OPSI - UNENACTED working proposal

v308 | 2026-10-28T08:16:26+00:00 | Corpus 85

DRAFT REGULATION

REGULATION RESPECTING PROFESSIONAL ACTIVITIES AND STANDARDS OF PRACTICE IN FIRE SAFETY

I - APPLICATION OF TECHNICAL REQUIREMENTS

Section 1 | ART_0SH9GWZKADU9WXFU | Version 3

This regulation is made by the board of directors under section 33 of the Act, examined by the Office and approved by the Government under section 95 of the Professional Code.

This Regulation does not make any code, technical standard or other technical document applicable.

A code, standard or other technical document, including NFPA 25, NFPA 10 or CAN/ULC-S536, applies only to the extent that it is made legally applicable to the case concerned, directly or indirectly, through the relevant chain of references.

Purely illustrative examples of technical references that may apply where legally incorporated include CAN/ULC-S536, CAN/ULC-S537 and CAN/ULC-S1001 for fire alarm systems and integrated testing, as well as NFPA references addressing acceptance tests, suppression systems and their inspection and maintenance. This open-ended list makes no edition, standard or intervention mandatory.

Section 2 | ART_YPKDCS65LTPPNRJD | Version 2

The member identifies in the report the applicable requirement on which the intervention is based.

Where that requirement results from one or more references, the member sufficiently identifies the chain of references needed to determine the code, technical standard or other technical document actually applicable to the case concerned.

II - INSPECTION AND TESTING

Section 3 | ART_BG3Y0KDTZSWXYKHN | Version 2

Where an inspection or test referred to in section 8 of the Act is performed, the report must indicate, in particular:

1° the purpose and scope of the intervention;

2° the system, installation, equipment, appliance or device concerned;

3° the applicable requirement;

4° the methods used;

5° the operations carried out;

6° the results;

7° the limitations;

8° the non-compliances identified, under a separate heading;

9° any apparent anomalies recorded, under a separate heading;

10° the date;

11° the identity of the responsible professional.

Where an element the applicable requirement required to be verified does not meet that requirement, it is treated as a non-compliance and not as an apparent anomaly.

Using professional judgment, the member may record an apparent anomaly incidentally observed outside the scope of the required verification where it appears capable of affecting a fire-safety function or of warranting further verification.

The member may recommend that further verification be carried out by a legally authorized person.

An apparent anomaly must not be presented as a definitive determination of non-compliance with a design, construction, installation or modification requirement unless the member has sufficient information, the necessary knowledge and competence, and the legal authority required to reach that conclusion.

The report contains a statement substantially equivalent to the following: “Apparent anomalies recorded in the report do not constitute an exhaustive verification of the compliance of the design, construction or installation. The absence of an apparent anomaly concerning an element does not mean that the element was verified or declared compliant.”

Observations, results and evidence needed to support the report are preserved in the member’s professional record or by an eligible custodian under the records regulation, without requiring duplicate archives.

For an initial verification, acceptance, return to service or integrated tests, the report identifies the scope and legal basis of the intervention; where multiple systems interact, it distinguishes the sequences and results verified, tests not performed, limitations, persons responsible for independent parts and the person assuming responsibility for the overall professional conclusions.

Section 4 | ART_AB9TX3BY9QGURYZU | Version 5

The member may not represent an operation that was not performed as having been performed.

The member clearly distinguishes:

1° what the member personally observed;

2° what was carried out under the member’s supervision;

3° information obtained from a third party.

Ordinary reporting of an apparent anomaly remains discretionary in the absence of serious, objectively grounded reasons to fear a reportable danger. Where a member has such reasons within their competence, even outside a mandate, section 27 of the Act requires a free substantiated report 'requiring verification', or a formal notice if the elements are sufficiently established and the member is legally authorized. Unless the mandate or an applicable requirement otherwise provides, the member is not obliged, merely because of a periodic inspection or test:

1° to actively search for anomalies outside the mandate;

2° to systematically verify the system design;

3° to recalculate spacing, clearances, flows, pressures or capacities;

4° to systematically verify whether all historically required equipment is present;

5° to determine the historical edition of an applicable code or standard;

6° to analyze acquired rights or grandfathered conditions;

7° to reconstruct prior modifications;

8° to search for alternative solutions, equivalent measures or prior approvals;

9° to carry out a general compliance audit of the building or system.

A member who incidentally discovers a sufficiently established reportable danger, or has serious and objectively grounded reasons to fear its existence, even outside a mandate, promptly performs the applicable reporting steps described above and records observed facts, reliable sources, limitations and steps taken. Emergency services or the competent authority are contacted first where immediate danger or another legal duty so requires. This duty requires no search beyond the mandate, whole-building verification, fee-bearing report or conclusion beyond legal authority. Unverified information remains marked as such and does not automatically become confirmed non-compliance.

III - APPROVAL OF FIRE SAFETY PLANS

Section 5 | ART_GJ8DHU5U813A0L1Y | Version 2

Before approving a fire safety plan, the member must sufficiently verify:

1° identification of the building;

2° the occupancy and principal relevant risks;

3° the responsibilities provided for;

4° procedures in the event of fire;

5° evacuation measures;

6° means of communication;

7° relevant information concerning fire safety systems;

8° personnel training needs;

9° required drills;

10° other legally required elements.

Section 6 | ART_LFUDHKLMHCRLZAPQ | Version 2

The member clearly states the scope and limitations of the approval.

IV - DRILLS

Section 7 | ART_B1HVB4NCUC96GJS2 | Version 2

When producing a professional assessment of a drill, the member must distinguish:

1° direct observations;

2° information from the ordinary drill report;

3° the member’s analyses;

4° the member’s conclusions;

5° the member’s recommendations.

V - PROFESSIONAL ATTESTATION OF TRAINING OR COMPETENCE

Section 8 | ART_AMVH2J930YU4NJCB | Version 2

A member may issue a professional attestation only after a sufficient assessment.

Section 9 | ART_XWTGMS4S6UCUFWUA | Version 2

The attestation must indicate:

1° the identity of the person assessed;

2° the competency or training concerned;

3° the scope of the assessment;

4° the assessment methods;

5° the date;

6° any relevant limitation.

Section 10 | ART_DCHESGDCQ66EC5CB | Version 2

The attestation must not suggest that the Order or the member permanently guarantees the future competence of its holder.

VI - NON-RESERVED ACTIVITIES

Section 11 | ART_T3D25P2KTYK6LFS7 | Version 2

This Regulation does not reserve:

1° teaching;

2° training;

3° self-training;

4° ordinary drills;

5° inspections or tests whose mandatory frequency is less than three months;

6° material or preparatory operations;

7° the material drafting of a document that is subsequently submitted for professional approval.

Section 12 | ART_HTF9CQC6BC9NC0WD | Version 2

A member maintains competence throughout practice and keeps knowledge current according to the activities performed and the evolution of applicable requirements, standards, technologies and professional practices.

Continuing-education requirements applicable to members are determined by the Order within the powers conferred by the Act and the Professional Code, without limiting the member’s personal obligation to accept only mandates for which the member has the necessary competence.