Edwards Heat Detector Recall

[Kevin Meijerink]

Stumbled across this the other day.  These detectors are everywhere.  Wondering the best way to deal with this at this time when systems with these detectors are encountered.

I have not seen anything from CFAA on this giving any notification or direction to technicians.

https://healthycanadians.gc.ca/recall-alert-rappel-avis/hc-sc/2019/70945r-eng.php

[Joseph Gardiner]

Hello Kevin,

I saw this when it came out and this is how i dealt with it. I looked up our local fire safety suppliers in North Bay and forward the hyperlink to them all advising them of the situation. Most of them were not aware. I also asked the OMFPOA administrator to post it on the OMFPOA website.

I think sharing it with your local stakeholders is a good way of handling it.

Joe Gardiner

North Bay

[Kevin Meijerink]

I have engaged a few service providers and they knew nothing of it.

How are you treating this when you inspect a building that has these detectors with accompanying reports indicating “this system is fully functional?”

[Joseph Gardiner]

Because of the seriousness of this.

“Issue: The product may fail to activate, causing users and central monitoring stations to not be alerted to the elevated temperature, in a location, which could lead to the spread of fire.”

“The product is a mechanical heat detector used in specific indoor applications to detect the presence of an elevated temperature.  It does not detect smoke, nor does it contain an audible notification device as part of the assembly.  This product is professionally installed and used as part of a fire detection system, in places where a smoke alarm would be unsuitable.  In residential settings this product is installed in kitchens, attics and garages for the purpose of property protection, but not life safety.  This detector must be connected to a fire alarm or security panel for monitoring and supervision, as the panel, and not the affected product, drives the connected alarm signals. “

I have not dealt with this type of situation yet. If I did come across this during an inspection and identified there were detectors falling under this recall I would have the building start a documented “fire watch” until the devices were replaced. Unless, they the owner can prove it does not affect life safety which I believe will be hard to attain. If they can justify that it does not affect life safety, provisions in the fire safety plan to elevate emergency procedures could be amended until the affected devices are replaced. You may also consider updating your fire cad system so that attending fire crews are aware of the situation.

Hopefully this helps,

[Al Bastien]

As a service company representative, I want to share a couple of things from this side of the issue.

A heat detector is not a life safety device and they are not intended for the purpose of life safety. They are for the detection of a fire for property protection. Every one of them has clearly labelled on it “This is not a life safety device”. There are only a handful of situations where a heat detector would be deemed to be performing a life safety function. I would point out that Joseph’s quote supports this position. Additionally, it is not every detector that may not operate.

One would be as permitted by the Ontario Building Code in Sentence 3.2.4.12.(7) – Fire detectors are permitted to be installed in lieu of the smoke detectors required by Sentence (5) in Group F occupancies where the smoke detectors may be subjected to false alarms due to the activities in the building.

Another might be in an older building that still has heat detectors installed at the top of the stairwells or elevator shaft as was permitted by the building code of the day.

It also needs to be noted that the service companies cannot write the existence of these devices up as deficiencies. When we are performing an annual inspection under CAN/ULC-S536-04, there is no test or inspection criteria that the device would fail. Bear in mind that the only way to prove the fixed temp portion of a heat detector works is to perform a destructive test. Some of the detectors under the Health Canada alert also have a rate-of-rise detection capability and this is tested annually. The fixed temperature is never tested, but the electrical circuit that the activation shorts is tested annually.

I sit on the CAN/ULC-S500 working groups for S536, S537 and S524 and have submitted a proposal to ammend the standard to reflect recalled devices already. We’ll see where that goes.

15 year lot testing of fixed temp heat detectors is addressed in CAN/ULC-S536, but only in the informative index:

“G2.2 Non-restorable heat detectors may be replaced or tested on an annual lot sampling basis with the initial test following 15 years of service. The results of the initial tests and examination for deterioration will determine the frequency of subsequent tests. Sample sizes of one unit for lots of 20 or less, two units for lots of 21 to 99, and 2% for lots exceeding 99, are recommended as a minimum. Selected samples should be subjected to the Operating Temperature Test detailed in the Standard for Heat Actuated Fire Detectors for Fire Alarm Systems, CAN/ULC-S530. When failures are encountered, the lot sample size should be determined in accordance with normal quality plans.”

Because the statement exists outside the body of the standard (which it has to under Canadian Standards Council requirements and the nature of the statement), it is not required for a service company to perform or a building owner to abide by.

Rather than simply “ordering the detectors out”, I might suggest using the following from an bulletin ULC issued in 2006 (email me if you want a copy):

“The AHJ may enforce some or all portions of the Preface or any informative appendix”

Issue an order that the building owner have lot testing of the devices done (and this would include any and all fixed temps that exist and are not ever tested). For the number that exist in the building, it would likely be cheaper to replace them all then the cost of having ULC or another agent perform the testing.

Suddenly putting nearly every building in Ontario which has these devices on a fire watch for a potential failure of devices that have existed for decades seems a bit extreme for a “maybe it won’t work”. Issue the order to have them tested. It gives them 30 days to decide what to do. That seems like a more balanced approach to me. My opinion only of course.

[John Wilson]

I came across it by chance late October when speaking with a CFAA tech (not from my area) for advice on a situation. I’d also asked OMFPOA to post it but still don’t see it listed on the site.

When considering  the recall, to me it is irrelevant if these devices are there for life safety or property preservation. The F.P.P.A. and Fire Code both speak to fire safety, life safety, damage to property, etc.  I imagine there has to be a proven failure rate to support the recall otherwise the recall wouldn’t exist.  Without going into any specific criteria of S536, it seems to me that the existence of the recall would be in contravention of 1.1.1.2.(3) and an easy Order to repair or replace.

I fail to see how the lot testing parameters are applicable when the recall exists – that makes sense in absence of the recall.

I do agree that a fire watch may be a bit excessive but that would be site specific. What other detection components exist in the building? What’s the risk of the occupancy? I’d be inclined to go with the 30 day Order.

It’s rather surprising that considering the magnitude of this that there hasn’t been any official word from OFM.

[Al Bastien]

I agree Jon, that the FPPA and the Fire Code may address the issue. That is exactly why I made the statements I did.

There was a question posed as to what the technicians and service companies were doing about it. There is nothing in the Standard that the device fails, so we can do nothing.

Enforcement as you know falls to the AHJ. The requirements of the Fire Code can’t be applied by a technician or a service provider.

I’m all for the AHJ forcing the device out of a building if they have a concern. I do however question one part of how you would apply 1.1.1.2.(3). It states

“(3) Any appliance, device or component of a device that does not operate or appear to operate as intended when checked, inspected or tested as required by this Code shall be repaired or replaced if the failure or malfunctioning of the appliance, device or component would adversely affect fire or life safety.”

You can’t test if it operates because it would be a destructive test. You can’t look at it and state that it does not appear that it would operate as intended because not all of them would fail the destructive test. The ones that pass and the ones that fail the destructive test look identical. If as the AHJ you feel it would stick if appealed – you’ve got my vote – Write the order. The AHJs are the only ones who can force the building owner to remove these devices.

As to the failure rate, my understanding is that because a few tests of the devices (as ordered by an AHJ who wanted to enforce the appendix in CAN/ULC-S536) indicated that some didn’t activate, it prompted the requirement to notify Health Canada and the recall was issued. My understanding is also that this failure was self reported by the manufacturer to Health Canada.

[John Wilson]

I would say that the recall would be sufficient proof of “…does not operate or appear to operate as intended…” even without testing the unit or visibly being able to see that it is defective.

[Kevin Meijerink]

I was fortunate to run into an Edwards technician.  They are documenting these detectors when they find them as a deficiency and indicating the same on the cover page of the fire alarm report.

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