INTER-OFFICE MEMORANDUM

To: Assistant State Fire Marshal

From: GSFIC/State ADA Coordinator’s Office

Subject: Technical Assistance for the Georgia Accessibility Code

Date: April 6, 2010

Visual Alarms – Heights and Equivalency of 120-3-20-.08(14) & 120-3-20-.39(3)(f) with NFPA 72 1999 and 2002 Edition

Question:

What is the correct mounting height for visual alarm signal appliances?

Background:

NFPA 72, National Fire Alarm Code, 2002 Edition, Chapter 7, paragraph 7.5.4 states: “Wall-mounted appliances shall be mounted such that the entire lens is not less than 2.0 m (80 in.) and not greater than 2.4 m (96 in.) above the finished floor.” Rules and Regulations of the State Fire Commissioner - The Georgia Accessibility Code (GAC), Section 120-3-20-.39(3)(f) states: The appliance shall be placed 80 inches (2030 mm) above the highest floor level within the space or 6 inches (152 mm) below the ceiling, whichever is lower.”

Answer:

The setting of visual alarm signal appliance at 80” to 96” is permissible as “equivalent facilitation” under [120-3-20(14)(f)]. The basis for this conclusion is as follows: Our Georgia Accessibility Code (GAC) is based on Federal Guidelines as mentioned under 120-3-20-.01 and must meet the minimum requirements of Title II and III of the ADA and the ADA Accessibility Guidelines (ADAAG). The guidelines were developed by the Federal Access Board (U.S. Architectural and Transportation Barriers Compliance Board). Both ADAAG and GAC set forth identical scoping and technical requirements for the accessibility of visual alarm signal appliances. (See ADAAG 4.1.3 (14) & 4.28 & Georgia Accessibility Code 120-3-20-.08(14) &120-3-20-.39). Both ADAAG (section 2.2) and the GAC (section 120-3-20-.04(2) permit “equivalent facilitation” of technical requirements. When applying “equivalent facilitation,” we look to new developments and supplemental guidance provided by the Federal Access Board. The latest information provided by the Federal Access Board posted on the Federal Registry as the “final rule” (awaiting adoption by the U.S. Department of Justice to become the new ADA “standards”) and entitled the Americans with Disability Act and Architectural Barriers Act dated July 23, 2004 reference the guidance provided in NFPA 72 National Fire Alarm Code , 1999 and 2002 Edition (see 702.1 and 809.5.2 – ADAABAAG/final rule). These referenced sections provide that the height of the alarms can be set from 80” to 96”.

TEB/State ADA Coordinator’s Office