Review Process for Instructional Facilities
When performing work that is considered construction, remodeling, or an addition to a State-regulated instructional facility, plans and specifications must be submitted to the State of Michigan Bureau of Fire Services (MBFS) in accordance with this guideline.
The guideline is intended to outline basic requirements and to show how the plan review and inspection process is handled at the University, including interaction between the University and MBFS. The guideline is NOT intended to provide specific requirements for construction of buildings or installation of required life safety systems or equipment. All work must be performed in accordance with the MBFS Administrative Rules for New and Existing School, College and University Fire Safety, the Codes and Standards that are referenced by the Administrative Rules, and any other applicable law, rule, code, or standard.
Plan review submittals to MBFS must be coordinated through Ms. Jacquline Jeffery in the University’s AEC Department. Copies of all plans and specifications that are sent to MBFS must also be sent to OSEH Fire Safety Services for review.
- Determine Applicability
- Plan Submittal
AEC maintains a list of buildings which contain instructional occupancies. The list can be found at the end of the “Codes and Regulatory Agencies” document published on the AEC website. However, please bear in mind that the list of instructional facilities contained in the Design Guideline may not be complete, and that the actual use of the building or space must govern the plan review submittal process. Designers should consult the list as standard practice, but must validate the data before proceeding with the project. If any discrepancies are discovered, they should be brought to the attention of Ms. Jacquline Jeffery.
If it is determined that a building or space contains an MBFS-regulated instructional occupancy, it must then be determined if the scope of work will require a plan review submittal. MBFS requires that plans and specifications be submitted for any project involving construction, remodeling, or an addition to the building. Submittals are NOT required for work that is limited to maintenance functions or cosmetic remodeling.
"Remodeling" is defined as an alteration or change of a fire-rated assembly, or the installation of new equipment required by the MBFS Administrate Rules.
"Cosmetic Remodeling" is defined as surface changes solely to the wall, floor, and ceiling that do not decrease the fire rating of the wall, floor, or ceiling, including the replacement of windows and doors.
"Maintenance" is defined as repair required to keep a building and its component parts in an operative condition at all times, including the replacement of its component parts when, for any reason, the component parts are no longer dependable. "Maintenance" does not include remodeling.
Note: If you have determined that the scope of work for your project involves ONLY "cosmetic remodeling" or "maintenance functions," a submittal to MBFS is not required. However, a submittal to OSEH Fire Safety Services may still be required, in accordance with the Fire Safety Review Process for Non-Regulated Facilities and Projects Outside the Scope of MBFS Review.
If you have determined that the scope of work for your project involves construction, remodeling, or an addition, plans and specifications must be submitted to MBFS. Plan review submittals must contain ALL of the following, if they are applicable to the scope of work being performed:
- A complete floor plan and layout of the building drawn accurately to scale.
- The use of each room.
- The dimensions of each room.
- The size, location, direction of swing, and fire rating of each door and frame assembly.
- The size and location of windows.
- The wall construction, including the fire-resistance rating.
- The type of construction as identified in national fire protection association pamphlet no. 220, 1995 edition, entitled "Standard on Types of Building Construction."
- The number of stories, including basement and attic areas.
- The interior finish classification.
- The location of fuel-fired equipment.
- The type of furnace and water heater.
- Air-handling systems.
- Fire detection and alarm systems.
- Sprinkler or other suppression systems.
- The type, size, and location of fire extinguishers.
- Other pertinent information that is required to determine compliance with the BFS Administrative Rules.
ONLY the information that is applicable to your project is required. For example, if the project does not involve altering or replacing a furnace or air handling equipment during the renovation of an office suite in an existing building, it IS NOT necessary to submit information regarding the furnace or air handling equipment, even though these items are listed above.
Note: Plans for work involving the practice of architecture or engineering must be sealed by a registered architect or engineer, if the contemplated total expenditure for the project exceeds $15,000. If the contemplated total expenditure is less than $15,000, plans and specifications must still be submitted for review, but they are not required to be sealed.
Also note that special rules apply to construction, renovation, and additions that affect fire alarm systems, fire suppression systems, the outside configuration of the building, and installation or modification of electrical equipment or wiring. More information regarding these rules, and required submittals, are below.
- Construction barriers and means of egress during construction:
The MBFS Administrative Rules for New and Existing School, College and University Fire Safety provide for the following:
1-3.11.1. A person may occupy a building or portion of a building during construction, repair, alterations, or additions only if all means of egress and all fire protection features in the building and on-site are in place and continuously maintained for the part occupied and if the occupied portion is separated from the part under construction by a wall that has a 1-hour-fire-resistance rating. The temporary 1-hour-rated wall that is used for separation may be constructed of combustible material. Instead of having all means of egress and fire protection features in place, the school, college, university, or designated representative may take other measures that would provide equivalent safety if approved by the office of fire safety.
You may refer to the OSEH Fire Safety Services Guideline for Construction Barrier Requirements for further information. Any questions regarding the location of construction barriers or means of egress must be addressed prior to beginning work on the project. If requested, OSEH Fire Safety Services will coordinate an on-site review with a representative from the MBFS.
- Change of occupancy:
This guideline is intended to be used in renovation projects taking place in buildings with existing instructional occupancies. If your renovation project involves creating classroom or instructional laboratory space in a building that does not contain these occupancies already, the MBFS will review the ENTIRE building as if it were new construction. Their review WILL NOT be limited to the renovated area, and a complete set of plans for the building will have to be submitted, demonstrating that the entire facility is in compliance with the applicable codes and standards. Prior to beginning a project that will involve converting an existing, non-instructional building to instructional use, AEC, as well as OSEH Fire Safety Services, must be consulted.
- Separation of occupancies:
The MBFS Administrative Rules for New and Existing School, College and University Fire Safety provide for the following:
27-1.2.1. If other types of occupancies occur in the same building that houses an educational occupancy, then either of the following provisions shall apply:
(a) The college, university, or designated representative shall ensure that the mixed occupancies are completely separated, both horizontally and vertically, by fire separation walls or floor ceiling assemblies, or both. The wall and assemblies shall have a minimum 2-hour-fire-resistance-rating.
(b) The college, university, or designated representative shall apply the provisions of the code for the more restrictive of the separate occupancies to the entire facility in compliance with section 4-1.12 of the code.
In some cases, a construction or remodeling project will affect only a portion of a building that is separated from the instructional occupancy. If it has been confirmed that the construction area is not going to be used for instructional purposes, and is completely separated from the instructional area of the building by at least 2-hour fire-resistance-rated construction, submission of architectural plans and specifications to MBFS will not be required. The existence of the 2-hour separation will have to be confirmed by the design professional responsible for the project.
However, if the project involves any modification to the building’s fire alarm or fire suppression system, and the fire alarm or suppression system serves both the instructional and non-instructional compartments of the building, MBFS review will be required for these systems. MBFS will generally NOT review the submittal for compliance with code in the non-instructional compartment, but WILL require that the certified firm responsible for the fire alarm or suppression system installation complete an FS-12A form, documenting that the installation in the non-instructional areas will not adversely affect the normal required operation of the system serving the instructional areas.
Note: In all cases, when a project involves renovations to a non-instructional, separated compartment of an instructional building, plans and specifications must be submitted to OSEH Fire Safety Services in accordance with the OSEH Fire Safety Services Fire Safety Review Process for Non-Regulated Facilities and Projects Outside the Scope of MBFS Review.
- Projects that affect the outside configuration of the building:
When a project will affect the outside configuration of an MBFS-regulated instructional building, a site plan and specifications that detail all of the following information, as applicable, must be submitted to MBFS and to the local fire department:
- The available water supply.
- Hydrant locations.
- Vehicle access routes.
- Fire lanes.
The site plan and specifications should be submitted to MBFS along with the other required plans and specifications for the project. The submittal to the local fire department should be made to OSEH Fire Safety Services. Who will coordinate any necessary review with the Ann Arbor Fire Department, or other local fire department for projects outside the City of Ann Arbor.
Projects involving fire alarm systems and/or fire suppression systems:
When a project involves installation of new fire alarm devices, installation of new fire suppression system(s), or modifications to existing fire alarm or suppression systems, complete shop drawings for the affected system(s) must be submitted to MBFS. MBFS requires that these drawings be prepared by a certified firm, in accordance with the requirements of the State of Michigan Fire Prevention Code. The University of Michigan Plant Department Fire Protection Shop is a State-certified firm, and can prepare the necessary drawings. If outside contractors are used for this work, they must be certified, and they are responsible for submitting shop drawings to MBFS. In either case, copies of the shop drawings must also be submitted to OSEH Fire Safety Services and Factory Mutual.
Projects involving electrical work:
MBFS requires that any electrical wiring and equipment installed in instructional buildings be in compliance with the Michigan Electrical Code. This includes the Code’s requirements for electrical inspections and issuance of an electrical inspection certificate. The electrical inspection certificate must be issued by an inspection authority that has been found to be acceptable by MBFS. In the case of the University, the Code Inspection Group in AEC is considered to be an acceptable inspection authority. All electrical work requiring an electrical code inspection must be inspected by an AEC Electrical Inspector, and a copy of their Final Electrical Inspection Certificate must be given to the MBFS Fire Marshal Inspector at the time of the final MBFS inspection.
If a project is limited ONLY to electrical work, it must be submitted to MBFS if the scope of work involves altering a fire rated assembly, or involves a required life safety system. If the project involves only minor work (such as relocating an electrical outlet or installing additional outlets in an existing room), without altering a fire rated assembly, the project DOES NOT need to be submitted to MBFS for review. However, the project must still be inspected in accordance with established University procedures.
It should also be noted that the Michigan Electrical Code does NOT require electrical construction permits or electrical inspections for certain types of electrical work. If your project consists ONLY of this type of work, it is not necessary to submit plans to MBFS for approval, unless the work will involve altering a fire rated assembly (such as a rated wall, ceiling, or floor). The following types of electrical work DO NOT require permits in accordance with the Michigan Electrical Code:
- Minor repair work, which is defined as "electrical wiring not in excess of a valuation of $100."
- The installation, alteration, repairing, rebuilding, or remodeling of elevators, dumbwaiters, escalators, or man lifts performed under a permit issued by an elevator inspection agency of the state of Michigan or political subdivision of the state of Michigan.
- The installation, alteration, or repair of electrical equipment and its associated wiring installed on the premises of consumers or subscribers by or for electrical energy supply or communication agencies for use by such agencies in the generation, transmission, distribution, or metering of electrical energy or for the operation of signals or transmission of intelligence.
- The installation, alteration, or repair of electric wiring for the generation and primary distribution of electric current, or the secondary distribution system up to and including the meters, where such work is an integral part of the system owned and operated by an electric light and power utility in rendering its duly authorized service.
- Any work involved in the manufacture of electric equipment, including the testing and repairing of such manufactured equipment.
- The installation, alteration, or repair of equipment and its associated wiring for the generation or distribution of electric energy for the operation of signals or transmission of intelligence where such work is in connection with a communication system owned or operated by a telephone or telegraph company in rendering its authorized service as a telephone or telegraph company.
- Any work involved in the use, maintenance, operation, dismantling, or reassembling of motion picture and theatrical equipment used in any building with approved facilities for entertainment or educational use and which has the necessary permanent wiring and floor and wall receptacle outlets designed for the proper and safe use of such theatrical equipment, but not including any permanent wiring.
- The installation, maintenance, or servicing of burglar alarm systems within a building or structure.
- The installation, maintenance, or servicing of listed residential and commercial lawn irrigation equipment, except any permanent wired connections exceeding 30 volts.
- The construction, installation, maintenance, repair, and renovation of telecommunications equipment and related systems by a person, firm, or corporation primarily engaged in the telecommunications and related information systems industry. This exemption does not include the construction, installation, maintenance, repair, and renovation of a fire alarm system.
If you are unsure whether your scope of work involves one of the above items, an AEC Electrical Inspector should be consulted.
Other equipment and systems:
The MBFS administrative rules call for certain work to be performed in conformance with specified regulatory requirements. You should be prepared to demonstrate that these requirements have been met, if such documentation is requested by MBFS.
- Equipment which utilizes natural gas and related natural gas piping must be installed in compliance with the provisions of NFPA 54, the National Fuel Gas Code. Natural gas piping and equipment should be inspected by an AEC Mechanical Inspector.
- Elevators, escalators, dumbwaiters, and moving walks must be installed and maintained in accordance with the State of Michigan Elevator Code. Any work related to this equipment should be coordinated with the University of Michigan Plant Department Elevator Shop.