What’s Happening?
On Monday April 19th at 10:00 am, the San Francisco Fire Department will hold a public hearing on proposed modifications to Fire Department Administrative Bulletin 2.11 – Submittal Guidelines for Emergency Evacuation Signs. The stated purpose of the hearing is for the Department to receive public comment on proposed revisions to Administrative Bulletin 2.11. The Department anticipates presenting the proposed amendments to the Fire Commission at its regular meeting on Thursday, April 22, 2010 at 6:00 p.m. Final action on the Bulletin is expected to be presented at the Fire Commission meeting on Thursday, May 13, 2010 at 6:00 p.m.
The Current and Proposed Bulletin 2.11
If you are interested in the details, I have prepared a comparison document (named “Comparison Document”) from the two versions as provided which can be downloaded from the
Lightner Property Group web site public library. (Site registration is not required for download, but you will be allowed access to additional site features and resources if you do take the time to register.)
Comments or Suggestions?
Interested members of the public may attend the hearing, to be held at the Fire Commission Room, the Fire Department Headquarters at 698 Second Street at Townsend, San Francisco.
Interestingly, the current Administrative bulletin was adopted only late last year and the new proposed revisions are in response to State modifications to Title 19, which have not yet been finalized and are not expected to be finalized until sometime later this year.
Modifications Premature?
This means San Francisco would be adopting modifications to its Administrative Bulletin, based upon proposed modifications to State rules that are still subject to change and have yet to be adopted. (from the San Francisco Fire Department web site: “These guidelines are modeled after the draft revisions to Title 19, Section 3.09 that have been generated by a committee convened by the California State Fire Marshal’s office, and are expected to be finalized over the next year.” http://38.106.4.187/index.aspx?page=989 ) Sadly, as of this writing it was not possible to track down the State’s proposed regulation changes because the link provided by the State Fire Marshall web site was a dead link resulting in a 404 error message.
If this process does not sound just a bit premature or like a waste of taxpayer time and money, then please read the prior paragraph again. Regardless of what you think of the proposed changes, why would anyone make changes, spend time, money and resources to comply with something that has not yet occurred and may dramatically change in the approval process is mind boggling. It is - simply stated - a waste of our precious governmental resources, at a time when the City has no business wasting anything; not even a pencil.
What is particularly troubling is that the proposed guideline modifications include substantial changes to the building emergency exit signage requirement. The change would require that only 5 months after making signage changes to comply with the current Bulletin 2.11 requirements, a property owner would be faced with changing their signage again. Perhaps not surprisingly, the new change could result in “net positive” review and permitting fee revenue to the City.
Finally, residential buildings are also regulated by the signage and notification requirements found in California Health and Safety Code Section 13220(c). Whether there could or would be conflicts, confusions, redundancies or just plain errors is entirely possible given we are working with a State proposal that is still subject to change and modification.
Submit your Comments or Suggestions
Interested members of the public are strongly encouraged to submit their comments, opinions, or points of view by attending the hearing or, if you don’t have time due to scheduling conflicts, submit your comments no later than 5:00 pm April 19th, by email or physical delivery to:
San Francisco Fire Department
Office of the Fire Marshal
698 Second Street, Room 109
San Francisco, CA 94107
If you are a property owner or manager, please weigh in on this issue, if only to point out that the actions of the Department are premature and ill conceived at this point in time.
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