SCHOOL DRILLS AND FIRE SAFETY DURING COVID-19 PANDEMIC
FREQUENTLY ASKED QUESTIONS

BARRIERS -including any type of dividers or partitions used to create separate spaces [See also the “Egress” section of this FAQ for additional discussion regarding barrier requirements.]

Q. What are considered “barriers”?

A. A barrier, for purposes of this discussion, is any type of partition or divider that may be used to create separate areas and/or to separate children or desks or hallways. Many schools are contemplating the use of plastic sheeting, fabric, plexiglass or other products to ‘divide’ or separate desks or workstations or hallways (to allow 2-way traffic while minimizing social interaction) to help prevent the spread of COVID-19. Some of these barriers are being attached to desks or to the floor to extend between desks or are being suspended from the ceiling by various devices. All such partitions and dividers could potentially implicate fire safety.

Q. Does the Ohio Fire Code apply to barriers to be used in schools to help prevent the spread of COVID-19?

A. Yes. The Ohio Fire Code applies to any barrier, including plexiglass, plastic sheeting, drapery, etc. and to any piping, hangers or fasteners, that may be used in schools to help separate children and/or staff.
Such items cannot interfere with, impede or block the operation of fire suppression systems, smoke alarms, or fire alarm systems.
Such items also cannot interfere with, impede or obstruct established egress pathways or exit routes from the building – or visibility thereto.
          Note: reduced and rearranged seating configurations may affect adequacy of egress pathways and mitigate some concerns.
Finally, all materials used must also meet flame propagation performance criteria or exhibit a maximum rate of heat release, and must not exceed applicable flame spread indices.
          Note: Decreased occupant load may affect requirements and potentially mitigate some concerns.

Q. Are barriers “allowed” under the Ohio Fire Code?

A. Maybe. Barriers may generally be allowed under the Ohio Fire Code, but there are some limitations on what materials may be used and some limitations on where and how such barriers can be installed.
When selecting materials to be used, officials should choose materials that have appropriate flame-retardant properties. In addition, barriers must be installed in such a way that they do not block, impede or in any manner alter the function and operation of smoke alarms or fire detectors. They also cannot impede egress or exit pathways.

Q. Is there a limit to how much drapery and fabric can be used to create barriers?

A. Yes. Drapery and fabric used to separate individuals or groups that is suspended from walls or ceilings must not exceed 10% of the wall or ceiling area where they are located.

Q. Can I attach barriers – or rods or piping or hangars for such – to the ceiling or suspend them from the ceiling?

A. Generally, no. Items hung from the ceiling typically interfere with fire suppression equipment and are not allowed. However, if the suspension of items from the ceiling does not in any manner compromise or hinder the efficiency or performance of smoke detectors, sprinkler heads and/or other fire protection equipment it may be allowed but would need to be approved by the building code official. In addition, any drapery or fabric that is suspended from walls or ceilings must not exceed 10% of the wall or ceiling area where they are located.

Q. Do I have to submit plans to the building or fire code official before installing any barriers, dividers or partitions?

A. Generally, no; most public health-related modifications to schools won’t trigger the need for the submission and approval of building plans to the building or fire code official. However, some modifications may require approval (such as suspending items from the ceiling). Therefore, school officials are strongly encouraged to consult with their building and fire code officials prior to installing any new devices to ensure that they do not inadvertently create fire and safety hazards or violations of Ohio Building Code or Ohio Fire Code requirements.

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FIRE DRILLS

Q. Are schools required to do fire drills during the COVID-19 pandemic?

A. Yes. Fire drills are not only still required during the pandemic, they are more important than ever. Many things will be different in the 2020-2021 school year, including that altered pathways may be used by schools, such as one way traffic in certain hallways, different class sizes, the use of dividers or partitions, changed designated meeting points for classes due to social distancing requirements, and a potentially high volume of substitute teachers. Therefore, it is more important than ever to instruct students and staff in the safest means to evacuate school buildings even in the midst of all the other changes they may face.

Q. Why are fire drills required?

A. Fire drills are required to ensure that all students and staff know the correct procedures to follow in the event of an actual fire-related emergency.
Drills offer an opportunity to evaluate the efficiency of emergency evacuation plans and procedures and to make any necessary adjustments. The best way to evaluate preparedness is to mimic evacuation as closely as possible to an actual event.

Q. How many fire drills are required each school year?

A. It depends. If a school has either smoke detectors or a sprinkler system in all classroom buildings at least six (6) fire drills must be conducted each school year.
If a school does not have either smoke detectors or a sprinkler system in all classroom buildings at least nine (9) fire drills must be conducted each school year.

Q. How often do fire drills have to be conducted?

A. At least one fire drill must be conducted during each month of the school year.

Q. When does the first fire drill of the school year have to be conducted?

A. The first fire drill of each school year must be conducted within ten (10) days of the beginning of classes.

Q. If my school is going to have a bifurcated or split schedule, are fire drills required for each “shift” of students?

A. Yes. If students and/or teachers attend in “shifts” (e.g., some students attending 2 or 3 days a week and other students attending the other 3 or 2 days a week) each “shift” of students must participate in the required number of drills (6 if the school has either smoke detectors or a sprinkler system in all classroom buildings; 9 if the school does not have either smoke detectors or a sprinkler system in all classroom buildings).

Q. If schools are operating on a split shift and students and/or staff will be on-campus less time, why are the standard number of fire drills required for each shift?

A. Because of the many other changes and alterations that are occurring in response to the pandemic, it is important to maintain the required number of fire drills for all students and staff even if – or especially if – some may physically be on campus less time during the school year due to split schedules. Students and staff who will spend less time in buildings will therefore potentially be less familiar with their surroundings. In addition, and even if building familiarity is not an issue for some building occupants, responses to the COVID-19 pandemic are necessitating other alterations to school settings that will likely hinder the ‘normal’ conducting of fire drills. These can include the installation of barriers or partitions, changes to previously existing egress pathways, altered hallway traffic patterns, the potential necessary utilization of substitute teachers who will be less familiar with the settings and protocols for drills, social distancing and or masking procedures, and the establishment of socially distanced meeting places. Therefore, maintaining the required number of fire drills for all students and staff is especially important during this period of pandemic.

Q. Who has to participate in fire drills?

A. All building occupants must participate in each fire drill, including all students, staff, faculty and visitors present when the drill occurs.

Q. Do school officials have to ensure that remote students (those participating in distance learning or on-line learning from an off-campus location) participate in fire drills?

A. No. School officials are not responsible for conducting fire drills for those students who participate solely in on-line or distance learning from their homes or other locations not on school property.
The purpose of conducting fire drills is to ensure that in the event of an actual fire-related emergency at a school building, all staff and students will know how to evacuate the school building(s) in the shortest possible time and without confusion. Those students who will not attend classes on-campus at school buildings do not have to participate in fire drills. However, if students are going to be on-campus for some of their learning, they will have to participate in any drill that occurs while they are present on-campus.

Q. Are face coverings required during fire drills?

A. The Ohio Fire Code does not require the use of face masks or shields during fire drills. However, the Ohio Department of Health (ODH) has issued orders that require all students, faculty and staff in any K-12 educational facility to wear face coverings. To view that order, click here: ODH Order.

Q. If school officials conduct fire drills could they be in trouble for not following social distancing guidelines?

A. No. The Ohio Department of Health’s (ODH) COVID-19 Health and Prevention Guidance for Ohio K-12 Schools” (ODH Guidance) states that schools should “reduce the mixing of student groups” and “try when possible” to maintain social distancing. However, it is acknowledged that social distancing may not always be possible. To view that guidance document, click here: ODH Guidance; see pp. 12-13. In the case of fire drills, if it is possible to conduct the drills and maintain social distancing, school officials are encouraged to do so. However, if it is not possible, individual classes should be kept together as normal but be distanced from other classes as much as possible. In addition, face coverings should be utilized.

Q. Are school officials required to make changes to the way their school conducts fire drills due to the pandemic?

A. The Ohio Fire Code does not require any fire drill changes in response to the COVID-19 pandemic. However, schools may need to make changes to accommodate health orders. This may include: changing the location of meeting point designations so that each student class or group can be located a safe distance from buildings as well as from other groups or classes while awaiting completion of the drill; egress pathways or exit routes may need to be altered to accommodate social distancing or to create one-way traffic patterns. In these instances, school officials should work with their local fire code officials to make sure that egress pathways are adequate for building evacuation and compliant with Ohio Fire Code requirements.

Q. Will school officials still be required to submit fire drill reports?

A. Yes. The person responsible for conducting fire drills must submit a copy of their fire drill records to the Ohio Department of Commerce, Division of State Fire Marshal at the middle point and again at the end of each school year.

Q. What fire drill reports have to be submitted and where do they have to be sent?

A. The Ohio Department of Commerce, Division of State Fire Marshal (SFM) has a form on its website that can be used for reporting fire drills. To ensure that all required information is submitted, the SFM’s form is recommended; however, it is not required that school officials specifically use the SFM’s form. Schools can use whatever form they choose, but all required information – as set forth on the SFM’s form – must be included in whatever documentation is submitted. The SFM’s form can be found at the following link: Fire Drill Reporting Form and should be submitted to the SFM’s Code Enforcement Bureau via sfm_codeenf@com.state.oh.us or fax (614-728-5168).

Q. Are fire drills required if a school begins in-person classes and then switches to an on-line format or vice versa?

A. Schools are only required to conduct fire drills – and report such – for months when school is in session and students are in attendance at the school. Therefore, if no students are “attending” classes at the school, drills will not have to be conducted.
For example, if a school begins in-person classes and conducts classes for August, September and October and then switches to an on-line only format for November and December, the school must conduct fire drills for August, September and October, but not for November or December.
Conversely, if a school conducts on-line learning only for the first semester and does not being in-person classes until January, no fire drills would be required for August, September, October, November or December. But fire drills would be required beginning in January (the first one being done within the first 10 days of the start of the in-person January classes) and then monthly thereafter.

Q. How should drill reporting be done if a school delays in-person classes and begins the year with on-line only classes – or if a school begins with in-person classes and later switches to an on-line format?

A. If a school begins classes – virtually or in-person – on Sept. 15, that date should be listed as the “First Day of School.” However, in the actual reporting of the date and time of a particular fire drill for a particular month, the report should include an indication of what actually happened for that month.
For example, if in-person classes were conducted in September a fire drill should be done and the date and time of the fire drill for the month of September should be indicated as it normally would be for that month. If only on-line or virtual classes were conducted during the month of September, then for the month of September the form should indicate something to the effect of “no in-person classes” or “virtual learning only.”

Q. As a fire code official, should I insist that all egress pathways in school buildings remain exactly the same or can they be altered to accommodate social distancing?

A. If egress pathways can be altered and still remain adequate for building evacuation, suggested changes may be considered to accommodate social distancing. In addition, since school attendance may be drastically reduced, changes to previously existing egress pathways may be acceptable. Each situation will have to be considered on a case-by-case basis given all the many variables that must be considered.

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TORNADO DRILLS

Q. Are schools required to do tornado drills during the COVID-19 pandemic?

A. Tornado drills are required during ‘tornado season’ which is from April 1 to July 31 of each year.

Q. How many tornado drills are schools required to do?

A. At least one tornado drill must be conducted during each month of ‘tornado season’ which is from April 1 to July 31 of each year.

Q. How often do tornado drills have to be conducted?

A. Tornado drills only have to be conducted during ‘tornado season.’ However, during tornado season (April 1 – July 31), at least one tornado drill must be conducted each month.

Q. Who has to participate in tornado drills?

A. All building occupants must participate in tornado drills, including all students, staff, faculty and visitors present when the drill occurs.

Q. Do school officials have to ensure that remote students (those that are participating in distance learning or on-line learning from an off-campus location) participate in tornado drills?

A. No. School officials are not responsible for conducting tornado drills for those students who participate solely in on-line or distance learning from their homes or other locations not on school property.
The purpose of conducting tornado drills is to ensure that in the event of an actual tornado, all students and staff will know where designated tornado shelter areas are located and how to proceed to those locations in a quick and orderly fashion. Those students who will not attend classes on-campus at school buildings do not have to participate in tornado drills. However, if students are going to be on-campus for some of their learning, they will have to participate in any drill that occurs while they are present on-campus.

Q. If my school is going to have a bifurcated or split schedule, are tornado drills required for each “shift” of students?

A. Yes. If students and/or teachers attend in “shifts” (e.g., some students attending two or three days a week and other students attending the other three or two days a week) each “shift” of students must participate in one tornado drill each month during the months of April, May, June and July.

Q. If schools are operating on a split shift and students and/or staff will be on-campus less time, why are the standard number of tornado drills required for each shift?

A. As with fire drills and because of the many other changes and alterations occurring in response to the pandemic, it is important to maintain the required number of tornado drills for all students and staff even if – or especially if – some may physically be on campus less time during the school year due to split scheduling. Students and staff who will spend less time in buildings will therefore potentially be less familiar with their surroundings. In addition, and even if building familiarity is not an issue for some building occupants, responses to the COVID-19 pandemic are necessitating other alterations to school settings that will likely hinder the ‘normal’ conducting of tornado drills. These can include the installation of barriers or partitions, changes to previously existing pathways, altered hallway traffic patterns, the potential necessary utilization of substitute teachers who will be less familiar with the settings and protocols for drills, social distancing and or masking procedures, and the potential establishment of socially distanced meeting places (if possible within the confines of designated shelter areas). Therefore, maintaining the required number of tornado drills for all students and staff is especially important during this period of pandemic.

Are face coverings required during tornado drills?

A. The Ohio Fire Code does not require the use of face masks or face shields during tornado drills. However, the Ohio Department of Health (ODH) has issued orders that require all students, faculty and staff in any K-12 educational facility to wear face coverings. To view that order, click here: ODH Order.

Q. If school officials conduct tornado drills, could they be in trouble for not following social distancing guidelines?

A. No. The Ohio Department of Health’s (ODH) COVID-19 Health and Prevention Guidance for Ohio K-12 Schools” (ODH Guidance) states that schools should “reduce the mixing of student groups” and “try when possible” to maintain social distancing. However, it is acknowledged that social distancing may not always be possible. To view that guidance document, click here: ODH Guidance; see pp. 12-13. In the case of tornado drills, if it is possible to conduct the drills and maintain social distancing, school officials are encouraged to do so. However, if it is not possible, individual classes should be kept together as normal but be distanced from other classes as much as possible. In addition, face coverings should be utilized.

Q. Are school officials required to make changes to the way their school conducts tornado drills?

A. The Ohio Fire Code does not require any tornado drill changes due to the COVID-19 pandemic. However, schools may need to make changes to accommodate health orders. This may include the alteration of travel routes to designated shelter areas to accommodate social distancing, if possible, or to create one-way traffic patterns. School officials should work with their local fire code officials to make sure adequate shelter areas are designated and marked and travel routes to such locations are adequate.

Q. What is the purpose of conducting tornado drills?

A. The purpose of tornado drills is to ensure that in the event of an actual tornado, all students and staff will know what procedures to follow and where designated tornado shelter areas are located.

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EGRESS

Q. Why is egress regulated by the Ohio Fire Code?

A. Maintaining proper egress in all occupied buildings (including schools) is crucial for fire safety. Having established and maintained egress pathways ensures that those pathways will be adequate and readily accessible for all building occupants to safely exit the building in the event of a fire or other emergency.

Q. What does the Ohio Fire Code require regarding egress?

A. The Ohio Fire Code requires adequate egress be maintained from all areas of all school buildings, including any separate waiting spaces that are designated for individuals with COVID-19 related symptoms.
All areas should have designated evacuation routes and those routes must remain clear at all times.

Q. Is it a violation of the Ohio Fire Code to put a table and chairs – or other equipment – at school entrances to facilitate the taking of student and staff temperatures upon entry to school buildings?

A. Generally, yes. Main entrances and doorways are a part of established egress pathways and cannot be obstructed or blocked in such a way that would congest the area and prevent exit from the building in the event of an emergency. However, depending on the configuration of a specific school, hallway, door, and the established egress routes, there may be a way of setting up a ‘temperature taking station’ in such a manner egress is not compromised.
Therefore, as school officials configure means and methods to take student and staff temperatures upon entry to school buildings, they must ensure that they are not obstructing egress from the building. Special care should be taken to ensure any table placement or staff/student influx does not impede egress routes and capacities. Local fire officials can assist in determining whether any specific configuration is permissible or needs to be altered to allow for proper egress.
          Note: reduced occupant loads may affect the adequacy of egress pathways and mitigate some concerns.

Q. Can schools establish directional markers or “one-way-traffic” patterns in school hallways?

A. Maybe. Schools can establish such directional markers and “one-way traffic” patterns within schools as long as such patterns and markers are placed and used in such a manner that maintains proper egress.
          Note: reduced and rearranged seating configurations and/or occupant loads may affect the adequacy of egress pathways and mitigate some concerns.

Q. Does the Ohio Fire Code “allow” schools to put barriers in hallways to help prevent the spread of COVID-19?

A. No. But, if the barriers do not impede or alter established egress pathways, are limited in quantity, and are made of appropriate materials that do not increase the ‘fire load’ of the building or area they may be permissible. If such barriers did impede egress (or if they were too numerous or made of improper material or material quantity) they would be prohibited under the Ohio Fire Code.
          Note: reduced and rearranged seating configurations and/or occupant loads may affect the adequacy of egress pathways and mitigate some concerns.

Q. Does the Ohio Fire Code “allow” schools to put barriers around or in between desks to help prevent the spread of COVID-19?

A. No. But if the barriers do not impede or alter established egress pathways, are limited in quantity and are made of appropriate materials that do not increase the ‘fire load’ of the building or area they may be permissible. If such barriers did impede egress (or if they were too numerous or made of improper material or material quantity) they would be prohibited under the Ohio Fire Code.
          Note: reduced and rearranged seating configurations may affect adequacy of egress pathways and mitigate some concerns.

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HAND SANITIZER

Q. Are schools required to provide hand sanitizer?

A. Yes. Although the Ohio Fire Code does not require schools to provide hand sanitizer, guidance issued by the Ohio Department of Health (ODH) states schools must provide hand sanitizer throughout schools in “high traffic areas including entrances and classrooms.” To see ODH’s guidance, click here: ODH Guidance; see p. 8.

Q. Does the Ohio Fire Code have any rules that apply to hand sanitizer in schools?

A. Yes. Several rules in the Ohio Fire Code apply including rules about quantity limitations, storage, and dispenser placement.

Q. Can hand sanitizer dispensing devices be placed in hallways?

A. Yes. The Ohio Fire Code (O.F.C.) does not prevent the placement of hand sanitizer dispensers in hallways. However, the O.F.C. does state that dispensing devices cannot project more than four (4) inches into egress pathways.

Q. Can hand sanitizer dispensing devices be placed anywhere in a school?

A. Generally, yes; however, there are some limitations. For example, if a school has carpeted floors, dispensing devices can only be installed in areas that are equipped throughout with an approved automatic sprinkler system. In addition, if a school elects to place dispensers in hallways, the devices have to be of a kind and placed in such a manner that they do not project more than four (4) inches into egress pathways.

Q. Is there a limit to how much hand sanitizer schools can have on hand at any one time?

A. Yes. Hand sanitizer is a flammable and combustible liquid and as such is subject to maximum quantity limits. Generally, cumulative quantities of all flammable and combustible liquids to be stored (including hand sanitizer) cannot exceed that necessary for demonstration, treatment, laboratory work, maintenance purposes and operation of equipment.
However, at no time can schools store more than 120-gallons of flammable and combustible liquids (including hand sanitizer) at one time.

Q. Does hand sanitizer have to be stored in any particular container or place?

A. Yes. Hand sanitizer is a flammable and combustible liquid and as such is subject to certain storage requirements. Specifically, cumulative quantities of flammable and combustible liquids (including hand sanitizer) that are in excess of 10-gallons (38 L) used for maintenance purposes and the operation of equipment must be stored in liquid storage cabinets.

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FACE COVERINGS / FACE SHIELDS

Q. Are there any rules in the Ohio Fire Code that apply to the type of face coverings that can be used?

A. Not specifically. However, extreme caution should be used when face coverings (whether cloth face masks or plastic face shields) are to be used in settings where an open flame is in use, such as in science labs.
The use of face coverings could present an even bigger hazard due to a risk of catching fire and melting. As with any other clothing in such settings, face coverings should not be placed over or near an open flame source and should not be hanging loose. The use of open flames while face coverings are being worn should be limited and closely supervised to ensure that such coverings are kept an appropriate distance from all flame sources.

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RESOURCES

Q. What resources are available from the State Fire Marshal to help school officials incorporate COVID-19 related safety protocols into the operation of their facilities for the upcoming school year?

A. School officials are encouraged to contact their local fire code officials who can work with them to institute policies and practices that implement necessary distancing, safety and sanitization protocols to help protect from pandemic related concerns without compromising fire safety.
In addition, and if needed, inspectors from the State Fire Marshal’s Code Enforcement Bureau can assist school and fire officials in creating plans, procedures and solutions that accomplish both health and fire safety goals. The Code Enforcement Bureau can be reached via phone at: 614-728-5460 (or toll free at 888-276-0303) or e-mail at: sfm_codeenf@com.state.oh.us.