A code review should not be an exercise in searching through regulations, finding paragraphs and placing comments on drawings. That may form part of the work, but it is not the real objective.
The real question is much more practical: is this facility being designed and operated with an appropriate level of fire and life safety?
This article explains how we at Java Fire Protection carry out fire and life-safety code reviews: where we start, what we look at, how we report findings, and why the difference between compliance and risk matters. It is written for developers, owners, architects, engineers, contractors, lenders and public authorities in Lebanon. Where it helps, we point to the references behind our practice:
- NFPA 101, Life Safety Code;
- NFPA 1, Fire Code;
- the NFPA standards for each fire protection system;
- Lebanon's public safety decree.
Our view in brief
- We start from the building and how it will be used, not from the code book.
- We review the whole picture: escape, compartmentation, systems, water, interfaces and commissioning.
- Every finding explains what the issue is, why it matters and what can realistically be done.
- We distinguish compliance from risk, and good design needs both.
- The earlier the review, the cheaper the solution.
What is a fire and life-safety code review?
An independent check that a building, or its design, protects the people in it and meets the requirements that apply to it. A review can be carried out on drawings before construction, during construction, at handover, or on an existing building in operation. In each case, it compares what is designed or built against the applicable codes and against the actual risks of the facility, and it sets out what needs to change.
Where do we start?
With the building itself. At Java, we begin by understanding the building itself. What is the occupancy? How many people are expected to use it? What activities will take place inside? Are there special hazards? What fire-protection systems are proposed? What codes and local authority requirements apply? Once those fundamentals are understood, the review becomes much more meaningful.
The occupancy matters because NFPA 101 sets different requirements for an office, a hotel, a hospital, a school, a mall or a factory. The number of occupants drives the number and width of exits. Special hazards, such as kitchens, generator rooms, fuel storage or laboratories, need their own protection and separation.
What do we look at?
Everything that decides whether people can get out safely and whether a fire can be controlled. Depending on the project, we may look at occupancy and hazard classification, means of escape, fire compartmentation, alarm and detection, portable firefighting equipment, sprinklers and firefighting systems, water supply, pumps, special-hazard suppression, emergency interfaces, emergency access, testing and commissioning requirements.
| Area | What we check | Main references |
|---|---|---|
| Occupancy and hazard classification | The use of each area, mixed occupancies, hazardous areas | NFPA 101 |
| Means of escape | Number and capacity of exits, travel distances, dead ends, stairs, doors, emergency lighting and exit signs | NFPA 101 |
| Fire compartmentation | Fire-rated walls, floors and doors, protection of openings, firestopping of penetrations | NFPA 101 |
| Alarm and detection | Coverage, notification, the control panel and its power supply | NFPA 72 |
| Portable firefighting equipment | Type, number, placement and maintenance | NFPA 10 |
| Sprinklers and firefighting systems | Design basis, coverage, standpipes and hose systems | NFPA 13, NFPA 14 |
| Water supply and pumps | Tank capacity, pump arrangement and power, private mains and hydrants | NFPA 20, NFPA 22, NFPA 24 |
| Special-hazard suppression | Kitchens, server rooms, electrical rooms, fuel storage and aircraft hangars | NFPA 17A, NFPA 96, NFPA 2001, NFPA 11, NFPA 409 |
| Emergency interfaces | What the fire alarm triggers: lift recall, door releases, air conditioning shutdown, dampers, smoke control | NFPA 72, NFPA 92 |
| Emergency access | Access for fire brigade vehicles, hydrants, fire department connections | NFPA 1 |
| Testing and commissioning | How each system and the interfaces between them will be tested before handover | NFPA 3, NFPA 4 |
Is identifying the issues enough?
No. A useful review explains each issue, why it matters and what can realistically be done about it. Simply identifying these points is not enough. A useful code review should explain what the issue is, why it matters and what can realistically be done about it.
Each finding in our reports follows the same structure:
| Element | Example |
|---|---|
| What we found | A final exit door from the ground floor is locked with a padlock while the building is occupied. |
| Where | Ground floor, rear exit, with a photograph and its location on the plan. |
| The requirement | Doors in the means of egress must be readily openable from the egress side whenever the building is occupied, without a key, a tool, or special knowledge or effort (NFPA 101, 7.2.1.5). |
| Why it matters | In a fire, occupants directed to this exit would find it locked. |
| What to do | Remove the padlock now and keep the door unlocked while the building is occupied. If the door must be secured, fit listed panic hardware where the occupancy requires it, or a special locking arrangement that NFPA 101 permits for this occupancy, such as delayed-egress locking. |
| Priority | Immediate. |
Findings are ranked so that the client knows what must be corrected now, what can be planned, and what is a recommendation rather than a requirement.
Is compliance the same as safety?
No. Compliance sets the minimum; professional judgement asks whether that minimum is enough for this facility. We also believe there is an important difference between compliance and risk. Compliance establishes the minimum requirements that apply to a project. Professional fire-safety judgment asks whether those minimum requirements adequately address the actual conditions and risks in that particular facility.
Good design requires both.
The codes recognise this themselves. NFPA 101 accepts alternative systems, methods or devices where their equivalent level of safety is documented and approved by the authority having jurisdiction (Section 1.4). It also offers a performance-based design option (Chapter 5), often used for large or complex buildings. In Lebanon, for existing buildings that are extended or change use, Article 4(6) of the public safety decree allows the owner to ask a special committee, formed by the Minister of Public Works and Transport, for exemption from certain fire-prevention provisions. The committee can accept alternative solutions, provided protection elsewhere in the building is not reduced. In older buildings, this is often where engineering judgement matters most.
Why should a code review happen early?
Because a problem found on a drawing costs far less to fix than the same problem found on site. Our role is not to make projects unnecessarily complicated. In fact, the opposite is usually true. We want to help the client, architect, engineer and contractor identify problems early enough that they can be solved practically. A fire-safety issue identified on a drawing is normally far easier and less expensive to resolve than the same issue discovered after construction is complete.
| Stage | What a review adds |
|---|---|
| Concept and design | Correct occupancy, exit layout, compartmentation and system choices while they are still lines on a drawing |
| Tender | A specification and bill of quantities that bidders can price on the same basis |
| Construction | Shop drawings and installed work checked against the approved design |
| Handover | Commissioning and integrated testing witnessed, documentation complete |
| Operation | Changes of use, fit-outs and maintenance kept in line with the design |
In Lebanon, design and execution drawings for many projects also go through a technical control bureau under Article 5 of the public safety decree. A review before submission helps avoid comments and delays at that stage.
What about existing buildings?
The same method applies, with the building as it is used today as the starting point. For existing buildings, we compare what is installed and how the building is used with the applicable requirements and with the actual risk. The review then sets out a prioritised plan: what to correct immediately, what to plan, and what can wait for the next renovation. This is the basis of our work for owners, tenants, buyers and lenders who need to know where a building stands.
For a leading airport and airline service provider, our work included:
- a code review to NFPA 101 that assessed the business areas and the aircraft hangars separately;
- an illustrated code manual for the client's engineers;
- photographic corrective-action registers, with each finding tied to the exact code requirement.
Finding the problem while there is still time
That, for us, is one of the greatest values of a proper code review: finding the problem when there is still time to solve it properly.
Designing a new facility, buying or renting a building, or unsure whether an existing building is safe for how it is used today? Speak with our team about a code review.
Frequently asked questions
What is the NFPA 101 Life Safety Code?
NFPA 101 is the US-based National Fire Protection Association's code for protecting occupants from fire and similar emergencies. It covers means of escape, compartmentation, fire protection systems and building operation, with requirements for each type of occupancy. Unlike many building codes, it has separate requirements for new and existing buildings, which makes it a useful benchmark for older buildings. It is widely used outside the United States; the IFC/World Bank Environmental, Health and Safety Guidelines, for example, cite it as an internationally accepted life safety standard.
Does Lebanon follow NFPA fire codes?
Lebanon's public safety decree applies Lebanese standards and, where none exist, standards adopted in the EU, the US or Canada. NFPA codes are therefore one of the recognised options, and they are commonly used by consultants, insurers and international organizations working in Lebanon. The decree also requires a single source per safety subject, so standards should not be mixed within a subject.
Does Lebanon's public safety decree apply to older buildings?
The decree applies to new projects and, under Article 4(1), to modifications, additions and changes of use of existing buildings, even when no floor area is added. An existing building that is not being altered is not automatically brought up to the decree. The owner, or the owners' association, remains responsible for the periodic maintenance of the building and its equipment under Article 4(4). We often recommend a review of older buildings anyway, because the risk does not depend on the date of the permit.
Who can review a contractor's fire protection design before approval in Lebanon?
An independent fire protection engineer or specialist who is not the designer can review the design against the applicable standard and the project requirements. We carry out these reviews for owners, consultants and lenders. Our engineering is led by an NFPA Certified Fire Protection Specialist (CFPS). An independent review does not replace the technical control required under Article 5 of the public safety decree, but it helps the design pass it.
What deliverables should a fire protection design package include?
At minimum, the package should include:
- the design basis, naming the codes and standards used;
- a code analysis and life safety plans: occupancy, occupant load, exits, travel distances and fire-rated construction;
- layout drawings and riser diagrams;
- hydraulic calculations based on recent water-supply test data, and agent and room-integrity calculations for gas systems;
- fire alarm battery and voltage-drop calculations;
- equipment datasheets and listing documents;
- a narrative sequence of operation and a cause-and-effect matrix showing what each alarm triggers;
- specifications and a bill of quantities;
- the testing and commissioning requirements.
What does an independent fire and life safety review for a lender-financed project involve?
The lender wants to know that the asset it is financing is safe, insurable and compliant. The review typically covers:
- the design basis and drawings against the applicable codes;
- site visits during construction;
- witnessing of commissioning and integrated testing;
- a report listing outstanding items and the risk each one carries.
For projects financed by development finance institutions such as IFC, or by banks applying the Equator Principles, the review typically follows the IFC General EHS Guidelines (Section 3.3, Life and Fire Safety) and Performance Standard 4. These call for:
- compliance with local codes and with an internationally accepted standard such as the Life Safety Code;
- qualified review at design and at completion;
- corrective action plans.
Should I have a fire safety survey before buying or renting a commercial property in Lebanon?
Yes, especially if you plan to change how the space is used, since a change of use falls within the public safety decree under Article 4(1). A survey shows what protection exists, whether it works, and what would need to change for your intended use, before you commit.
References
- NFPA 101, Life Safety Code.
- NFPA 1, Fire Code.
- NFPA 3, Standard for Commissioning of Fire Protection and Life Safety Systems.
- NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing.
- NFPA 10, 11, 13, 14, 17A, 20, 22, 24, 25, 72, 92, 96, 409 and 2001, for the individual systems.
- IFC, Environmental, Health, and Safety General Guidelines, Section 3.3, Life and Fire Safety; IFC Performance Standard 4.
- References are to the current editions unless the project or the authority specifies otherwise.
- Decree No. 14293 of 11 March 2005 on public safety in buildings and facilities, as amended in full by Decree No. 7964 of 7 April 2012 (Lebanon), Articles 1(10), 3, 4(1), 4(4), 4(6) and 5.