 ASIS School Safety & Security Council
Planning Practice and Preparedness are the Keys to Survival
An emergency response plan is a continuous process; meaning it should never be viewed as a final, finished
product. Also important to note, all affected parties, agencies, and members of the various entities associated
with the plan must be part of the planning process and team. An effective emergency response plan needs the
involvement from all stakeholders across all walks of life. Every departments internally to your organization
must have an active role, as well as all outside stakeholders. This must include Police, EMS, Fire, Dispatch Agencies,
Public Health, Public Works, Legal, Human Resources, and administration at all levels.
An effective emergency response plan MUST include:
• an effective method for reporting threats and other emergencies
• an evacuation plan that is practiced with posted policies and procedures
• appropriately signed, marked emergency escape procedures, and route assignments (i.e. floor plans, safe
areas)
• up-to-date contact information for, and responsibilities of, individuals to be contacted under the ERP
• contact information concerning local area hospitals (i.e., name, telephone number, and distance from
your location)
• an emergency notification system to alert various parties of an emergency, including:
—— individuals at remote locations within premises
—— local law enforcement
—— local area hospitals
In addition, the emergency response plan specifies responsibilities and key contact information within your
organization. The ERP should also include an emergency notification as well.
In the event that evacuation is necessary, your facilities should have at least two evacuation routes that are conspicuous
and well marked.
With an effective emergency response plan and training in place, you and your staff will be better able to react,
respond, and recover from a situation that will tax all elements of the team.
Active Shooter 43 ASIS School Safety & Security Council
The Facility Managers’ Responsibilities
The facility manager’s responsibilities begin before any response is required. As part of the Emergency Response
Plan, your facility managers:
• Implement and understand site security procedures. Institute security access controls (e.g. keys, security
system pass codes).
—— Key fobs, door codes
• Distribute critical items to appropriate managers/employees, including:
—— Pocket-sized floor plans in break-glass cabinets
—— Keys and other access-control measures
—— Facility personnel lists with mobile telephone numbers
—— Daily schedule
• Assemble crisis kits containing:
—— Radios, tested and rotated batteries, chemical light sticks
—— Floor plans
—— Employee roster with emergency contact numbers
—— Triage supplies to be used in emergent situations
—— Catastrophic event medical supplies (tourniquets, chest wound sealers, combat gauze)
—— Appropriate First-Aid kits
—— Flashlights
• Activate the emergency notification system when an emergency situation occurs; as well as a backup plan.
• Ensure that the facility has at least two evacuation routes.
• Coordinate with the facility’s security department to ensure the physical security of the location, as well
as an alternate route.
• Advise according to plans and protocols and if in higher education, timely and clear notification.
• Secure doors.
• Order area supervisors to immediately direct all personnel (employees, customers, visitors, vendors, etc.)
in their area to evacuate the facility if it can be done safely and with caution.
• If an evacuation is not possible, go to PRE-IDENTIFIED secure location. Lock the door and turn off the
lights. Follow the protocol for the shades and other devices if appropriate.
• Keep personnel as calm as possible and try to notify 911 (using cell phones or telephones) of your location,
number of occupants and status. Turn all cell phones silent!
• Remain in the room until an appropriate all-clear signal is given or law enforcement arrives.
• Prepare an incident report documenting personal observations.
• Post evacuation routes in conspicuous location throughout the facility.
• Place up-to-date and secure removable floor plans near entrances and exits for emergency responders.
• Include local law enforcement and first responders during training exercises. The training must be as realistic
as possible.
• Encourage law enforcement, emergency responders, SWAT Teams, canine teams and bomb squads to
practice for an active shooter scenario at their locations.
• Foster a respectful workplace.
• Beware of early indications of potential workplace violence and follow appropriate protocols as trained
for the specific situation.
Active Shooter 44 ASIS School Safety & Security Council
Human Resources Responsibilities
As part of your Emergency Response plan, your human resources (HR) department must also engage in planning
for emergency situations involving an active shooter scenario.
Planning for situations may help to mitigate the likelihood of an incident by establishing processes such as:
• Conducting effective employees screening and background checks.
• Creating an effective system for reporting signs of potentially violent behavior by your employees.
• Making appropriate EAP counseling services available to employees.
Training
Once the emergency response process is ready for testing, you and your staff should be trained in preparing to
respond to actives hooters situations, including the use of exercises that involve local law enforcement and fire/
EMS responders.
It is important for you and your personnel to establish and effective education and training program and is effectively
and appropriately trained in its protocols and procedures so that you and your team can act effectively
if you are ever confronted with an active shooter situation.
One commonly used effective training practices in responding to an active shooter situation for you and your
team to conduct well planned out and implemented active shooter training exercises.
Security Consultants train in active shooter situations; along with local response agencies will be valuable resources
as you prepare an effective training scenario appropriate to your situation.
In addition to your immediate security staff, your employees should also be trained in:
• Recognize the sound of gunshots.
• Reacting quickly when gunshots are heard and/or when a shooting is witnessed.
• Training should cover:
—— knowing how to evacuation the area
—— knowing how to hide out
—— knowing how to action against the shooter as a last resort
—— know when to call 911 immediately
—— knowing how to respond when law enforcement arrives
—— keep your hands visible at all times
—— keep your fingers spread; drop any objects in your hand
—— how to respond to official commands
—— do not reach for or grab responders
—— knowing how to adopt a survival mindset during times of crisis
Active Shooter 45 ASIS School Safety & Security Council
Meeting the Needs of Those with Disabilities
In addition to developing the Emergency Response Plan, conducting regularly held evacuation instructions,
and performing any other retraining exercises, you should ensure that your plans, evacuation instructions, and
any other relevant information include provisions for managing the requirements of individuals with special
needs and/or disabilities. It is important to ensure that your building is accessible for individuals with disabilities,
in compliance with Americans with Disabilities Act (ADA) requirements.
Adopting these proactive measures to anticipate security concerns before they materialize can be achieved by
creating an effective security strategy, based on a robust Emergency Response Plan that is exercised.
All of the above may enhance the resiliency for your organization. This is essential to deterring potential threats.
Adversaries, including active shooters, generally focus on the MOST vulnerable target and may choose to strike
those targets (i.e., targets of opportunity or “soft” targets). Therefore mitigating the risk to your facility by minimizing
external threats outside your secure perimeter is of paramount importance. Having an effective security
program in place will reduce the likelihood of being perceived by your adversary as vulnerable and could help
dissuade such potential threats from selecting your facility as a target. Such as when an individual engages in
suspicious weapons and ammunition purchased and stockpiling.
Private sector security and law enforcement agencies may use a variety of protective measures to help disrupt
or mitigate a potential active shooter attack.
Target Selection, Planning, Rehearsal, Attack, Escape and Exploitation
Awareness is key. Observation of precursors such as behavior, elicitation, and unusual purchases are some of
the factors that can be looked at as we try to mitigate the effects of such an attack.
Planning, preparedness, practice, and options for consideration must be explored for the betterment of the
people we serve. Involving all relevant stakeholders in this process will provide the best potential for a managed
outcome at the time of an event’s occurrence.
Further Reading
Active Shooter: A Handbook on Prevention by Joshua Sinai, Ph.D. Published by ASIS International. (2013)
Active Shooter 46 ASIS School Safety & Security Council
Behaviorial Cues
by Inge Sebyan Black, CPP, CFE, CPOI
Introduction
While we cannot always predict human behavior and there is no definitive psychological profile of an active
shooter, many of these individuals do share similar behavioral characteristics. No singular behavior is absolute,
but a pattern of behavior would be worth identifying. For example, those who commit these acts often choose
places with little police presence and where citizens are unarmed. There are behavioral cues at the early stages
that are signs law enforcement and security personnel might recognize to prompt intervention.17 One might
recognize the suspect preparing for his event through the gathering and concealing of weapons; or notice the
suspect possibly warning certain individuals not to attend school or work. Being aware and observant of suspicious
activity and behaviors can help prevent an active shooting incident from happening.
When making assumptions about whether someone you encounter might be a shooter, there are some cautions.
We need to remain open about borderline dysfunctional personalities that might be missed because they
blend in. Although firearms are typically used, we should not discount the use of vehicles or improvised explosive
devices as weapons. And although women were identified as the shooter in only 6 of the 160 incidents the
FBI studied, we should not discount the possibility of women as shooters. Having studies of past active shooter
events helps the ongoing conversation of best practices and helps us develop/improve emergency practices.
But these events do change as time passes by, and we will have to be ready and prepared for other and new scenarios.
In the 2014 FBI report on the “Study on Active Shooter,” out of 160 incidents, in all but two, the shooter
acted alone.18
Active Shooter Training in the University Climate
The term “active shooter” describes an armed person (handgun, rifle, or other ballistic weapon) who is using
deadly force on other persons, and the engagement is in progress. Because the event is ‘live’, everyone and anyone
from law enforcement to the teachers and students have the potential to affect the outcome based on their
response or actions. Therefore training becomes the single most valuable way to affect positive responses, and
thus mitigating loss of lives.
17 School Resources & Training Institute. Active Shooter.
http://www.school-training.com/newsletter/articles/submitted/active-shooter.shtml
18 Federal Bureau of Investigations, U.S. Department of Justice. “A Study of Active Shooter Incidents in the United States between 2000 and 2013.”
http://www.fbi.gov/news/stories/2014/september/fbi-releases-study-on-active-shooter-incidents/pdfs/a-study-of-active-shooter-incidents-in-theu.
s.-between-2000-and-2013
Active Shooter 47 ASIS School Safety & Security Council
Training raises awareness to the real possibility that such an event will occur. Training facilitates dialogue which
creates ideas and protocols for when an active shooter occurs. Studying the active shooter events of the past
tells us these types of event can be over before the police arrive. Findings establish the largest impact of fatalities
occurs within a matter of minutes. In 64 incidents where the time duration was ascertained, 44 ended in under
5 minutes; 23 ended in 2 minutes or less. In some instances, law enforcement was present or able to respond,
but the individuals themselves made life and death decisions.
As with other emergency management protocols, the objectives of training are both discussing best practices
and conducting drills. Although lockdown drills were commonplace at one time and serve a particular purpose,
in active shooter drills, drills for all aspects of ‘run, hide and fight’ should be practiced and discussed. There
should be several different phases of training: one for management, one for new hires, and another ongoing,
annual training for all employees.
This training should include
• clear instructions on the announcement/communication of an active shooter scenario (i.e., “Active
Shooter on Campus”)
• overview of the company/faculty handbook
• overview of the emergency preparedness plan
• discuss active shooter scenarios (best and worst case)
• making life and death decisions
• individual options and recognizing the best one for survival
• safe meeting place following an active shooter
• behavioral signs/early warning signs to report, and who to report them to
• run, hide, and fight drills
• the role of management
Because of the unpredictable nature of active shooter situations, each person is required to make an individual
choice on how they would respond. School administrations implement various ways (email, computer pop-up
messaging, verbal or other notification through speaker systems) to notify students, teachers, and visitors about
impending crisis situations. It is clear that participating in training to estabilish what to do in emergency situations
will save lives. In those 2 to 5 minutes, students and teachers can make a life-changing difference. The
secret is Drill, Drill, Drill.
Active Shooter 48 ASIS School Safety & Security Council
To Arm or Not to Arm … Teachers
by Jason Thomas Destein
There is a growing debate in academic and school safety communities. A debate that could in fact become a
hot-button political issue in the next presidential election. This debate is centered around whether or not teachers
should be allowed to carry concealed handguns on school grounds and in the classroom. The debate itself
has been around for a number of years, but as violence from external intrusion in our schools increase, this
conversation is gaining more participants and a growing audience.
Support for arming teachers is growing around the country (and the world for that matter). As we see the increase
in attacks involving schools, there is no question that some people will lean towards responding with a more
forceful tactic. One group based in Kentucky called POST (Protecting Our Students and Teachers) advocate
arming teachers in schools.19 You can visit their website and see firsthand the positions and strategies they are
pushing for. Essentially, there are three points that POST outlines as reasons their program will work:
Deterrence – believing that a sign posted on a door stating that this school participates in the POST
program will prevent a shooter from entering, based on recent shooting events in schools, the shooters
were not looking for a fight but rather victims.
Immediate Armed Response – In the event of a shooting, there would be people already onsite to respond
quickly.
Thoroughness of training – POST requires extensive training and regular certification.
The other side of this debate is centered on those who support keeping guns out of teachers’ and administrators’
hands while in school. While there are many reasons offered by those on this side of the debate, there are a few
reasons that seem to be most prevalent. Kenneth S. Trump, a 25-year school safety expert and industry leader,
has articulately outlined some of the big reasons on his website.20
Training – No matter how many hours of firearms training are administered to a teacher, to think that
they would be able to respond and act in the same manner as our public safety officials is false.
Are there policies and procedures in place and approved by school boards, insurance companies and
their legal representatives.
What happens in an accidental shooting from one of these weapons or if a student takes the gun from a
teacher.
19 http://postky.org
20 Kenneth Trump. “Arming Teachers and School Staff.”
Active Shooter 49 ASIS School Safety & Security Council
Both sides of this debate add their points and counterpoints and argue their sides with equal passion. What is
interesting is both sides have the same goal, that is to keep our schools, the students, and teachers safe. Hopefully
reading this has presented you with thoughts of going out and conducting your own research, and be able
to support or challenge the school districts and local elected leaders on their position.
Should you decide to arm, consider what has to be done assuming you are staffed with tens to hundreds of
teachers. You might seek an assistance program from your local police department, which has Glock pistols and
a firing range with several certified range masters. Each teacher would need to be trained for two weeks on the
use of the same firearm, which equate to expending 1,000 to 1,500 rounds of ammunition. So with eight teachers
at the range at any one time, you will need to do the math to see how long it would take for them to complete the
training. Plus, you will need to take into consideration if someone doesn’t pass certification or staff that need to
be recertified. The process isn’t easy, and you will need local police help and assistance.
Active Shooter 50 ASIS School Safety & Security Council
APPENDIX A
Active Shooter Tabletop Exercise
by Victor Cooper, CPP
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Active Shooter 51 ASIS School Safety & Security Council
APPENDIX B
Shootings on the Rise
by Mark Tarallo
More than 1,000 Americans were
casualties of active shooter incidents
that took place between 2000 and 2013.
The actual figures—486 individuals
killed and 557 wounded—come from
a recent FBI report, A Study of Active
Shooter Incidents in the United States
Between 2000 and 2013.
The goal of the study, which the FBI
initiated in early 2014, is to provide federal,
state, and local law enforcement
with information and a better understanding
of active shooter incidents so
that they will be more prepared to prevent
and respond to future incidents.
Of the report’s many findings, one
clear message stands out: the frequency
of active shooter incidents is increasing.
From 2000 to 2007, an average of
6.4 active shooter incidents occurred
annually. In the next seven years of
the study, the average increased by 166
percent, to 16.4 incidents annually. The
peak years were 2010, with 26 incidents,
and 2012, with 21 incidents.
“This trend reinforces the need to
remain vigilant regarding prevention
efforts and for law enforcement to aggressively
train to better respond to—
and help communities recover from—
active shooter incidents,” the report
says.
On the ground, there is more and
more receptivity for active shooter
training, says Timothy Dimoff, CPP,
an active shooter training expert and
president of SACS Consulting & Investigative
Services, Inc. In the past, when
conducting training sessions, Dimoff
says he would often encounter an attitude
of, “Do we really need this?”
“Now, the shift is we’re seeing people
saying, ‘We’re very glad you’re here.
This thing can happen anywhere,’” Dimoff
says. He has also noticed an increased
demand for training among
churches and nonprofit organizations,
with administrators of those facilities
seeking tools to be prepared for a possible
incident, reflecting a mindset of,
“Let’s have a game plan, just in case,”
he says.
In the FBI report, the upward trend
in the number of incidents is even more
dramatic when examined in terms of
casualties. Before 2007, the number of
casualties in any given year peaked at
‘this is what we’re
doing and why,’” Klinger says.
However, for elementary students,
Klinger says her organization encourages
teachers to build on important
skills that are already being taught.
Among those skills are moving together
quickly without pushing or trampling,
and obeying certain commands
quickly without asking questions. For
younger kids, especially, it’s “not necessarily
saying ‘this is what we would do if
there was a guy with a gun,’ but instead
you’re saying ‘this is what we would
do if in an emergency we all needed to
move quickly away, or if we all needed
to get away very quickly, or we all needed
to be together.” She adds that these
are skills that are transferable to other
extreme situations, such as a weather
emergency.
John Bruner, founder of In-Crisis
Consulting, compares drills to gameday
training in professional sports; for
example, football players will practice
with loud crowd noise being pumped
in so they get used to playing in hostile
stadiums. He says he has at times
used simulated gunfire during drills
with teachers and faculty to simulate
the noise and smell of gunpowder that
might send the individuals into fight or
flight responses. He adds, however, that
they would only do this when students
are not at the school and with advance
notice to participants and cooperation
from local police and public safety.
“Even though [they] know what’s
going on … I’ve seen teachers at the end
get a little emotional and start crying
because they’ve gotten a true feel for
what this feels like,” says Bruner.
Some schools go even farther and
use the sounds of live gunshots on
drills with student participants. Those
sorts of drills may do more harm than
good, however, according to Stephen
Brock, school psychology professor at
California State University in Sacramento
and a member of the emergency
assistance team for the National Association
of School Psychologists. Brock
worries that many children are going to
be upset and potentially traumatized by
being exposed to that type of training.
Brock also says that training for an
active shooter could have the effect of
making young children, in particular,
view schools as violent, scary places,
even when their schools are safe. It can
help to avoid referring to the events as
active-shooter drills and to reassure
younger children that the school and
the teachers are there to protect them,
he says. However, he questions whether
active-shooter training is an effective
use of school resources. He says limited
dollars and time might be better spent
preparing for other incidents, including
natural disasters like earthquakes and
tornadoes.
Other experts agree that schools
must not forget about the natural disasters
that Brock mentions and other
emergencies that need to be prepared
for. Watson says that emergency managers
should consider using an all-hazards
approach because tornadoes and
hurricanes occur more frequently than
active shooters. Considering the high
consequences of this type of low-probability
event, however, it is understandable
why some schools find it worth a
portion of their limited resources.
Active Shooter 57 ASIS School Safety & Security Council
APPENDIX D
Early Warning, Timely Response: A Guide to Safe Schools
U.S. Department of Education
Although most schools are safe, the violence that occurs in our neighborhoods and communities has found its
way inside the schoolhouse door. However, if we understand what leads to violence and the types of support
that research has shown are effective in preventing violence, we can make our schools safer. Research–based
practices can help school community’s administrators, teachers, families, students, support staff, and community
members recognize the warning signs early, so children can get the help they need before it is too late.
This guide presents a brief summary of the research on violence prevention and intervention and crisis response
in schools. It tells school communities:
• What to look, for the early warning signs that relate to violence and other troubling behaviors.
• What to do, the action steps that school communities can take to prevent violence and other troubling
behaviors, to intervene and get help for troubled children, and to respond to school violence when it
occurs.
Early Warning Response
Section 1: Introduction.
All staff, students, parents, and members of the community must be part of creating a safe school environment.
Schools must have in place approaches for addressing the needs of all children who have troubling behaviors.
This section describes the rationale for the guide and suggests how it can be used by school communities to
develop a plan of action.
Section 2: Characteristics of a School That Is Safe and Responsive to All Children.
Well functioning schools foster learning, safety, and socially appropriate behaviors. They have a strong academic
focus and support students in achieving high standards, foster positive relationships between school staff and
students, and promote meaningful parental and community involvement. This section describes characteristics
of schools that support prevention, appropriate intervention, and effective crisis response.
Section 3: Early Warning Signs.
There are early warning signs that, when viewed in context, can signal a troubled child. Educators and parents
and in some cases, students can use several significant principles to ensure that the early warning signs are not
misinterpreted.
This section presents early warning signs, imminent warning signs, and the principles that ensure these signs
will not be misinterpreted. It concludes with a brief description of using the early warning signs to shape intervention
practices.
Active Shooter 58 ASIS School Safety & Security Council
Section 4: Getting Help for Troubled Children.
Effective interventions for improving the behavior of troubled children are well documented in the research
literature. This section presents research and expert based principles that should provide the foundation for all
intervention development. It describes what to do when intervening early with students who are at risk for behavioral
problems, when responding with intensive interventions for individual children, and when providing
a foundation to prevent and reduce violent behavior.
Section 5: Developing a Prevention and Response Plan.
Effective schools create a violence prevention and response plan and form a team that can ensure it is implemented.
They use approaches and strategies based on research about what works. This section offers suggestions
for developing such plans.
Section 6: Responding to Crisis.
Effective and safe schools are well prepared for any potential crisis or violent act. This section describes what to
do when intervening during a crisis to ensure safety and when responding in the aftermath of crisis. The principles
that underlie effective crisis response are included.
Section 7: Methodology, Contributors and Research Support.
This guide synthesizes an extensive knowledge base on violence and violence prevention. This section describes
the rigorous development and review process that was used. It also provides information about the projects
Web site.
A final section lists resources that can be contacted for more information.
The information in this guide is not intended as a comprehensive prevention, intervention, and response plan
school communities could do everything recommended and still experience violence. Rather, the intent is to
provide school communities with reliable and practical information about what they can do to be prepared and
to reduce the likelihood of violence.
Pursuant to R.I. Public Laws Chapter 12-337, the Life Safety Code of the National Fire Protection Association, Inc., Standard 101 (NFPA 101), 2012 edition, with annexes, except those portions specifically reserved, deleted, altered, added to, or otherwise amended as outlined in § 1.85 of this Part herein, and including all of the specific amendments to Standard 101, as outlined in section 8 herein, is hereby adopted by reference as the Rhode Island Life Safety Code. Copies of NFPA 101, 2012 edition, are available from the National Fire Protection Association, 1 Batterymarch Park, P.O. Box 9101, Quincy, Massachusetts 02269-9101. The National Fire Protection Association’s telephone number is 1-800-344-3555. Copies of NFPA 101, 2012 edition, have also been made available to state-operated libraries in Rhode Island.
Electronic copies of the reservations, deletions, alterations, additions and other amendments to this code, also known as the Rhode Island Fire Code Section 8, will be initially made available on the Fire Board’s website at http://www.fsc.ri.gov/. Copies shall subsequently be available from LexisNexis/Matthew Bender & Co., 1275 Broadway, Albany, N.Y. 12204-2694. The LexisNexis telephone number is 1-800-446-3410.
The State Fire Marshal is the sole authority having jurisdiction for the strict enforcement of the Rhode Island Life Safety Code. The Fire Safety Code Board of Appeal & Review is the sole authority having jurisdiction for administration of the Rhode Island Life Safety Code.
Except as outlined below, the Fire Safety Code Board of Appeal & Review is the sole authority having jurisdiction to grant variances, waivers and amendments from, or to review and accept any proposed fire safety equivalencies and alternatives to, the strict adherence to the provisions of the Rhode Island Life Safety Code and all referenced standards therein. Notwithstanding the above, the State Fire Marshal and his or her designees are hereby authorized to approve dimensional relief within the egress systems of any existing building in accordance with NFPA 101 and its annexes. Such dimensional relief shall be known as “AHJ modifications”. All “AHJ modifications” must be in writing and submitted to the State Fire Marshal’s Office for recording. Once recorded by the State Fire Marshal’s Office, the “AHJ modification” shall remain as permanent relief for the building as long as the use and/or occupancy of the building remains the same. Any change of use and/or occupancy shall subject the building to review under the relevant codes and reconsideration of the “AHJ modification” in light of the new use or occupancy.
For the purposes of uniform administration, and with the exception of “AHJ Modifications” as outlined above, all other exceptions listed in the Rhode Island Life Safety Code and its referenced standards, allowing for a discretionary waiver by the authority having jurisdiction, shall be referred directly to the Fire Safety Code Board of Appeal & Review as outlined in Fire Safety Code section 6-1-1 et seq. The only official formal and binding interpretations of the provisions of the Rhode Island Life Safety Code and its referenced standards are those approved and published by the Fire Safety Code Board of Appeal & Review pursuant to the procedures outlined in Fire Safety Code Section 6-1-3 et seq.
All new buildings and structures, for which a building permit was issued on or after January 1, 2013, shall be subject to the provisions of the Rhode Island Life Safety Code addressing the new occupancy unless this requirement is specifically modified by the issuance of a blanket variance by the Fire Safety Code Board of Appeal & Review to allow a grace period for plans, submitted after the above date, to be reviewed under the prior Code.
All existing buildings and structures, and those buildings and structures for which a building permit was issued prior to January 1, 2013, shall be subject to the provisions of the Rhode Island Life Safety Code addressing the existing occupancy.
Any existing building or structure, subject to the provisions of the Rehabilitation Building and Fire Code for existing Buildings and Structures, shall also comply with the existing occupancy provisions of the Rhode Island Life Safety Code addressing the current or proposed occupancy.
All existing required protection systems, such as sprinklers, fire alarms, emergency lighting and exit signs, installed in existing buildings, shall continue to be properly maintained. Non-required systems shall either be maintained, have the devices removed, or marked, to the satisfaction of the AHJ, so as to notify the public as the absence of these systems. Prior to the removal or marking of any non-required system, the system’s owner must first comply with the procedures outlined in Section 4.6.12.2.1 of this Code. The above marking of any de-activated system shall be at the direction and to the satisfaction of the State Fire Marshal or his or her designee
The effective date of the “Rhode Island Life Safety Code” is January 1, 2013. The provisions of NFPA 101, 2012 edition, as amended and referenced below, and incorporated herein as the “Rhode Island Life Safety Code”, shall be preceded by the acronym “RILSC”. All of the remaining provisions of NFPA 101, 2012 edition, adopted as the “Rhode Island Life Safety Code”, but not specifically addressed below, shall likewise be identified by the acronym “RILSC” preceding it. (Accordingly, “Chapter 1” below would be identified as “RILSC 1”. Likewise, “Section 1.1.2” below would be identified as “as RILSC 1.1.2”.)
8.1.1 CHAPTER 1 – ADMINISTRATION
1.1 Scope
(Amd) 1.1.1 Title.
The Title of this code shall be known as the “Rhode Island Life Safety Code”, is cited as such, and shall be referred to herein as “this Code” or “the Code”.
(Add) 1.1.1.2 Relationship to other fire codes.
The “Rhode Island Life Safety Code” (NFPA 101, 2012 Edition, as amended) and the “Rhode Island Fire Code” (NFPA 1, 2012 Edition, as amended) comprise the “Rhode Island Fire Safety Code” as mandated R.I. Gen. Laws Chapter 12-337.
The “Rhode Island Life Safety Code” is the major component of the “Rhode Island Fire Safety Code” which includes all other statutory mandates found in R.I. Gen. Laws Chapter 23-28 along with any additional rules and regulations adopted, by the Fire Safety Code Board of Appeal and Review, pursuant to R.I. Gen. Laws §§ 23-28.3-3 and 23-28.1-2.
1.3 Application
(Amd) 1.3.1 New and Existing Buildings and Structures.
The Code shall apply to both new construction and existing buildings and structures. All new buildings and structures, for which a building permit was issued on or after January 1, 2013, shall be subject to the provisions of Rhode Island Fire Safety Code addressing the new occupancy. All existing buildings and structures, and those buildings and structures for which a building permit was issued prior to January 1, 2013, shall be subject to the provisions of the Rhode Island Fire Safety Code addressing the existing occupancy. Any existing building or structure, subject to the provisions of the Rehabilitation Building and Fire Code for Existing Buildings and Structures, shall also comply with the existing occupancy provisions of the Rhode Island Fire Safety Code addressing the current or proposed occupancy. All active fire protection systems, such as sprinklers, fire alarms, emergency lighting and exit signs, installed in existing buildings shall be properly maintained.
(Amd) 1.4
Nothing in this Code is intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this code provided that any proposed equivalent systems, methods and devices are first approved by the Fire Safety Code Board of Appeal & Review.
(Amd) 1.4.2 Approval.
The system, method, or device shall be approved for the intended purpose by the Fire Safety Code Board of Appeal & Review.
(Amd) 1.4.3 Equivalent Compliance.
Alternative systems, methods, or devices approved as equivalent by the Fire Safety Code Board of Appeal & Review shall be recognized as being in compliance with this code.
(Amd) 1.6 Enforcement and Administration.
(Add) 1.6.1 Enforcement.
The State Fire Marshal is the sole authority having jurisdiction for the strict enforcement of the provisions of this Code. The State Fire Marshal shall have authority to appoint and certify as many deputy state fire marshals and assistant deputy state fire marshals as are deemed necessary to strictly enforce the provisions of this Code. All such deputy state fire marshals and assistant deputy state fire marshals maintain their certification at the pleasure of the State Fire Marshal. Accordingly, all deputy state fire marshals and assistant deputy state fire marshals shall be allowed to enforce this code as long as they maintain their certification in the above positions by the State Fire Marshal.
(Add) 1.6.1.1 Modifications.
The State Fire Marshal and his or her designees are hereby authorized to approve dimensional relief within the egress systems of any existing building in accordance with NFPA 101 and its annexes. Such dimensional relief shall be known as “AHJ modifications”. All “AHJ modifications” must be in writing and submitted to the State Fire Marshal’s Office for approval and recording. Once approved and recorded by the State Fire Marshal’s Office, the “AHJ modification” shall remain as permanent relief for the building as long as the use and/or occupancy of the building remains the same. Any change of use and/or occupancy shall subject the building to review under the relevant codes and reconsideration of the “AHJ modification” in light of the new use or occupancy.
(Add) 1.6.2 Administration.
The Fire Safety Code Board of Appeal & Review is the sole authority having jurisdiction for administration of this Code. Accordingly, the Fire Safety Code Board of Appeal & Review is the sole authority having jurisdiction to grant variances, waivers and amendments from, or to review and accept any proposed fire safety equivalencies and alternatives to, the strict adherence to the provisions of this Code and all referenced standards herein. For purposes of uniform administration, all exceptions listed in this Code, and its referenced standards, allowing for a discretionary waiver by the authority having jurisdiction, shall be referred directly to the Fire Safety Code Board of Appeal & Review as outlined in Fire Safety Code Section 6-1-1 et seq.
(Add) 1.6.2.1
Procedures, adopted by the Fire Safety Code Board of Appeal & Review, addressing administrative appeals, are outlined in Fire Safety Code sections 6-1-1 through 6-1-12.
(Add) 1.6.2.2
Procedures, adopted by the Fire Safety Code Board of Appeal & Review, addressing administrative hearings and court appeals, are outlined in Fire Safety Code sections 6-2-1 through 6-2-25.
(Add) 1.6.2.3
Procedures, adopted by the Fire Safety Code Board of Appeal & Review, addressing the Board’s rule making authority, are outlined in Fire Safety Code sections 6-3-1 through 6-3-5.
(Add) 1.6.2.4
Procedures, adopted by the Fire Safety Code Board of Appeal & Review, addressing code interpretation by the board, are outlined in Fire Safety Code 6-4-1 through 6-4-6.
(Add) 1.6.3
Police and other enforcement agencies shall have authority to render necessary assistance in the enforcement of this Code when expressly requested to do so by the State Fire Marshal.
(Add) 1.6.4
The State Fire Marshal may delegate to other qualified individuals such powers as are necessary for the proper enforcement of the Code. The Fire Safety Code Board of Appeal & Review may delegate to its appointed staff such powers as are necessary for the proper administration of this Code.
(Add) 1.6.5
The State Fire Marshal is authorized to inspect, at all reasonable times, any building or premises for dangerous or hazardous conditions or materials as set forth in this Code and the general provisions of the Fire Safety Code. The State Fire Marshal may order any person(s) to remove or remedy such dangerous or hazardous condition or material. Any person(s) failing to comply with such an order shall be in violation of the Fire Safety Code. Any person so charged with a violation of this Code shall have the right to appeal the order of the State Fire Marshal to the Fire Safety Code Board of Appeal & Review. An appeal shall automatically stay the State Fire Marshal’s order. However, where the State Fire Marshal, or his or her designee, advises that such an automatic stay would endanger the public and/or the owner’s tenants or employees, the chairperson of the board, or his or her designee, may, for such good cause shown, suspend the automatic stay of the State Fire Marshal’s order pending review by the full board.
(Add) 1.6.6. Abatement.
The State Fire Marshal, or his or her designee within the division, or an assistant deputy state fire marshal in accordance with the guidelines established by the State Fire Marshal, has the authority to summarily abate any condition which presents immediate danger to life. The conditions that present an “immediate danger to life” are outlined under the definition of “abatement or to abate a condition” found in fire safety code section 4. A failure to abate a condition that presents a clear and immediate danger to life shall be grounds for the person issuing the order to abate, to require that the premises be vacated. Any such order to vacate the premises shall be either approved in writing by the State Fire Marshal or a designee of the State Fire Marshal who has been given advanced written authority by the State Fire Marshal to approve such actions.
(Add) 1.7
When a conflict between the language of the original 2012 Edition of NFPA 101-Life Safety Code and any specific Rhode Island amendment occurs, the conflict shall initially be resolved by the Office of the State Fire Marshal.
8.1.2 CHAPTER 2 – REFERENCED PUBLICATIONS
8.1.3 CHAPTER 3 – DEFINITIONS
(Amd) 3.3.36.3 Apartment Building.
A building or portion thereof containing four or more dwelling units with independent cooking and bathroom facilities.
(Add) 3.4 Rhode Island Specific Definitions
(Add) 3.4.1 Abatement or to Abate a condition: Abatement, or to abate a condition, is the reduction, decrease, or diminution of a hazardous condition that presents immediate danger to life. The term “immediate” denotes that action is or must be taken either instantly or without any considerable loss of time. The condition may be singular or may be a set of conditions that in combination present an “immediate danger to life”. Such conditions, that present an “immediate danger to life”, shall include improper management or use of flammable and combustible materials, liquids and gases, pyrotechnics, fireworks or explosives, malfunctioning automatic sprinklers, fire alarms and emergency lighting, malfunctioning heating and electrical systems, blocked or inadequate exits or means of egress, the overcrowding of assembly occupancies and such other conditions as may be established by the Fire Safety Code Board of Appeal and Review.
(Add) 3.4.2 Adult Day-Care. A building or portion thereof used for less than 24 hours per day to house more than three adults requiring supportive care, maintenance, and supervision by other than their relatives.
(Add) 3.4.3 Authority Having Jurisdiction (Enforcement). Unless specifically defined to the contrary in this code, the authority having jurisdiction for the enforcement of this code shall be the state fire marshal. The state fire marshal may delegate this enforcement authority to any deputy state fire marshal or assistant deputy state fire marshal that he or she certifies and appoints pursuant to R.I. Gen. Laws § 23-28.2-1 et seq. However, as a condition of their continued certification, all such appointed deputy state fire marshals and assistant deputy state fire marshals shall apply the code, consistently and uniformly across the state, under the guidance of the state fire marshal.
(Add) 3.4.4 Bed and Breakfast Home.: An owner and/or innkeeper occupied building that provides sleeping accommodations for up to sixteen (16) guests. Every “Bed and Breakfast Home” must further have originated as a private home and must have at least 300 square feet of common space (i.e., dining room, living room, etc.) for guest use, and must further provide breakfast. Finally, the owner and/or innkeeper must occupy the building twenty-four hours a day, seven days a week, while guests are utilizing the facility. The owner and/or innkeeper of the Bed and Breakfast Home shall have a plan of action, approved by the local official, to assure the safety of the guests in the event the owner or innkeeper is required to temporarily leave the facility unsupervised for limited periods during the day.
(Add) 3.4.5 Certificate of Occupancy.: After the building official inspects the building or structure and, after consultation with the AHJ enforcing the provisions of this code, finds no violations of the provisions of this code or other laws that are enforced by the department of building safety, the building official issues an official document known as a “certificate of occupancy” that generally contains the following:
1. The building permit number.
2. The address of the structure.
3. The name and address of the owner.
4. A description of that portion of the structure for which the certificate is issued.
5. A statement that the described portion of the structure has been inspected for compliance with the requirements of this code for the occupancy and division of occupancy and the use for which the proposed occupancy is classified.
6. The name of the building official.
7. The edition of the code under which the permit was issued.
8. The use and occupancy, in accordance with the provisions of the State Building Code.
9. The type of construction as defined in the State Building Code.
10. The design occupant load.
11. If an automatic sprinkler system is provided, whether the sprinkler system is required.
12. Any special stipulations and conditions of the building permit.
(Add) 3.4.6 Citation System: A system of enforcement outlined in R.I. Gen. Laws § 23-28.2-14.
(Add) 3.4.7 Code: The term “code” means this Fire Safety Code established under the provisions of R.I. Gen. Laws § 23-28.1-1.
(Add) 3.4.8 Compliance Order: For the purposes of this Code, a compliance order is defined as a command or direction authoritatively given to a building owner or occupant to provide conformance with the Fire Safety Code. A compliance order takes effect when a building owner or occupant, after proper notice, has exhausted his/her administrative appeals or has failed to avail himself/herself of appropriate administrative appeals within a reasonable period of time after receiving proper notice.
(Add) 3.4.9 Emergency Shelter Occupancy: An occupancy or portion thereof used on a temporary basis to provide sleeping accommodations for transient or displaced individuals who have no other shelter arrangements during periods of severe weather or during the aftermath of a natural or man-made disaster.
(Add) 3.4.10 Family Day Care Home: The term “family day care home” means any home other than the child’s home in which child day care in lieu of parental care and/or supervision is offered at the same time to at least four (4) but not more than eight (8) children who are not relatives of the care giver, and which is licensed by the state department of children, youth, and families and subject to the department’s regulations.
(Add) 3.4.11 Funeral Establishment: An assembly occupancy, as defined by R.I. Gen. Laws § 5-33.2-1(11) as a “fixed place, establishment or premises, licensed by the department of health, devoted to the activities which are incident, convenient, or related to the care and preparation, arrangement, financial and otherwise, for the funeral, transportation, burial or other disposition of human bodies and including, but not limited to, a suitable room with all instruments and supplies used for the storage and/or preparation of dead human bodies for burial or other disposition”.
(Add) 3.4.12 Organized Dining Facility: A place of public accommodation which is characterized as a facility where private events are held and where the primary source of revenue, in general, is derived from rental charges for use of the facility and service of food. Such a facility shall not provide for cover charges or have as a primary attraction any event where entertainment is provided by a live band or recorded music. Such a facility primarily provides for organized banquets, private parties, fund raisers, wedding receptions, ceremonial events and the like.
(Add) 3.4.13 Nightclub: A place of public accommodation, which in general is characterized by all of the following:
1. Provides entertainment by a live band or recorded music generating above normal sound levels.
2. Has as its primary source of revenue, in general, the sale of beverages of any kind for consumption on the premises and/or cover charges. Food, if served, is considered a secondary attraction.
3. Has an occupant load in total or in any single area or room of at least 100 patrons.
Nothing in this definition shall be construed to include any place of public accommodation or any event within a place of public accommodation, which is in its nature distinctly private.
(Add) 3.4.14 Place of Worship: A building or structure, or an area thereof, the occupancy of which is for the religious rites and services and communal functions of a congregation, and which shall include sanctuaries, gathering halls, meeting rooms and offices and related facilities of the congregation, which may be located in the same, in connected, or in proximate structures.
(Add) 3.4.15 Suspended Ceiling: A ceiling system consisting of a grid of channels or “T-bars” suspended from the structure above for readily removable acoustical tiles or lay- in panels.
(Add) 3.4.16 Temporary Certificate of Occupancy: The building official may issue a temporary certificate of occupancy before the completion of the entire work covered by the permit, provided that such portion or portions shall be occupied safely. The building official shall set a time period during which the temporary certificate of occupancy is valid.
(Add) 3.4.17 Three Family Apartment Building.
A building or portion thereof containing three dwelling units with independent cooking and bathroom facilities. This code shall provide reasonable standards for the installation of smoke and carbon monoxide detectors in three family apartment buildings.
8.1.4 CHAPTER 4 – General
(Add) 4.6.9.3
The Authority Having Jurisdiction (AHJ) for the enforcement of this code may approve the issuance of a temporary certificate of occupancy (TCO) by the building official provided the major life safety systems (sprinkler, fire alarm, approved egress system, etc.) are operational in the area of the building to be so occupied. The AHJ is further authorized to require any additional safeguards he or she deems necessary to ensure the life safety of the temporary occupants.
(Add) 4.6.12.2.1 Existing fire protection systems, or portions thereof, shall only be removed in accordance with the following procedure:
1. The building owner shall request that the State Fire Marshal or local AHJ conduct a full inspection of the facility to determine whether the fire protection system is currently required and if there are any other fire code deficiencies in the subject facility. All such deficiencies must be corrected before removing or modifying the fire protection system.
2. The State Fire Marshal or the local AHJ conducting the full inspection shall further advise the owner if any variances, previously granted, would be voided in the absence of the fire protection system. If such variances were granted, the owner must either correct the underlying deficiencies, or secure additional relief from the Fire Board, before removing or modifying the fire protection system.
8.1.5 CHAPTER 5 – PERFORMANCE-BASED OPTIONS
(No Modifications)
8.1.6 CHAPTER 6 – CLASSIFICATION OF OCCUPANCY AND HAZARD OF CONTENTS
(Add) 6.1.14.4.5
Sections 6.1.14.4.1 through 6.1.14.4.4 above shall not be construed as to require that any or all occupancies be separated. These sections simply establish the separation requirements necessary if a building owner chooses to have a portion of the building not comply with the most restrictive requirements of the occupancies involved. All non-separated occupancies are mixed occupancies, as defined in section 6.1.14.2.2, and must comply with the provisions of this code covering mixed occupancies.
8.1.7 CHAPTER 7 – MEANS OF EGRESS
(Add) 7.2.8.9 Maintenance
(Add) 7.2.8.9.1 All fire escape stairs shall be maintained in good physical repair and remain useable at all times.
(Add) 7.2.8.9.2 Maintenance of fire escape stairs shall include:
1. Exit access shall remain clear and unobstructed at all times.
2. All moving parts shall remain operable at all times.
3. All structural members including landings, railings, stair components, handrails, guards, and support or mounting components shall be free of rust and corrosion.
4. All surfaces subject to corrosion shall be painted.
(Add) 7.2.8.9.3 Fire escape stairs that are not properly maintained and show signs of structural instability shall be repaired prior to continued use. All repairs shall be inspected by a person or firm acceptable to the State Fire Marshal.
(Add) 7.2.9.4 Maintenance
(Add) 7.2.9.4.1 All fire escape ladders shall be maintained in good physical repair and remain useable at all times.
(Add) 7.2.9.4.2 Maintenance of fire escape ladders shall include:
1. Exit access shall remain clear and unobstructed at all times.
2. All moving parts shall remain operable at all times.
3. All structural members including landings, railings, stair components, handrails, guards, and support or mounting components shall be free of rust and corrosion.
4. All surfaces subject to corrosion shall be painted.
(Add) 7.2.9.4.3 Fire escape ladders that are not properly maintained and show signs of structural instability shall be repaired prior to continued use. All repairs shall be inspected by a person or firm acceptable to the State Fire Marshal.
8.1.8 CHAPTER 8 – FEATURES OF FIRE PROTECTION
(No Modifications)
8.1.9 CHAPTER 9 – BUILDING SERVICE AND FIRE PROTECTION EQUIPMENT
(Amd) 9.1.3.2
New generator controllers shall be monitored by the fire alarm system, where provided, or at an attended location approved by the AHJ, for the following conditions:
1. Generator running
2. Generator fault
3. Generator switch in non-automatic position
Exception: A generator remote annunciator may be installed adjacent to the fire alarm control panel or fire alarm remote annunciator with the approval of the AHJ to satisfy this requirement.
(Add) 9.1.3.3 Where a building fire alarm system is provided, existing emergency generators shall be monitored by the fire alarm system for generator running.
Exception: A generator remote annunciator may be installed adjacent to the fire alarm control panel or fire alarm remote annunciator with the approval of the AHJ to satisfy this requirement.
(Add) 9.2.4.5 Where a building fire alarm system is provided, it shall be interconnected to the building’s heating, ventilating and air conditioning (HVAC) line voltage controls so that the fan(s) supplying 2,000 ft³/min. (cfm) (56.63 m³/min.) or greater capacity of any ventilating system not used for pressurization of a fire safe area shall automatically shut down any time, other than drills or when testing, that any initiating device connected to the fire alarm system is activated as provided in 9.6.5.2 (6).
(Add) 9.2.4.6 The requirements of 9.2.4.5 may be omitted in areas where shut down may interfere with clean room operations, temperature controlled environments protecting sensitive equipment, or other building operations as approved by the authority having jurisdiction.
(Amd) 9.4.2.1
Except as modified herein, new elevators, escalators, dumbwaiters, and moving walks shall be in accordance with the requirements of ASME A17.1/CSA B44, Safety Code for Elevators and Escalators and the Rhode Island Elevator Safety Code.
(Amd) 9.4.2.2
Except as modified herein, existing elevators, escalators, dumbwaiters, and moving walks shall conform to the requirements of ASME A17.3, Safety Code for Existing Elevators and Escalators and the Rhode Island Elevator Safety Code.
(Amd) 9.4.2.3
Elevators in accordance with ASME A17.1/CSA B44.7, Performance-Based Safety Code for Elevators and Escalators, shall be deemed to comply with ASME A17.1/CSA B44, Safety Code for Elevators and Escalators, or ASME A17.3, Safety Code for Existing Elevators and Escalators and the Rhode Island Elevator Safety Code.
(Amd) 9.4.3.2
All existing elevators shall conform to the Fire Fighters’ Emergency Operations requirements of ASME A17.3, Safety Code for Existing Elevators and Escalators and the Rhode Island Elevator Safety Code.
(Amd) 9.4.6.1
Elevators shall be subject to periodic inspections and tests as specified in ASME A17.1/CSA B44, Safety Code for Elevators and Escalators and the Rhode Island Elevator Safety Code.
(Amd) 9.4.6.2
All elevators equipped with fire fighters’ emergency operations in accordance with 9.4.3 shall be subject to a monthly operation with a written record of the findings made and kept on the premises as required by ASME A17.1/CSA B44, Safety Code for Elevators and Escalators and the Rhode Island Elevator Safety Code.
(Amd) 9.4.6.3 The elevator inspections and tests required by 9.4.6.1 shall be performed at frequencies complying with the Rhode Island Elevator Safety Code.
(Add) 9.6.1.1.1
The Authority having jurisdiction (AHJ), for the purpose of enforcing the Rhode Island Life Safety Code, Section 9.6 shall be the state fire marshal or his or her designee and those parties certified by the state fire marshal as prescribed by R.I. Gen. Laws § 23-28.2-6.
(Amd) 9.6.1.3*
Where required, a fire alarm system shall be installed, tested, and maintained in accordance with the applicable requirements of this Chapter, NFPA 70, National Electrical Code, and NFPA 72, National Fire Alarm and Signaling Code. Any conflicts between the provisions of this Chapter, as amended and NFPA 72 shall be resolved in favor of the provisions of this chapter as determined by the State Fire Marshal.
(Amd) 9.6.1.4
All systems and components shall be approved for the purpose for which they are installed, and listed by a nationally recognized testing laboratory.
(Amd) 9.6.1.6 Where a required fire alarm system is out of service for more than 4 hours in a 24-hour period for repair, maintenance or testing, the authority having jurisdiction shall be notified, and the building shall be evacuated, or an approved fire watch shall be provided for all parties left unprotected by the shutdown, until the fire alarm system has been returned to service.
(Add) 9.6.1.6.1 With the written approval of, and subject to any additional safeguards mandated by the AHJ, the fire alarm systems, or portions thereof may be temporarily disabled for events or other occasions where environmental, mechanical or human factors would lead to unnecessary nuisance, accidental or intentional false alarms.
(Amd) 9.6.1.8.1* Automatic smoke detection shall be installed to provide notification of fire at the following locations:
1. Each fire alarm control unit
2. Notification appliance circuit power extenders
3. Supervising station transmitting equipment
(Res.) 9.6.1.8.1.1
(Add) 9.6.2.2.1
Manual fire alarm boxes shall be double-action, colored red, key locked and shall be keyed the same as the fire alarm control panel unit door lock. Manual fire alarm boxes shall be installed in accordance with NFPA 72.
(Add) 9.6.2.2.2
Manual fire alarm boxes, new and existing, used in systems not intended for emergency forces notification shall be marked “In case of emergency, pull handle, then call 9-1-1”.
(Amd) 9.6.2.8 Where a sprinkler system provides automatic detection and alarm system initiation, it shall be provided with an approved alarm initiation device that operates within 90 seconds when the flow of water is equal to or greater than that from a single automatic sprinkler.
(Amd) 9.6.2.9 Where a total (complete) coverage fire alarm system is required by another section of this Code, automatic detection shall be provided as follows:
1. Automatic detection shall be located in all areas of the building as required by NFPA 72, National Fire Alarm and Signaling Code, for total (complete) coverage;
2. The detection required by 9.6.2.9 (1) shall include automatic smoke detectors in all common corridors, top of all stairwells, stairwell landings at each floor level, elevator machine rooms and machine spaces, and all elevator landings; and
3. Areas of the building not identified in 9.6.2.9 (2), but requiring detection based on 9.6.2.9 (1), shall be permitted to be protected by automatic heat detectors or an approved, supervised automatic sprinkler system.
(Amd) 9.6.2.11 Where required by Chapters 11 through 43, an automatic fire detection system for initiation of the signaling system shall be provided in accordance with all of the following:
(add) (1) Smoke detectors installed in accordance with NFPA 72, National Fire Alarm and Signaling Code, shall be provided in all common corridors, lobbies, top of all stairwells, stairwell landings at each floor level, elevator machine rooms and machine spaces, and all elevator landings.
(add) (2) Combination rate of rise and one hundred thirty-five degrees (135º) F to one hundred forty degrees (140º) F fixed temperature heat detectors installed in accordance with NFPA 72, National Fire Alarm and Signaling Code, shall be provided in kitchens within dwelling units, storage rooms greater than 24 square feet, utility rooms, electrical rooms, mechanical equipment rooms, maintenance shops, locker rooms, projection booths, above stage areas, below accessible stage areas, integral or attached garages and elevator hoistways.
(add) (3) Combination rate of rise and one hundred thirty-five degrees (135º) F to one hundred forty degrees (140º) F fixed temperature heat detectors installed in accordance with NFPA 72, National Fire Alarm and Signaling Code, shall be provided in spaces of twenty four inches (0.61 m) or more above suspended ceilings.
(add) (4) Automatic fixed temperature heat detectors with a rating of one hundred ninety degrees (190º) F to two hundred degrees (200º) F installed in accordance with NFPA 72, National Fire Alarm and Signaling Code, shall be provided in kitchens with cooking equipment, boiler or furnace rooms, common laundry rooms and accessible attics.
(Add) (5) Spaces twenty-four inches (0.61m) or more above suspended ceilings shall be exempt from the requirements of 9.6.2.11 (3) if the space is built of non- combustible construction and the space contains only wiring, ductwork and fixtures, properly installed under this Code or the State Building Code.
(Add) 9.6.2.12
In locations where heat detectors and/or smoke detectors are required, the type and/or temperature rating of the heat detector or smoke detector may be modified if the type or temperature rating of the device is unsuitable due to environmental or structural conditions unique to that location or where multiple nuisance alarms have occurred.
(Add) 9.6.2.13 Where a specific temperature rating or type of heat detector is specified elsewhere in this code, rate anticipation detectors, line-type detectors, beam detectors or other type detectors listed for the application may be installed where approved by the AHJ.
(Res) 9.6.3.2.1
(Amd) 9.6.3.2.2 Where duct-type smoke detectors are installed in HVAC systems, the duct-type smoke detectors shall be connected to the fire alarm control unit to signal an audible and visual supervisory signal at the fire alarm control unit and annunciator. An alarm condition shall not occur unless specifically requested and authorized by the AHJ.
(Res) 9.6.3.2.3
(Res) 9.6.3.5.3
(Res) 9.6.3.5.4
(Amd) 9.6.3.9 Automatically transmitted or approved live voice evacuation or relocation instructions shall be permitted to be used to notify occupants and shall comply with either 9.6.3.9.1 or 9.6.3.9.2.
(Amd) 9.6.3.9.1 Automatically transmitted or approved live voice evacuation or relocation instructions shall be in accordance with NFPA 72, National Fire Alarm and Signaling Code
(Amd) 9.6.3.9.2* Where permitted by Chapters 11 through 43 and subject to the approval of the authority having jurisdiction, automatically transmitted or live voice announcements shall be permitted to be made via a voice communication or public address system that complies with the following:
1. Occupant notification, either live or recorded, shall be initiated at a constantly attended receiving station by personnel trained to respond to an emergency.
2. An approved secondary power supply shall be provided for other than existing, previously approved systems.
3. The system shall be audible above the expected ambient noise level.
4. Emergency announcements shall take precedence over any other use.
(Amd) RILSC 9.6.4.2 Where emergency forces notification is required by this Code and installed in a building in a city, town, or fire district having a municipal alarm system, the fire alarm system within the building shall be connected into the municipal system via a local energy master box, auxiliary transmitter, radio master box, or other approved method so that any fire alarm signal within the building will be automatically transmitted to the community’s public fire service communications center.
(Add) 9.6.4.2.1 Systems installed in buildings in a city, town, or fire district not having a municipal alarm system shall be connected to the community public fire service communications center via a supervised leased telephone line, transmitters, remote stations or other method in a manner approved by the AHJ so that any fire alarm signal within the building will be automatically transmitted to the community’s public fire service communications center.
(Res) 9.6.4.3
(Add) 9.6.4.4 All fire alarm control panels (FACP) connected to the local Public Fire Alarm Reporting System shall be configured to restore the circuit when an alarm signal is silenced or acknowledged.
(Add) 9.6.4.5 Multiple-zone signaling from the protected premises shall be provided in any jurisdiction capable of receiving multiple-zone signals and shall be provided as required by the AHJ.
(Add) 9.6.4.6 In complexes consisting of multiple building clusters, a single means of connection in accordance with 9.6.4.2 may be used to accomplish emergency forces notification provided that each building is clearly identified visually on site in a manner approved by the AHJ (i.e.: strobe lights, etc.)
(Amd) 9.6.5.2 Where required by another section of this Code, the following functions shall be actuated:
1. Release of hold-open devices for doors or other opening protective’s
2. Stairwell or elevator shaft pressurization
3. Smoke management or smoke control systems
4. Unlocking of doors
5. Elevator recall and shutdown
6. HVAC shutdown
7. Operation of exterior horn/strobe notification appliances
(Add) 9.6.5.3 Where the functions identified in 9.6.5.2 (5), 9.6.5.2 (6) or 9.6.5.2 (7) are provided, they shall be actuated upon the initiation of any manual fire alarm box, automatic fire detector or extinguishing system operation installed within the building.
(Add) 9.6.5.4 A manual override for each fire safety function identified in 9.6.5.2 shall be provided at the fire alarm control unit for drills and testing of the fire alarm system.
(Add) 9.6.7.2.1 A directory or zone map as required by the AHJ shall be provided for every fire alarm system. Fire alarm annunciator location shall meet the requirements of the AHJ. The map shall be mounted in a location deemed proper by the AHJ.
(Amd) 9.6.7.3 For the purposes of alarm annunciation, each floor of the building shall be considered as not less than one zone, unless otherwise permitted by 9.6.7.4.4, 9.6.7.4.6 or another section of this Code.
(Amd) 9.6.7.4.3 Where a building is protected by an automatic sprinkler system in accordance with 9.7.1.1 (1), any alarm originating from a sprinkler or a Class II or Class III standpipe connection shall provide two (2) separate indications on the system annunciator, one to indicate “sprinkler/standpipe” and one to indicate the activated zone
(Amd) 9.6.7.4.5 Where a building is protected by an automatic sprinkler system in accordance with 9.7.1.1 (3), any alarm originating from a sprinkler or a Class II or Class III standpipe connection shall provide two (2) separate indications on the system annunciator, one to indicate “sprinkler/standpipe” and one to indicate the activated zone
(Add) 9.6.7.4.6 Where an existing building that is not classified as a high-rise is protected by an existing sprinkler system in accordance with 9.7.1.1 (1) or 9.7.1.1 (3), the sprinkler system shall be permitted to be annunciated on the fire alarm system as a single zone.
(Add) 9.6.7.6.1 Supervisory signals, including the operation of valve supervisory switches or duct type smoke detectors, shall be permitted to annunciate as a trouble signal on existing fire alarm systems.
(Add) 9.6.7.8 In complexes consisting of multiple building clusters without emergency forces notification, each building shall be clearly identified visually on site in a manner approved by the AHJ (i.e.: strobe lights, etc.).
(Add) 9.6.8 Equipment
(Add) 9.6.8.1 The fire alarm system owner shall provide a 24-hour emergency telephone number of the owner or owner’s representative for the fire department to call in the event of an alarm or trouble condition. This telephone number shall be conspicuously posted at the fire alarm control unit.
(Add) 9.6.8.2 Where emergency forces notification is provided in accordance with 9.6.4.2, the fire alarm system shall be provided with a standby battery source capable of supplying the entire system for sixty (60) hours.
(Add) 9.6.8.3 Where emergency forces notification is not provided in accordance with 9.6.4.2, a weather-proof horn/strobe shall be installed on the exterior of the building at a location approved by the AHJ.
(Add) 9.6.8.4 The provisions of 9.6.8.3 shall not apply to residential board and care occupancies equipped with a weather-proof strobe notification appliance installed on the exterior of the building at a location approved by the AHJ.
(Add) 9.6.8.5 Fault isolation modules or bases shall be installed on all signaling line circuits to prevent a wire-to-wire short circuit fault from disabling more than twenty-five (>25) devices on the circuit.
(Add) 9.6.8.6 When a common signaling line circuit serves more than one floor of a building, fault isolation modules shall be installed to prevent a wire-to-wire short circuit fault on one floor from disabling the remainder of the SLC on any other floor.
(Add) 9.6.8.7 When control and/or signaling modules are used for the activation of notification appliance circuits or to initiate emergency forces notification, fault isolation modules shall be installed on each side of the control or signaling module.
(Add) 9.6.8.8 Low-Power Radio
(Add) 9.6.8.8.1 Low-Power Radio (Wireless) Systems shall comply with all provisions of this Chapter. All systems shall be UL listed as a commercial or industrial fire alarm system – systems listed only for household or residential applications shall not be permitted.
(Add) 9.6.8.8.2 Wireless components of the system shall not be required to comply with 9.6.9; however, any hard-wired component(s) of the system including initiating device circuits, notification appliance circuits, signaling line circuits or auxiliary circuits shall fully comply with 9.6.8.4.2.1 through 9.6.8.4.2.3.
(Add) 9.6.8.8.2.1 Wiring between wireless control panel(s) and remote annunciation may be #18 AWG solid unlimited footage if installed in conduit or type MC Cable.
(Add) 9.6.8.8.2.2 Wiring between wireless control panel(s) and remote receiver(s) may be #18 AWG solid unlimited footage if installed in conduit or type MC Cable.
(Add) 9.6.8.8.2.3 Wiring from a transmitter to a single device shall be limited to twenty feet (20’) and may be #18 AWG solid if installed in either the cavity of the wall or in conduit or type MC Cable.
(Add) 9.6.8.8.3 If there is interference to the system causing multiple false alarms or numerous trouble indications that cannot be resolved to the satisfaction of the AHJ, the wireless system shall be removed and a hard-wired system installed in compliance with the Code. The contractor shall notify the owner of this requirement in writing prior to the installation of the wireless system.
(Add) 9.6.8.8.4 The Control Panel shall have the capability of acknowledging an alarm and restoring the municipal connection while maintaining all other functions, if a municipally connected system as described in 9.6.4.4.
(Add) 9.6.8.8.4.1 The Control panel shall have its means of acknowledgement, silence, activation, reset, or any other functions which require manual intervention to be performed by either key switches or other controls secured behind a key-locked cover to prevent unauthorized operation.
(Add) 9.6.8.8.4.2 The maximum allowable response delay from activation of an initiating device to activation of required alarm functions shall be ten (10) seconds.
(Add) 9.6.8.8.5 Low-Power Radio (Wireless) Repeater/Receiver The Repeater(s) and/or Receiver(s) shall be UL Listed 864 (UOXX), Control Unit Accessories/Systems and must comply with the provisions of NFPA 72.
(Add) 9.6.8.8.5.1 The repeater/receiver shall be listed for use with the listed control panel.
(Add) 9.6.8.8.5.2 When repeaters and/or receivers are used, the system must provide for a Class “A” signaling as defined in NFPA 72 National Fire Alarm and Signaling Code (2010), Chapter 10. An alternative communications path shall exist between the wireless control panel and peripheral devices used to establish initiation, indication, control, and annunciation.
(Add) 9.6.8.8.5.3 When the means of transmission to a wireless control panel is accomplished by means other than air, such as through wiring, the requirements of the Installation and Wiring section of this chapter shall apply. A redundant path must be established requiring the installation of a second repeater in order to establish a redundant communication path back to the control panel.
(Add) 9.6.8.8.5.4 Reception of an unwanted (interfering) signal, which is continuous for a period of twenty (20) seconds or more, shall cause the repeater to report this condition to the control panel at intervals not exceeding two hundred (200) seconds.
(Add) 9.6.8.8.5.5 Loss of primary AC power to a repeater shall cause a distinct indication at the control panel and shall latch until a normal condition is restored.
(Add) 9.6.8.8.6 Low-Power Radio (Wireless) Smoke Detector, Heat Detector, Supervised Normally-Open Monitor Modules, and Manual Fire Alarm Boxes shall operate as follows:
1. shall be listed for use with the listed control panel.
2. shall have the ability to send initial and repeat alarms.
3. shall have a minimum battery life of one (1) year under normal operation.
4. In the event of a low battery, the device must be able to remain operable for a minimum of seven (7) days and this condition must be displayed at the control panel indicating a low battery signal and the exact device.
5. Low battery signals shall be sent no less than once every four (4) hours for a minimum of seven (7) days.
6. All devices shall be supervised for tamper (removal). This signal shall be sent to the control panel and indicate a tamper condition and the exact device. This condition must continue to report no less than every two hundred (200) seconds or latch until restored.
7. Devices installed on a removable ceiling tile must have the ability to indicate the removal of the tile through a tamper indication.
8. Devices shall send test signals not less than once every ninety (90) minutes.
(Add) 9.6.9 Installation and Wiring
(Add) 9.6.9.1 Transponders, Data Gathering Panels, Nodes, etc. shall communicate with the Central Processing Unit (CPU) via a Class “X” Signaling Line Circuit (SLC) meeting the requirements as described in NFPA 72.
(Add) 9.6.9.2 Signaling line circuits (SLC), initiating device circuits (IDC) and notification appliance circuits (NAC) shall be installed utilizing Class “A” pathways meeting the requirements as described in NFPA 72.
(Add) 9.6.9.3 The requirement of 9.6.9.2 shall not apply to fire alarm systems not requiring emergency forces notification in accordance with 9.6.4.2.
(Add) 9.6.9.4
All fire alarm system wiring within a building and between buildings in multiple building clusters shall be installed in metal raceway with steel couplings and box connectors or type MC cable rated as FPL and 2-hour fire rated for penetrations by a nationally recognized testing laboratory. Cast “LB” or “T” type connectors shall be permitted. An equipment-bonding conductor shall be provided in all flexible metallic raceways unless otherwise exempted elsewhere in this Code.
(Add) 9.6.9.5
Wiring between buildings may be buried if enclosed in PVC conduit using approved IMSA cables, or installed either using approved direct burial type MC cable or run aerially with approved IMSA shielded cable(s) subject to approval by the AHJ.
(Add) 9.6.9.6
All conductors shall be minimum #16 gauge and be solid copper, type “thhn”, “thwn” or “tfn” unless otherwise recommended by the manufacturer. All wiring shall be run continuously from device to device. With the approval of the AHJ, junction points may be made due to construction hardships where a continuous run would be impractical.
(Add) 9.6.9.6.1 Junction points between devices shall be permitted on existing fire alarm systems provided the junction points are terminated on terminal strips.
(Add) 9.6.9.7
UL listed type MC cable connectors with insulated bushings and screw type cable attachments or box clamps with anti-short inserts shall be used in all MC cable installations. Connectors shall be made of steel, not the cast type.
(Add) 9.6.9.8
The color code for all newly installed fire alarm system conductors shall be as follows:
1. INITIATING DEVICE CIRCUIT shall be red and black. Red shall be positive and black shall be negative [IDC/SLC].
2. NOTIFICATION APPLIANCE CIRCUIT shall be blue and white. Blue shall be positive and white shall be negative. When speakers, bells, chimes or other audible/visual devices are used in lieu of horns, this color code shall be followed [NAC].
3. STROBE CIRCUIT, if a separate feed is required, shall be blue and white. Blue shall be positive and white shall be negative.
4. SMOKE DETECTOR CIRCUITS, if a separate power feed is required, shall be brown and violet. Violet shall be positive and brown shall be negative.
5. “LOCAL” SMOKE DETECTOR CIRCUITS, if an interconnect wire between sounder bases is required, shall be violet.
6. AUXILIARY REMOTE POWER SUPPLY CIRCUITS shall be brown and violet. Violet shall be positive and brown shall be negative.
7. ELECTRO-MAGNETIC DOOR HOLDBACK CIRCUITS shall be gray and gray if powered by 24 vDC or black and white if powered by 120 vAC.
8. MUNICIPAL MASTER BOX TRIPPING CIRCUITS shall be orange and orange. Conductors for this circuit shall be installed in a separate raceway.
9. ELEVATOR CAPTURE CIRCUITS shall be brown and yellow.
10. HVAC SHUTDOWN CIRCUITS and AUDIO/VISUAL SYSTEMS SHUTDOWN CIRCUITS shall be orange and yellow.
11. REMOTE ANNUNCIATOR CIRCUITS shall be violet and numbered at each end or as required by the control unit manufacturer.
12. MUNICIPAL FIRE ALARM LOOP from the master box to the municipal loop shall be black and white.
(Add) 9.6.9.9
Primary AC power and/or battery charger circuits shall be on a dedicated branch circuit(s). Circuit disconnecting means shall have a red marking, shall be accessible only to authorized personnel, and shall be identified as “FIRE ALARM CIRCUIT”. Where the disconnecting means is a circuit breaker located within a distribution panel, a circuit breaker lock listed for use with that breaker shall be provided. The location of the circuit disconnecting means shall be permanently identified inside the fire alarm control unit. AC and DC portions of the system shall be installed in separate raceways.
(Add) 9.6.9.10
Terminal cabinets shall be provided at all junction points. Terminal cabinets shall be red with hinged locked covers. All conductor splices or terminations shall be made on screw- type terminal blocks – wire nuts, butt or crimp type connectors shall not be used. All terminals within a terminal cabinet shall be properly identified.
Exception: Crimp-type connectors may be used on bonding conductors.
(Add) 9.6.10 System Acceptance
(Add) 9.6.10.1 A pre-acceptance test will be held with the installer and the manufacturer’s technical representative present. The pretest shall be a 100% test as follows:
1. Manually operate every manual fire alarm box, activate every rate of rise type heat detector and rate anticipation heat detector with heat.
2. Manually operate or electrically short out every non-restorable fixed temperature heat detector.
3. Activate every smoke detector with smoke generated from a wick/punk source or in accordance with the manufacturer’s recommendations to demonstrate that smoke can enter the chamber and initiate an alarm.
4. Activate all automatic extinguishing system switches.
5. Activate and time every water sprinkler/standpipe flow switch by a flow of water through the inspectors’ test valves.
6. All notification appliances shall be verified as operational at the time of this test.
(Add) 9.6.10.2 Prior to the final operational acceptance test, a NFPA 72 Fire Alarm System Record of Completion shall be prepared and submitted to the fire alarm system owner and the AHJ. The contractor shall prepare and submit a single line diagram of each installation, as built, indicating wiring between equipment and locations of control units, initiating and notification devices to the owner and AHJ.
(Add) 9.6.10.3 The installing contractor shall conduct a final acceptance test including a complete functional test of the system in the presence of the AHJ and the manufacturer’s authorized technical representative. During this test each circuit will be tested by class, or style or both, to assure the circuit’s capability to continue to operate during specified fault condition.
(Add) 9.6.10.4 The fire alarm system may be placed in operation prior to final acceptance if in the opinion of the AHJ it will enhance public safety or provide property protection during the final phases of construction. In this case all devices will be thoroughly cleaned or replaced prior to the system acceptance test. The system will not be placed in operation without the written permission of the AHJ. Under no circumstances will this be considered a final acceptance test.
(Add) 9.6.11 Maintenance and Testing
(Add) 9.6.11.1 All fire alarm systems shall be tested at least once every three (3) months with twenty-five percent (25%) of all initiating devices operated with each test. A different twenty-five percent (25%) of the above-mentioned devices will be operated at each inspection so that the entire system will have been tested at the end of a twelve (12) months period as per NFPA 72.
(Add) 9.6.11.2 A fire alarm system with twenty-four (24) or less initiating devices shall be tested at least once every six (6) months with fifty percent (50%) of all initiating devices operated with each test so that the entire system will have been tested at the end of a twelve (12) months period as per NFPA 72.
(Add) 9.6.11.3 Certification of tests and results shall be forwarded to the AHJ and the fire alarm system owner from the person(s) or firm performing the test within ten (10) days of the completion of the test. The person(s) or firm performing the testing of the fire alarm shall notify the AHJ within five (5) days, in writing, after any cancellation of a testing agreement with the fire alarm owner.
(Add) 9.6.11.4 Certification of any periodic testing required by the Code shall be on Uniform Testing Report (UTR) as prescribed in NFPA 1, Section 1.13.1(3). This UTR shall be utilized by all persons and firms performing fire alarm testing and inspections pursuant to this Code and shall bear the name and license number of the licensed person performing the test.
(Add) 9.6.11.5 In addition to the testing requirements, all system smoke detectors located within the protected premises shall be externally cleaned at least once every twelve (12) month period.
(Add) 9.7.2.3 Whenever any supervised automatic sprinkler supervisory signal is required to sound and be displayed at a location that is constantly attended by qualified personnel, signals that sound and are displayed in a public or common area of the building shall be deemed to be in compliance.
8.1.10 CHAPTER 10- INTERIOR FINISH, CONTENTS, AND FURNISHINGS
(No Modifications)
8.1.11 CHAPTER 11 – SPECIAL STRUCTURES AND HIGH-RISE BUILDINGS
(Add) 11.8.4.3 Emergency voice/alarm communication systems shall also be provided with standby amplifiers equal to the amount of amplification required for the complete system operation.
(Add) 11.8.4.4 Smoke detectors shall be installed in stairwells at the first floor, every third floor thereafter and at the top of every stairwell.
(Add) 11.8.4.5 Stairwell smoke detector activation shall not cause an evacuation signal to be sounded; however; emergency forces notification shall occur.
8.1.12 CHAPTER 12 – NEW ASSEMBLY OCCUPANCIES
(Amd) 12.3.4.1.1 Assembly occupancies shall be provided with an approved fire alarm system in accordance with 9.6.1 and 12.3.4, unless otherwise permitted by 12.3.4.1.2 or 12.3.4.1.3.
(Add) 12.3.4.1.3 Places of worship with a calculated occupant load of seventy four (74) or less occupants and no more than one (1) story above grade shall not be required to be provided with a fire alarm system.
(Amd) 12.3.4.2.1 Initiation of the required fire alarm system shall be all of the following means:
1. Manual means in accordance with 9.6.2.1(1).
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Res) 12.3.4.2.2
(Res) 12.3.4.2.3
(Add) 12.3.4.2.4 A manual fire alarm box shall be installed on every stage, near any fixed lighting control panel and in any projection booth.
(Add) 12.3.4.2.5 Manual fire alarm boxes, with the approval of the AHJ, may be omitted from required exits and installed in such supervised locations as bar areas, hostess stands, refreshment stands, ticket booths or other areas attended by permanent staff.
(Amd) 12.3.4.3 Notification. Occupant notification by both audible and visible means shall be provided automatically in accordance with 9.6.3.
(Amd) 12.3.4.3.3 Audible occupant notification in places of assembly classified as theaters shall be by means of voice announcements in accordance with 9.6.3.9.
(Res) 12.3.4.3.4
(Amd) 12.3.4.3.6 Evacuation or relocation instructions shall be permitted to be made via a voice communication or public address system in accordance with 9.6.3.9.2.
(Res) 12.3.4.3.7
(Add) 12.3.4.3.8 Upon the activation of any fire alarm system in any nightclub place of assembly or theater, the fire alarm system shall be interconnected with the building systems so that all emergency lights or other appropriate lighting shall activate and that all other conflicting sounds and visuals shall cease.
(Add) 12.3.4.3.9 Emergency forces notification shall be provided in accordance with where one of the following conditions exists:
1. The place of assembly has a total occupant load of three hundred one (301) or greater.
2. The place of assembly is classified as a nightclub place of assembly and has an occupant load of one hundred fifty (150) or greater.
3. The place of assembly is classified as a theater.
(Add) 12.3.4.4 Detection
(Add) 12.3.4.4.1 Where a fire alarm system is required, a fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 12.3.4.4.2 In any assembly occupancy where the exemption to the requirement for automatic sprinklers is utilized, the fire alarm system shall meet the requirements for total (complete) coverage.
Exception: Places of Worship.
(Res) 12.4.7.5
(Add) 12.4.11 Nightclubs
(Add) 12.4.11.1
All nightclubs, as defined in 3.4.13, shall comply with the requirements of 12.4.11.2 through 12.4.11.4 and shall be inspected annually by the AHJ.
(Add) 12.4.11.2
Each stage area, within a nightclub, shall be provided with two fire extinguishers maintained in accordance with NFPA 10, Standard for Portable Fire Extinguishers and approved by the AHJ.
(Add) 12.4.7.11.3
The responsible management of each nightclub shall provide an audible announcement of the location of emergency exits prior to each act or set.
(Add) 12.4.7.11.4
The responsible management of each nightclub shall have an emergency plan for the rapid evacuation of the premises approved by the state fire marshal. The plan shall identify the egress system of the building, explain, on a step-by-step basis, how the crowd manager on duty will complete the evacuation, and explain how the crowd manager will direct the occupants to safety in the event of one or more blocked exits.
(Add) 12.7.1.4
In places of assembly which have scheduled activities for recreational, educational, political, fraternal, social, or amusement purposes, the owner or management must inspect every exit from the building not more than ninety (90) minutes prior to the beginning of any meeting, concert, etc. If the inspection reveals blocked exits, the scheduled presentation must not begin until the exits are cleared and made easily accessible, assuring the safety and welfare of the patrons.
(Add) 12.7.3.1
The use of open flame devices or pyrotechnic devices, outlined in 12.7.3, shall be limited to the places of assembly with occupancy loads in excess of 1000 persons and to those places of assembly, that are theaters, with occupancy loads of greater than 300 but less than 1001. All such places of assembly must be fully sprinkled and further protected by a fire alarm system providing emergency forces notification.
Exception: Places of Worship.
(Amd) 12.7.6 Crowd Management
(Amd) 12.7.6.2
The crowd manager shall receive appropriate training in emergency planning and basic crowd control techniques, by the state fire marshal, or his or her designee.
(Add) 12.7.6.2.1
The crowd manager(s) identified in 12.7.6.1 shall be in addition to the detail fire fighter(s) identified in 12.7.6.4 through 12.7.6.10.
(Add) 12.7.6.3 Admissions supervised.
Admissions to all places of assembly shall be supervised by the responsible management or by the person or persons delegated with the responsibility by the management, and the responsible person shall not allow admissions in excess of the maximum occupancy posted by the State Fire Marshal or his or her designee.
(Add) 12.7.6.4
All places of assembly with an occupancy load of greater than 1000 people shall have a uniformed fire fighter, and any additional uniformed fire fighters on duty when deemed necessary by the chief of the department.
(Add) 12.7.6.5
All places of assembly, of less concentrated use, with an occupancy load of greater than 300 people, but less than 1001 people, shall have a uniformed fire fighter and any additional uniformed fire fighters on duty when deemed necessary by the chief of the department.
(Add) 12.7.6.6
All places of assembly, of concentrated use, with an occupancy load of greater than 50 people, but less than 1001 people shall have a uniformed fire fighter and any additional uniformed fire fighters on duty when deemed necessary by the chief of the department except as provided under 12.7.6.7.
(Add) 12.7.6.7
All places of assembly, of concentrated or less concentrated use, with an occupancy load of greater than 50 people, but less than 1001 people, being utilized for activities that could potentially cause the place of assembly to be unsafe, dangerous or hazardous shall have one uniformed fire fighter on duty during such activity and any additional uniformed fire fighters on duty when deemed necessary by the chief of the department unless this requirement is specifically waived in writing for each such event.
(Add) 12.7.6.8
The cost of all fire fighters on duty under 12.7.6.4 through 12.7.6.7 shall be borne by the management of the facility.
(Add) 12.7.6.9
Fire fighter(s) assigned a detail pursuant to 12.7.6.4 through 12.7.6.7 shall be equipped with portable communication devices which shall be provided by the local fire department to allow direct communication to the dispatcher of the local fire department.
(Add) 12.7.6.10
The provisions of R.I. Gen. Laws § 23-28.2-17 shall apply to any fire fighter assigned a detail, to a place of assembly, pursuant to 12.7.6.4 through 12.7.6.7.
(Add) 12.7.6.11
Any building owner or occupant may request a partial or full exemption from the mandates of 12.7.6.2 through 12.7.6.10 by the State Fire Marshal and/or the Fire Safety Code Board of Appeal & Review.
8.1.13 CHAPTER 13 – EXISTING ASSEMBLY OCCUPANCIES
(Add) 13.1.8 Places of Worship
A Place of Worship is defined as a building or structure, or an area thereof, the occupancy of which is for the religious rites and services and communal functions of a congregation, and which shall include sanctuaries, gathering halls, meeting rooms, rooms used on a limited basis for religious education, offices and related facilities of the congregation, which may be located in the same, in connected, or in proximate structures.
In areas where there are incidental uses such as non-licensed day care or nurseries the provisions of the Rhode Island Fire Alarm Code, NFPA 72, as amended, also shall apply.
Any one, two or three family residential building that comes under the classification of a Place of Worship that is utilized as a rectory, parsonage, convent or other residence used exclusively for religious personnel, shall only be required to be protected by approved hardwired smoke detectors. In addition, approved carbon monoxide detectors shall be installed when these CO units would be otherwise required under the fire code provisions covering one, two and three family homes.
Any religious-related business office use of a portion of a one, two or three family residential building, or a place of worship, as outlined above, that is confined to a space of less than one thousand square feet of that building, shall not be required to maintain a fire alarm system provided that the above required smoke and/or CO detection system is operational and maintained. Larger business office space, up to the square footage threshold for fire alarm coverage as outlined in this code, may be exempted from fire alarm coverage if it is properly separated from the remainder of the residential building, by approved “acceptable separation”, as outlined in RIFC 10-5-1 through 10-5-1.5.
(Add) 13.1.8.1 Approved existing Places of Worship.
Any place of worship, existing as of January 1, 2008, shall be deemed in compliance with the provisions of this Chapter 13, upon meeting the following fifteen requirements within the time frames provided in this code. The owners and/or operators of any such existing Place of Worship shall not be required to comply with any additional assembly occupancy requirements. The owners and/or operators of any such existing Place of Worship shall be given one year, from the AHJ’s issuance of an inspection report or plan review approval, to bring the existing Place of Worship into compliance with the fifteen requirements outlined below. The AHJ is hereby authorized to extend this time period in light of good faith efforts by the above owners and/or operators. The above owners and/or operators may also seek an additional time extension from the Fire Board.
1. The building maintains a fire alarm system that complies with the provisions of Section 9.6 and Chapter 13 of this Code to the satisfaction of the state fire marshal, deputy state fire marshal and/or the assistant deputy state fire marshal (hereinafter the “AHJ”);
2. Buildings that provide licensed nursery or licensed day care services shall maintain an approved system of either hardwired or wireless smoke and carbon monoxide detectors installed in accordance with NFPA 72, 2010 edition, and NFPA 720, 2012 edition and any additional requirements of these occupancies;
3. The building maintains emergency lighting approved by the AHJ. Buildings with an occupant load less than three hundred (300) persons and used solely for worship shall not required to meet this section. In addition, one story buildings used only during daylight hours shall not be required to meet this section;
4. The building maintains approved exit signage, if so required by the AHJ;
5. The building shall maintain egress calculated for its maximum occupancy with a minimum of two means of egress. The egress doors within a Place of Worship may be allowed to swing opposite to the direction of exit travel provided that these doors are held in an open position, to the satisfaction of the AHJ, by either hold-open devices, during all hours when the Place of Worship is occupied as a place of assembly or by trained ushers as outlined below. The AHJ may further approve a plan of action allowing trained ushers to open these doors during an evacuation of the Place of Worship.
6. The walls of the internal means of egress are made of plaster and/or sheetrock, are in good repair, and maintain an approximate fire rating of twenty (20) minutes. The AHJ is hereby authorized to accept the existing hard wood or other substantial construction of a sanctuary and/or fellowship or parish hall and not require these materials to be coated with a Class A or B flame spread material. Religious banners, cloth coverings, flowers and other limited vegetation, in reasonable amounts, shall be permitted. The AHJ is authorized to approve the temporary placement of a freshly cut natural Christmas tree in accordance with an approved plan addressing the care, maintenance and eventual removal of the fresh-cut Christmas tree.
7. All combustible covering materials, within the approved egress systems, such as existing paneling or wainscoting, mounted on approved plaster or sheetrock walls or ceilings, shall be rendered flame resistant by the application of an approved Class A flame-spread rated material to the satisfaction of the AHJ;
8. The existing dimensions of the egress system appear to adequately support the rapid evacuation of the building, in the opinion of the AHJ and the internal means of egress may contain winding stairs;
9. There shall be no smoking allowed in Places of Worship;
10. Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ;
11. Any furnace, boiler or comparable central heating plant above 160,000 BTU input and all floor mounted units requiring a non-combustible floor by their listing, shall be either segregated from the remainder of the building by an enclosure maintaining an approximate one hour rating or protected by domestically-supplied sprinkler head(s) to the satisfaction of the AHJ;
12. Portable fire extinguishers shall be provided in accordance with section 9.7.4.1;
13. Automatic sprinkler coverage, only if specifically required by the State Fire Marshal in accordance with R.I. Gen. Laws § 23-28.6-24.
14. Any commercial cooking equipment shall be protected in accordance with NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations, 2001 edition. Provided however, this requirement shall not apply where the cooking equipment is used only to reheat or warm food and there is the absence of smoke or grease-laden vapors. In cases where there is an intermittent use of commercial cooking equipment used for actual cooking, not exceeding two (2) hours per week as an annual average, this requirement shall be waived by the AHJ provided that a plan of action is approved by the AHJ for each use.
The management of a Place of Worship shall not allow the operation, within the facility, of a commercial deep fat fryer unit, such as a “fry-o-lator”, without first providing that potentially hazardous commercial deep fat fryer unit with approved ventilation control and fire protection, in accordance with the referenced edition of NFPA 96, at the direction and to the satisfaction of the AHJ. The above requirement shall be waived if the deep fat frying unit is currently protected by a properly maintained ventilation control and fire protection system that had been previously approved by an AHJ.
15. The use of any open flame(s) shall be in accordance with 101:13.7.3.
Any new construction, renovations, alterations, reconstruction and/or additions to an existing Place of Worship, covered by the above fifteen-point plan, shall comply with the applicable fire codes covering those activities in an existing place of assembly. Notwithstanding the above, the existing portions of a Place of Worship shall not be required to be sprinkled unless they are not separated, from any new addition proposed for assembly occupancy, by approximately one hour fire rated separation. In the absence of an approximate one hour fire separation between an existing and a new assembly occupancy, the merged existing and new assembly occupancies shall be calculated on the basis of fifteen square feet per person to determine whether sprinklers are to be required.
(Add) 13.1.8.2 Time Table for Compliance by Places of Worship:
All existing occupancies, falling under the definition of Places of Worship, as defined in 13.1.8 above, are hereby granted relief, by a time variance as outlined below, from bringing their facilities into compliance with the current provisions of the State Fire Code as follows:
Exception: Any residential occupancy falling under the definition of Places of Worship shall be equipped with hardwired smoke and CO detectors if required, on or before January 1, 2013.
1. All existing Places of Worship shall be inspected by the State Fire Marshal, or designee, and comprehensive written reports shall be issued on or before December 31, 2013.
2. All existing Places of Worship shall be brought into compliance with all fire code requirements on or before December 31, 2014.
Places of Worship containing other regulated occupancies, such as licensed Daycare, etc., shall bring only those portions of the building into compliance with the fire codes covering that regulated occupancy, at the direction and to the satisfaction of, and within a reasonable timetable established by, the State Fire Marshal or his or her designee.
(Amd) 13.3.4.1.1 Assembly occupancies shall be provided with an approved fire alarm system in accordance with 9.6.1 and 13.3.4, unless otherwise permitted by 13.3.4.1.2 or 13.3.4.1.5.
(Res) 13.3.4.1.3
(Res) 13.3.4.1.4
(Add) 13.3.4.1.5 Places of worship with a calculated occupant load of seventy four (74) or less occupants and no more than one (1) story above grade shall not be required to be provided with a fire alarm system.
(Amd) 13.3.4.2.1 Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1).
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Res) 13.3.4.2.2
(Res) 13.3.4.2.3
(Add) 13.3.4.2.4 A manual fire alarm box shall be installed on every stage, near any fixed lighting control panel and in any projection booth.
(Add) 13.3.4.2.5 Manual fire alarm boxes, with the approval of the AHJ, may be omitted from required exits and installed in such supervised locations as bar areas, hostess stands, refreshment stands, ticket booths or other areas attended by permanent staff.
(Amd) 13.3.4.3 Notification. Occupant notification by both audible and visible means shall be provided automatically in accordance with 9.6.3.
(Amd) 13.3.4.3.3 Audible occupant notification in places of assembly classified as theaters shall be by means of voice announcements in accordance with 9.6.3.9.
(Res) 13.3.4.3.4
(Amd) 13.3.4.3.6 Evacuation or relocation instructions shall be permitted to be made via a voice communication or public address system in accordance with 9.6.3.9.2.
(Res) 13.3.4.3.7
(Add) 13.3.4.3.8 Upon the activation of any fire alarm system in any nightclub place of assembly or theater, the fire alarm system shall be interconnected with the building systems so that all emergency lights or other appropriate lighting shall activate and that all other conflicting sounds and visuals shall cease.
(Add) 13.3.4.3.9 Emergency forces notification shall be provided in accordance with where one of the following conditions exists:
1. The place of assembly has a total occupant load of three hundred one (301) or greater.
2. The place of assembly is classified as a nightclub place of assembly and has an occupant load of one hundred fifty (150) or greater.
3. The place of assembly is classified as a theater.
(Add) 13.3.4.4 Detection
(Add) 13.3.4.4.1 Where a fire alarm system is required, a fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 13.3.4.4.2 In any existing place of worship where the exemption to the requirement for automatic sprinklers is utilized, the fire alarm system shall not be required to meet the requirements for total (complete) coverage.
(Amd) 13.3.5.1
Unless exempted by another provision of this chapter, all existing places of assembly shall be completely protected by an approved, supervised automatic sprinkler system installed and maintained in accordance with 9.7.1.1(1).
(Add) 13.3.5.1.1
The requirements of 13.3.5.1 shall not apply to the following:
1. Any place of assembly of less concentrated use, such as an organized dining facility, with occupancy of 300 or fewer people, calculated at 15 square feet per person. (The above fifteen square feet (15 sq. ft.) per person calculation shall be exclusive of any separately calculated limited incidental spaces designated as a waiting area by the AHJ. The above fifteen square feet (15 sq. ft.) per person calculation shall also not apply to buildings, containing separately calculated booths or similar fixed seating, determined not to be concentrated occupancies by the AHJ.)
2. Any place of assembly of concentrated use, with an occupancy of 300 or fewer people, not meeting the definition of a nightclub as outlined in 3.4.12.
3. Any place of assembly of concentrated use, meeting the definition of a nightclub, as outlined in 3.4.13, with a posted maximum occupancy of less than 150 people.
4. Any existing building used exclusively as a place of worship as defined in 13.1.8. (This exemption shall include places of worship with incidental business offices, religious education programs, and other programs designed watch children during the limited period of time that their parents or guardians attend religious services in the building. It shall also include the temporary programs outlined in Chapter 27 of this Code. This exemption shall not include places of worship maintaining such licensed activities as child day care and bingo. Permission for limited one time or annual events may be sought from the AHJ in accordance with an approved plan of action. Denial of this permission may be appealed to the Fire Safety Code Board of Appeal & Review.)
5. Existing fully alarmed performance theaters, with occupancies of less than five hundred (500) patrons, equipped with operational stages, as defined in section 3.3.262 of NFPA 101, 2012 edition; provided that the theater maintains double the required remotely located egress calculated for the theater’s maximum occupancy, and further provided that the theater’s patrons discharge through code compliant exit doors directly to grade; and finally provided that the stage, and other potentially hazardous areas, are protected by an approved properly engineered system of sprinkler heads, on or before January 1, 2013.
6. All existing licensed “funeral establishments”, having an occupancy capacity of five hundred (500) or fewer persons, shall not be required to be sprinkled provided they install and maintain a full coverage fire alarm system, at the direction and to the satisfaction of the state or local fire marshal with jurisdiction.
As a further condition of the above relief, the Board directs that there shall be no smoking in all licensed “funeral establishments” and there shall be no open flame with the exception of approved gas log fireplaces having glass doors. Additionally, the Rhode Island Funeral Directors’ Association and the State Fire Marshal’s office will coordinate crowd management training for the owners and operators of all licensed “funeral establishments”.
The chemical storage in all embalming rooms shall comply with NFPA 1 – RIFC, 2012 edition and its referenced codes and standards. Additionally, all crematoriums shall be suitably separated and shall further comply with all Federal and State fire, mechanical, building and health code standards.
Any attached garage(s), not suitably separated in the opinion of the state or local fire marshal with jurisdiction, shall be further protected with approved heat detection connected to the fire alarm system protecting the facility. Existing boiler rooms may utilize properly engineered, domestically-supplied, sprinkler head(s), installed in accordance with local water board requirements (if any), in lieu of the enclosure requirements. All such facilities shall have egress approved for their maximum occupant load. Finally, any existing dimensional issue, determined to be a structural hardship by the state or local fire marshal with jurisdiction, may be granted a modification by that state or local fire marshal in accordance with the procedure outlined in 1.6.1.1.
(Add) 13.3.5.5
The occupancy of any place of assembly without a required fire alarm system and/or sprinkler system, shall have its maximum occupancy adjusted by minus ten percent (10%) for the absence of a fire alarm system and minus twenty (20%) for the absence of a sprinkler system, when sprinklers are required by law or regulation. Such downward adjustment in occupancy shall be cumulative and shall cease to apply when the premises are in compliance with the requirements for fire alarm systems and sprinklers, and shall not affect any other requirements of this Code, or the Fire Safety Code Board of Appeal and Review, applicable to the premises.
(Add) 13.3.5.5.1
A place of assembly, with an occupancy of between one hundred fifty (150) and three hundred (300) people, may avoid the requirements of 13.3.5.6 by requiring a fire fighter on duty, as outlined in 13.7.6.6, during all hours of occupancy or by complying with an alternative plan of action approved by the AHJ. However, the occupancy re-adjustment with the required firefighter shall not alter the January 1, 2013 deadline for the installation of sprinklers.
(Add) 13.4.4.1 Existing high-rise buildings shall be provided with a detection, alarm and communication system in accordance with 11.8.4 and an emergency command center complying with 11.8.6.
(Add) 13.4.11 Nightclubs
(Add) 13.4.11.1
All nightclubs, as defined in 3.4.13, shall comply with the requirements of through 13.4.11.4 and shall be inspected annually by the AHJ.
(Add) 13.4.11.2
Each stage area, within a nightclub, shall be provided with two fire extinguishers maintained in accordance with NFPA 10, Standard for Portable Fire Extinguishers and approved by the AHJ.
(Add) 13.4.11.3
The responsible management of each nightclub shall provide an audible announcement of the location of emergency exits prior to each act or set.
(Add) 13.4.11.4
The responsible management of each nightclub shall have an emergency plan for the rapid evacuation of the premises approved by the state fire marshal. The plan shall identify the egress system of the building, explain, on a step-by-step basis, how the crowd manager on duty will complete the evacuation, and explain how the crowd manager will direct the occupants to safety in the event of one or more blocked exits.
(Add) 13.7.1.4
In places of assembly which have scheduled activities for recreational, educational, political, fraternal, social, or amusement purposes, the owner or management must inspect every exit from the building not more than ninety (90) minutes prior to the beginning of any meeting, concert, etc. If the inspection reveals blocked exits, the scheduled presentation must not begin until the exits are cleared and made easily accessible, assuring the safety and welfare of the patrons.
(Add) 13.7.3.1
The use of open flame devices or pyrotechnic devices, outlined in 13.7.3, shall be limited to the places of assembly with occupancy loads in excess of 1000 persons and to those places of assembly, that are theaters, with occupancy loads of greater than 300 but less than 1001. All such places of assembly must be fully sprinkled and further protected by a fire alarm system providing emergency forces notification.
Exception: Places of worship.
(Amd) 13.7.6 Crowd Management
(Amd) 13.7.6.2
The crowd manager shall receive appropriate training in emergency planning and basic crowd control techniques, by the state fire marshal, or his or her designee, on or before January 1, 2013.
(Add) 13.7.6.2.1
The crowd manager(s) identified in 13.7.6.1 shall be in addition to the detail fire fighter(s) identified in 13.7.6.4 through 13.7.6.10.
(Add) 13.7.6.3 Admissions supervised.
Admissions to all places of assembly shall be supervised by the responsible management or by the person or persons delegated with the responsibility by the management, and the responsible person shall not allow admissions in excess of the maximum occupancy posted by the State Fire Marshal or his or her designee.
(Add) 13.7.6.4
All places of assembly with an occupancy load of greater than 1000 people shall have a uniformed fire fighter, and any additional uniformed fire fighters on duty when deemed necessary by the designee of the state fire marshal in the local fire department.
(Add) 13.7.6.5
All places of assembly, of less concentrated use, with an occupancy load of greater than 300 people, but less than 1001 people, shall have a uniformed fire fighter and any additional uniformed fire fighters on duty when deemed necessary by the designee of the state fire marshal in the local fire department.
(Add) 13.7.6.6
All places of assembly, of concentrated use, with an occupancy load of greater than 50 people, but less than 1001 people shall have a uniformed fire fighter and any additional uniformed fire fighters on duty when deemed necessary by the designee of the state fire marshal in the local fire department except as provided under 13.7.6.7.
(Add) 13.7.6.7
All places of assembly, of concentrated or less concentrated use, with an occupancy load of greater than 50 people, but less than 1001 people, being utilized for activities that could potentially cause the place of assembly to be unsafe, dangerous or hazardous shall have one uniformed fire fighter on duty during such activity and any additional uniformed fire fighters on duty when deemed necessary by the designee of the state fire marshal in the local fire department unless this requirement is specifically waived in writing for each such event.
(Add) 13.7.6.8
The cost of all fire fighters on duty under 13.7.6.4 through 13.7.6.7 shall be borne by the management of the facility.
(Add) 13.7.6.9
Fire fighter(s) assigned a detail pursuant to 13.7.6.4 through 13.7.6.7 shall be equipped with portable communication devices which shall be provided by the local fire department to allow direct communication to the dispatcher of the local fire department.
(Add) 13.7.6.10
The provisions of R.I. Gen. Laws § 23-28.2-17 shall apply to any fire fighter assigned a detail, to a place of assembly, pursuant to 13.7.6.4 through 13.7.6.7.
(Add) 13.7.6.11
Any building owner or occupant may request a partial or full exemption from the mandates of 13.7.6.2 through 13.7.6.10 by the State Fire Marshal and/or the Fire Safety Code Board of Appeal & Review.
8.1.14 CHAPTER 14 – NEW EDUCATIONAL OCCUPANCIES
(Amd) 14.1.2.3 In cases where instruction is incidental to some other occupancy, the section of this Code governing the other occupancy shall apply. Sunday schools or church schools that are not used for daily classes throughout the week shall comply with the section of this Code dealing with places of worship.
(Amd) 14.3.4.2.1 Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.
(Res) 14.3.4.2.2
(Res) 14.3.4.2.3
(Res) 14.3.4.2.3.1
(Res) 14.3.4.2.3.2
(Add) 14.3.4.4 Detection
(Add) 14.3.4.4.1 Where a fire alarm system is required, a total (complete) coverage fire detection system in accordance with 9.6.2.9 shall be provided.
(Add) 14.3.4.4.2 The requirement of 14.3.4.4.1 shall not apply to educational occupancies equipped throughout with an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1) and an automatic smoke detection system in accordance with 9.6.2.11(1).
(Add) 14.3.4.5
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Add) 14.7.3.4 Annual Inspections
All educational occupancies shall be inspected annually by the AHJ.
(Amd) 15.1.2.3 In cases where instruction is incidental to some other occupancy, the section of this Code governing the other occupancy shall apply. Sunday schools or church schools that are not used for daily classes throughout the week shall comply with the section of this Code dealing with places of worship.
(Amd) 15.3.4.2.1 Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.
(Res) 15.3.4.2.2
(Res) 15.3.4.2.3
(Res) 15.3.4.2.3.1
(Res) 15.3.4.2.3.2
(Amd) 15.3.4.3.2.1 Emergency Forces Notification shall be in accordance with 9.6.4.2.
(Res) 15.3.4.3.2.2
(Add) 15.3.4.4 Detection
(Add) 15.3.4.4.1 Where a fire alarm system is required, a total (complete) coverage fire detection system in accordance with 9.6.2.9 shall be provided.
(Add) 15.3.4.4.2 The requirement of 15.3.4.4.1 shall not apply to educational occupancies equipped throughout with an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1) and an automatic smoke detection system in accordance with 9.6.2.11(1).
(Add) 15.3.4.5
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 15.4.2 High-Rise Buildings. High-rise buildings shall comply with 11.8.1 and be provided with a detection, alarm and communication system in accordance with 11.8.4 and an emergency command center complying with 11.8.6.
(Add) 15.7.3.4 Annual Inspections
All educational occupancies shall be inspected annually by the AHJ.
8.1.16 CHAPTER 16 – NEW DAY-CARE OCCUPANCIES
(Amd) 16.1.4.2 Special Definitions. A list of special terms used in this chapter follows:
1. Day-Care Home. See 3.3.140.1.
2. Flexible Plan and Open Plan Educational or Day-Care Building. See 3.3.36.6.
3. Self-Preservation (Day-Care Occupancy). See 3.3.240.
4. Separate Atmosphere. See 3.3.26.2.
5. Adult Day Care. See 3.4.2.
(Add) 16.2.2.2.3.4 It shall be recognized that, in buildings. or portions thereof, housing certain clients who exhibit behavior that is harmful to themselves or others, it might be necessary to lock egress doors to confine and protect building inhabitants.
(Add) 16.2.2.2.3.5 Buildings, or sections thereof, that primarily house clients who, in the opinion of the governing body of the facility, the governmental licensing agency, or authority having jurisdiction, are incapable of self-preservation under emergency conditions shall be permitted to have locking arrangements complying with the provisions of 18.2.2.2.5.
(Add) 16.2.2.2.3.6 The requirements of 16.2.2.2.3.5 shall only apply when staff is available in all secured client-occupied areas to perform certain fire safety functions as required in 18.2.2.2.5 through 18.2.2.2.5.2, and 18.7.
(Amd) 16.3.4.1 General. Day-care occupancies shall be provided with a fire alarm system in accordance with 9.6.
(Amd) 16.3.4.2 Initiation. Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.9.
(Add) 16.3.4.4.1 Emergency forces notifications shall not be required for day care occupancies with less than nineteen (19) clients, under 3,000 ft2 (278.71 m2) and located on a ground floor.
(Amd) 16.3.4.5 Detection. Where a fire alarm system is required, a total (complete) coverage fire detection system in accordance with 9.6.2.9 shall be provided.
(Add) 16.3.4.5.1 In addition to the requirements of 9.6.2.9(2), smoke detectors shall be installed in all lounges, recreation areas and sleeping rooms within the day-care occupancy.
(Add) 16.3.4.6 Smoke and Carbon Monoxide Alarms. Every child day-care occupancy shall be provided with either hardwired or wireless smoke and carbon monoxide detectors installed in accordance with the referenced editions of NFPA 72 and NFPA 720. Local smoke alarms shall not be required in areas protected by system smoke detectors.
(Add) 16.3.4.7
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Add) 16.6.3.4.6. Carbon Monoxide Alarms.
Day-care homes shall be provided with either hardwired or wireless carbon monoxide detectors installed in accordance with the referenced editions of and NFPA 720.
8.1.17 CHAPTER 17 – EXISTING DAY-CARE OCCUPANCIES
(Amd) 17.1.4.2 Special Definitions. A list of special terms used in this chapter follows:
1. Day-Care Home. See 3.3.140.1.
2. Flexible Plan and Open Plan Educational or Day-Care Building. See 3.3.36.6.
3. Self-Preservation (Day-Care Occupancy). See 3.3.240.
4. Separate Atmosphere. See 3.3.26.2.
5. Adult Day Care. See 3.4.2.
(Add) 17.2.2.2.3.4 It shall be recognized that, in buildings or portions thereof, housing certain clients who exhibit behavior that is harmful to themselves or others, it might be necessary to lock egress doors to confine and protect building inhabitants.
(Add) 17.2.2.2.3.5 Buildings, or sections thereof, that primarily house clients who, in the opinion of the governing body of the facility, the governmental licensing agency, or authority having jurisdiction, are incapable of self-preservation under emergency conditions shall be permitted to have locking arrangements complying with the provisions of 18.2.2.2.5.
(Add) 17.2.2.2.3.6 The requirements of 16.2.2.2.3.5 shall only apply when staff is available in all secured client-occupied areas to perform certain fire safety functions as required in 18.2.2.2.5 through 18.2.2.2.5.2, and 18.7.
(Amd) 17.3.4.1. General. Day-care occupancies shall be provided with a fire alarm system in accordance with 9.6.
(Amd) 17.3.4.2 Initiation. Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.9.
(Amd) 17.3.4.4.1 Emergency forces notification shall be accomplished in accordance with 9.6.4.
(Amd) 17.3.4.4.2 Emergency forces notifications shall not be required for day care occupancies with less than nineteen (19) clients, under 3,000 ft2 (278.71 m2) and located on a ground floor.
(Amd) 17.3.4.5 Detection. Where a fire alarm system is required, a total (complete) coverage fire detection system in accordance with 9.6.2.9 shall be provided.
(Add) 17.3.4.5.1 In addition to the requirements of 9.6.2.9(2), smoke detectors shall be installed in all lounges, recreation areas and sleeping rooms within the day-care occupancy.
(Add) 17.3.4.6 Smoke and Carbon Monoxide Alarms. Every child day-care occupancy shall be provided with either hardwired or wireless smoke and carbon monoxide detectors installed in accordance with the referenced editions of NFPA 72 and NFPA 720. Local smoke alarms shall not be required in areas protected by system smoke detectors.
(Add) 17.3.4.7
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Add) 17.6.3.4.5. Carbon Monoxide Alarms.
Day-care homes shall be provided with either hardwired or wireless carbon monoxide detectors installed in accordance with the referenced editions of and NFPA 720.
8.1.18 CHAPTER 18- NEW HEALTH CARE OCCUPANCIES
(Amd) 18.3.4.5.1 General. A total (complete) coverage fire detection system in accordance with 9.6.2.9 shall be provided.
(Res) 18.3.4.5.3
(Add) 18.3.4.6
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
8.1.19 CHAPTER 19 – EXISTING HEALTH CARE OCCUPANCIES
(Res) 19.3.4.2.3
(Amd) 19.3.4.5.1 A total (complete) coverage fire detection system in accordance with 9.6.2.9 shall be provided, unless otherwise permitted by 19.3.4.5.3.
(Add) 19.3.4.5.3 Health care occupancies built or converted prior to January 1, 2005 shall be permitted to have a fire detection system complying with 9.6.2.11.
(Add) 19.3.4.6
Any conflict between the provisions of this section and the provisions of amended Section 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 19.4.2.1 All high-rise buildings containing health care occupancies shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with the RIFC, NFPA 1, as amended.
(Res) 19.4.2.2
(Add) 19.4.2.3 High-rise buildings shall be provided with a detection, alarm and communication system in accordance with 11.8.4 and an emergency command center complying with 11.8.6.
8.1.20 CHAPTER 20- NEW AMBULATORY HEALTH CARE OCCUPANCIES
(Amd) 20.3.4.1 General. Ambulatory health care facilities shall be provided with fire alarm systems in accordance with 9.6, except as modified by 20.3.4.2 through 20.3.4.5.
(Amd) 20.3.4.2 Initiation. Initiation of the required fire alarm systems shall be by manual means in accordance with 9.6.2 and by means of any required sprinkler system waterflow alarms, detection devices or detection systems.
(Add) 20.3.4.5 Detection. A total (complete) coverage fire detection system in accordance with 9.6.2.9 shall be provided.
(Add) 20.3.4.6
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
8.1.21 CHAPTER 21- EXISTING AMBULATORY HEALTH CARE OCCUPANCIES
(Amd) 21.3.4.1 General. Ambulatory health care facilities shall be provided with fire alarm systems in accordance with 9.6, except as modified by 21.3.4.2 through 21.3.4.5.
(Amd) 21.3.4.2 Initiation. Initiation of the required fire alarm systems shall be by manual means in accordance with 9.6.2 and by means of any required sprinkler system waterflow alarms, detection devices or detection systems.
(Add) 21.3.4.5 Detection.
1. (Add) 21.3.4.5.1 A total (complete) coverage fire detection system in accordance with shall be provided, unless otherwise permitted by 21.3.4.5.2.
2. (Add) 21.3.4.5.2 Ambulatory health care occupancies built or converted prior to January 1, 2005 shall be permitted to have a fire detection system complying with 9.6.2.11.
(Add) 21.3.4.6
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
8.1.22 CHAPTER 22 – NEW DETENTION AND CORRECTIONAL OCCUPANCIES
(Res) 22.3.4.2.2
(Amd) 22.3.4.3.2.1. Fire department notification shall be accomplished in accordance with 9.6.4.
(Res) 22.3.4.3.2.2.
(Amd) 22.3.4.4 Detection. An approved fire detection system, including a smoke detection system throughout all resident sleeping areas and adjacent day rooms, activity rooms, or contiguous common spaces, shall be in accordance with 9.6.2.11 as modified by 22.3.4.4.1 through 22.3.4.4.5.
(Add) 22.3.4.5.
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 22.4.3 High-Rise Buildings. High-rise buildings shall comply with 11.8.3, 11.8.4 and 11.8.6.
(Amd) 22.4.4.9 Detection, Alarm, and Communications Systems (Nonsprinklered Buildings). A fire alarms system in accordance with 22.3.4 and 9.6 shall be provided.
(Res) 22.4.4.9.1
(Res) 22.4.4.9.2
8.1.23 CHAPTER 23- EXISTING DETENTION AND CORRECTIONAL OCCUPANCIES
(Amd) 23.4.2.1 Initiation of the required fire alarm system shall be by manual means in accordance with 9.6.2 and by means of any required sprinkler system water flow alarms, detection devices, or detection systems, unless otherwise permitted by the following:
1. Manual fire alarm boxes shall be permitted to be locked, provided that staff is present within the area when it is occupied and staff has keys readily available to unlock the boxes.
2. Manual fire alarm boxes shall be permitted to be located in a staff location, provided that both of the following criteria are met:
a. The staff location is attended when the building is occupied.
b. The staff attendant has direct supervision of the sleeping area.
(Res) 23.3.4.2.2
(Amd) 23.3.4.3.2.1 Fire department notification shall be accomplished in accordance with 9.6.4.
(Res) 23.3.4.3.2.2
(Amd) 22.3.4.4 Detection. An approved fire detection system, including a smoke detection system throughout all resident housing areas, shall be in accordance with 9.6.2.11 as modified by 23.3.4.4.1 through 23.3.4.4.4.
(Add) 23.3.4.5
Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Add) 23.4.3.1 Existing high-rise buildings shall comply with 11.8.4 and 11.8.6.
8.1.24 CHAPTER 24 – ONE- AND TWO-FAMILY DWELLINGS
24.1.1 Application
(Amd) 24.1.1.1
The Rhode Island Fire Code’s application to one and two family dwellings is strictly limited to the installation of smoke and carbon monoxide smoke detection as outlined in sections 24.6.1 through 24.6.3.1.7 as outlined below. Sections 24.1 through 24.5.1.2 may therefore only be otherwise utilized by the AHJ if they are specifically referenced by, and mandated under, a separate occupancy section of this code.
(Add) 24.6.1
Compliance with State Building and Minimum Housing Codes.
(Add) 24.6.1.1
All one and two family dwellings shall remain subject to, and comply with, the State Building Code, SBC-2, adopted pursuant to R.I. Gen. Laws § 23-27.3 et seq.
(Add) 24.6.1.2
All one and two family dwellings shall further remain subject to, and comply with the Minimum Housing Standards outlined in R.I. Gen. Laws § 45-24.2-1 et seq.
(Add) 24.6.2 Installation of Smoke and Carbon Monoxide Alarms-New and converted buildings.
(Add) 24.6.2.1
All buildings hereinafter constructed or converted for residential occupancy, including mobile and modular homes, shall be provided with smoke and carbon monoxide detectors, installed in accordance with NFPA 72, 2010 edition, and NFPA 720, 2012 edition, at the direction and to the satisfaction of the AHJ.
(Add) 24.6.2.1.1
The above smoke and carbon monoxide detectors may be installed as either separate or combination units approved by the AHJ.
(Add) 24.6.2.1.2
The above smoke and carbon monoxide detectors may be either hardwired or wireless units approved by the AHJ.
(Add) 24.6.2.1.3
The local fire authorities certified by the State Fire Marshal as prescribed in R.I. Gen. Laws § 23-28.2-6, in cooperation with the local building code officials, shall enforce the provisions of this chapter.
(Add) 24.6.2.1.4
Compliance with the above provisions shall be considered a prerequisite to the approval, by the fire authority, of any certificate of occupancy issued by the building official pursuant to R.I. Gen. Laws § 23-27.3-120.
(Add) 24.6.2.1.5
It shall be the responsibility of the owner to maintain in operable condition smoke and carbon monoxide detection systems, installed as required pursuant to this chapter, and the owner shall make operable, within seven (7) days after being notified by certified mail by the occupant and/or enforcement official, any inoperable system.
(Add) 24.6.2.1.5.1
If the owner fails to make the system operable within the required seven (7) days, the tenant may cause the system to be made operable if the reasonable total reasonable cost of making the repairs does not exceed the sum of fifty dollars ($50.00), and the tenant may deduct from his or her rent the actual reasonable cost of repairs not to exceed fifty ($50.00).
(Add) 24.6.2.1.5.2
The payment of the reasonable costs, outlined in 24.2.1.5.1, shall not exempt the owner from the payment of fines for violation of this Code as outlined in R.I. Gen. Laws § 23-28.3-9.
(Add) 24.6.3 Installation of Smoke and Carbon Monoxide Alarms-Existing Buildings
(Add) 24.6.3.1
All occupied residential properties, including mobile homes, shall, at the responsibility of the seller before title to the property is transferred, be provided with smoke and carbon monoxide detectors, installed in accordance with NFPA 72, 2010 edition, and NFPA 720, 2012 edition, at the direction and to the satisfaction of the AHJ.
(Add) 24.6.3.1.1
The above smoke and carbon monoxide detectors may be installed as either separate or combination units approved by the AHJ.
(Add) 24.6.3.1.2
The above smoke and carbon monoxide detectors may be either battery operated, hardwired or low power radio units approved by the AHJ. Plug-in type carbon monoxide detectors shall not be acceptable.
(Add) 24.6.3.1.3
The local fire authorities shall enforce the provisions of this chapter. The State Fire Marshal’s Office may enforce the provisions of this chapter when so requested to by the local authority or when the local authority is either unwilling or unable to fulfill its obligations under this chapter.
(Add) 24.6.3.1.3.1
The local fire authority that performs smoke and carbon monoxide detector inspections in all residential occupancies shall, at the time of the inspection, be allowed to charge a thirty dollar ($30.00) fee for the inspection of any residential occupancy. The responsibility of this charged fee will be borne by the seller on each occurrence before title to the property is transferred. A sixty dollar ($60.00) fee will be allowed for any subsequent re-inspection of the same residential occupancy due to improper installation, wrong location, improper wiring method, or the seller’s failure to maintain a mutually agreed upon appointment with the local fire authority that performs the inspection function. The fees collected by the local fire authority shall be used for fire prevention purposes in that particular city, town, fire district, or other municipal subdivision.
(Add) 24.6.3.1.4
At the time of the transfer of title, the seller must provide the purchaser with a certificate from the fire department for the community in which the dwelling is located stating that the smoke and carbon monoxide detector systems have been inspected within one hundred twenty (120) days prior to the date of sale and has been determined to be in good working order. The fire department for the community in which the dwelling is located must inspect the smoke and carbon monoxide detector systems of the dwelling within ten days of a request from the owner. The inspection may be conducted by qualified personnel of the department or the State Fire Marshal’s Office. Neither the fire department nor the State Fire Marshal shall be liable for any damage caused by the subsequent malfunction of a smoke detection system or carbon monoxide detector system which it inspected.
(Add) 24.6.3.1.4.1
Transfers of real property are exempt from compliance with the provisions of 24.6.2 and 24.6.3 if:
(1) The property being transferred does not contain residential dwellings;
(2) Within the past six months a certificate of use or occupancy has been issued for the property being transferred;
(3) The property being transferred currently maintains the smoke and carbon monoxide detection systems, as certified by the local AHJ, in accordance 24.6.3.1.3.1;
(4) The property being transferred is uninhabitable without the issuance of a certificate of use and occupancy;
(5) The property is being transferred pursuant to a foreclosure sale, a tax sale, as a redemption of a tax sale, or in lieu of foreclosure, and provided further that the requirements of this chapter 24 shall be met prior to the re-occupancy of the property;
(6) The property is being transferred by operation of law, or pursuant to an order of any United States court, or any superior or family court of the State of Rhode Island, and provided further that such court order specifically directs non-compliance with this Chapter 24; or
(7) The property is being acquired by the state for demolition and will not be sold or used by the state for residential purposes.
(Add) 24.6.3.1.5
It shall be the responsibility of the owner to maintain in operable condition smoke and carbon monoxide detection systems, installed as required pursuant to this chapter, and the owner shall make operable, within seven (7) days after being notified by certified mail by the occupant and/or enforcement official, any inoperable system.
(Add) 24.6.3.1.5.1
If the owner fails to make the system operable within the required seven (7) days, the tenant may cause the system to be made operable if the reasonable total reasonable cost of making the repairs does not exceed the sum of fifty dollars ($50.00), and the tenant may deduct from his or her rent the actual reasonable cost of repairs not to exceed fifty ($50.00).
(Add) 24.6.3.1.6
Owners of existing residential properties, previously required to install smoke detectors, shall maintain those detectors in good operating condition.
(Add) 24.6.3.1.7
Owners of existing residential properties, previously required to install smoke detectors, shall not be required to immediately install the carbon monoxide detectors. However, full compliance with 24.6 shall be required with the next transfer of title.
8.1.25 CHAPTER 25 – Three Family Apartment Building.
(Add) 25.1 Compliance with State Building and Minimum Housing Codes.
(Add) 25.1.1
All three family apartment buildings shall remain subject to, and comply with, the State Building Code adopted pursuant to R.I. Gen. Laws Chapter23-27.3 et seq.
(Add) 25.1.2
All three family apartment buildings shall further remain subject to, and comply with the Minimum Housing Standards outlined in R.I. Gen. Laws § 45-24.2-1 et seq.
(Add) 25.2 Installation of Smoke and Carbon Monoxide Alarms.
(Add) 25.2.1
All three family apartment buildings hereinafter constructed or converted for residential occupancy, including modular homes, shall be provided with smoke and carbon monoxide detectors, installed in accordance with NFPA 72, and NFPA 720, at the direction and to the satisfaction of the AHJ.
(Add) 25.2.1.1
The above smoke and carbon monoxide detectors may be installed as either separate or combination units approved by the AHJ.
(Add) 25.2.1.2
The above smoke and carbon monoxide detectors may be either hardwired or wireless units approved by the AHJ.
(Add) 25.2.1.3
The local fire authorities certified by the State Fire Marshal as prescribed in R.I. Gen. Laws § 23-28.2.6, in cooperation with the local building code officials, shall enforce the provisions of this chapter.
(Add) 25.2.1.4
Compliance with the above provisions shall be considered a prerequisite to the approval, by the fire authority, of any certificate of occupancy issued by the building official pursuant to R.I. Gen. Laws § 23-27.3-120.
(Add) 25.2.1.5
It shall be the responsibility of the owner to maintain in operable condition smoke and carbon monoxide detection systems, installed as required pursuant to this chapter, and the owner shall make operable, within seven (7) days after being notified by certified mail by the occupant and/or enforcement official, any inoperable system.
(Add) 25.2.1.5.1
If the owner fails to make the system operable within the required seven (7) days, the tenant may cause the system to be made operable if the reasonable total reasonable cost of making the repairs does not exceed the sum of twenty dollars ($20.00), and the tenant may deduct from his or her rent the actual reasonable cost of repairs not to exceed twenty ($20.00).
(Add) 25.2.1.5.2
The payment of the reasonable costs, outlined in 25.2.1.5.1, shall not exempt the owner from the payment of fines for violation of this Code as outlined in R.I. Gen. Laws § 23-28.3-9.
(Add) 25.2.2
All three family apartment buildings, shall, at the responsibility of the owner, be provided with smoke and carbon monoxide detectors, installed in accordance with NFPA 72, 2010 edition, and NFPA 720, 2012 edition, at the direction and to the satisfaction of the AHJ.
(Add) 25.2.2.1
The above smoke and carbon monoxide detectors may be installed as either separate or combination units approved by the AHJ.
(Add) 25.2.2.2
The above smoke and carbon monoxide detectors shall be hardwired or wireless units approved by the AHJ.
(Add) 25.2.2.3
The local fire authorities shall enforce the provisions of this chapter. The State Fire Marshal’s Office may enforce the provisions of this chapter when so requested to by the local authority or when the local authority is either unwilling or unable to fulfill its obligations under this chapter.
(Add) 25.2.2.3.1
The local fire authority that performs smoke and carbon monoxide detector inspections in all residential occupancies shall, at the time of the inspection, be allowed to charge a thirty dollar ($30.00) fee for the inspection of any residential occupancy. The responsibility of this charged fee will be borne by the seller on each occurrence before title to the property is transferred. A sixty dollar ($60.00) fee will be allowed for any subsequent re-inspection of the same residential occupancy due to improper installation, wrong location, improper wiring method, or the seller’s failure to maintain a mutually agreed upon appointment with the local fire authority that performs the inspection function. The fees collected by the local fire authority shall be used for fire prevention purposes in that particular city, town, fire district, or other municipal subdivision.
(Add) 25.2.2.4
At the time of the transfer of title, the seller must provide the purchaser with a certificate from the fire department for the community in which the dwelling is located stating that the smoke and carbon monoxide detector systems have been inspected within one hundred twenty (120) days prior to the date of sale and has been determined to be in good working order. The fire department for the community in which the dwelling is located must inspect the smoke and carbon monoxide detector systems of the dwelling within ten (10) days of a request from the owner. The inspection may be conducted by qualified personnel of the department or the State Fire Marshal’s Office. No fire department nor the State Fire Marshal shall be liable for any damage caused by the subsequent malfunction of a smoke detection system or carbon monoxide detector system which it inspected.
(Add) 25.2.2.4.1
Transfers of real property are exempt from compliance with the provisions of 25.2.2 through 25.2.2.7 if:
1. The property being transferred does not contain residential dwellings;
2. Within the past six months a certificate of use or occupancy has been issued for the property being transferred;
3. The property being transferred currently maintains the smoke and carbon monoxide detection systems, as certified by the local AHJ, in accordance with 25.2.2.3.1;
4. The property being transferred is uninhabitable without the issuance of a certificate of use and occupancy referenced in 25.2.1.4;
5. The property is being transferred pursuant to a foreclosure sale, a tax sale, as a redemption of a tax sale, or in lieu of foreclosure, and provided further that the requirements of this Chapter 25 shall met prior to the re-occupancy of the property;
6. The property is being transferred by operation of law, or pursuant to an order of any United States court, or any superior or family court of the State of Rhode Island, and provided further that such court order specifically directs non-compliance with this Chapter 25; or
7. The property is being acquired by the state for demolition and will not be sold or used by the state for residential purposes.
(Add) RILSC 25.2.2.5
It shall be the responsibility of the owner to maintain in operable condition smoke and carbon monoxide detection systems, installed as required pursuant to this chapter, and the owner shall make operable, within seven (7) days after being notified by certified mail by the occupant and/or enforcement official, any inoperable system.
(Add) RILSC 25.2.2.5.1
If the owner fails to make the system operable within the required seven (7) days, the tenant may cause the system to be made operable if the reasonable total reasonable cost of making the repairs does not exceed the sum of fifty dollars ($50.00), and the tenant may deduct from his or her rent the actual reasonable cost of repairs not to exceed fifty ($50.00).
(Add) RILSC 25.2.2.6
Owners of existing residential properties, previously required to install smoke detectors, shall maintain those detectors in good operating condition.
(Add) RILSC 25.2.2.7
Owners of existing residential properties, previously required to install smoke detectors, shall not be required to immediately install the carbon monoxide detectors. However, full compliance with 25.2.2 through 25.2.2.7 shall be required with the next transfer of title.
(Add) RILSC 25.2.2.8
The State Fire Marshal is hereby authorized to consult with the Chief Judge of the Rhode Island Family Court to develop and implement a plan of action, addressing the installation appropriate limited smoke and carbon monoxide detection for the immediate safe temporary placement of children, supervised by the Rhode Island Department of Children, Youth and Families, in properties covered under this chapter.
8.1.26 CHAPTER 26 – LODGING OR ROOMING HOUSES
(Amd) 26.1.1.1
The requirements of this chapter shall apply to buildings that provide sleeping accommodations for 16 or fewer persons on either a transient or permanent basis, with or without meals, but without separate cooking facilities for individual occupants, except as provided in Chapter 24 and/or 26.1.1.1.1 through 26.1.1.1.7 (Bed and Breakfast Homes) as outlined below.
(Add) 26.1.1.1.1
A “Bed and Breakfast Home” is defined as an owner and/or innkeeper occupied building that provides sleeping accommodations for up to sixteen guests. Every “Bed and Breakfast Home” must further have originated as a private home and must have at least 300 square feet of common space (i.e. dining room, living room, etc.) for guest use, and must further provide breakfast. Finally, the owner and/or innkeeper must occupy the building twenty-four hours a day, seven days a week, while guests are utilizing the facility. The owner and/or innkeeper of the Bed and Breakfast Home shall have a plan of action, approved by the local official, to assure the safety of the guests in the event the owner or innkeeper is required to temporarily leave the facility unsupervised for limited periods during the day.
(Add) 26.1.1.1.2
A “No Smoking” policy, throughout the building, shall be strictly enforced.
(Add) 26.1.1.1.3
With the exception of fireplaces and/or wood stoves, approved by local fire department and/or the local mechanical inspector, there shall be no open flame in the bedrooms of these facilities. Specifically, candles, incense or similar materials shall not be allowed in the bedrooms. All approved fireplaces and/or wood stoves shall further be provided with approved metal screens or glass doors. Any fireplace or wood stove located in the common areas shall also be approved by local fire department and/or the local mechanical inspector with the above safeguards.
(Add) 26.1.1.1.4
All “Bed and Breakfast Homes” require hardwired, interconnected smoke and carbon monoxide detectors installed in accordance with the regulations and standards covering a new single family residence. There shall be approved detection in each bedroom.
(Add) 26.1.1.1.5
All “Bed and Breakfast Homes” with a capacity of between four (4) and six (6) guests shall meet the following requirements for this occupancy:
1. Hardwired or low power radio wireless interconnected smoke alarms and carbon monoxide detectors shall be installed in accordance with NFPA 72, 2010 edition, and NFPA 720, 2012 edition.
2. Emergency lighting shall be installed in any corridors and/or stairways greater than eight (8) feet in length.
3. Externally illuminated exit signs shall be installed.
4. An evacuation plan, containing alternative emergency egress routes, shall be presented to the local fire authority for approval.
5. The owner and/or innkeeper shall receive comprehensive fire extinguisher training.
6. It is recommended that the facility be annually inspected by the local fire authority. Any existing curtains, bedding, rugs or similar flammable materials, shall only be replaced, in the future, by fire retardant materials, manufactured and/or treated to the satisfaction of the local fire authority.
7. Any existing fire detection and/or suppression system shall be maintained as a required system.
(Add) 26.1.1.1.6
All “Bed and Breakfast Homes” with a capacity of between seven (7) and sixteen (16) guests shall meet the following requirements for this occupancy:
1. A fire alarm system installed in accordance with 26.3.4.1.1 shall be provided.
2. Hardwired or low power radio wireless interconnected smoke alarms and carbon monoxide detectors shall be installed in accordance with NFPA 72, 2010 edition, and NFPA 720, 2012 edition. (May be incorporated into the above fire alarm system).
3. Solid core doors, maintaining an approximate fire rating of twenty (20) minutes, shall be installed in the existing egress system door jambs with spring-loaded hinges. The local fire authority may approve an alternative plan of action allowing historically significant doors, with an approved Class-A flame-spread finish and spring loaded hinges, to be retained.
4. Emergency lighting shall be installed in any corridors and/or stairways greater than eight (8) feet in length.
5. Externally illuminated exit signs shall be installed.
6. An evacuation plan, containing alternative emergency egress routes, shall be presented to the local fire authority for approval.
7. The owner and/or innkeeper shall receive comprehensive fire extinguisher training.
8. The facility shall be annually inspected by the local fire authority. Any existing curtains, bedding, rugs or similar flammable materials, shall only be replaced, in the future, by fire retardant materials, manufactured and/or treated to the satisfaction of the local fire authority.
9. Any existing fire detection and/or suppression system shall be maintained as a required system.
(Add) 26.1.1.1.7
Any building complying with the above “Bed and Breakfast Home” guidelines, with a capacity in excess of sixteen (16) guests, shall be required comply with the requirements for a “Hotel and Dormitory” occupancy as outlined in the provisions of Chapters 28 or 29, as applicable (new or existing), of the Rhode Island Life Safety Code.
(Amd) 26.3.4.1.1
Lodging and rooming houses shall be provided with a fire alarm system in accordance with 9.6.
(Res) 26.3.4.1.2
(Amd) 26.3.4.2 Initiation. Initiation of the required fire alarm system shall be by manual means in accordance with 9.6.2, a fire detection system required by 23.3.4.4, and by alarm initiation in accordance with 9.6.2.1(3) in buildings protected throughout by an approved automatic sprinkler system in accordance with 26.3.6.
(Amd) 26.3.4.4 Detection. A fire detection system in accordance with 9.6.2.11 shall be provided.
(Amd) 26.3.4.5.1 Approved single-station smoke alarms shall be installed in accordance with 9.6.2.10 in every sleeping room.
(Res) 26.3.4.5.3
(Amd) 26.3.4.6.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with 9.8 and 26.3.4.6 shall be provided in lodging or rooming houses where either of the following conditions exists:
1. Lodging or rooming houses with communicating attached garages, unless otherwise exempted by 26.3.4.6.3
2. Lodging or rooming houses containing fuel-burning appliances
(Res) 26.3.4.7
(Add) 26.3.4.8 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 26.3.6.1
All new lodging or rooming houses shall be protected throughout by an approved automatic sprinkler system in accordance with 26.3.6.3.
(Amd) 26.3.6.2
Every existing lodging or rooming house built, or converted to this occupancy, on or after June 29, 1990, shall be protected throughout by an approved automatic sprinkler system in accordance with 26.3.6.3.
(Add) 26.3.6.4
Portable fire extinguishers shall be provided in accordance with 9.7.4.1 of this Code.
(Add) 26.5.2.3
Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ.
8.1.27 CHAPTER 27- EMERGENCY SHELTER OCCUPANCY.
(Add) 27.1 General Requirements.
(Add) 27.1.1 Application.
(Add) 27.1.1.1
The requirements of this chapter shall apply to buildings that provide temporary emergency sleeping space for 16 or fewer persons unless a greater number of occupants is specifically approved by the Fire Safety Code Board of Appeal & Review.
(Add) 27.1.1.2
Places of worship, maintaining this temporary occupancy in accordance with the provisions of this chapter, shall not lose their exception from the requirements of 13.3.5.1 and 13.3.5.1.1 as outlined in 13.3.5.2.1(4) of this Code.
(Add) 27.1.1.3
For buildings with larger occupancies, the requirements of Chapters 28 and 29 are applicable. The owners of such facilities may seek interim relief from specific requirements from the Fire Safety Code Board of Appeal & Review.
(Add) 27.1.1.4
All emergency shelter occupancies shall be located on the on the first floor or on the level of exit discharge unless specifically authorized by the AHJ to be located on a lower or upper level.
(Add) 27.2 Means of Escape Requirements
(Add) 27.2.1
There shall be at least two (2) clearly defined means of escape to grade from the space used as an emergency shelter.
(Add) 27.2.2
The means of escape, stairways and doors shall comply with the provisions of 26.2.1.1 through 26.2.3 of this Code.
(Add) 27.2.3
The means of escape shall be further protected with emergency lighting and exit signs approved by the AHJ.
(Add) 27.3 Protection.
(Add) 27.3.1 Smoke and Carbon Monoxide Detection
(Add) 27.3.1.1
Smoke alarms and carbon monoxide detection shall be immediately provided and maintained in accordance with the provisions of 26.3.4. All such facilities shall also be in compliance with 26.3.4 of this Code.
(Add) 27.3.2 Supervision
(Add) 27.3.2.1
At least one responsible adult, approved by the AHJ and not a resident of the emergency shelter occupancy, shall maintain a fire watch during all hours of occupancy of the emergency shelter facility.
(Add) 27.3.2.1.1
In shelters used to temporarily house families, a responsible adult member of each such family may be approved by the AHJ to maintain the fire watch referenced in 27.3.2.1.
(Add) 27.3.2.2
The responsible adult(s) must be trained in fire prevention techniques, fire department notification, evacuation procedures and fire extinguisher operation by the AHJ prior to being approved to oversee the fire watch.
(Add) 27.3.2.3
The owner or management of the shelter shall provide the AHJ with a schedule listing the names of the responsible adults conducting the fire watch and the times to which they have been assigned this duty.
(Add) 27.3.2.4
A fire fighter on duty, as defined in 12.7.5.9 and 13.7.5.9 may be substituted for the responsible adult at the discretion of the owner or management of the emergency shelter facility.
(Add) 27.3.3 Protection from Hazards.
(Add) 27.3.3.1
No smoking shall be allowed in any building utilized as an emergency shelter facility during any and all periods of this occupancy.
(Add) 27.3.3.2
No cooking shall be allowed in any building utilized as an emergency shelter facility during any and all periods of overnight occupancy. If specifically authorized by the AHJ, cooking, with the appropriate temporary safeguards required by the AHJ, may be allowed during limited periods when the occupants are all awake and fully capable of self preservation.
(Add) 27.3.4 Fire Extinguishers.
(Add) 27.3.4.1
A minimum of two fire extinguishers, installed at the direction and to the satisfaction of the AHJ, shall be provided in every emergency shelter facility in accordance with section of this Code.
8.1.28 CHAPTER 28 – NEW HOTELS AND DORMITORIES
(Amd) 28.3.4.4 Detection. A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 28.3.4.7 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 28.3.5.1.
All new hotel and/or dormitory occupancies shall be protected throughout by approved automatic sprinkler systems in accordance with 28.3.5.3.
(Amd) 28.3.5.2.
Every hotel and/or dormitory occupancy, every addition hereafter made to a hotel and/or dormitory, and every building hereafter converted for the purposes of a hotel and/or dormitory shall be completely protected by an approved system of automatic sprinklers installed and maintained in accordance with 28.3.5.3.
(Add) 28.3.5.9 Portable fire extinguishers shall be provided in all new hotel occupancies in accordance with 9.7.4.1 of this Code.
(Add) 28.5.2.3 Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ.
8.1.29 CHAPTER 29 – EXISTING HOTELS AND DORMITORIES
(Amd) 29.3.4.1 General. A fire alarm system in accordance with 9.6, except as modified by 29.3.4.2 through 29.3.4.5, shall be provided.
(Amd) 29.3.4.3.3 Guest rooms and guest suites specifically required and equipped to accommodate hearing impaired individuals shall be provided with a visible notification appliance.
(Amd) 28.3.4.3.4 In areas subject to occupancy, other than guest rooms and guest suites, visible notification appliances shall be provided.
(Amd) 29.3.4.3.6 Emergency forces notification shall be accomplished in accordance with 9.6.4.
(Res) 29.3.4.3.7
(Amd) 29.3.4.4 Detection. A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 29.3.4.4.1 A combination rate of rise and one hundred thirty-five degree (135°) to one hundred forty degree (140°) F. fixed temperature heat detector shall be installed in every sleeping room, other than sleeping rooms equipped with an approved, supervised automatic sprinkler system in accordance with 28.3.5.3.
(Add) 29.3.4.6 Carbon Monoxide Alarms and Carbon Monoxide Detection Systems.
(Add) 29.3.4.6.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with 9.8 and 29.3.4.6 shall be provided in hotels and dormitories where either of the following conditions exists:
1. Guest rooms or guest suites with communicating attached garages, unless otherwise exempted by 29.3.4.6.3
2. Guest rooms or guest suites containing a permanently installed fuel-burning appliance
(Add) 29.3.4.6.2 Where required by 29.3.4.6.1, carbon monoxide alarms or carbon monoxide detectors shall be installed in the following locations:
1. Outside of each separate guest room or guest suite sleeping area in the immediate vicinity of the sleeping rooms
2. On every occupiable level of a guest room and guest suite
(Add) 29.3.4.6.3 Carbon monoxide alarms and carbon monoxide detectors as specified in 29.3.4.6.1(1) shall not be required in the following locations:
1. In garages
2. Within guest rooms or guest suites with communicating attached garages that are open parking structures as defined by the building code
3. Within guest rooms or guest suites with communicating attached garages that are mechanically ventilated in accordance with the mechanical code
(Add) 29.3.4.6.4 Carbon monoxide alarms or carbon monoxide detectors shall be provided in areas other than guest rooms and guest suites in accordance with 9.8, as modified by 29.3.4.6.5.
(Add) 29.3.4.6.5 Carbon monoxide alarms or carbon monoxide detectors shall be installed in accordance with the manufacturer’s published instructions in the locations specified as follows:
1. On the ceilings of rooms containing permanently installed fuel-burning appliances
2. Centrally located within occupiable spaces adjacent to a communicating attached garage
(Add) 29.3.4.7 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 29.3.5.2.
Every existing hotel and/or dormitory occupancy built, or converted to this occupancy, on or after June 29, 1990, and all existing hotels and/or dormitories of construction types III, IV and V, as outlined in NFPA 220, which have sleeping accommodations for guests or employees above the third story, shall be protected throughout by an approved automatic sprinkler system in accordance with 29.3.5.3.
(Add) 29.3.5.8 Portable fire extinguishers shall be provided in all existing hotel occupancies in accordance with 9.7.4.1 of this Code.
(Amd) 29.4.1.1 High-rise buildings shall comply with 29.3.5.1, 11.8.4 and 11.8.6.
(Add) 29.5.2.3
Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ.
8.1.30 CHAPTER 30 – NEW APARTMENT BUILDINGS
(Amd) 30.3.4.1.1 General. Every apartment building, other than those meeting 30.3.4.1.2, shall be provided with a fire alarm system in accordance with amended 9.6 of this Code, except as modified by 30.3.4.2 through 30.3.4.5
(Amd) 30.3.4.1.2 A fire alarm system shall not be required in buildings where each dwelling unit is completely separated from other contiguous dwelling units by fire barriers (see 8.3) having a fire resistance rating of not less than 1 hour, and where each dwelling unit has either its own independent exit or its own independent stairway or ramp discharging at grade. However, such exempted buildings shall fully comply with the provisions for smoke and carbon monoxide alarms in accordance with 30.3.4.5 and 30.3.4.6.
(Amd) 30.3.4.2.1 Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Res) 30.3.4.2.2
(Res) 30.3.4.2.3
(Res) 30.3.4.3.3
(Res) 30.3.4.3.4
(Add) 30.3.4.3.5 Emergency forces notification shall not be required for apartment occupancies containing less than twelve (12) dwelling units between fire barriers (see 8.3). The above fire barriers shall have a fire resistance rating of not less than two (2) hours.
(Amd) 30.3.4.4 Detection. A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 30.3.4.7 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Add) 30.3.5.13 Portable fire extinguishers shall be provided in all new apartment occupancies in accordance with 9.7.4.1 of this Code.
(Add) 30.3.5.13.1 As an alternative to the location requirements for portable fire extinguishers outlined in 9.7.4.1 of this Code, the owner or management of a new apartment building may provide each apartment unit with an approved fire extinguisher installed at the direction and to the satisfaction of the AHJ.
(Add) 30.5.2.3 Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ.
(Amd) 30.6 All apartment buildings, used as housing for elderly or disabled people, shall be inspected annually by the AHJ.
8.1.31 CHAPTER 31 – EXISTING APARTMENT BUILDINGS
(Amd) 31.1.1.1 The requirements of this chapter shall apply to existing buildings or portions thereof currently occupied as apartment occupancies. In addition, the building shall meet the requirements of one of the following options:
1. Option 1, buildings previously inspected and deemed compliant with 31.1.1.5.
2. Option 2, buildings provided with a complete approved automatic fire detection and notification system in accordance with 31.3.4.4
3. Option 3, buildings provided with approved automatic sprinkler protection in selected areas, as described in 31.3.5.8
4. Option 4, buildings protected throughout by an approved automatic sprinkler system
(Add) 31.1.1.5 Approved apartment buildings.
Any existing apartment building, that was originally converted to this occupancy from an existing one, two, or three family dwelling, shall be deemed in full compliance with the provisions of this Chapter 31, upon meeting the following fifteen requirements:
1. The building maintains a fire alarm system that complies with the provisions of 31.3.4 and 9.6; and
2. The building maintains an approved system of either hardwired or lower power radio wireless smoke and carbon monoxide detectors installed in accordance with the referenced edition of NFPA 72 and NFPA 720; and
3. The building maintains emergency lighting approved by the AHJ; and
4. The building maintains approved exit signage, if so required by the AHJ; and
5. The building shall have at least two means of egress of which one may be a properly maintained existing fire escape or platform and ladder system, approved by the AHJ.
6. The walls of the internal means of egress are made of plaster and/or sheetrock, are in good repair, and maintain an approximate fire rating of twenty (20) minutes as determined by the AHJ; and
7. All combustible covering materials, within the approved egress systems, such as existing paneling or wainscoting, mounted on approved plaster or sheetrock walls or ceilings, shall be rendered flame resistant by the application of an approved Class A flame-spread rated material to the satisfaction of the AHJ; and
8. The existing dimensions of the egress system appear to adequately support the rapid evacuation of the building in the opinion of the AHJ.
9. The internal means of egress may contain winding stairs approved by the AHJ.
10. Approved solid core or steel doors, maintaining an approximate fire rating of twenty (20) minutes, have been installed in the existing egress system door jambs, with approved spring loaded hinges, to the satisfaction of the AHJ; and
11. Existing fire escapes, platform and ladder systems, maintained in good repair, may be utilized as a second means of egress, as approved by the AHJ. The above existing fire escape systems may be accessed through windows providing a clear opening of at least 5.7 square feet, as approved by the AHJ. All locks and locking devices shall be permanently removed from the doors to the rooms providing access to the fire escape system; and
12. Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ.
13. Any furnace, boiler or comparable central heating plant above 160,000 BTU input and all floor mounted units requiring a non-combustible floor by their listing, shall be either segregated from the remainder of the building by a one hour rated enclosure or protected by domestically-supplied sprinkler head(s) to the satisfaction of the AHJ.
14. Portable fire extinguishers shall be provided in accordance with 9.7.4.1 of this Code. As an alternative to the location requirements for portable fire extinguishers outlined in 9.7.4.1 of this Code, the owner or management of the apartment building may provide each apartment unit with an approved fire extinguisher installed at the direction and to the satisfaction of the AHJ.
15. Every existing apartment building, containing more than six (6) living units between approved fire barriers (see 8.3) having a fire resistance rating of two (2) hours, built or converted to this occupancy, on or after June 29, 1990 shall be provided with sprinkler coverage, at the direction and to the satisfaction of the AHJ, in accordance with the standards outlined in the referenced editions of NFPA 13 or NFPA 13R where applicable.
The AHJ shall provide the building owner a reasonable time, pursuant to guidelines established by the State Fire Marshal’s Office, to bring the building into full compliance with the above Fifteen Point Plan, after the owner is officially notified of any deficiencies in writing. Any emergency or life threatening items shall be addressed through the abatement procedures as outlined in the RIFC, Section 1.7.6 et seq.
(Amd) 31.3.4.2.1 Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Res) 31.3.4.2.2
(Res) 31.3.4.2.3
(Res) 31.3.4.2.4
(Res) 31.3.4.2.5
(Res) 31.3.4.3.2
(Res) 31.3.4.3.3
(Res) 31.3.4.3.4
(Add) 31.3.4.3.5.1 Emergency forces notification shall be not required for apartment occupancies containing less than twelve (12) dwelling units between fire barriers (see Section 8.3). The above fire barriers shall have a fire resistance rating of not less than two hours.
(Amd) 31.3.4.4.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Res) 31.3.4.4.2
(Amd) 31.3.4.5.1* Smoke alarms shall be installed in accordance with 9.6.2.10 outside every sleeping area in the immediate vicinity of the bedrooms and on all levels of the dwelling unit, including basements.
(Res) 31.3.4.5.2
(Res) 31.3.4.5.3
(Res) 31.3.4.5.4
(Add) 31.3.4.6 Carbon Monoxide Alarms and Carbon Monoxide Detection Systems.
(Add) 31.3.4.6.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with 9.8 and 31.3.4.6 shall be provided apartment buildings where either of the following conditions exists:
1. Dwelling units with communicating attached garages, unless otherwise exempted by 31.3.4.6.3
2. Dwelling units containing a permanently installed fuel-burning appliance
(Add) 31.3.4.6.2 Where required by 31.3.4.6.1, carbon monoxide alarms or carbon monoxide detectors shall be installed in the following locations:
1. Outside of each separate sleeping area in the immediate vicinity of the sleeping rooms
2. On every occupiable level of a dwelling unit
(Add) 31.3.4.6.3 Carbon monoxide alarms and carbon monoxide detectors as specified in 31.3.4.6.1(1) shall not be required in the following locations:
1. In garages
2. Within dwelling units with communicating attached garages that are open parking structures as defined by the building code
3. Within dwelling units with communicating attached garages that are mechanically ventilated in accordance with the mechanical code
(Add) 31.3.4.6.4 Carbon monoxide alarms or carbon monoxide detectors shall be provided in areas other than dwelling units in accordance with 9.8, as modified by 31.3.4.6.5
(Add) 31.3.4.6.5 Carbon monoxide alarms or carbon monoxide detectors shall be installed in accordance with the manufacturer’s published instructions in the locations specified as follows:
1. On the ceilings of rooms containing permanently installed fuel-burning appliances
2. Centrally located within occupiable spaces adjacent to a communicating attached garage
(Add) 31.3.4.7 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 31.3.5.1
Every existing apartment building, containing more than six (6) living units between approved fire barriers (see Section 8.3) having a fire resistance rating of not less than two hours, built, or converted to this occupancy, on or after June 29, 1990 shall be protected throughout by an approved automatic sprinkler system in accordance with 31.3.5.2.
(Amd) 31.3.5.12 Portable fire extinguishers shall be provided in all existing apartment occupancies in accordance with 9.7.4.1 of this Code.
(Amd) 31.3.5.12.1 As an alternative to the location requirements for portable fire extinguishers outlined in 9.7.4.1 of this Code, the owner or management of an existing apartment building may provide each apartment unit with an approved fire extinguisher installed at the direction and to the satisfaction of the AHJ.
(Amd) 31.4.1.1 High-rise buildings shall comply with 31.2.11.1 and 31.3.5.11 and 11.8.4. and 11.8.6.
(Amd) 31.6
All existing apartment buildings, used as housing for elderly or disabled people, shall be inspected annually by the AHJ.
8.1.32 CHAPTER 32 – NEW RESIDENTIAL BOARD AND CARE OCCUPANCIES
(Amd) 32.2.3.4.1 General. Every residential board and care occupancy shall be provided with a fire alarm system in accordance with amended 9.6 of this Code.
(Amd) 32.2.3.4.1.1 Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Add) 32.2.3.4.4 Detection. A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 32.2.3.4.5 Carbon Monoxide Alarms and Carbon Monoxide Detection Systems.
(Add) 32.2.3.4.5.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with 9.8 and 32.2.3.4.5.2 shall be provided residential board and care occupancies where either of the following conditions exists:
1. Living areas with communicating attached garages, unless otherwise exempted by 32.2.3.4.5.3
2. Living areas containing a permanently installed fuel-burning appliance
(Add) 32.2.3.4.5.2 Where required by 32.2.3.4.5.1, carbon monoxide alarms or carbon monoxide detectors shall be installed in the following locations:
1. Outside of each separate sleeping area in the immediate vicinity of the sleeping rooms
2. On every occupiable level of a living area
(Add) 32.2.3.4.5.3 Carbon monoxide alarms and carbon monoxide detectors as specified in 32.2.3.4.5.1(1) shall not be required in the following locations:
1. In garages
2. Within living areas with communicating attached garages that are open parking structures as defined by the building code
3. Within living areas with communicating attached garages that are mechanically ventilated in accordance with the mechanical code
(Add) 32.2.3.4.5.4 Carbon monoxide alarms or carbon monoxide detectors shall be provided in areas other than living areas in accordance with 9.8, as modified by 32.2.3.4.5.5.
(Add) 32.2.3.4.5.5 Carbon monoxide alarms or carbon monoxide detectors shall be installed in accordance with the manufacturer’s published instructions in the locations specified as follows:
1. On the ceilings of rooms containing permanently installed fuel-burning appliances
2. Centrally located within occupiable spaces served by the first supply air register from a permanently installed, fuel burning HVAC system
3. Centrally located within occupiable spaces adjacent to a communicating attached garage
(Add) 32.2.3.4.6 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 32.2.3.5.1 All facilities shall be protected throughout by an approved, automatic sprinkler system installed in accordance with 32.2.3.5.3 using quick response or residential sprinklers.
(Res) 32.2.3.5.2
(Add) 32.2.5.2.4 Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ.
(Amd) 32.3.3.4.8 Detection.
(Amd) 32.3.3.4.8.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 32.3.3.4.9 Carbon Monoxide Alarms and Carbon Monoxide Detection Systems.
(Add) 32.3.3.4.9.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with 9.8 and 32.3.3.4.9.2 shall be provided residential board and care occupancies where either of the following conditions exists:
1. Living areas with communicating attached garages, unless otherwise exempted by 32.3.3.4.9.3
2. Living areas containing a permanently installed fuel-burning appliance
(Add) 32.3.3.4.9.2 Where required by 32.3.3.4.9.1, carbon monoxide alarms or carbon monoxide detectors shall be installed in the following locations:
1. Outside of each separate sleeping area in the immediate vicinity of the sleeping rooms
2. On every occupiable level of a living area
(Add) 32.3.3.4.9.3 Carbon monoxide alarms and carbon monoxide detectors as specified in 32.3.3.4.9.1(1) shall not be required in the following locations:
1. In garages
2. Within living areas with communicating attached garages that are open parking structures as defined by the building code
3. Within living areas with communicating attached garages that are mechanically ventilated in accordance with the mechanical code
(Add) 32.3.3.4.9.4 Carbon monoxide alarms or carbon monoxide detectors shall be provided in areas other than living areas in accordance with 9.8, as modified by 32.3.3.4.9.5
(Add) 32.3.3.4.9.5 Carbon monoxide alarms or carbon monoxide detectors shall be installed in accordance with the manufacturer’s published instructions in the locations specified as follows:
1. On the ceilings of rooms containing permanently installed fuel-burning appliances
2. Centrally located within occupiable spaces served by the first supply air register from a permanently installed, fuel burning HVAC system
3. Centrally located within occupiable spaces adjacent to a communicating attached garage
(Add) 32.3.3.4.10 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
8.1.33 CHAPTER 33 – EXISTING RESIDENTIAL BOARD AND CARE OCCUPANCIES
(Amd) 33.2.3.4.1 General. Every residential board and care occupancy shall be provided with a fire alarm system in accordance with amended 9.6 of this Code.
(Amd) 33.2.3.4.1.1 Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Res) 33.2.3.4.1.2
(Res) 33.2.3.4.3.7
(Add) 33.2.3.4.4 Detection. A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 33.2.3.4.5 Carbon Monoxide Alarms and Carbon Monoxide Detection Systems.
(Add) 33.2.3.4.5.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with 9.8 and 33.2.3.4.5.2 shall be provided residential board and care occupancies where either of the following conditions exists:
1. Living areas with communicating attached garages, unless otherwise exempted by 33.2.3.4.5.3
2. Living areas containing a permanently installed fuel-burning appliance
(Add) 33.2.3.4.5.2 Where required by 33.2.3.4.5.1, carbon monoxide alarms or carbon monoxide detectors shall be installed in the following locations:
1. Outside of each separate sleeping area in the immediate vicinity of the sleeping rooms
2. On every occupiable level of a living area
(Add) 33.2.3.4.5.3 Carbon monoxide alarms and carbon monoxide detectors as specified in 32.2.3.4.5.1(1) shall not be required in the following locations:
1. In garages
2. Within living areas with communicating attached garages that are open parking structures as defined by the building code
3. Within living areas with communicating attached garages that are mechanically ventilated in accordance with the mechanical code
(Add) 33.2.3.4.5.4 Carbon monoxide alarms or carbon monoxide detectors shall be provided in areas other than living areas in accordance with Section 9.8, as modified by 33.2.3.4.5.5
(Add) 33.2.3.4.5.5 Carbon monoxide alarms or carbon monoxide detectors shall be installed in accordance with the manufacturer’s published instructions in the locations specified as follows:
1. On the ceilings of rooms containing permanently installed fuel-burning appliances
2. Centrally located within occupiable spaces adjacent to a communicating attached garage
(Add) 33.2.3.4.6 Any conflict between the provisions of this section and the provisions of amended 9.6 of this shall be resolved in favor of compliance with the most reasonable combined requirements as determined by the State Fire Marshal’s Office.
(Amd) 33.2.3.5.1 All facilities shall be protected throughout by an approved, automatic sprinkler system installed in accordance with 33.2.3.5.3 using quick response or residential sprinklers.
(Add) 33.2.5.2.4 Any furnace or boiler in the building shall be equipped with an approved remote shutoff switch approved by the AHJ.
(Amd) 33.3.3.4.1 General. Every residential board and care occupancy shall be provided with a fire alarm system in accordance with amended 9.6 of this Code.
(Amd) 33.3.3.4.2 Initiation. The required fire alarm system shall be initiated by each of the following means:
1. Manual means in accordance with 9.6.2.
2. Manual fire alarm box located at a convenient central control point under continuous supervision of responsible employees
3. Automatic sprinkler system.
4. Required detection system, other than sleeping room smoke alarms
(Amd) 33.3.3.4.6.1 Emergency forces notification shall be accomplished in accordance with 9.6.4.
(Res) 33.3.3.4.6.2
(Amd) 33.3.3.4.8 Detection.
(Amd) 33.3.3.4.8.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 33.3.3.4.8.1.1 A combination rate of rise and one hundred thirty-five degree (135°) to one hundred forty degree (140°) F. fixed temperature heat detector shall be installed in every sleeping room, other than sleeping rooms equipped with an approved, supervised automatic sprinkler system in accordance with 32.2.3.5.3.
(Res) 33.3.3.4.8.2
(Add) 33.3.3.4.9 Carbon Monoxide Alarms and Carbon Monoxide Detection Systems.
(Add) 33.3.3.4.9.1 Carbon monoxide alarms or carbon monoxide detectors in accordance with 9.8 and 33.3.3.4.9.2 shall be provided residential board and care occupancies where either of the following conditions exists:
1. Living areas with communicating attached garages, unless otherwise exempted by 33.3.3.4.9.3
2. Living areas containing a permanently installed fuel-burning appliance
(Add) 33.3.3.4.9.2 Where required by 33.3.3.4.9.1, carbon monoxide alarms or carbon monoxide detectors shall be installed in the following locations:
1. Outside of each separate sleeping area in the immediate vicinity of the sleeping rooms
2. On every occupiable level of a living area
(Add) 33.3.3.4.9.3 Carbon monoxide alarms and carbon monoxide detectors as specified in 33.3.3.4.9.1(1) shall not be required in the following locations:
1. In garages
2. Within living areas with communicating attached garages that are open parking structures as defined by the building code
3. Within living areas with communicating attached garages that are mechanically ventilated in accordance with the mechanical code
(Add) 33.3.3.4.9.4 Carbon monoxide alarms or carbon monoxide detectors shall be provided in areas other than living areas in accordance with 9.8, as modified by 33.3.3.4.9.5
(Add) 33.3.3.4.9.5 Carbon monoxide alarms or carbon monoxide detectors shall be installed in accordance with the manufacturer’s published instructions in the locations specified as follows:
1. On the ceilings of rooms containing permanently installed fuel-burning appliances
2. Centrally located within occupiable spaces served by the first supply air register from a permanently installed, fuel burning HVAC system
3. Centrally located within occupiable spaces adjacent to a communicating attached garage
(Add) 33.3.3.5.1 All facilities shall be protected throughout by an approved, supervised automatic sprinkler system installed in accordance with 9.7, as modified by 33.3.3.5.1.1, 33.3.3.5.1.2 and 33.3.3.5.1.3.
(Res) 33.3.3.5.1.3
(Res) 33.3.3.5.5
(Amd) 33.3.4 Special Provisions
(Add) 33.3.4.1 High-rise buildings shall comply with 11.8.4 and 11.8.6.
8.1.34 CHAPTER 34 – RESERVED
(No Modifications)
8.1.35 CHAPTER 35 – RESERVED
(No Modifications)
8.1.36 CHAPTER 36- NEW MERCANTILE OCCUPANCIES
(Amd) 36.3.4.1 General
All Class A mercantile occupancies, all Class B mercantile occupancies occupying more than 3000 square feet per floor for sales purposes, and all mercantile occupancies requiring sprinkler coverage, under this Code or the State Building Code, shall be provided with a fire alarm system in accordance with 9.6
(Amd) 36.3.4.2 Initiation
Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 36.3.4.3.1 Occupant Notification
The required fire alarm system, once initiated, shall perform one of the following functions:
1. It shall activate an alarm in accordance with 9.6.3 throughout the mercantile occupancy.
2. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
(Amd) 36.3.4.3.2 Emergency Forces Notification
Emergency forces notification shall be provided for all Class A mercantile occupancies and all Class B mercantile exceeding 12,000 gross square feet and shall include notifying both of the following:
1. Fire department in accordance with 9.6.4
2. Local emergency organization, if provided
(Add) 36.3.4.4 Detection
(Add) 36.3.4.4.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Amd) 36.3.5.2 Automatic sprinkler systems, where required by either this Code or the Rhode Island Building Code, in either Class A or Class B mercantile occupancies shall be supervised in accordance with 9.7.2.
(Amd) 36.4.4.4.2 Initiation
Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 36.4.4.4.3.1 Occupant Notification
1. The required fire alarm system, once initiated, shall perform one of the following functions:
2. It shall activate a general alarm in accordance with 9.6.3 throughout the mall, and positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
3. Occupant notification shall be made via a voice communication or public address system in accordance with 9.6.3.9.2.
(Add) 36.4.4.4.5 Detection
(Add) 36.4.4.4.5.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Amd) 36.4.5.4.2 Initiation
Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 36.4.5.4.3 Occupant Notification
The required fire alarm system, once initiated, shall activate an alarm in accordance with throughout the mercantile occupancy, an positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
(Add) 36.4.5.4.5 Detection
(Add) 36.4.5.4.5.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
All Class A mercantile occupancies, all Class B mercantile occupancies occupying more than 3000 square feet per floor for sales purposes, and all mercantile occupancies requiring sprinkler coverage, under this Code or the State Building Code, shall be provided with a fire alarm system in accordance with 9.6.
(Amd) 37.3.4.2 Initiation
Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 37.3.4.3.1 Occupant Notification
The required fire alarm system, once initiated, shall perform one of the following functions:
1. It shall activate an alarm in accordance with 9.6.3 throughout the mercantile occupancy, and both of the following also shall apply:
2. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
3. A presignal system in accordance with 9.6.3.3 shall be permitted.
4. Occupant notification shall be made via voice communication or public address system in accordance with 9.6.3.9.2.
(Amd) 37.3.4.3.2 Emergency Forces Notification
Emergency forces notification shall be provided for all Class A mercantile occupancies and all Class B mercantile exceeding 12,000 gross square feet and shall include notifying both of the following:
1. Fire department in accordance with 9.6.4
2. Local emergency organization, if provided
(Add) 37.3.4.4 Detection
(Add) 37.3.4.4.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Amd) 37.3.5.1 Extinguishing Requirements
Mercantile occupancies shall be protected by an approved automatic sprinkler system in accordance with 9.7.1.1(1) in any of the following locations:
1. Throughout all mercantile occupancies three or more stories in height not protected by an approved fire alarm system providing emergency forces notification.
2. Throughout all mercantile occupancies built or converted on or after June 4, 1976 that are more than two (2) stories in height above the basement and constructed of Type III, IV or V construction in accordance with NFPA 220.
3. Throughout stories below the level of exit discharge where such stories have an area exceeding 2,500 square feet (232 m2) and are used for the sale, storage, or handling of combustible goods and merchandise.
4. Throughout multiple occupancies protected as mixed occupancies in accordance with 6.1.14 where the conditions of 37.3.5.1(1), (2), or (3) apply to the mercantile occupancy.
(Amd) 37.3.5.2 The provisions of 37.3.5.1(2) shall not apply to existing business occupancies with a total gross area less than 12,000 square feet (1115 m2).
(Add) 37.3.5.4
Automatic sprinkler systems, where required by either this Code or the Rhode Island Building Code, in either Class A or Class B mercantile occupancies, shall be supervised in accordance with 9.7.2.
(Amd) 37.4.2 High-Rise Buildings. High-rise buildings shall comply with 11.8.4 and 11.8.6.
(Amd) 37.4.4.4.2 Initiation
Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 37.4.4.4.3.1 Occupant Notification
The required fire alarm system, once initiated, shall perform one of the following functions:
1. It shall activate a general alarm in accordance with 9.6.3 throughout the mall, and positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
2. Occupant notification shall be made via a voice communication or public address system in accordance with 9.6.3.9.2.
(Add) 37.3.4.4.5 Detection
(Add) 37.3.4.4.5.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Amd) 37.4.5.4.2 Initiation.
Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 37.4.5.4.3 Occupant Notification
The required fire alarm system, once initiated, shall perform one of the following functions:
1. It shall activate a general alarm in accordance with 9.6.3 throughout the mercantile occupancy, and positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
2. Occupant notification shall be made via a voice communication or public address system in accordance with 9.6.3.9.2.
(Add) 37.4.5.4.5 Detection
(Add) 37.4.5.4.5.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
8.1.38 CHAPTER 38- NEW BUSINESS OCCUPANCIES
(Amd) 38.3.4.1 General
A fire alarm system in accordance with 9.6 shall be provided in all business occupancies where any one of the following conditions exists:
1. The building is three or more stories in height.
2. The occupancy is subject to 50 or more occupants above or below the level of exit discharge (5,000 Square feet).
3. The occupancy is subject to 300 or more total occupants (30,000 Square feet).
4. All business occupancies in which sprinkler coverage is required by either this Code or the Rhode Island Building Code.
(Amd) 38.3.4.2 Initiation. Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 38.3.4.3 Occupant Notification
The required fire alarm system, once initiated, shall activate a general alarm in accordance with 9.6.3 throughout the building, and positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
(Add) 38.3.4.5 Detection
(Add) 38.3.4.5.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 38.3.5.1
All new business occupancies shall be protected by an approved automatic sprinkler system in accordance with 9.7.1.1(1) in any of the following locations:
1. Throughout all new business occupancies three or more stories in height.
2. Throughout all new business occupancies exceeding 12,000 square feet (1115 m2) in area.
3. Throughout multiple occupancies protected as mixed occupancies in accordance with 6.1.14 where the conditions of 38.3.5.1(1) or (2) apply to the new business occupancy.
(Add) 38.3.5.2
Automatic sprinkler systems, where required by either this Code or the Rhode Island Building Code, in new business occupancies shall be supervised in accordance with 9.7.2.
8.1.39 CHAPTER 39 – EXISTING BUSINESS OCCUPANCIES
(Amd) 39.3.4.1 General
A fire alarm system in accordance with 9.6 shall be provided in all business occupancies where any one of the following conditions exists:
1. The building is three or more stories in height.
2. The occupancy is subject to 50 or more occupants above or below the level of exit discharge (5,000 Square feet).
3. The occupancy is subject to 300 or more total occupants (30,000 Square feet).
4. All business occupancies in which sprinkler coverage is required by either this Code of the Rhode Island Building Code.
(Amd) 39.3.4.2 Initiation. Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 39.3.4.3 Occupant Notification
The required fire alarm system, once initiated, shall activate a general alarm in accordance with 9.6.3 throughout the building, and positive alarm sequence in accordance with 9.6.3.4 shall be permitted.
(Amd) 39.3.4.4 Emergency Forces Notification
Where a fire alarm is required by this code, emergency forces notification shall be provided and shall include notifying both of the following:
1. Fire department in accordance with 9.6.4
2. Local emergency organization, if provided
(Add) 39.3.4.5 Detection
(Add) 39.3.4.5.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
(Add) 39.3.5.1
All existing business occupancies shall be protected by an approved automatic sprinkler system in accordance with 9.7.1.1(1) in any of the following locations:
1. Throughout all business occupancies built or converted on or after June 4, 1976 that are more than two (2) stories in height above the basement and constructed of Type III, IV or V construction in accordance with NFPA 220.
2. Throughout multiple occupancies protected as mixed occupancies in accordance with 6.1.14 where the conditions of 39.3.5.1(1) or (2) apply to the existing business occupancy.
(Add) 39.3.5.2
The provisions of 39.3.5.1 shall not apply to existing business occupancies with a total gross area less than 12,000 square feet (1115 m2).
(Add) 39.3.5.3
Automatic sprinkler systems, where required by either this Code or the Rhode Island Building Code, in existing business occupancies shall be supervised in accordance with 9.7.2.
(Add) 39.4.2.4 All high-rise buildings shall comply with 11.8.4 and 11.8.6.
8.1.40 CHAPTER 40 – INDUSTRIAL OCCUPANCIES
(Amd) 40.3.4.1 General
A fire alarm system in accordance with 9.6 shall be provided in all industrial occupancies where any one of the following conditions exists:
1. The total gross area exceeds 10,000 square feet.
2. Any one floor above or below the level of exit discharge exceeds 2,500 Square feet.
3. All industrial occupancies in which sprinkler coverage is required by either this Code of the Rhode Island Building Code.
(Amd) 40.3.4.2 Initiation.
Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 40.3.4.3.1 Occupant Notification
The required fire alarm system, once initiated, shall activate a general alarm in accordance with 9.6.3 throughout the building,
(Add) 40.3.4.3.5 Emergency Forces Notification
In buildings where a fire alarm is required, emergency forces notification shall be provided in buildings greater than 30,000 gross square feet in area and shall include both of the following:
1. Fire department in accordance with 9.6.4
2. Local emergency organization, if provided
(Add) 40.3.4.4 Detection
(Add) 40.3.4.4.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
8.1.41 CHAPTER 41 – RESERVED
(No Modifications)8.1.42 CHAPTER 42 – STORAGE OCCUPANCIES
(Amd) 42.3.4.1.1
Low hazard storage occupancies, and the specific non-residential farm buildings listed below, shall not be required to have a fire alarm system:
1. All non-residential, farm buildings such as barns, riding rinks, horse stables and farm stands that are not utilized as places of assembly and are not open to the general public.
2. All non-residential farm buildings such as barns, riding rinks and horse stables, that are either solely owner occupied or accessed solely by the owners of horses stabled within.
3. All non-residential farm buildings such as barns, riding rinks, horse stables and farm stands, without electricity and heat;
4. All greenhouses.
(Amd) 42.3.4.1.2
Storage occupancies with ordinary or high hazard contents not exceeding an aggregate floor area of 10,000 square feet (930 m2) shall not be required to have a fire alarm system.
(Res) 42.3.4.1.3
(Amd) 42.3.4.2 Initiation. Initiation of the required fire alarm system shall be by all of the following means:
1. Manual means in accordance with 9.6.2.1(1),
2. Where automatic sprinklers are provided, initiation of the fire alarm system by sprinkler system waterflow.
3. An approved fire detection system in accordance with 9.6.2.11.
(Amd) 42.3.4.3. Occupant Notification
The required fire alarm system shall meet one of the following criteria:
1. It shall provide occupant notification in accordance with 9.6.3.
2. It shall sound an audible and visible signal in a constantly attended location for the purposes of initiating emergency action.
(Add) 42.3.4.4 Emergency Forces Notification
Where a fire alarm is required, emergency forces notification shall be provided in buildings greater than 30,000 gross square feet in area and shall include both of the following:
1. Fire department in accordance with 9.6.4(2)
2. Local emergency organization, if provided
(Add) 42.3.4.5 Detection
(Add) 42.3.4.5.1 A fire detection system in accordance with 9.6.2.11 shall be provided.
8.1.43 CHAPTER 43 – Building Rehabilitation (Reserved)
The Fire Board hereby temporarily reserves Chapter 43 for further review and the eventual development of an updated Rehabilitation Code with participation from both the Rhode Island Building Commission and the Joint Committee on the Rehabilitation Building and Fire Code for Existing Buildings and Structures. Until the new updated Rehabilitation Code is adopted, the Rhode Island Rehabilitation Building and Fire Code, previously adopted by the Fire Safety Code Board of Appeal and Review, and the Rhode Island Building Commission, is hereby re-adopted, in full, as FIRE SAFETY CODE SECTION 9.
In any building where a fire alarm system is exempted due to the minimum occupant load provisions or the minimum square footage provisions of Chapters 12 through 42, a fire alarm system as prescribed in Section 9.6 may be required by the State Fire Marshal where it is proven that life safety of the occupants is compromised due to the hazard of contents, proximity of exposures, limitations to fire department vehicle access or other such hazardous conditions.
Introduction
To insure that the ever-changing security requirements of a facility are met, a periodic review of a
site’s access control system and its associated policies is a necessity. In fact, conducting an
annual access control system review is the first step in establishing a systematic process for
assessing the security of your organization; it is the principle best practice that provides the
framework for all the other guidelines.
Once a yearly review process is in place, the fundamental best practices concept is that an effective
security system uses a layered approach to security. A good analogy of this concept would be one
where a home protected by a burglar alarm might use both glass break detectors and motion
sensors to detect when an intruder enters the house.
This white paper contains important guidelines for all of the stakeholders in an access control
installation including the facility owner, the system specifier, the installer, and the end user.
Choosing the Right Reader and Card Technology
Contactless smart cards are fast becoming the technology of choice for access control applications.
Security, convenience, and interoperability are the three major reasons for this growth. Since there
are a wide variety of reader technologies being offered by today’s manufacturers, it is important to
make sure that the correct technology is chosen to match the desired level of security. Using a
good, better, best grading system will help make the correct choice easier.
Recognizing that there are many legacy card technologies still in use and that replacing them with
the latest contactless smart card technology may be expensive or logistically difficult, implementing
the recommendations included in this paper will raise the level of security of an installation and
should be done regardless of the card technology employed.
Relative Security of Commonly Used Card Technologies
Figure 1 illustrates and ranks the relative strength of commonly used card technologies based on
how much publicly available information there is about the technical details of the card technology
and the degree of difficulty required to illegally read or copy from the technology. The higher the
number, the more secure the technology: \
Figure’1:’Relative’Security’Levels’of’Commonly’Used’Card’
Technologies'(lowest’to’highest)
3
Magnetic stripe (magstripe) has the lowest security with its technical details being well documented
by ISO standards. This technology typically uses little or no security protections. Additionally, offthe-shelf devices are widely available to encode magstripe cards. Although there are some
techniques that can make magstripe more secure, widespread adoption of these techniques in the
access control industry have not occurred due to the convenience, security, and increased memory
available in contactless smart cards.
125 kHz proximity (Prox) card technology and the use of the Card Serial Number (CSN) of a
contactless smart card are better than magnetic stripe but are not as secure as contactless smart
cards. Prox card devices that can copy and emulate (mimic) Prox cards have been demonstrated.
Similarly, because there is no secure authentication of the CSN and the knowledge of the CSN
workings are published as part of the ISO standards, CSN emulation is also easily accomplished.
(For more details on the dangers of using CSN readers, see the Appendix that describes these
dangers in greater detail.)
Contactless smart cards, when properly implemented and deployed, offer the highest level of
security and interoperability. These cards use mutual authentication and employ cryptographic
protection mechanisms with secret keys. They may also employ special construction and electrical
methods to protect against external attacks.
Use Proper Key Management
Key management deals with the secure generation, distribution, storage, and lifecycle management
of cryptographic keys. This important subject deserves an entire white paper by itself, but here are
a few of the essential key management best practices.
Whenever there is a choice, choose a manufacturer that allows you to utilize your own
cryptographic authentication key that is different that its other customers so you have a unique key
for your facility or organization. Although it may be easier not to have the responsibility of managing
and safeguarding your own keys, utilizing your own authentication keys will protect your
organization from a key compromise that occurs in someone else’s readers purchased from the
same manufacturer.
Do not choose a manufacturer that stores the same key in all of its credentials. Extraction of the key
from a single card compromises all of the cards in use. Use a manufacturer that uses diversified
keys, which means that each card uses a different key that is cryptographically derived from a
master key. Ideally this diversification would use a public scrutinized algorithm such as DES or
AES.
If offered a choice, use readers that protect their master key from being easily extracted from the
reader. Reader manufactures that use a secure element such as a Trusted Platform Module (TPM),
Secure Access Module (SAM), or other equivalent device to store cryptographic keys. Some
manufacturers even go one step further and actually do all of the cryptographic operations inside
the secure element making it even more difficult to compromise the integrity of the key or data.
Be prepared to act quickly in case a key compromise does occur and know how to use the
manufacturer’s procedures to roll or change the keys in both the readers and cards. Some
manufacturers have the capability to move cryptographic data, such as keys as well as reader
firmware upgrades, securely from a secure ‘vault’ on their premise directly into the secure element
inside the reader using end-to-end security among trusted devices.
4
Protect the Communications
The individual components of an access control system need to communicate with each other.
Typical data includes card read messages, door unlock messages, audit trail data, cardholder
privilege changes, and much more. Consequently, it is critical to protect this information exchange
on the communications media on two levels. The actual communications medium, be it hard-wired
or wireless, as well as the data content must be protected.
When the communication takes place using wires, there are many different methods, interfaces and
protocols to choose from. The most popular and de-facto industry standard is the Wiegand
Protocol. This protocol became very popular because it is universally supported by almost all reader
and panel manufacturers. More modern communication methods such as RS485 and TCP/IP offer
more security and are therefore more desirable.
If a perpetrator can get access to the wires used for communications between the reader and the
upstream device, it may be possible to intercept messages; this could result in a loss of privacy as
well as the possibility of replaying a previously captured message and unlocking the door. It may
also be possible to simply send an ‘unlock’ message as well. That is why a secure protocol is
important, ideally employing 1) mutual authentication to ensure that each device trusts the other
device, 2) encryption, and 3) message replay protection.
An additional reason to protect the wiring is to prevent a ‘denial of service’ attack in which the wires
are cut or shorted together to interrupt communications. Another vulnerability due to unencumbered
access to the wires can be initiated by the use of command cards used by some manufacturers to
program the operating characteristics of readers. Typically, command cards are only accepted for a
short time after power has been interrupted and then restored to prevent them from being used at
any time. If the power wires to a reader are accessible, then a perpetrator would be able to interrupt
the power to the reader so that command cards could be read in an attempt to put the reader in a
state where cards are no longer read, creating a denial of service attack. An even more destructive
denial of service attack can be launched in which the communication wires are connected to a high
power source in an attempt to destroy the reader and/or the upstream device.
To minimize these risks, installing the security systems wiring in conduit makes it more difficult to
access the wires without being noticed due to the difficulty of identifying the correct conduit, not to
mention the additional time required to compromise the wiring in the conduit. Even if the entire wire
run is not fully enclosed in conduit, just using conduit in the most vulnerable publicly accessible
areas is desirable. Additionally, bundling several wire runs together (ideally in conduit) to make it
more difficult to identify the correct set of wires is also desirable. (Follow the manufacturer’s
recommended installations. Some wiring, such as power wiring, may not be recommended to be in
the same conduit as data communications wires.) It is particularly important to protect the wiring of
outside readers that are located at the entrance to a premise.
Additionally, avoid the use of readers with built-in connectors that make it easier to quickly swap out
a reader and avoid the use of wire-nut connectors to connect the reader wire pigtails to the panel
wiring. Instead, connect the wires in a more secure and permanent fashion, such as soldering with
shrink-wrap tubing to cover the connections.
5
Use Security Screws
Always utilize security screws that require special tools to remove a reader and other security
components. If the correct tool is not available, then it makes it nearly impossible to remove the
reader without causing damage to the screws. This damage may be noticed alerting security of a
potential intrusion attempt – especially if policy dictates that readers be physically examined on a
periodic basis. (Physical examination of readers should be included on guard tours.) It also has the
effect of making the removal process more difficult, and slowing down the removal increases the
possibility that the perpetrator will be noticed.
Prevention Using Antipassback
Another best practice that may be feasible is to program the access control host software to refuse
granting access to a cardholder that is already inside the facility, which will prevent a duplicate card
from entering the facility. This mechanism, referred to as antipassback, is available in many access
control systems. Note that this feature requires two readers at the door – an ‘in’ reader and an ‘out’
reader. One additional benefit of using antipassback is that it prevents a user from using their card
with others following through an open door (tailgating).
Use Additional Factors of Authentication
It is generally accepted that multiple factors of authentication consisting of something you have
(e.g., a card), something you know (e.g., a password), and something you are (e.g., a biometric)
increases the probability that the person presenting his card at a reader is the same person that
was initially issued the card. Ideally the use of all three factors is best but just adding one additional
factor can be effective. A relatively inexpensive, easy-to-use second factor is a password, which
can be achieved with the use of card readers with built-in keypads. Keypad readers are ideal
solutions for environments where additional layers of security are required – such as in a lab or
corporate research environment and the perimeter entrances to a facility.
Readers with a built-in keypad minimize the likelihood that a lost card can be picked up and simply
used to enter a facility. It also minimizes the threat of card cloning. Ideally, the password should be
changed periodically, or if a common password is utilized, change it every day to increase the
effectiveness. Note that some systems store the actual password inside the card itself. Although
this is generally effective if the card technology is secure, it is better to have the password stored on
the host.
The use of biometric readers to insure that the person presenting the card is actually the same
person that was issued the card can be used in environments where an even higher level of
security is required. A similar solution is to use hand-held biometric fobs that only emit RFID card
data after a biometric authentication has occurred. These types of devices actually help to increase
privacy and cannot be surreptitiously read without the user’s permission since the access control
credential cannot be read until the biometric authentication process has taken place.
If the use of multiple factors presents throughput or convenience obstacles, consider only requiring
multiple factors of authentication outside of normal business hours where the risk of unauthorized
entries are highest or automatically turned on when there is an elevated ‘threat level’.
6
Mind the Cards
A perpetrator may use surreptitiously obtained cards for nefarious purposes. One way to do this is
to claim that a card was lost when it really wasn’t. Make sure that lost cards are voided immediately.
Another way for a perpetrator to fraudulently obtain cards is through gray market sources such as
eBay or even legitimate card resellers. There are several best practices to prevent this. First, make
sure that only issued cards are valid; don’t have spare cards pre-validated and ready to hand out.
Some access control systems can also generate a different message than just denied in the case of
presented card in an ID number range that haven’t been entered in the system. When an illegally
obtained card is used, if the message generated by the access control system was ‘Card out of
range’ instead of simply ‘Denied’, it should signal more urgency to be investigated. Similarly, cards
using a different data format that are reported as ‘Unrecognized’, as well as cards with the wrong
facility code are also indications that illegally obtained cards are being presented to the system.
Therefore, any messages reported by the host access control system with wrong formats, wrong
site codes, or out of range should be immediately investigated.
Don’t succumb to the argument made by alternate card suppliers that proprietary card formats are
more expensive and are an attempt by manufacturers to keep you from buying cards from open
sources. The use of proprietary formats offered by an OEM or one that is exclusive to a particular
site is a desirable best practice.
Cards with proprietary formats are much more difficult to fraudulently obtain as compared to the
industry-standard open-format 26-bit Wiegand format and proprietary cards typically provide
provisions for non-duplication of card numbers. Some manufacturers’ readers can even be set to
ignore ‘foreign’ cards completely, which will also present an obstacle to using cards obtained on the
open market.
As described earlier, never use contactless smart card readers that solely rely on the card serial
number such as CSN readers. It doesn’t make sense to use a contactless smart card with
increased security over legacy card technologies and ignore the security capabilities built-into the
card. Some companies advocate these types of readers because they do not require
implementation of security mechanisms which may not be available for license to that reader
manufacturer and typically add additional costs which makes the readers more expensive. Using
CSN readers is analogous to using a high security reader on a glass door.
Protect the Cards
Cardholders should be instructed not to wear their badges in prominent view when outside the
premises and be aware of people approaching them attempting to perform a ‘bump and clone’ in
which an attempt is made to try and surreptitiously read their card using an electronic skimming
device. For contactless smart cards operating at 13.56 MHz, there are many companies that sell
RFID shielding devices that are packaged into a card holder that are very convenient to use that
prevents these kinds of attacks.
Another best practice is to avoid putting any identifying data on the card that gives an indication as
to the location or address of the facility to make it harder to identify where a lost card can be used.
Of course, many companies put their company logo on their cards but organizations should balance
this requirement with the disadvantage of including artwork that reveals the company’s location.
For companies with multiple facilities at different physical locations, do not use the same facility
code (also known as site code) data in all of the cards so that a lost card can be used at any of the
locations.
7
Another best practice is to have a policy that lost cards need to be reported as soon as possible.
And make it a policy that when a card is reported lost, it is immediately removed from the system.
As an alternative, consider making the cost for a replacement card high enough so that a
cardholder will think twice about being careless. Of course, this policy may actually discourage a
cardholder from immediately reporting a lost card in the hope that it might be found.
Detection – The Second Line of Defense
Buy readers with a tamper detect mechanism that provides a signal when the reader has been
removed from the wall. Almost every panel manufacturer provides the ability to monitor this alarm
signal and report when a reader is tampered with. If the panel supports ‘supervision’, another
method that can be used by installers is to include an additional pair of wires that are connected
together through a resistor at the reader. This loop can be monitored by the panel using a technique
called ‘supervision’ that can detect when the wires are cut, shortened, or other changes in the
electrical characteristics of the wires are made. Of course the panel must support this capability.
Immediately investigate tamper alarms even if they are momentary and return to normal. You might
actually detect the perpetrator in action or find that a foreign device has been installed in an attempt
to monitor and/or modify the communications between a reader and the upstream device. If the
reader is controlling a sensitive location, such as a perimeter door, have it and the door monitored
by CCTV. Some access control systems can automatically switch the viewing monitor to the door
with the tamper alarm as well as tag the video history log with the event for later review. And, if you
are using your own company-specific cryptographic keys that are stored in a reader, realize that a
reader that has been removed from the wall might have had the cryptographic keys extracted from
the reader, which compromises the entire security of your installation.
Many reader manufacturers also have the capability of sending ‘health’ messages (also referred to
as ‘heartbeat’ or ‘I am Alive’ messages) on a periodic basis to the upstream device.
This functionality can also be used to detect when the wires are cut and does not require any
additional wires to get this protection. If these periodic messages are set to occur faster than it
would take to install a rogue listening device, then the panel would notice and report the
interruption. Ideally these messages would be set to occur as fast as every second. Monitoring
health messages also provides additional benefits since they will detect reader malfunctions. It is
better to know when a reader is not working before somebody complains (usually in the middle of
the night when they cannot get in the door).
For converged physical and logical access control systems, geographic monitoring is available. For
example, if a person has just come in through a door at a site in Buffalo but is trying to log into his
computer in Denver, then obviously there is a problem. Another benefit in converged systems is to
not allow a person to log onto his computer if he hasn’t used his card at a perimeter reader. This
simple concept will get people to change their behavior and not tailgate when they are denied
access during the computer log-on process.
Protect and Study the Security Logs
The audit trail of the transactions (i.e., security logs) should be protected as it contains very
sensitive data, such as who is going through what doors at what times, card numbers, and much
more. If audit trails are electronically stored, keep them encrypted and secure. If they are printed
out, shred them when done. (If any of this data is available from a remote site over the network, or
for that matter, if the server is accessible or uses the public Internet, make sure that a proper
penetration [PEN] test is performed by a reliable third-party.)
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The security logs are invaluable after a security-related event has occurred because they might
provide clues as to who the perpetrator was. But that is not the only time to study the logs.
Periodically look at the logs in an attempt to see patterns of events that don’t make sense. Even
better yet, use computer software to analyze the logs for suspicious behavior patterns. For
example, a cardholder requires a finite amount of time to travel between entry points and if the
same card is used at two different locations in a very short time, this could indicate that a cloned
card is being used.
System Upgrades and Migration Strategies
Choose a manufacturer who has a strong portfolio of migration products and strategies including
multi-technology cards in which both the legacy credential and the new credential technology can
co-exist on the same card. Similarly, multi-technology readers capable of reading both the legacy
credential and the new replacement higher security credential are useful in a migration strategy.
And often a combination of these products may be necessary to effectively migrate in the shortest,
most convenient, and cost effective manner.
Conclusion
Following as many of these best practices as feasible, with attention to appropriate levels of
security, will result in a system that better fulfills its intended function with less possibility of being
compromised. And these are just a few best practices to look for. There are many additional best
practices that have not been discussed in this paper, such as the use of security mechanisms on
the card (like holograms) and other tamper evident technologies and much more. This paper will be
continually expanded to include additional best practices for organizations to effectively balance
cost, convenience and security when deploying an access control system. Please set a book mark
where you downloaded this document check back for later versions.
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Appendix A: The Dangers of Using CSN-only Smart Card Readers
Introduction
Some manufacturers, in an attempt to sell a ‘universal’ reader capable of reading almost any
contactless smart card technology, actually disable all of the built-in security mechanisms in order
to achieve their goal. Reading only the CSN of a contactless smart card actually provides a false
sense of security analogous to installing a high security door without any locking mechanism.
These readers, referred to as ‘CSN readers’, only read the card’s serial number which, as per ISO
standards, must NOT be protected by any security since they are needed by the reader to be able
to detect when more than one card is presented to a reader at the same time. This process,
referred to as anticollision, takes place before the card and reader mutually authenticate each other.
Because the ISO specifications are a publicly available document, details of how this anticollision
process works can be used by a perpetrator to build a device to clone (simulate) the CSN of a
contactless smart card.
Understanding this misuse of the CSN is critical for users of the technology to ensure that access
control security is maximized. If implemented and deployed properly, contactless smart cards
represent one of the most secure identification technologies available today.
Why Use Contactless Smart Cards?
The most modern contactless smart cards incorporate advanced state-of-the-art security
mechanisms. Before a reader can begin a dialogue with a card, it uses mutual authentication to
ensure that both the reader and card can ‘trust’ each other. Only after this process occurs is the
reader allowed to access the data stored inside the card. This data is protected by cryptographic
algorithms and secret keys so that if the data were somehow extracted or even spied on, it can be
very difficult to decipher and utilize.
As with 125 kHz Prox technology, contactless smart cards are convenient for users who merely
present their cards near a reader. In addition, users do not have to carefully insert the card into a
slot or worry about proper orientation. This also minimizes the physical wear-and-tear on both the
card and the reader, the potential for vandalism, and environmental elements.
Amplifying the convenience of contactless smart cards is their capability to support more than one
application at a time. For example, a single card can be used for the dual purposes of opening a
door and logging on to a computer.
Contactless smart cards also provide greater and ever-increasing amounts of memory, enhancing
the sophistication of applications. Enough memory is available to store biometric templates and
even photos, enabling additional factors for user authentication. Such authentication of both the
card and user increases the security and likelihood that the person using the card is indeed the
authorized user of that card.
A False Sense of Security
To understand why using the serial number of contactless smart cards provides a false sense of
security, it is first important to understand some basic definitions and contactless smart card
mechanisms.
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CSN: CSN refers to the unique card serial number of a contactless smart card. All contactless
smart cards contain a CSN as required by the ISO specifications 14443and 15693. CSNs are
typically 32 to 64 bits long.
The CSN goes by many other names including UID (Unique ID), CUID (Card Unique ID), and of
course CSN (Card Serial Number). It is important to note that the CSN can always be read without
any security or authentication as per the ISO requirements.
Think of the CSN using the analogy of the identifying number on a house. It is important for
everyone to be able to read the house number to find it. Similarly, the CSN is used to uniquely
identify a card when more than one card is presented at a reader at the same time. Moreover,
nobody can get in to your house or get in to a smart card without using the correct key.
Anticollision: Anticollision is part of the communications protocol used by contactless smart cards
to uniquely identify a card when more than one card is presented at a reader at the same time. It
provides the ability to communicate with several contactless smart cards simultaneously. This is
especially important in long-range readers, as illustrated by Figure 2: Anticollision.
Figure’2:’Anticollision
The ISO standards require that every contactless smart card have a unique CSN and these
standards describe several methods to implement anticollision. It must be pointed out that the CSN
was never intended by ISO to be used for any purpose other than anticollision.
How is a CSN Used for Access Control?
CSN readers are readers that use the CSN of a contactless smart card instead of the credential
data stored in the secure area of the card. When a card is presented to the reader, it reads the CSN
and typically extracts a subset of the CSN, converts it to a 26-bit Wiegand or other output format,
and then outputs this data to an upstream device such as a panel or host computer.
The Most Commonly Used CARD Format Intensifies the Problem
There are many card formats available and formats are comprised of multiple fields. The most
commonly used format contains a total of 26-bits and includes a site code field (8-bits), a card
number field (16-bits), and two parity bits.
The site code field (also called a facility code) is usually the same for all cards at a given site and is
used to ensure that cards from different facilities in the same geographic area can be distinguished
from each other. Without this field, cardholders with the same card number might be able to access
facilities for which they do not have authorization. The card number field uniquely identifies each
cardholder and the parity bits are used to detect data communication errors.
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If the 26-bit Wiegand protocol is being used, the 16-bit card number field is extracted from the CSN
and the site code field is usually created from a pre-programmed number stored in the reader.
Because the smart card manufacturer preprograms the CSN, using only a small portion of the CSN
is utilized. This introduces the likelihood that there will be duplicate card numbers. Statistically, out
of every 65,535 cards, there will be at least one duplicate.
This is why it is desirable to use a card format with more bits in the card number field. Some
manufacturers offer a card format that uses both a larger card number field and includes an
additional OEM field together with the site code field.
Keep in mind that the issue of duplicate card numbers is not limited to the Wiegand protocol. It
occurs in any protocol that uses a reduced number of bits derived from the CSN to represent a card
number.
Using the CSN Sacrifices Security for Interoperability
To create a low-cost, universal reader capable of reading any manufacturer’s contactless smart
card, reading the CSN is the easiest and sometimes the only way to achieve interoperability. One or
more of the following reasons are at the heart of the problem:
1. The inclusion of the hardware chip containing the security algorithms adds cost.
2. The reader manufacturer may have to pay a license fee for the security algorithms or the
reader manufacturer may not even be able obtain a license.
3. The security keys to the contactless smart cards are not available.
Using a low-cost, universal reader that does not avail itself of the security features that contactless
smart cards offer will compromise the security of the facility or area where it is used. As noted
earlier, the three major reasons to use contactless smart cards are security, convenience, and
interoperability. Figure 3 illustrates how using the CSN compromises these three key reasons.
Diagram C: Using Smart Card with CSN Reduces Security
Security
Convenience
Interoperability
Using Smart Card w/Security
(Ideal Balance)
Using Smart Card w/CSN
(Reduced Security)
Figure’3:’Using’Smart’Card’with’CSN’Reduces’Security
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Using the CSN is Inconvenient and May Add Hardware Costs
CSNs are non-consecutive numbers that are in a random order. Therefore, referring to a cardholder
by its CSN makes it impossible to group employees by card number ranges such as 1 – 100.
Furthermore, as discussed above, it is desirable to use all of the bits required to represent the entire
CSN. A 32-bit CSN would be represented as a number with as many as 10 digits and a 64-bit CSN
requires as many as 20 digits. Even using the hexadecimal notation to enter, CSNs still require a
person to type up to 16 characters to add or change a card.
With an enrollment reader, the process of adding cards to a system can be simplified since the CSN
of a card can be automatically read instead of being typed. However, this introduces more
complexity to the system, requiring additional access control software and hardware enrollment
readers. Moreover, if a cardholder’s privileges have to be changed, an enrollment reader is of no
use when the card is not available.
Using the CSN Can Decrease Privacy
Because reading only the CSN of a contactless smart card requires less power, read distances are
often greater. This is because the power-hungry cryptography circuitry inside the contactless smart
card is not used. Greater read distances, coupled with no authentication or security, make the cards
far less secure from illegal activities at even greater distances.
In addition, using the CSN gives the false impression that a particular reader’s performance is
greater than it actually is. This may be doubly misleading for users because the CSN reader may be
less expensive and offer better read distances than a reader that fully implements the security
protections available with contactless smart card technology.
CSN Emulation
An earlier section identified additional security threats based upon the availability of information
required to illegally read or copy a card technology. It concluded that using the CSN of a
contactless smart card is low security because it is well documented by ISO standards and no
security is used to authenticate a CSN. Many smart card development tools such as protocol
analyzers can emulate an ISO 14443 or 15693 CSN. Furthermore, universities are also teaching
the ISO protocols and students are writing firmware to emulate CSNs. What better way to prove
that a student correctly understands the ISO protocol than to actually create firmware to emulate a
CSN and fool a reader to prove that the firmware actually works?
U.S. Government and International Organizations Recommendations
A US Government report recommends not using the CSN for identification purposes since “… using
the CSN as a unique identifier works only for 14443A, and for 14443B it [may] be a random number
that changes every time and will be discussed in a future version of the specification.”
The International Civil Aviation Organization also warns, “There is no protection in use of a CSN
because this is often set in software by chip manufacturers and can be changed.”
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Cryptographers and Industry Expert Opinions
Both cryptographers and industry experts also warn of the dangers of using the CSN to identify a
cardholder. David Engberg of Corestreet Ltd. said, “The serial number has no cryptographic or
protocol-level protections to prevent an attacker from asserting the same serial number as any real
card. By implementing ISO 14443 directly, an attacker can imitate any desired CSN.”
Bruno Charrat, CTO of Inside Contactless, concurs with David Engberg, adding, “As soon as there
is no security in the communications, you can clone a card and then enter anywhere you want! It is
as simple as that.”
In an article from Security Technology & Design, Greg Young, Technical Sales Manager for RFI
Communications & Security Systems, warns against the assumption that contactless smart cards
offer more secure transmission than 125 kHz Prox cards. “They can be more secure, but they’re not
necessarily more secure,” he said. “Many manufacturers are touting readers that read multiple
types of smart card technology —MIFARE, iCLASS—when really all they’re reading is the serial
number sent unencrypted from the card, in the same way Prox is. Unless you make sure that what
you’re reading is from a secure sector on the card that can be truly encrypted, and there is a
handshake procedure between the reader and the card before transmission, what you’re getting is
no more secure than proximity technology.”
Refuting Commonly Held CSN Beliefs
What About Encrypted CSNs?
Encrypted CSNs offer no real protection from cloning and replay attacks.
Chips with Programmable CSNs
The statement – ‘The CSN is a unique serial number permanently written into the device’s
nonvolatile memory at the factory; it cannot be modified and is guaranteed to be unique for all
devices.’ – is not always true.
Some contactless smart cards have programmable CSN. For example, one vendor’s contactless
smart card chip data sheet states: “The CSN is written at time of manufacture, but part of it can be
customer-accessible and customer-writable, on special request.”
Similarly, another manufacturer’s data sheet states: “The CSN is defined by the customer during
personalization … it is usually unique… may be set to any value.”
Clearly, we see that there is no guarantee of the authenticity of a CSN and CSN reader’s
compromise security.
When Should a CSN Reader Be Used?
CSN readers are very useful as a temporary solution to migrate from one smart card manufacturer
to another. A single reader can be used to read both the existing cards using its CSN and the new
replacement cards using full security and authentication. This provides a window of time to replace
the cards. When all of the existing cards have been replaced, the reader can then be instructed to
turn off its CSN reading capability. For maximum security, it is best to keep the replacement time
period as short as possible.
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Conclusion
Using the CSN for anything other than its intended use severely reduces the security of a
contactless smart card. In other words, CSN is really an acronym for Compromizable Serial
Number. When implementing and deploying contactless smart card technology, always consider
the following:
1. Contactless smart cards are secure when used properly.
2. Using the CSN of a contactless smart card bypasses the security built into smart cards.
Understanding the security risks associated with using the CSN instead of reading the data
protected by security mechanisms will help ensure that the proper protections are in place for both
personnel and property.