SPRINKLER AND FIRE PROTECTION INSTALLER TRADE: FURTHER CLARIFICATIONS
July 25, 2017
The present communiqué supplements Fire Marshal’s Communiqué 2017-03, Sprinkler and Fire Protection Installer Trade: Clarifications, issued on February 8, 2017. Its purpose is to provide clarifications to the fire service on how new compulsory qualification requirements for the sprinkler and fire protection installer trade, which became a “compulsory trade” on February 2, 2017, apply to sections 6.4, 6.5 and 6.6 of Division B of the Fire Code (Ontario Regulation 213/07, as amended).
The Ontario College of Trades (College), in conjunction with the Office of the Fire Marshal and Emergency Management (OFMEM) and the Sprinkler and Fire Protection Installer Trade Board (SFPI TB), has reviewed the work elements specified in sections 6.4, 6.5 and 6.6 of Division B of the Fire Code to determine which ones fall within the scope of practice for the trade of sprinkler and fire protection installer, as set out in subsection 41. (1) of Ontario Regulation 275/11, Scope of Practice - Trades in the Construction Sector. The parties (i.e. the College, SFPI TB and OFMEM) have agreed on the following:
- all inspections, checks and tests scheduled at intervals of six (6) months or longer as required under sections 6.4, 6.5 and 6.6 of Division B of the Fire Code fall within the scope of practice for the sprinkler and fire protection installer trade outlined in section 41 of Ontario Regulation 275/11;
- all inspections, checks and tests prescribed in sections 6.4, 6.5 and 6.6 of Division B of the Fire Code that are undertaken as a result of alterations, repairs or restoration of a fire suppression system that is out of service fall within the scope of practice for the sprinkler and fire protection installer trade outlined in section 41 of Ontario Regulation 275/11;
- persons that undertake the work specified above shall comply with section 4, part II of the Ontario College of Trades and Apprenticeship Act, 2009 (OCTAA), which stipulates the following: “No person shall employ or otherwise engage an individual to perform work or engage in a practice that constitutes engaging in the practice of a compulsory trade unless the individual holds a certificate of qualification in that trade that is not suspended or unless the individual is an apprentice in that trade and is working pursuant to a registered training agreement that is not suspended.”
In addition to the work elements mentioned above, the parties have identified an additional group of work elements in sections 6.4, 6.5 and 6.6 of the Fire Code that are critical to ensuring that fire suppression systems operate as intended and that fire protection water supplies are available during a fire. The extent to which these work elements must be carried out by qualified trade members is outlined in the attached table.
Notwithstanding the requirement for work specified above and in the attached table to be undertaken by qualified trade members, it should be noted that some exemptions may exist for employees of industrial plants who work on in-house fire protection systems. Any questions regarding these exemptions should be directed to the College.
All inspections, checks and tests mentioned in sections 6.4, 6.5 and 6.6 of Division B of the Fire Code that are not required to be carried out by a qualified trade member as described in the attached table may be carried out by the owner (as defined in the Ontario Fire Code) or a delegate. It is recommended that this work be carried out by competent persons knowledgeable about the fire protection system.
The College, the SFPI TB, and the OFMEM continue their discussions and anticipate providing additional clarifications regarding the application of the sprinkler and fire protection installer compulsory qualification requirements, including clarifications about qualification requirements for persons undertaking work elements outlined in section 6.8 of Division B of the Fire Code.
Questions regarding matters explained above should be directed to the College; staff members can be reached by telephone at (647) 847-3000 or 1-855-299-0028 (toll free), or by using the e-mail form on the College’s Web site.
 A compulsory trade, as defined by the Ontario College of Trades, is a trade in which registration as an apprentice or journeyperson candidate, or certification as a journeyperson, is mandatory.