HomeMy WebLinkAbout01/23/2007, BUS 3 - MULTI-DWELLING PROPERTY FIRE AND LIFE SAFETY INSPECTION PROGRAM council M«m,o,m Jan. 23,2007
Agenba REpoRt �N L<.s. 3
CITY O F SAN LUIS OBISPO
FROM: John Callahan, Fire Chief
Prepared by: Viv Dilts, Administrative Analyst II
Molly Brown, Fire Inspector H
SUBJECT: MULTI-DWELLING PROPERTY FIRE AND LIFE SAFETY
INSPECTION PROGRAM
CAO RECOMMENDATION
Review and discuss the performance of the Multi-Dwelling Property Fire and Life Safety
Inspection Program during 2005-06, but do not make any changes to the program at this time.
REPORT-IN-BRIEF
In accordance with past Council direction, the purpose of this report is to provide a
comprehensive status report on the performance of the City's fire and life safety inspection
program for multi-dwelling properties during 2005-06. This review shows impressive results in
making San Luis Obispo a safer community. Given the benefits of this program and its
consistency with our adopted cost recovery policies, we do not recommend making any changes
in the program scope or funding sources at this time.
DISCUSSION
Background
During the 2003-05 Council goal-setting process, representatives from Residents for Quality
Neighborhoods (RQN) expressed concern about the quality of rental properties in the City, and
the existence of substandard and un-permitted rental units. RQN described an ordinance in
effect in the City of Azusa that funds annual inspections of rental units by that city, including
single family residences (SFR) to ensure compliance with required state and municipal housing
code provisions. The inspections are funded by an annual fee paid by rental property owners.
RQN wanted San Luis Obispo to implement a similar program.
As part of the 2003-05 Financial Plan, the Council ultimately adopted a major City goal for
"Neighborhood Wellness," which included as part of its work plan an analysis of implementing a
comprehensive residential rental inspection program similar to the one in Azusa.
In spring 2005 staff presented to the Council a comprehensive report discussing options for an
enhanced rental property inspection program, with a focus on full-cost recovery for whichever
program was developed. As noted above, one of the options included inspecting single-family
residences (SFR).
Multi-Dwelling Property Fire And Life Safety Inspection Program Page 2
After much discussion, including public input, the Council directed staff to develop
recommendations for achieving cost recovery and program enhancement for only the current
State-mandated requirements for fire and life safety inspections for multi-dwelling units.
What are the State Mandated Inspection Requirements?
California Health & Safety Code, Section 13146.2 states: "Every city or county fire department
or district providing fire protection services ... shall, annually, inspect all structures subject to
subdivision (b) of 17921 (hotels, motels, lodging houses, apartment houses and dwellings)."
Additionally, this mandate states, "A city, county, or district which inspects a structure ... may
charge and collect a fee for the inspection from the owner of the structure in an amount as
determined by the city, county or district, sufficient to pay its costs of that inspection."
Adoption of Enhanced Program
After additional Council meetings, the Council approved an enhanced program that included the
State-mandated fire and life safety inspections as well as a more proactive public education
program.
The adopted program includes annual fire and life safety inspections for hotels, motels, lodging
houses, bed & breakfast facilities, youth hostels, senior facilities, and sororities & fraternities. It
also includes annual inspections of apartment buildings containing three or more dwelling units,
including residential condominiums designated as R-1 properties. An R-1 property is defined in
the California Building Code as a multi-dwelling property without a real property line between
units, which means it does not include a two-hour firewall between individual dwelling units,
constructed in accordance with building code standards.
With regard to cost recovery, Council initially agreed with the recommendation to pursue full
cost recovery, with program costs to be paid by the property owners rather than by the general
purpose taxpayer.
Enhanced Program Not Without Controversy - Especially Regarding Cost Recovery
While almost everyone agreed that a multi-dwelling inspection program is a worthy undertaking,
there were significant differences regarding the relationship of the inspections to the proposed
fees. Council directed staff to work with property owners to refine the initial recommendation to
assure the highest level of equity possible. As such, the City later reduced the fees for sororities
and fraternities to match the fee structure of hotels and motels. Additionally, the Housing
Authority and Peoples' Self Help Housing were exempted from fees..
Even after these adjustments were made, differences persisted within the community over the
next several months, as implementation took shape. As such, shortly after the new Fire Chief
began with the City in November 2005, he was directed to "take an objective look" at the
program, and return to Council in early 2007 to report on the program's performance and its
relationship to the fees.
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Multi-Dwelling Property Fire And Life Safety Inspection Program Page 3
The balance of this report addresses this direction. A Powerpoint presentation, with added
information/photographs, will be made at the January 23, 2007 Council meeting.
Program Components
There are three basic components in the City's multi-dwelling fire and life safety inspection
program:
1. Annual Inspections
2. Public Education Program
3. Annual Fees for Service
1. Annual Inspections
How are inspections conducted?
a. Research occupancy files
b. Visit site, contact managers, invite them along for inspection
c. Identify hazards and violations
d. Review required corrections with manager
e. Mail notice to owner and manager
f. Conduct follow up inspection(s) for compliance
What are the 2005-06 inspection statistics?
All 523 annual properties, subject to the program, (which include 8,852 units), were
inspected during 2005-06. Three hundred and eight (58%) of these properties had violations
and required at least one re-inspection. On average, there were more than two violations in
each of these facilities. Ninety-six percent of the properties have corrected their violations
and four percent are currently in enforcement.
What were the most frequent violations or hazards we found?
There were a number of common violations/hazards found during these inspections. They
included:
a. Non-operational emergency exit lights and exit signs
b. Non-operational fire extinguishers and smoke detectors
c. Excess storage in exit corridors
d. Fire alarm systems and fire sprinkler systems needing required maintenance
e. Obstructed fire hydrants
f. Substandard illegal electrical wiring
g. Excess vegetation and combustible trash
h. Damaged fire-rated walls
i. Obstructed fire lanes
j. Illegally dumped hazardous materials and hazardous waste
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Multi-Dwelling Property Fire And Life Safety Inspection Program Page 4
What are the benefits of annual inspections?
Inspections were completed by focused, well-trained fire inspectors. Corrected violations
resulted in better maintained properties and safer living environments for tenants. Overall,
the risk of fires and hazardous materials environmental contamination were significantly
reduced.
2. Public Education Program
The Fire Department has developed and presented to the public a number of public education
messages and formats to instruct occupants in multi-dwelling properties about fire and life
safety. These public education messages included:
a. Ten presentations given to residents of the rental facilities we inspect, regarding home
safety, life safety, and disaster preparedness.
b. Informational door-hangers on proper use of smoke detectors delivered to 1,500
apartments.
c. Home fire safety program slides aired on the public access television channel, Channel
20.
d. Public education display booths viewed by approximately 200 people at the Cal Poly
Housing Fair and Mid-State Fair.
e. Distribution of 500 Apartment Living Guides (booklets) to property management
companies.
f. Fire extinguisher training given to several groups of apartment residents, including
Housing Authority residents.
3. Annual Fees for Service
At the July 5, 2005 meeting, the Council set the current fire inspection fee structure as
follows:
CURRENTFEE - -
Apartments & R-1 Condominiums Hotels, Motels, B&B, Senior.Facilities,
Fraternities and Sororities
$65 Administrative Fee Per Facility 1-30 Units $200
$50/Unit Fee 31-80 Units $300
$15,000 Maximum Per Facilit Over 80 Units $400
Alternative Fee Methodologies
Due to property owners' concerns and suggestions, staff researched several alternatives.
1. Square Footage of Buildings - Currently, no accurate data exists for many of these
properties. Substantial labor costs would be incurred to determine accurate square
footage data. The size of a building does not necessarily relate to the time an inspection
takes.
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Multi-Dwelling Property Fire And Life Safety Inspection Program Page 5
2. Time and Materials Per Inspection - This method would bill each property differently
based on the time spent by inspection staff on property-by-property basis. This would be
very labor intensive to calculate and track this data for each property. Additionally, we
would no longer be able to collect fees on the County tax roll; and therefore, we would
incur higher collection costs. Lastly, we believe that this approach in practice would
generate significant customer concerns, as property owners will never know how much
the inspection will cost until it is completed: could be $50, could be $5,000. Whatever
our cost recovery goal and related fee, we believe it is important to clearly communicate
the amount.
3. Reduction for Well-Kept Properties - This methodology is also subjective. The public
could perceive that inspectors are overly scrutinizing properties to generate higher fees.
As with hourly rate per inspection methodology, it would be more labor intensive. The
City could no longer collect fees on the County tax roll, and the revenues collected would
be unpredictable from year-to-year.
Stakeholder Notification
In advance of this report, staff has notified all 523 affected property owners as well as 93 other
interested groups and individuals such as the Chamber of Commerce, Property Owners
Association, Board of Realtors and Residents for Quality Neighborhoods about this meeting. A
display ad was also published in The Tribune.
CONCURRENCES
The Finance Department concurs with the findings of this report. The City's "Cost of Services
Study" consultant, Maximus, has reviewed the data and also concurs that the City's cost recovery
methodology and rate structure based on units is reasonable.
FISCAL IMPACT
Annual costs for this program are $394,900. On May 17, 2005, the Council approved cost
recovery for this program of$370,400 (94%).
On July 5, 2005, Council approved a fee structure exempting properties owned by government
agencies or non-profit organizations like the Housing Authority and Peoples' Self Help Housing,
and reducing fees for sororities and fraternities. This change led to revenues of $340,100, or
86% cost recovery for this program..
However, after completing a detailed analysis of the number of units, staff identified some
discrepancies in the database, which further reduced revenues to $302,300, or 76.5% cost
recovery.
This shortfall was presented to the Council as part of the 2005-06 mid-year budget review, when
all City revenue projections were discussed. The database records have since been corrected,
and the actual cost recovery for 2005-06 was right on target at$300,900.
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Multi-Dwelling Property Fire And Life Safety Inspection;Program Page 6
__ _ Programo
Csts
Fire Inspector III (2 FTE) 209,800
Admin.Asst. (1 FTE) 67,600
Office Supplies/Printing 800
Postage 200
Fire Training 1,000
Amortized Start-Up Costs 8,600
Indirect Costs 37.1% _106,900
Total Program Costs 394;900
Total Billing for 2005=06(76%jwu_ avgY(30_0;900)
Cost to the General Fund 94,000
ALTERNATIVES
1. Continue the Current Cost Recovery Program of Approximately 75%. The Council
could elect to continue inspections and keep the fee structure as is, with cost recovery that
represents about a 75% property owner-to-25% community cost-sharing split. Given the
benefits of the program and its consistency with our cost recovery policy, this is our
recommended option.
2. Reduce Cost Recovery to 50%. The Council could consider reducing the overall cost
recovery goal to 50%. Under this option, rather than across-the-board reductions, we would
recommend leaving fees the same for hotels and institutional users; retaining the current $65
fee per property for apartments and R-1 condominiums; and reducing per unit fees from $50
per unit to $28 per unit. This would result in an additional General Fund subsidy of
$105,000 annually. This added General Fund cost is the equivalent of the traffic enforcement
police officer we had to cut in 2005-07 in balancing the budget.
COST RECOVERYTO
_. _ i._.
TOTALP-ROGRAM COSTS__.
H6tel§,Motet, B&B, Senior Facilities 14,624
Sororities& Fraternities 3,500
Apartments Administrative Fee ($65) 27,495
Proposed Apartment Per Unit Fee ($28/per unit) x 4494 Units 125,832
Condo Admin. Facility Fee ($65) 715
Condo Unit Fees ($28/per unit) x 297 Units 8,316
Mustang Village over 500 Apt. Units 15,000
TOTAL- BILLING-0-50% ' ^_ _.- _ __. .- 1951482
Cu__ �rrent _-._---------------
._.._. ___9__4_,_0_0_0'_._Cost at 76—.1%
Additional Cost at 50% 105,418
TOTAL COST TO GENERALFUND @
Multi-Dwelling Property Fire And Life Safety Inspection Program Page 7
Under the City's cost recovery policies, it makes sense for property owners to fund a large
portion of the cost of this program: not only do they benefit from owning safer property, but
they drive the need for these services. And our cost recovery policy recognized the
distinction between service recipients (who in this case include the tenants as well as the
community at large) versus service drivers—which in this case are the property owners. And
the current "75/25" split recognizes the dual benefit.
On the other hand, while property owners drive the need for this cost, recognizing that there
are benefits to others as well could be the basis for a "50/50" sharing of costs. In the final
analysis, this "policy calculus" is the Council's call. But we should recognize that shifting
costs to general purpose revenues where we could reasonably have higher cost recovery
means fewer resources for other services, like police, fire, streets, flood protection, open
space, senior services and parks.
3. No Cost Recovery. The entire $394,900 cost of the program would be absorbed by the
General Fund. This would result in an added General Fund subsidy of$300,000 annually.
This is the equivalent of three of the four police positions we had to cut as part of the 2005-
07 budget balancing process. While a case for"50/50" sharing under our cost recovery
policies can be made, it is more difficult to see how shifting all costs of the program would
be consistent with our current fiscal policies.
CONCLUSION
The program is going very well overall. The City is in full compliance with the State mandate to
inspect multi-dwelling properties on an annual basis. Properties within the City are better
maintained because identified hazards and violations are being corrected, and program costs are
being funded in accordance with the City's adopted user fee cost recovery policies. Renters and
property owners receive focused fire and life safety education messages. Finally, with this
program in place the City is a safer community.
G:/Prevent/Word/Rental Inspection Program/CAR/Jan.2007 CAR-Update.doc
- ' RECEIVED
I
JAN 10 2007
Ms. Christine Mulholland January 9,2007 S LO CITY COUNCIL
San Luis Obispo City Council .
I am writing in regards to the agenda item before Council on January 23rd dealing with
the "Multi Dwelling Life Safety Inspection Program".
As a 30-year resident, a local apartment owner, and a 32-year professional
firefighter,I am strongly against continuation of this program.
This inspection program is extremely costly to a small business owner,and is nota"life
safety"inspection. There is no interior inspection of fire alarms, smoke detectors,
electrical systems,heaters, living conditions, or any other safety items. It is a"drive by"
inspection,with costs that far outweigh services provided.
For the$370 I was assessed last year,I was told that one of my 6 apartments did not have
a door number on it. (The door had primer paint, and was in the process of being re-
painted) This year there were no items listed. So for two years of"inspections"totaling
$740, I was told I did not have a door number.
For a small business owner with only 6 apartments,this is a very high cost. With all the
discussion about affordable housing, I actually contribute clean, safe,affordable
apartments to young working class residents. I do not wish to pass on this cost to my
residents,I would rather invest$370 per year into maintenance and upgrades to the
property.
I change the smoke detector batteries each year, I service the fire extinguishers each year,
I have a maintenance crew cut the lawn and weeds every two weeks. I am a responsible
property owner who is being charged for a program that is causing me undue financial
hardship. I urge you to cancel this unfair assessment.
I supported and voted for a %z cent sales tax increase this year to support our police and
fire departments. If Council feels this property inspection program is worthy of
continuation,then please fund it out of that increase.
Sincerely,
Michael Harkness
1610 Phillips Lane
San Luis Obispo b e
540-0334 COUNCIL ;TCDD DIS
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RECEIVED
San Luis Obispo City Council !.DAN 1 1 2007
Re: Agenda Jan 23, 2007 SLO CITY COUNCIL
Fire Safety and Inspection Program
I am the owner of a four-unit apartment in San Luis Obispo and want
to protest this ordinance as merely a way to compensate the city by
these fees for lost State monies.
If this program actually did something it would be different. What I
understood from talking to Molly Brown last year was that the
inspectors merely walk around the building.
I would like to know that my tenants were at least being educated for
the annual $200 that I pay. Also, I think that the inside of the units
should be looked at for any hazardous materials or situations. I think
that loose or worn wires, small heating appliances and so on could be
a threat. This seems to be a more important than merely walking
around the outside. Perhaps small fire extinguishers could be
required inside the units instead of only outside the building and that
these could be checked to see if they are functional.
If I am to be charged for these services I would like to be paying for
something identifiable.
Thank You,
CL crw.
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Mayor of SLO
Re: Multi-Dwelling Property Fire and Life Safety Inspection Program
Background
Prior to last year the City of San Luis Obispo was in compliance of the State
mandated requirements for fire and safety inspections for multi-dwelling
units. This was before the $394,000 program under discussion tonight.
Enhanced Program Not Without Controversy
Council directed staff to work with property owners to refine the initial
recommendation to assure the highest levet of equity possible. As the
property owner of 1334 Palm, I instead received my property tax bill with a
new tax of$617 as an announcement. After many conversations with Molly
Brown and John Callahan I was assured this would be up for review again.
Annual Inspections
Total properties 523 .
Properties passed first time 220
Properties needing reinspection 303
Total inspections 826-875
Is this the highest level of equity possible to charge the same fee to
those who comply vs. those who require 2 or 3 visits? The 27% who
passed are in essence subsidizing for the reinspections of the 73% who did
not. Why not charge per inspection?
Public Education Program
What is the expense of this component? In discussing this with Molly she
admitted that most of the education is not reaching the audience who can
improve the conditions. I ask you to question its effectiveness.
Annual Fees for Service
Is it fair to charge $617 for my property with 11 units, a total of 5150 sq
ft vs. $200 for a sorority with up to 30 units? I submit that the wear and
tear and overall upkeep is far more with a sorority/fraternity than my 11
tenants yet I'm paying 300% more. Current total units 8852
Apartment units 4494/51%
Total revenue $300.9
Apartment revenue $252.,2/84%
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Is this the highest level of equity possible? Apartments are 51% of the
inventory and pay for 84% of the program?
Here is where you could lower the first inspection per unit to $20 and charge
again till they've passed. This would reward good behavior and put the
charges where they are actually being incurred. (If you take a class at Cal
Poly and fail, don't you have to pay again to take the class?)
Fiscal Impact
If we were doing these inspections before this enhanced program was started
it seems a bit bloated to charge 37% to indirect costs. Add to that the
Admin. Asst and time for the educational programs which are impossible to
measure as to their effectiveness and start up costs and you have
$184,100/47% of the programs expenses. Is this the highest level of equity
possible for the current property owners?
Alternatives
• Consider no cost recovery as the true cost is probably closer to $210,000.
• If you need added revenue, charge for reinspectons.
• Adjust apartment fees to be 51% of the revenue which represents their
portion of the inventory.
Conclusion
As a property owner is San Luis Obispo for over 27 years, I am finding it
increasingly unfair to subsidize city services. It seems a reoccurring theme to
not hold accountable the ones who are causing the problems. Please consider
these alternatives as a way to achieve the highest level of equity possible for
current property owners_ I'm sorry I could not be there in person, but I'm
working to pay the mortgage. Thanks for your consideration.
Don and Marlain:e Hubbard
1334 Palm
San Luis Obispo, CA 93401
760-634-5612
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Council, SloCity
From: Steve[steve@slohomes.com] Sent: Tue 1/23/2007 1:06 PM
To: Council,SloCity
Cc: Callahan,John
Subject: Multi-Dwelling Property Fire Inspection Program RECEIVED
Attachments:
JAN 2 4 2601
Dear Members of the City Council:
SLO CITY CLERK
While we fee that the inspection program by the Fire Department is helpful and needed, we don't feel the financing of the
program is equitable. Commercial properties in the City are also inspected by the Fire Department, but there is no inspection
fee charged. Presumably,the business license fees paid into the City General Fund justify not charging commercial properties
an additional fire inspection fee. By comparison, residential rental property owners not only pay business license fees, but also
are charged a fire inspection fee for buildings of three or more units under the same roof.
In fairness to rental property owners,we hope you will adopt Chief Callahan's Alternative#2 that would reduce the Cost
Recovery to 50%. That would be a big step in making the cost of the Fire Inspections more equitable.
Thank you for your consideration, L4C
Ig e - O
Stephen and Gina Nelson
1580 Lizzie Street
San Luis Obispo
8.2D6citi/
441-0336 S 7-,o'9 71-Z'e-
https:Hmaii.slocity.org/exchange/slocitycounci L/Inbox/Multi-Dwel ling%20Property%20Fire%20Inspecti o... 1/24/2007
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DATE: January 23, 2007 MEETING AGENDA
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FROM: John Callahan, Fire Chief ® CLERK/ORIG Z POLICE CHFQ QEPT HEADS ® REC DIR
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SUBJECT: Response to Councilmember Carter's Questions SPP t® H01R .
51 c.Ao 1 &4j cle
The following is a response to questions asked by Councilm-ember Carter regarding tonight's Council Kccan6l
Meeting Agenda Item B-3.
Question: What is the difference between previous "basic"program and current "enhanced"
program?
1. In the enhanced program, inspections are completed by well focused, well-trained Fire Inspectors.
Previously, the inspections were conducted by engine companies on an "as time permits" basis by
Firefighters with less specialized training than the Fire Inspectors.
2. The enhanced program provides the community with a higher level of service by developing and
conducting public education programs with regard to fire and life safety issues relating to multi-
dwelling living.
3. The enhanced program provides greater accuracy and consistency to the data base because information
is being entered and tracked by dedicated personnel. This improves services in several ways, including
distribution of data to emergency responders. This data includes emergency response information such
as emergency phone contacts, utility shutoff locations and special hazards
4. The enhanced program added one vehicle. This additional vehicle is necessary for completion of these
inspections in a timely manner.
Question: What exactly is inspected?
The program includes annual fire and life safety inspections for hotels, motels, lodging houses, bed &
breakfast facilities, youth hostels, senior facilities, and sororities & fraternities. It also.includes annual
inspections of apartment buildings containing three or more dwelling units, including residential
condominiums designated as R-1 properties. An R-1 property is defined in the California Building Code as
a multi-dwelling property without a real property line between units, which means it does not include a
two-hour firewall between individual dwelling units, constructed in accordance with building code
standards.
CADocuments and SetGngs\slouser\Local Settings\Temporary Internet Res\OLK1 RItem
B-3.doc
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Council Memorandum
January 23, 2007
Page 2
Inspections include:
1. Conducts file review prior to inspection.
2. Check address numbering on building exterior.
3. Check clearance around all fire hydrants.
4. Check fire extinguishers including placement, minimum rating and service records.
5. Check fire sprinkler system (if applicable)for routine maintenance and clearance around fire risers.
6. Check standpipe hose cabinets and.standpipe outlets for obstructions and covers.
7. Check fire alarm system (if applicable) for maintenance records, battery dates and fire alarm
control panel status.
8. Check common areas; i.e. hallways, for penetrations in walls, floors or ceilings.
9. Check exit doors, exit signs, and exit pathways for code compliance.
10. Check utilities/laundry rooms and mechanical rooms for general housekeeping issues.
11. Check main electrical panels for clearance and access.
12. Check smoke detectors in any vacant rental units for placement and operation.
13. Check smoke detector and battery testing records for all apartment units.
14. Check Fire Department's knox box (if applicable) for current keys.
15. Check perimeter for weeds or any other combustibles.
16. Check fire lanes for signage and red curbs.
17. Update records; i.e. emergency contacts.
18. Input data into computerized inspection tracking program and file paper copies.
19. Telephone owner's representative after completion of inspection to verify records and emergency
contacts.
20. Re-inspect, if applicable, to verify that deficiencies have been corrected.
Question: What is the reason for difference in fees for apartments/condos vs. hoteUmotels/B&B's
/senior facilities/fraternities, etc.
March 1. 2005 Agenda Report—Explanation of Differences
1. Apartment Rental Units
Explanation of Fees
The inspections of these facilities are mandated by law. Apartment inspections are very time consuming
and often require follow-up inspections. Per unit and administration fees are set so that full cost
recovery is attained and includes the administration of the program as well as actual time spent on
inspections and follow-up.
2 Hotels, Motels, Bed& Breakfast Facilities, and Youth Hostel Facilities
Explanation of Fees
These types of facilities frequently have maintenance personnel available 24 hours a day, and
historically, have fewer code violations than other types of rentals. In addition, it was recognized that
hotels and motels generate added revenue for the City (TOT), while the cost of serving residential housing
of any kind typically exceeds property tax revenues by a substantial amount.
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Council Memorandum
January 23, 2007
Page 3
Senior Facilities
Extlanation of Fees
These facilities have maintenance staff available 24 hours a day.
4. Sororities/Fraternities
Explanation of Fees
Sororities and fraternities traditionally have a high number of code violations requiring numerous
reinspections.
On July 5, 2005 Council modified the rate structure for sororities and fraternities to be the same as all
other congregate residences (such as hotels, motels, youth hostels, and senior facilities). This followed
direction from the Council at its June 7, 2005 meeting when it directed staff to reconsider fees set at the
May 17, 2005 Council meeting for sororities and fraternities and low and very-low income rental
properties.
Question: Do the 2 FTE's spend 100%of their time on the program as opposed to other Fire
functions.
Yes, 100% of their time is spent on the program.
Question: What is the percentage of time spent on the public education component?
These statistics are for the first year of the program, fiscal year 2005-06 only. The public education
component is being expanded in the current fiscal year 2006-07. These percentages will increase with the
expanded program.
FTE Administrative Assistant - 11%
FTE Fire Inspector III - 9%
FTE Fire Inspector 111 - 8%
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A FIRE SAFETY MESSAGE
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SMOKE ALARMS SAVE LIVES!!
-low do I test the smoke alarm?
Push the test button
-low often should I change the battery>
Twice each year
Which rooms need smoke alarms?
Each sleeping room
Hallway outside sleeping rooms
At least one on each floor (if multistory)
low do I install a new smoke alarm?
Follow manufacturer's guidelines
On wall: install 4-10 inches from highest
point
On ceiling: install minimum 4-10 inches
from wall at highest point
0
FIRE & LIFE SAFETY TIPS
• Develop and practice a family evacuation plan,
have two ways out.
• Keep at least one 5 pound dry chemical fire
extinguisher in your home. (2-A:10-B:C)
• Use candles with care. NEVER leave candles
unattended or within reach of children.
• For your electrical safety DO NOT,place cords
under rugs, over nails, or in high traffic areas.
AVOID overloading electrical outlets.
• DO NOT use heaters to dry clothing or other j
items. KEEP curtains, furniture and storage I
away from heater (3 ft. minimum). i
• Plug electric portableheaters directly into wall
socket (DO NOT use extension cord).
• Clean dryer lint screens after each use. Clean
washer and dryer motors as needed to eliminate
grease and lint accumulation.
• When cooking DO NOT leave food unattended on
stove. Smother grease fires with lid, turn off
heat source.
• When barbecuing with charcoal or wood use only
enough charcoal lighter fluid to start the fire.
• When barbecuing with propane DO NOT store or
use propane inside buildings or on balconies.
• Store gasoline outside the home. DO NOT use
gas as a cleaner. Never use gas to start a fire.
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A Practical ]Fire and ]Life Safety wide for Apartment giving
BROUGHT TO YOU BY:
San Luis Obispo City Fire Department
Working with You for a Fire-Safe Community
FORWARD
Perhaps nothing is as devastating as fire out of control. Fire can spread to a deadly level
in a matter of seconds. Fire can kill, disable, destroy property and completely disrupt
lives. Your chances of survival are greatly dependant upon your level of fire safety
awareness, having a working smoke detector, having an emergency exit plan and being
prepared for any emergency.
According to the US Fire Administration, 20 percent of fires in the United States occur in
apartments. This information is provided by the San Luis Obispo Fire Department to
educate apartment owners, managers and residents in an effort to not only prevent fires
from occurring but also to increase your chances of survival in the event a fire does occur.
If you have any questions regarding any information provided herein, please do not
hesitate to call the Fire Prevention Bureau at (805) 781-7380. We're more than happy to
help.
SPECIAL ACKNOWLEDGEMENT
The San Luis Obispo Fire Department would like to
acknowledge and thank the City of Mesa, Arizona Fire
Department, Mesa Crime Free Multi-housing Program and
RRM Design Group for their contributions to this document.
TABLE OF CONTENTS
Exiting Systems/Exit Plans..........................................................................1
Address................................................................................................2
FireAlarm Systems..................................................................................3
Fire Sprinkler Systems................................................_.._.._.......................4
FireExtinguishers....................................................................................5
FireLanes................................................................_...................._.......6
Emergency Medical Services.......................................................................7
PoolSafety............................................................................................8
Chemical Storage/Flammable Combustible Liquids Storage...................................9
Cooking Inside Common Areas/Barbeque Grills................................................10
Locks/Lock Boxes...................................................................................1 I
Heating and Ventilation Units/Fireplaces/Furnaces.............................................12
LaundryRooms......................................................................................13
Dumpsters............................................................................................14
Electrical..............................................................................................15
Working with the Fire Department...............................................................16
Community Safety Committee.....................................................................17
Community Newsletter..............................................................................18
Conducting Property Inspections..................................................................19
Apartment Self-Inspection Checklist..............................................................20
EX�UNG SYSTEMS
o The most important aspect of fire safety is getting everyone out quickly
: and safely. All exit corridors, doors, and stairways must be safely
maintained at all times.
r' • Keep stairways free of obstructions at all times. Anything
�I which may render the stairway unusable should be kept away
' from stairs. Propane barbeque grills, motorcycles, and
' combustible materials should not be stored under stairways.
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• If there are interior corridor systems, ongoing maintenance is
' necessary. Remember, you are not the only one using these
` exit systems.
r
• Keep all storage and obstructions out of corridors.
EMERGENCY • Maintain and test emergency lighting monthly.
Check for burned out bulbs, low and dead
batteries.
• Maintain exit signs. Replace burned out bulbs as
soon as possible.
• Fire doors along the corridor should be
maintained self-closing, self-latching (especially
laundry rooms) and not propped open. Properly
maintained fire doors can hold back fire and
smoke from the corridor, allowing tenants time to
get out.
• Post evacuation plans in common areas of the
complex. Each plan must indicate two exits from
each area and a safe place for everyone to
congregate. Provide evacuation information to
new tenants regarding procedures to be followed
j — if the alarm is activated or a smoke detector
sounds.
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ADDILRESS
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�' ¢ o It is very important that address numbers are easily seen from the street to
i r assist emergency personnel in quickly locating the appropriate address.
�= In an emergency, time is of the essence. The easier it is to find you, the
faster we can help.
o The apartment complex address numbers should be at least six inches in
height, contrasting with the background they are mounted on and be
visible from the street, especially at night.
ra
o Post apartment numbers conspicuously. They should be contrasting with
their background, and at least three inches in height.
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I � RRE ALARM SYSTEMS\ TEDS
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Fire Alarms are designed to notify residents of a fire in time to safely
N' evacuate a building. Building managers should consider providing
residents with information to assist them in planning their evacuation.
Keep Fire Alarm Systems in proper operating condition at all times. This
can be accomplished by utilizing the following recommendation.
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a Complete regular testing and maintenance by qualified
personnel. This includes, but is not limited to, testing all
}, devices (such as pull stations and smoke or heat detectors).
Cleaning all smoke detectors, checking battery levels, etc.
Documentation may be requested by insurance underwriters
seeking verification that reasonable efforts are being made to
maintain the system in good working order.
• A trouble condition, indicated on the alarm panel by a yellow
light, can be caused by numerous conditions. This situation
requires contacting qualified service personnel to troubleshoot
and correct the problem.
r
• False alarms, besides being annoying, can cause residents to
become "desensitized" to the alarm and possibly disregard it.
jProper maintenance can help avoid this situation.
Occasionally, manual pull stations are maliciously pulled. If
this occurs frequently, contact the Fire Prevention Bureau for
assistance.
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' FIRE SPRINKLER SYSTEMS
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Y ♦ Fire Sprinkler Systems are the most effective means of controlling fires,
minimizing fire spread and damage caused by smoke and fire. Sprinkler
heads are strategically placed throughout apartment living areas.
" Activated by heat, only those heads nearest the fire will discharge water.
Fire Sprinkler Systems do require regular testing and maintenance.
• Testing and Maintenance of Fire Sprinkler Systems.
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• Fire Sprinkler Systems require at least annual
testing and maintenance by a qualified contractor.
The system is required to be certified every five
years.
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• The system is required to be monitored by a
licensed Central Station Monitoring Company
a d 4 D ° which supervises the water flow and control valve
a a D ° tamper switches. These switches will notify the
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alarm company that water is flowing or that
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someone has turned off the system.
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RRE E ]1U1 V G MSHERS
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Fire Extinguishers, when operated by a person knowledgeable in their use
can significantly reduce fire damage. Training is essential. If you have a
fire extinguisher available, be sure it is a Class ABC extinguisher and that
it is in proper working order (the yellow arrow should be in the green area
of the gauge).
Use an extinguisher only after the Fire Department has been
called. Dial 9-1-1.
Make sure the building has been evacuated and the fire alarm
has been activated prior to using an extinguisher.
Make sure you have a Class ABC Extinguisher and that you
know how to use it properly.
• Make sure the fire is small enough to be extinguished with the
size of fire extinguisher you have.
ii • Always make certain there is an exit behind you before you
j.' attempt to fight the fire. Never put the fire between you and
an exit.
I Training information pertaining to fire extinguishers, is
available from the Fire Prevention Bureau.
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• Keep fire extinguishers in good working order at all times. Be
sure they are mounted in conspicuous, accessible locations.
Annual servicing by qualified personnel and monthly
inspections by maintenance personnel is required.
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lam' o RRE LANES
Fire lanes are designed to provide direct access for emergency activities
and emergency vehicles. Most frequently, they are used for fire apparatus
during medical emergencies. When fire lanes, red curbs and fire hydrants
are blocked by vehicles, a delay in receiving emergency assistance may
occur. In a fire or medical emergency, seconds count. Proper signage is
very important to enforce no parking in the fire lane. The San Luis
Obispo Police Department will cite illegally parked vehicles and may
assist apartment managers with enforcement. Contact the Fire Prevention
Bureau for information on signage wording and placement.
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' EMERGENCY MIEIDaCA1L S ERVaC ES
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f o Learn CPR. For information pertaining to classes, call the American Red
,�. Cross or American Heart Association.
o Place 9-1-1 stickers, your address and phone number, and emergency
.' numbers on or near the phone. Stickers are available at the fire dept.
o When dialing 9-1-1, be sure to answer all the dispatcher's questions and
follow their directions. Speak slowly and clearly and stay calm. Stay on
the phone until you are told to hang up.
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o Provide specific information about where the emergency is taking place.
For example, the building number, apartment number, nearest entrances,
which pool, etc.
o To direct emergency personnel to the scene, turn on an outside light and,
if available, send someone out to meet them.
o Unlock gates or doors leading to the apartment so firefighters can make
entry.
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POOL SAYETY
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Many water-related incidents occur each year. These frequently involve young
children, but adults can also be victims. Water-related incidents include not only
drowning,,f but near drowning, which can leave a victim severely brain damaged.
Also, diving from other than designated areas can cause head and spinal cord injuries
if the victim strikes their head on the bottom. Permanent paralysis can result.
r Alcohol consumption may precipitate water-related incidents by impairing judgment.
• Adults, as well as children, should never swim alone. Children must
always be directly supervised by an adult.
• Provide approved life-saving equipment, such as a pole with a hook or a
Styrofoam ring, in the pool area.
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• Persons supervising others should know CPR.
• Interior perimeter pool fences should be installed. Fences should be at
�> least 5 feet in height, with self-closing and self-latching gates, which
should be checked frequently. Vertical bars should not be spaced more
than four inches apart.
: • Keep pool area free of toys and other objects that might attract children.
• Keep tables and chairs away from the outside of the interior perimeter
fence so children cannot climb over the fence by using furniture or other
objects.
• Do Not allow pets in the pool area where young children are present.
• Post pool rules conspicuously and enforce them. Suggested rules
include:
I
• Children must always be directly supervised by a
`d responsible adult.
�L • Rules addressing the consumption of alcoholic beverages
O
should be considered.
• Roughhousing is not allowed.
• Dive only from the diving board, not from the side of the
pool.
• Gates must be closed after entering or exiting the pool
area; never prop them open.
• Glass containers are not allowed in the pool area.
i
• It is recommended that a telephone be installed near the pool, with 9-1-1
posted for emergencies. 8
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STORAGE
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Pool Chemicals
Store pool chlorine and muriatic acid separate from one
another in a well ventilated area.
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o Flammable and Combustible Liquids
• Store gasoline in approved safety cans only. Place caps tightly
on container.
• Do not exceed five gallons.
It is recommended that flammable and combustible liquids be
�,. stored in a well ventilated area, away from open flame (i.e.;
gas water heaters, gas clothes dryers or other similar types of
ignition sources).
• Label all chemicals on outside of containers.
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COOKING IN COMMON AREAS
o Cooking is a frequent cause of fire loss. Cooking which produces grease (such as
frying,browning of meat or deep fat fryers) is not allowed unless an approved grease
removal system and commercial fire protection system has been installed. When an
_ extinguishing system has been installed, servicing every six months by a qualified
contractor is required. All cooking areas, hood and ducts should be kept free or grease
accumulation.
` • Barbeque Grills
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t • Use only enough charcoal lighter fluid to start the fire. Using charcoal
+ which is pre-treated with fluid is always best.
r ; . • Keep the flame low.
• Never use gasoline to start the fire.
• Keep the grill lid closed or cover on when cooking. The grill should be
J constantly attended.
' • Have an approved fire extinguisher or garden hose nearby and know how
r t to use it.
Let coals cool overnight or wet the ashes thoroughly prior to disposal.
Dispose of ashes by placing them in a metal container with a tight fitting
lid. Never dump ashes directly into the dumpster.
• Keep matches, lighters and combustible liquids out of reach and sight of
children.
• Do not use or store barbeque grills on common balconies used for
j exiting.
! • It is strongly recommended that barbeques not be used on balconies or
terraces.
♦ LPG/Natural Gas
• It is strongly recommended that LPG cylinders (propane) such as
barbeques, not be used or stored inside buildings or on balconies, but
` preferably in a secured shaded area outside, away from building openings
a and stairs. If a cylinder leaks or vents, flammable vapors may travel
inside buildings.
Check rubber"O" rings and supply hoses every time the cylinder is
filled.
• Protect natural gas meters and piping from damage by vehicles or other
impact.
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y141 , LOCKS/LOCK BOXES
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At least two vehicular access points into larger complexes may be
required for fire department access. If gates are to be installed or locked
or if access will be blocked in any manner, a Knox Box application shall
."<., be obtained from the Fire Prevention Bureau. At that time, a detail shall
be provided, showing distances from the street, turn-arounds, etc. Gates
may not be installed or locked until after the application has been
submitted. Applications for Knox locks and /or boxes may be obtained
from the Fire Prevention Bureau by calling (805) 781-7380.
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HEATING, VENTILATI®N
AND
{
FIREPLACES
t ♦ Heating and ventilation units require regular service. Develop and use
preventative maintenance programs for all mechanical equipment. Keep
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motors free of grease and dust. Check filters regularly and change them
when necessary. Make sure fresh air returns/vents are kept clean and
� s; r open to prevent carbon monoxide poisoning.
♦ Floor and Wall Heaters should be kept free of dirt, dust and lint build up.
Vacuum frequently, especially prior to first winter use. Provide at least
three feet of clearance around all heaters and provide means of keeping
children away. Do not hang clothes, towels or similar items over heaters
to dry.
i♦ Fireplaces (including chimneys and flue spaces) should be cleaned
j regularly. Never dump hot ashes into trash cans. Allow ashes to cool
overnight and place them in a metal can with a lid. Accumulations of
creosote (a residue formed by products of the burning process) can self-
ignite over time, causing chimney, attic and roof fires. Contact a
professional chimney sweep for further information on how to care for
your fireplace. Never burn paper, trash, Christmas trees or other items in
i
your fireplace.
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LAUNDRY ROOMS
y o A laundry room is another area for common fire hazards. Lint and
combustible debris can accumulate behind the dryer and can ignite when
r' heated.
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• Clean dryer lint screens after each use.
• Dryer vents should be continuous to the outside.
• Clean dryer and washer motors as needed to eliminate grease
and lint accumulation.
• Gas vents for water heaters and dryers should be maintained in
n good repair and be continuous to the outside.
• Provide earthquake strapping for your water heater.
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t? o Locate dumpsters away from buildings. Maintain at least a five foot
�. r. separation from combustible construction and eaves. The intent is that in
the event of a fire in the dum ster the fire may Ff I p Y be contained to the
dumpster and not spread to adjacent buildings.
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ELECTRffCAL
o Many apartment fires are caused by electrical problems. These include
e improper use of extension cords, damaged flexible cords, overloaded
w
circuits, and defective appliances.
Electrical installations and wiring throughout the complex
' + . .. should be installed by a qualified electrician in accordance
y with the National Electrical Code.
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Extension cords: Do Not use these as a replacement for
y ' '' •
^4 permanent electrical wiring. Extension cords are designed for
�}
temporary use only. They should be kept free from damage
and the wiring size should be appropriate for the amperage of
the appliance it is supplying. Use only UL listed cords.
• Flexible cords: Maintain flexible cords to appliances (lamps,
toasters, etc.) in good condition and place them where they are
not subject to damage. Replace damaged, frayed, dried, or
{ cracked cords or replace appliances if needed.
• Overloaded circuits: These can occur when too many
appliances are plugged into one circuit, exceeding the capacity
of the wiring, heating the wiring, and possible starting a fire.
Never plug in more appliances than the receptacle will accept.
Two plugs are usually allowed in a typical household
receptacle.
Defective appliances: Heat producing appliances are
especially prone to create a fire problem if misused or allowed
to become defective. Unplug heat producing appliances
(toasters, blow dryers, curling irons, clothes irons, and portable
heaters, etc.) when not in use. Place space heaters at least
p three feet from anything that will burn, or further if
r� recommended by the manufacturer. Never use an extension
cord to supply power to a space heater. Space heaters should
be unplugged when sleeping or leaving the premises.
• Never allow tenants to run extension cords from one apartment
to another to supply power to an apartment without electricity.
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WORKING WITH YOUR FIRE
DEPARTMENT
o The information provided in this manual regarding fire and life safety is
intended to raise your-awareness of safety issues and assist you in
recognizing potential problems. Ongoing education and training is
essential. Contact the Fire Prevention Bureau for further information.
o As a manager or landlord, you have the ability to significantly reduce
'' �► safety hazards by being observant and by following up on concerns
forwarded to you by tenants.
•fi,
• Tenant Complaints
• Occasionally complaints are received and
evaluated by the fire department. The first
question asked is "Have you notified your
apartment manager or landlord?" If not, it is
usually suggested that tenants notify the manager
prior to any intervention by the fire department.
• If fire department intervention occurs, an
~= inspector will first discuss the concern with the
manager and perform an inspection to evaluate
�r the situation. If a problem exists, the inspector
will then present recommended solutions to the
manager and agree on a reasonable time frame for
correction.
• Manager/Landlord Complaints
• If the tenant is maintaining an unsafe condition,
the fire department, when requested by the
manager or landlord, will determine if
intervention is called for and what type of
intervention is necessary. Often, as a manager or
landlord, the lease may allow you the ability to
act on a problem, depending on the nature of the
situation.
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CO MIlMIUM'II'Y SAFETY (CO M[1M ffTTIEIE
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o A safe committee may be formed to provide management with
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additional input into developing fire evacuation plans, fire safety plans,
and other safety matters. The committee may also solicit and receive
notification of safety concerns from tenants. If requested, the fire
d rti;
department will gladly provide assistance with training safety committees.
The San Luis Obispo Fire Department offers a Community Emergency
Response Team (CERT) program which provides training and education
for emergency situations. Fore information regarding the CERT program
contact the CERT Coordinator at (805) 783-7777.
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COMMUNITY NEWSLETTER
� _ ♦ A newsletter may be helpful in keeping tenants informed of important
f issues within the complex. Fire safety information on topics pertinent to
apartment safety may be included. The fire department has information
which may be printed in your newsletter.
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.. CONDUCTING PROPERTY
INSPECTIONS
's ; ♦ The San Luis Obispo Fire Department conducts regular inspections of
most multi-family residential buildings. Fire safety inspections can easily
r: be conducted by the manager/landlord to maintain a complex free from
fire safety hazards and avoid correction notices by the fire department.
.L
♦ Since an unsafe condition in a tenant's apartment or in common areas of
the complex can affect other tenants, it is crucial to correct unsafe
conditions immediately. Questions about specific problems can be
addressed by contacting the fire department.
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♦ Use the attached Fire Safety Self-Inspection Checklist to help you identify
and correct existing hazards.
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FIME SAFETY SELF-INSPECTION CHECKLIST
HOTELS/MOTELS AND APARTMENTS
OUTSIDE OF THE BUILDING YES NO
Is your address plainly visible and legible from the street? [ ] [ ]
Are your apartment/guest room doors clearly marked? [ ] [ ]
Do numbers contrast with their background? [ ] [ ]
Are Fire Department Connections to fire sprinkler systems visible and accessible? [ ] [ ]
Are fire hydrants clearly visible and have 3' of clear space around them? [ ] [ ]
Are required fire lanes clearly marked with signs and red curbs? [ ] ( ]
Are all sides of the building free of weeds, trash, debris or combustible rubbish? [ ] [ ]
Does the Fire Department Key Box contain updated keys for emergency access? [ ] [ ]
(If you have changed locks, contact the fire department for placement of new keys.)
Is your dumpster at least 5 feet from combustible walls, eaves and building overhangs? [ ] [ ]
PORTABLE FIRE EXTINGUISHERS
Are fire extinguishers properly mounted between 3 and 5 feet on a wall? [ ] [ ]
Has a licensed contractor serviced the extinguisher in the past 12 months? [ ] [ ]
(You can check this by looking at the service tag for the last service date)
Are the extinguishers clearly visible, along an exit path and no more than 150 feet apart? [ ] [ ]
Do all fire extinguishers gauges register with the arrow in the green? [ ] [ ]
Does the extinguisher have a minimum rating of 2A-10BC? [ ] [ ]
(You can check this by looking on the manufacturer's sticker next to the UL Listing)
EXITS and EMERGENCY LIGHTING
Are all exit ways and doors free of obstructions or storage? [ ] [ ]
Are all exit doors in operable condition, openable from the inside without the use of a key or
any special knowledge and not blocked open? [ ] [ ]
Are all exit paths; such as balconies, stairways and common hallways, clear of obstructions? [ ] [ ]
Are exit signs lit and are all bulbs working? [ ] [ ]
Do windows open easily so they can be used as an alternate exit in the event of a fire? [ ] [ ]
Are the batteries for emergency lights charged and ready for operation? [ ] [ ]
Is there an occupant load sign posted near the exit for rooms of 50 or more? ( ] [ ]
Is the hotel/motel emergency procedure plan posted at each exit? [ ] [ ]
ELECTRICAL
Is there at least 30" of clearance around the main electrical shut-off panel? [ ] [ ]
Are all circuit breakers labeled to show which units they control? [ ] [ ]
Are all circuit breakers free of tape or any obstructions preventing them from functioning? [ ] [ ]
Do all electrical outlets, switches and junction boxes have proper cover-plates?
Is all wiring and electric cords properly installed, in good repair and plugged directly
into an outlet and not an extension cord? [ ] [ ]
(Be sure cords or wiring does not go under carpets, through walls or across traffic paths)
Are electrical motors free from accumulations of oil, dirt, dust, etc.? [ ] [ ]
Are power taps (multi-plug outlet boxes incorporating surge protectors or built in circuit
breakers) plugged directly into a wall outlet?
HOUSEKEEPING AND STORAGE
Are combustible waste containers, greater than 40 gallons, made of metal? [ ] [ ]
Are all vents and filters of heat producing appliances (heaters, cloths dryers, etc.) in good
repair, clean, and properly vented to the outside? [ ] [ J
Have all holes in walls or ceilings, that could allow fire into hidden places, been repaired? [ ] [ ]
Are hot water heater closets, electrical rooms and under stairwells clean and free of storage? [ ] [ ]
Are combustibles stored at least 3 feet away from gas appliances [ ] [ ]
Are above ground gas meters and regulators protected from vehicle damage and have
readily accessible shut-off valves? [ J [ ]
Is all storage neat and orderly? [ ] [ ]
All water heaters have pressure relief valves and earthquake straps? [ ] [ ]
All laundry rooms, washers and dryers are free of dust and lint build-up? [ ] [ ]
There are no more than 10 gallons of flammable liquids stored on site? [ ] [ ]
All flammable liquids are stored in an approved safety can away from heating devices
and open flame? [ ] [ ]
Are oily rags stored in metal or metal lined containers with a tight fitting or self-closing lid? [ ] [ ]
SMOKE DETECTORS
Is there at least one smoke detector in each apartment/guest room? [ ] [ ]
Have all smoke detectors been tested for proper operation? [ ] [ ]
Are all smoke detectors operable, and have fresh batteries? [ ] [ ]
Do smoke detectors (wired directly to the buildings electrical power) have
battery back up with fresh batteries? [ ] [ ]
FIRE SPRINKLER SYSTEMS
Has the fire sprinkler system been tested in the last year? [ ] [ ]
Has a licensed contractor conducted a certification test in the last five years? [ ] [ ]
(Check for a certification label on the main fire sprinkler riser)
Does the fire sprinkler system provide complete coverage to areas remodeled or altered? [ ] [ ]
Are there a minimum of 6 spare sprinkler heads and a sprinkler wrench near the riser? [ ] [ ]
Is there at least 18" clearance provided below each sprinkler head? [ ] [ ]
Are standpipe outlets and hose cabinets clearly visible and unobstructed? [ ] [ ]
FIRE ALARM SYSTEMS
Is the green system power light on? [ ] [ ]
Are there any red alarm condition lights on? [ ] [ ]
Are there any yellow system trouble lights on? [ ] [ ]
Has the fire alarm system been regularly maintained and are test records available? [ ] [ ]
Do you have an alarm system permit posted or readily available? [ ] [ ]