Do ADA compliant smoke detector strobes need to operate during power failure?

[Yikes]

I say "yes", and it won't be the first time that a manufacturer has (IMO erroneously) claimed ADA compliance.
Example:

First Alert Hardwired Smoke and CO Alarm with LED Strobe Light and 10-Year Sealed Battery - 7030BSL (1038870)​

But wait - - open the Owner's manual, and it says the strobe won't operate during power failure:



ADA 809.5.2.1 requires visible alarms in communication units. During a power outage the audio alarm will operate but the visible strobe won't. And a power outage is when residents are more likely to use candles or other open flames in their units.

So, under ADA 233.3.5, how is this an equivalent facilitation for persons with hearing impairments?

BTW, I'm not picking on First Alert. Kidde and other manufacturers have the same issues.
At the moment, I'm not sure I can have an ADA compliant communications unit using all-in-one combo units without also adding an external battery backup + inverter.

 

[Yankee Chronicler]

So, under ADA 233.3.5, how is this an equivalent facilitation for persons with hearing impairments?

It's not. I agree -- it doesn't comply with the ADA. Visible alarms are also required by the IBC:

[F] 907.5.2.3 Visible alarms. Visible alarm notification appliances shall be provided in accordance with Sections 907.5.2.3.1 through 907.5.2.3.3.

[F] 907.5.2.3.3.1 Wired equipment. Where wired equipment is
used to comply with the future capability required by Section
907.5.2.3.3, the system shall include one of the following
capabilities:

1. The replacement of audible appliances with combination
audible/visible appliances or additional visible notification
appliances.
2. The future extension of the existing wiring from the
unit smoke alarm locations to required locations for
visible appliances.
3. For wired equipment, the fire alarm power supply and
circuits shall have not less than 5-percent excess capacity
to accommodate the future addition of visible alarm
notification appliances, and a single access point to
such circuits shall be available on every story. Such circuits
shall not be required to be extended beyond a single
access point on a story. The fire alarm system shop
drawings required by Section 907.1.2 shall include the
power supply and circuit documentation to accommodate
the future addition of visible notification appliances.

And:

[F] 907.6.2 Power supply. The primary and secondary power
supply for the fire alarm system shall be provided in accordance
with NFPA 72.

Exception: Back-up power for single-station and multiplestation
smoke alarms as required in Section 907.2.11.6.

Which leads us to:

[F] 907.2.11.6 Power source. In new construction, required
smoke alarms shall receive their primary power from the
building wiring where such wiring is served from a commercial
source and shall be equipped with a battery backup.
Smoke alarms with integral strobes that are not equipped with
battery backup shall be connected to an emergency electrical
system in accordance with Section 2702. Smoke alarms shall
emit a signal when the batteries are low. Wiring shall be
permanent and without a disconnecting switch other than as
required for overcurrent protection.
Exception: Smoke alarms are not required to be equipped
with battery backup where they are connected to an emergency
electrical system that complies with Section 2702.

I don't see any exceptions for the visible (strobe) function of required alarm notification devices.

 

[mtlogcabin]

it won't be the first time that a manufacturer has (IMO erroneously) claimed ADA compliance.

They do meet ADA they do not meet NFPA 72 or the building codes.

ADA only specifies the candela requirement for hearing impairment not how the strobe is powered.

Specifically, the ADA includes requirements for fire alarm strobes to accommodate individuals with hearing impairments. These requirements ensure that the flashing lights are intense enough to be visible to individuals with varying degrees of visual acuity.

 

[Yankee Chronicler]

They do meet ADA they do not meet NFPA 72 or the building codes.

ADA only specifies the candela requirement for hearing impairment not how the strobe is powered.

Specifically, the ADA includes requirements for fire alarm strobes to accommodate individuals with hearing impairments. These requirements ensure that the flashing lights are intense enough to be visible to individuals with varying degrees of visual acuity.

That's an interesting perspective, but I don't agree with it. The ADA is, fundamentally, federal civil rights, anti-discrimination legislation. Its purpose is trying to ensure that folks with disabilities have (to the extent possible) the same access to buildings and facilities as the able-bodied. Despite the ADA not specifying that an alarm notification device must provide visible as well as audible alert on back-up power, I don't think that needs to be stated. If it doesn't do that, it's not providing "equivalent" function for those with impaired hearing.

I'll stand by the analysis (code path) I outlined above.

 

[mark handler]

The strobe would drain the battery too quickly.
You would need to wire the alarm into the back-up generator, assuming you have one.

 

[Yikes]

I don't see any exceptions for the visible (strobe) function of required alarm notification devices.

Right. To me, 907.2.11.6 means (my words added in bold italics):
Smoke alarms with integral strobes that are not equipped with
battery backup that can operate the strobe shall be connected to an emergency electrical
system in accordance with Section 2702.

I don’t know how to diagram a sentence, but to me the phrase “that are not equipped with a battery backup” is applicable to “integral strobes”, not “smoke alarms”.

 

[steveray]

I had one FM that would do all of his fire alarm tests with the power off and you can do egress lighting at the same time.....Miss that guy.....

 

[mtlogcabin]

I was wrong they do meet NFPA 72 2016 edition

NFPA 72 29.6.5 Notification Appliance (with Smoke or Heat Alarm)
If a visible notification appliance is used in conjunction with a smoke or heat alarm application for compliance with 29.3.7, the notification appliance shall not be required to be supplied with a secondary power source

 

[Yikes]

Crazy thing is, it should be so easy for a manufacturer to add a small rechargeable battery for the strobe. You see rechargeable flashing bicycle lights all the time.

 

[Yikes]

I was wrong they do meet NFPA 72 2016 edition

NFPA 72 29.6.5 Notification Appliance (with Smoke or Heat Alarm)
If a visible notification appliance is used in conjunction with a smoke or heat alarm application for compliance with 29.3.7, the notification appliance shall not be required to be supplied with a secondary power source

That appears to be in opposition to IBC 907.2.11.6. And from an ADA standpoint it also seems inherently discriminatory to deaf people living in communication accessible units.
I think there is a high correlation between loss of power and residents using open flame for light or heat.
In event of fire, deaf people are not given an equivalent opportunity to be notified for escape?

 

[mtlogcabin]

Do you see anything in 2702 that would apply to all integral strobes or just specific occupancies

 

[mtlogcabin]

[F] EMERGENCY POWER SYSTEM. A source of automatic electric power of a required capacity and duration to operate required life safety, fire alarm, detection and ventilation systems in the event of a failure of the primary power. Emergency power systems are required for electrical loads where interruption of the primary power could result in loss of human life or serious injuries.

[F] 2702.1.5 Load duration.
Emergency power systems and standby power systems shall be designed to provide the required power for a minimum duration of 2 hours without being refueled or recharged, unless specified otherwise in this code.

[F] 2702.2 Where required.
Emergency and standby power systems shall be provided where required by Sections 2702.2.1 through 2702.2.18.

 

[mark handler]

 

[Yikes]

View attachment 14101

Mark, are you saying that because ABA 809.3.1.2 refers back to NFPA 72, and because (per mtlogcabin in post #8) NFPA 72 29.6.5 does not require the strobe to be on battery backup, then 809.3.1.2 does not require battery backup for the strobe?
Also, can you provide a link to the ABA? I notice that 809.3.1.2 is not the same ref. numbering system as the 2010 ADAS.

 

[arwat23]

Mark, are you saying that because ABA 809.3.1.2 refers back to NFPA 72, and because (per mtlogcabin in post #8) NFPA 72 29.6.5 does not require the strobe to be on battery backup, then 809.3.1.2 does not require battery backup for the strobe?

ADAS has similar language. For example, see 2010 ADAS 809.5.2 and 702.1 that reference NFPA 72. However, I don't see those ABA exceptions in ADAS.

I'm pretty sure the ABA wouldn't be applicable here unless the project has federal funds and/or falls under the jurisdiction of HUD, GSA, DOD, or USPS.

 

[Yikes]

ADAS has similar language. For example, see 2010 ADAS 809.5.2 and 702.1 that reference NFPA 72. However, I don't see those ABA exceptions in ADAS.

I'm pretty sure the ABA wouldn't be applicable here unless the project has federal funds and/or falls under the jurisdiction of HUD, GSA, DOD, or USPS.

I do a lot of tax credit projects. The California DSA has determined that 2010 ADAS applies.
https://www.dgs.ca.gov/-/media/Divi...access/ch_11B/DSA_Public_Housing_Guidance.pdf



No mention of 504/UFAS in line 10, but I think the "N/A" really means I need to achieve 504 compliance via the Deeming Notice (with its exceptions) and the 2010 ADAS.

 

[Yankee Chronicler]

I had one FM that would do all of his fire alarm tests with the power off and you can do egress lighting at the same time.....Miss that guy.....

That's the way the State Building Inspector and State Fire Marshal do their tests. They also do them at night, with a light meter, to verify that the emergency lighting actually puts the required illumination on ALL portions of the means of egress.

 

[Yikes]

View attachment 14101

OK, so here's what I've found. When projects have federal funding to comply with UFAS, then ABA 809.3.1.2 applies - - but the ABA website says HUD did not adopt ABA.
We typically use the "HUD deeming notice" to utilize 2010 ADAS in lieu of UFAS, and under that scenario HUD still has 11 exceptions where we need to follow UFAS. Exception #11 covers this very issue:




The narrative explanation further states:
Visible Alarms – Exception to Section 215.1 of the 2010 Standards

[2010ADAS] Section 215.1 includes a new exception for visible alarms in the alteration of existing facilities, providing that visible alarms must be installed only when an existing fire alarm system is upgraded or replaced, or a new fire alarm system is installed. Under this exception, visible alarms would not be required as part of alterations unless the alarm system is upgraded, replaced, or newly installed. HUD is not permitting use of this exception because its application may result in less accessibility than is currently required under HUD’s Section 504 regulation. Instead, recipients engaged in alterations must refer to HUD’s regulation at 24 CFR §§ 8.22, 8.23, 8.24, and 8.25 to determine whether visible alarms must be installed. For recipients engaged in substantial alterations, the new construction requirements apply (with the exception that building alterations are not required that have little likelihood of being accomplished without removing or altering a load-bearing structural member) and visible alarms would be included in the alterations. For recipients engaged in other alterations not rising to the level of substantial alterations, any alterations (including alterations to dwelling units, common areas, or parts of facilities that affect accessibility of existing housing facilities) must, to the maximum extent feasible, be made to be readily accessible to and usable by individuals with disabilities. “To the maximum extent feasible” means recipients are not required to make alterations if doing so would impose undue financial and administrative burdens on the operation of the multifamily housing project, but must provide for accessibility up to the point of undue financial and administrative burdens. This is a high threshold to meet. Therefore, HUD recipients must continue to comply with the provisions in HUD’s Section 504 regulation, and not utilize the exception in the 2010 Standards. If visible alarms are not provided, there must be an effective means of alerting individuals who are deaf or hard of hearing to fires and other emergencies in order to afford them an equal opportunity to evacuate to safety.​

So HUD is acknowledging that 2010 ADAS does not require smoke detectors to have visible alarms. But that last sentence "...and other emergencies..." seems to leave vulnerability if we don't have visible smoke alarms.

4.1.2 ACCESSIBLE BUILDINGS: NEW CONSTRUCTION.​

Accessible buildings and facilities shall meet the following minimum requirements:
(13) If emergency warning systems are provided, then they shall include both audible alarms complying with 4.28.2 and visual alarms complying with 4.28.3. In facilities with sleeping accommodations, the sleeping accommodations shall have an alarm system complying with 4.28.4. Emergency warning systems in health care facilities may be modified to suit standard health care alarm design practice.

 

[mark handler]

Mark, are you saying that because ABA 809.3.1.2 refers back to NFPA 72, and because (per mtlogcabin in post #8) NFPA 72 29.6.5 does not require the strobe to be on battery backup, then 809.3.1.2 does not require battery backup for the strobe?
Also, can you provide a link to the ABA? I notice that 809.3.1.2 is not the same ref. numbering system as the 2010 ADAS.

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