Apartment Inspection Program Review

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					                                                       Apartment Inspection Program   1



Running head: APARTMENT INSPECTION PROGRAM REVIEW




                         Apartment Inspection Program Review

                                  Kenneth Chadwick

    Gwinnett County Department of Fire & Emergency Services, Lawrenceville, Georgia
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                                    CERTIFICATON STATEMENT

I hereby certify that this paper constitutes my own product, that where the language of others is

set forth, quotation marks so indicate, and that appropriate credit is given where I have used the

language, idea, expressions, or writings of another.



                                               Signed: __________________________________
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                                             Abstract

In Gwinnett County, since 2008, 6 fire fatalities have occurred in apartments. Causality and

fatality rates from apartment fires in Gwinnett County were twice the national average. During

January, 2010, an apartment inspection program was initiated. The problem was that Gwinnett

County continues having monetary loss and civilian casualties attributed to apartment fires. The

purpose of this research was to determine if the department’s current apartment inspection

program will decrease these losses. Descriptive research was used to answer the 4 research

questions: (a) Under state and local law, what legal restrictions exist in reference to apartment

inspections in Gwinnett County, (b) what procedures do other jurisdictions in Metropolitan

Atlanta follow when conducting apartment inspections, (c) what procedure does Gwinnett

County Fire and Emergency Services follow when conducting apartment inspections, (d) what

are the causes of apartment fire casualties in Gwinnett County? Procedures included interviews

of fire prevention personnel from career departments around Metropolitan Atlanta to provide

insight into regional apartment inspection procedures. Results indicated that state and local code

defines how inspections are completed. Two jurisdictions did not complete inspections, 4 did not

conduct annual inspections, 2 used suppression personnel, and 6 completed annual inspections.

Inspections consisted of life safety inspections of the common areas and excluded occupied

apartments. Results also showed that a majority of apartment fires started inside the dwelling and

cooking was a major contributor. Recommendations included modifying local codes to mandate

sprinkler or stove hood suppression systems, train and allow suppression personnel to perform

apartment inspections, allow access into living units to inspect rated assemblies, provide fire

prevention education to apartment management and tenants, confirm enforcement restrictions in
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structures 2 stories or less, and conduct an impact analysis of the apartment inspection program

bi-annually and benchmark the program to other local jurisdictions.
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                                                          Table of Contents


Abstract ........................................................................................................................................... 3

Table of Contents ............................................................................................................................ 5

Introduction ……………………………………………………………………………………….7

Background and Significance ......................................................................................................... 8

Literature Review.......................................................................................................................... 10

Procedures ..................................................................................................................................... 25

Results ........................................................................................................................................... 29

Discussion ..................................................................................................................................... 37

Recommendations ......................................................................................................................... 50

References ..................................................................................................................................... 52

Appendix A: Results of Inspection Questionnaire........................................................................ 56

Appendix B: Causes of Apartmetn Fires in Gwinnett County ..................................................... 57

Appendix C: Apartment Fire Casualties by Cause ....................................................................... 58

Appendix D: Interview Questions for Metropolitan Atlanta Fire Marshalls ................................ 59

Appendix E: Interview Responses from Metropoltan Atlanta Fire Marshalls ............................. 60

Appendix F: Email from B. Mitchell ............................................................................................ 65

Appendix G: Emails from M. Phillips .......................................................................................... 67

Appendix H: Interview notes with Assistant Fire Marshall J. Yoder ........................................... 70

Appendix I: Gwinnett County Inspection Consent Form ............................................................ 73

Appendix J: GCFES NFIR Query Incident by Property Type 2007-2010 ................................... 75

Appendix K: GCFES Incident Query Causality by Heat Source 2007-2010 ............................... 79
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Appendix L: GCFES Apartment Inspection Forml ...................................................................... 83

Appendix M: U.S. Census Bureau Fact Finding Website ............................................................ 85
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                                  Apartment Inspection Program Review

                                            Introduction

       As the population of a community increases and more housing is constructed, the risk of

fire in a community increases. Karter (2010) states “78% of all structure fires occur in residential

properties” (p i). Karter (2010) continues, “76% of all civilian injuries occur in residential

properties” (pii). The report Fire in the Unites States 2003–2007 shows that 28% of all

residential fires occur in multifamily buildings (U. S. Fire Administration/National Fire Data

Center [USFA], 2009).

       In Gwinnett County, during the last 10 years, the population has increased 37% to an

estimated 805,321 citizens (Gwinnett County Department of Planning and Development, 2010).

Additionally, during the last 10 years, single family housing units have increased 37% to a total

of 72,127 units while multifamily housing units have increased 38% to a total of 58,351 units

(Gwinnett County Department of Planning and Development, 2010).

       Nationally, apartment fire deaths have increase seven percent and injuries have increased

4% between 2003 and 2007 (USFA, 2009). In Gwinnett County, these statistics hold true. During

2009 and 2010, six fire fatalities have occurred which is a 300% increase from the previous 5

years (Gwinnett County Department of Fire and Emergency Services [GCFES], 2011). Fifty

percent of all fire injuries in Gwinnett County occur in apartment structures (GCFES, 2011).

Dollar loss from apartment fires has increased 64% during the time period of 2007-2010

(GCFES, 2011). From 2007-2010, monetary fire loss increased from $8.7 million to $13.7

million (GCFES, 2011).
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       The Gwinnett County Department of Fire and Emergency Services (GCFES) identified

this trend and initiated an apartment inspection program in January, 2010. The problem is that

Gwinnett County continues to have dollar loss and civilian casualties attributed to apartment

fires. The purpose of this applied research paper is to determine if the department’s current

apartment inspection program will decrease these losses.

       Descriptive research will be used to answer the following four research questions: (a)

Under state and local law, what legal restrictions exist in reference to apartment inspections in

Gwinnett County, (b) what procedures do other jurisdictions in Metropolitan Atlanta follow

when conducting apartment inspections, (c) what procedure does GCFES follow when

conducting apartment inspections, and (d) what are the causes of apartment fires casualties in

Gwinnett County?

                                  Background and Significance

       The Gwinnett County Department of Fire and Emergency Services (GCFES) provides

fire protection and EMS services for all of Gwinnett County and is a suburb of Atlanta, Georgia.

The county encompasses 432 square miles and protects a population of 805,321 citizens

(Gwinnett County Department of Planning and Development, 2011). The department currently

staffs 30 fire stations, 30 ALS capable engines, 11 ALS capable trucks, 23 ALS ambulances, and

2 ALS squads staffed by dual role firefighter paramedics and firefighter EMT’s. The department

employs 845 personnel and all sworn employees are required to obtain Georgia EMT-I and

Firefighter certification. The department operates on a three-platoon schedule with a 24/48 work

schedule. During 2010, the department responded to an excess of 63,000 calls for service.

       Gwinnett County has experienced rapid population growth over the last 10 years. The

county has added 212,852 residents and is the second most populous county in the Metropolitan
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Atlanta (Gwinnett County Department of Planning and Development, 2011). During the period

of rapid growth, the GCFES Fire Marshall Office was inundated with requests for new

construction inspections. Due to these requests, existing buildings and maintenance inspections

became a lower priority (J. Yoder, personal communication, July 13, 2011).

       This decision caused the county some embarrassment in 2007. “Fire Inspectors Skipped

30 Schools-Missed Checks Lead To Department Shake-Up” was the headlines in the local paper

(Diamond & Stanford, 2006, p. j1). This report caused the resignation of the Fire Chief, Fire

Marshall, a prevention Captain and one inspector (J. Yoder, personal communication, July 13,

2011). One of the key recommendations of the report was to create an Assistant Fire Marshall

position to oversee the annual maintenance inspection program, especially for schools, daycare

centers and personal care homes (Ghirardini, 2006). During 2007 and 2008, the maintenance

inspection division completed inspections of all the required occupancies (J. Yoder, personal

communication, July 13, 2011).

       Since 2008, the housing crash and recession has severely affected the county. Gwinnett

County leads the metropolitan area in home foreclosures during the last two years. In 2010, the

county had 14,371 foreclosures and so far this year, the county had logged 13,602 foreclosures

(Hunt, 2011). Since new construction has diminished greatly, more inspectors were available to

continue and expand the maintenance inspections. At the same time, Gwinnett County has seen a

rapid increase in apartment fires. Data from internal reports show that fire injuries and deaths

have increased 50% since 2007 (GCFES, 2011). Additionally, a third of all monetary fire loss in

the county is attributed to apartment fires (GCFES, 2011).

       With this backdrop, the GCFES apartment inspection program was initiated. Myers

(2003) states “as is the case with any organization, perception, whether or not reality based, can
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be the driving force behind the decision making process” (p10). The reality is that there are

significant losses due to apartment fires in Gwinnett County. The perception is that initiating an

apartment inspection program will reduce those losses. If the current inspection program is not

routinely reviewed, then the desired results may not be achieved. As the population continues to

grow and the structures in Gwinnett County continue to age, increased fire loss is probable.

       This research will produce recommendation that can be used by GCFES to analyze and

review the current apartment inspection program. This project is linked to Unit 1,

Introduction/Integrity and the course goal ‘the Executive Fire Officer (EFO) will develop the

ability to conceptualize and employ the key processes and interpersonal skills used by effective

executive-level managers (United States Fire Administration [USFA], 2005, p. sm 1-3). Further,

this research supports the USFA strategic goal to ‘reduce risk at the local level through

prevention and mitigation” (United States Fire Administration [USFA], 2011, p. II-2).

                                        Literature Review

       The literature review was organized around the four research questions: (a) Under state

and local law, what legal restrictions exist in reference to apartment inspections in Gwinnett

County, (b) what procedures do other jurisdictions in Metropolitan Atlanta follow when

conducting apartment inspections, (c) what procedure does GCFES follow when conducting

apartment inspections, and (d) what are the causes of apartment fire casualties in Gwinnett

County?

Legal restrictions

       The Tenth Amendment of the United States Constitution gives the legal basis for state

and local government to enforce state and local codes (Diamantes, 2007). Diamantes (2007)

further clarifies that “…local governments have only those powers expressly conferred by the
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state constitution, state statutes, or home rule charter” (p. 13). When reviewing what legal

restrictions apply to apartment inspections in Gwinnett County, one must start with state law.

       The Official Code of Georgia Annotated (OCGA) Title 25, Chapter 2 contains the

Regulation of Fire and Other Hazards to Persons and Property Generally (Regulation of Fire and

Other Hazards to Persons and Property Generally, 2006). Section 25-2-12 (a) (1) gives a county

governing authority with a population greater than 45,000 the mandate to adopt the minimum

state fire safety standards and all additional revisions (Regulation of Fire and Other Hazards to

Persons and Property Generally, 2006). Section 25-2-12 (2) allows any local government to

enforce fire codes and standards within its jurisdiction and shall be required under section (a) to

“conduct fire safety inspections of existing buildings and structures” (Regulation of Fire and

Other Hazards to Persons and Property Generally, 2006, § 25-2-12 (2) (A)).

       OCGA 25-2-13 (b) (1) (A) applies the minimum state fire codes to buildings or structures

more than three stories tall with the exception of individually owned residential units in that

building (Regulation of Fire and Other Hazards to Persons and Property Generally, 2006).

Section 25-2-13 (b) (B) clearly gives authority to apply the minimum codes to any building

three or more stories in height that is used as a residence by three or more families, and is

equipped with individual cooking and bathroom facilities of each family. The section continues

by stating “nothing in this Code section shall apply to any individually owned residential unit

within any such building” (Regulation of Fire and Other Hazards to Persons and Property

Generally, 2006, § 25-2-13(b) (B)).

       OCGA 25-2-40 (a) (2) requires the installation by the owner and maintenance by the

occupant of an approved battery operated smoke detector within an apartment, house or

townhome (Regulation of Fire and Other Hazards to Persons and Property Generally, 2006).
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Section 25-2-40 (d) requires any smoke detector to be installed per NFPA 72 (Regulation of Fire

and Other Hazards to Persons and Property Generally). Section 25-2-40 (f) (1) states

       The provisions of this code may be enforced by local building and fire code officials in

       the case of residential buildings which are not covered by Code Section 25-2-13;

       provided, however, that this code section shall not establish a special duty on said

       officials to inspect residential facilities for compliance with this Code section; provided,

       further, that inspections shall not be conducted for the purpose of determining

       compliance with this Code section absent reasonable cause to suspect other building or

       fire code violations. (Regulation of Fire and Other Hazards to Persons and Property

       Generally, 2006, § 25-2-40 (f) (1)).

       Further mandate in Georgia Law is found in Chapter 120-3-3, Rules and Regulations for

the State Minimum Fire Safety Standards. Section 120-3-3-.03, provides several key definitions

when applying the code. 120-3-3-.03 (6) defines a story as a story occupied by people on a

regular basis (Rules and Regulations for the State Minimum Fire Safety Standards, 2010).

Section 120-3-3-.03 (8) describes the primary level of exit discharge as “that story which is level

with or above finished grade by more than 50% of the cubic volume of the occupiable story.

Building levels below the primary level shall not count as a story in determining the height of a

building” (Rules and Regulations for the State Minimum Fire Safety Standards, 2010, p2).

Section 120-3-3-.03 (10) further defines stories as “……. That level starting at the primary level

of exit discharge and ending at the highest occupiable story. A building level below the primary

level shall not count as a story in determining the height of a building” (Rules and Regulations

for the State Minimum Fire Safety Standards, 2010, p2).
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       Section 120-3-3-.04 addresses modifications of the International Fire Code (IFC), 2006

edition. Section (b) (2) mandates application and enforcement of the code to certain residential

occupancies including apartment buildings (Rules and Regulations for the State Minimum Fire

Safety Standards, 2010). Section 120-3-3-.04 section (e) (6) addresses modifications to the Life

Safety Code to include the application and enforcement of that code to apartment buildings

(Rules and Regulations for the State Minimum Fire Safety Standards, 2010).

       Gwinnett County’s local code is titled Gwinnett County Ordinance, Chapter 46, Fire

Prevention and Protection. Section 46-26 mandates the adoption of the International Fire Code,

2006, as amended by the state laws OCGA 25-2 and Chapter 120-3-3 (Gwinnett County

Ordinance Chapter 46, Fire Prevention and Protection, 2006). Section 46-28 gives the authority

to enforce the fire code ordinance to “authorized personnel of the county fire and emergency

services, authorized officers of the county police and any authorized officers of any city police

department operating in the county” (Gwinnett County Ordinance, Chapter 46, Fire Prevention

and Protection, 2006). Section 46-29 gives the county authority to fine offenders of the code,

issues stop work orders, and provide notifications of non-compliance (Gwinnett County

Ordinance, Chapter 46, Fire Prevention and Protection, 2006). Section 46-30 further clarifies that

the fire prevention code shall be enforced by the fire prevention section of the department and

shall be under the Fire Marshal (Gwinnett County Ordinance, Chapter 46, Fire Prevention and

Protection, 2006).

       When reviewing the code further, apartment buildings are addressed at two specific

sections. In section 46-40, apartments are not required to have fire sprinkler protection while in

section 46-42, each individual apartment unit is required to have a 1 hour fire resistance rating

(Gwinnett County Ordinance, Chapter 46, Fire Prevention and Protection, 2006).
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       In Georgia, state law does not regulate landlord-tenant relationships. General

responsibilities of landlords and tenants are contained in OCGA, Title 44, Chapter 7. If there is a

dispute between a tenant and landlord, then both parties would need to go to court. Because of

this, there is an extensive history of case law that applies to landlord-tenant relationships. The

Georgia Legal Services Program, Inc has produced the Georgia Landlord Tenant Handbook that

is commonly used in Georgia to clarify landlord-tenant relationships.

       In addition to state code, the management of residential rental property can be regulated

by local codes (Georgia Legal Services Program, Inc., 2011). A landlord is “responsible to keep

an apartment safe, make repairs, select tenants and collect rent” (Georgia Legal Services

Program, Inc., p. 5). A tenant is “one who pays rent for exclusive right to use the premises,

usually for a defined period” (Georgia Legal Services Program, Inc., p. 5). A tenant has the right

to “use, occupy and enjoy the premises in accordance with the lease or rental agreement”

(Georgia Legal Services Program, Inc., p. 5). Unless is it stated specifically in the lease, a tenant

can refuse to allow a landlord to enter an apartment except in the case of an emergency (Georgia

Legal Services Program, Inc.)

       When reviewing the state and local law, it appears that state and local fire codes do apply

to apartment buildings that are three or more occupied stories in height. It also appears that the

first level is the level of “primary exit discharge”. The state code also clearly specifies that

nothing in this code shall apply to any “individually owned residential unit within any such

building" with the exception of smoke detectors. Smoke detectors must be installed and

maintained by the owner per NFPA 72 in each floor of an apartment unit. In Georgia, under

Code 25-2-40, the occupant of the apartment is required to maintain the detector. State code also

states that code officials are not required to inspect apartments for compliance unless there is
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reasonable cause to suspect other code violations. State code also does not mandate the

frequency of inspections in apartment buildings. Diamantes (2007) agrees in that the model

codes include within their scope residential dwellings but does not require routine inspections.

        With concerns to tenant law, the landlord is required to maintain a building in a safe

condition and provide smoke detectors. The tenant has the right to use the premises for a

specified time period. Unless it is specifically stated in the lease agreement, the landlord or their

agent has no right to enter a tenant space unless there is an emergency situation.

        Gwinnett County’s Fire Prevention Ordinance gives authority for the Fire Marshall and

Fire Prevention Section to apply and enforce local and state codes. In reference to apartments,

the only local requirement is one hour rated fire protection for each apartment unit.

Metropolitan Atlanta Apartment Inspection Procedures

        Metropolitan Atlanta is composed of 13 counties surrounding the City of Atlanta. Each

county has a career fire department and is tasked with either protecting the whole county or the

unincorporated sections of their jurisdiction. Either the Fire Marshall or an inspector from each

jurisdiction was contacted and interviewed to provide insight into their apartment inspection

program. Two jurisdictions, Cherokee County and Hall County, replied by email. The results of

the interview are summarized in Appendix A. Each interview is detailed in the Appendix E.

        The City of Atlanta and DeKalb County do not complete apartment inspections. Both

jurisdictions state they are only inspecting mandated maintenance inspections and new

construction. The DeKalb County Fire Prevention office has been reduced from 6 to 2 inspectors

due to budget restraints and does not have the staffing to complete apartment inspections (W.

Wright, personal communication, August 3, 2011). Fayette County did not have any apartment

buildings in their jurisdiction.
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       Fulton County and Clayton County complete apartment inspections annually by utilizing

Engine and Truck companies. In Fulton County, each company is given an inspection list for

apartment complexes in their first in territory. In Clayton County, the inspections are divided up

by zone to one of six inspectors. Those inspectors then assign the apartment inspections to the

first in Engine companies. The Engine companies inspect the complex and then report back to

the inspector. Clayton County claims that the advantage to this system is if an Engine company

needs technical advice about a code enforcement situation, the inspector assigned to the territory

is familiar with the complex (M. Griffin, personal communication, August 2, 2011).

       The remaining county jurisdictions in Metropolitan Atlanta utilize Field Inspectors

assigned to their respective Fire Marshall office. Cherokee County and Rockdale County have a

goal of completing inspections once every two years. In both jurisdictions, the reasoning was the

same. In Cherokee County, the staff of the Fire Marshalls office has been decreased 50 % to four

inspectors (R. Ruh, personal communication, August 7, 2011). In Rockdale County, staffing has

been cut to two inspectors with one inspector assigned to maintenance inspections (B. Norton,

personal communication, August 3, 2011).

       Douglas, Hall and Henry Counties all utilize one inspector for maintenance inspections

which includes apartment inspections. These jurisdictions also have the goal of completing

inspections annually. Douglas County has maintained this goal due to there being less than 10

complexes requiring inspections in their jurisdiction (T. Furr, personal communication, August

2, 2011). Henry County also has less than 10 complexes to inspect and is able to meet their goal

(M. O’Brien, personal communication, August 3, 2011). Hall County has not been able to meet

this goal due to only having one inspector available for maintenance inspections county wide and
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prioritizes their inspections to high risk occupancies such as schools and daycare centers (S.

Cagle, personal communication, August 17, 2011).

       Cobb County has one inspector dedicated to apartment inspections. This inspector

completes all the inspections annually and inspects approximately 200 complexes (N. Thomas,

personal communication, August 3, 2011). Inspector Thomas (personal communication, August

3, 2011) also advised his inspection consists of spot checks of the common areas and reviews of

the annual sprinkler test, fire extinguisher records, alarm test records, and fire hydrant test

records maintained by the complex management on site.

       Forsyth County divides its complexes into zones and requires the inspector assigned to

each zone to complete the inspection (K. Wallace, personal communication, August 2, 2011).

The inspector in that zone is required to inspect new construction as well as existing buildings

with new construction receiving the priority (K. Wallace, personal communication, August 2,

2011). The county has less than 10 complexes in their jurisdiction and the inspections have been

completed annually (K. Wallace, personal communication, August 2, 2011).

       Review of census data for each jurisdiction listed above is shown in Appendix A.

Gwinnett County has the most population at 805,321 followed by DeKalb County at 691,893,

Cobb County at 575,519 and the City of Atlanta at 486,411(U. S. Census Bureau, 2010). The

City of Atlanta had the most multifamily housing units at 119,586 followed by DeKalb County at

105,013, Gwinnett County at 53,042, and Cobb County at 41,262 (U.S. Census Bureau).

       Clayton County was the next most populous at 259,424 with 28,609 multifamily units

(U. S. Census Bureau, 2010). Fulton County had 18,330 multifamily housing units with a

population of 82,844 (U. S. Census Bureau). The remaining county jurisdictions in Metropolitan

Atlanta had less than 10,000 multifamily units listed (U. S. Census Bureau).
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       All jurisdictions that did complete apartment inspections did complete a life safety

inspection. These inspections consisted of checking the common areas, leasing office, clubhouse

and grounds of the complex. Emergency lighting, fire extinguishers and sprinkler inspection

letters are reviewed. Clayton, Hall and Rockdale Counties inspect the actual sprinkler riser in the

building. Cobb County reviews the inspection reports from the sprinkler companies, fire

extinguisher companies, and hydrant maintenance companies while only conducting spot checks

of the common areas and vacant apartments (N. Thomas, personal communication, August 3,

2011). Rockdale County also confirms that the mandatory sprinkler, alarm and fire extinguisher

inspection records are complete (B. Norton, personal communication, August 3, 2011). Cherokee

County does make it a practice to spot check vacant apartments during their building inspections

(R. Ruh, personal communication, August 7, 2011).

       What the interviews show is that all except two of the jurisdictions conduct apartment

inspections. Most have a goal of an annual inspection with the exception of Cherokee and

Rockdale Counties. Diamantes, (2007) agrees in that model codes do not establish the frequency

of inspections. Cobb, Douglas, Hall and Henry County each use one inspector. Cobb County’s

inspector is dedicated to apartment inspections but is also responsible for 200 complexes.

       Forsyth County divides their jurisdiction into zones and the inspector assigned to the

zone is responsible for both new and existing structures. New inspections, due to the time

constraints of the contractor, get a higher priority. In many other jurisdictions this is common.

Smith (2006) explains that this is a common practice in the Austin Texas Fire Department and is

acceptable unless there is a state mandate to complete the inspections.

       Fulton County and Clayton County were the only two jurisdictions interviewed that used

Engine companies to conduct the inspections. Even though Diamantes (2007) agrees that Engine
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company inspections are a great opportunity to establish relations with the community and

familiarize themselves with the structures in the community, he also cautions that “…an

uneducated or untrained inspector essentially is not noticed until a disaster occurs” (p24). Both

(Gillettee, III, 2001; Webb, 2008) agree that engine company personnel, properly trained as

inspectors in their jurisdiction, can be utilized as fire inspectors. Both Fulton and Clayton County

inspect each of their complexes annually. Perez (2008) agrees and recommends that using

Engine companies is an effective way to increase the number of multifamily residential

inspections.

       All jurisdictions that have an apartment inspection program complete a life safety

inspection that includes the common areas. None of the departments ask to inspect occupied

apartments. Cherokee County will make it a practice to spot check any vacant apartment during

an inspection. Due to the Fourth Amendment and case law rulings on the police power of the

state vs. the public rights to privacy, it is common practice for inspectors not to inspect private

dwellings (Diamantes, 2007). Diamantes (2007) continues, “The nonconsensual warrantless

entry of a dwelling is an especially serious breach, unless the entry is in response to an

emergency” (p21). Since a vacant apartment does not have a tenant, it is not considered a

dwelling, and an inspection can be conducted in that unit.

GCFES Apartment Inspections

       In 1947, Harry Truman led the Presidents Fire Prevention Conference. From it came the 3

E’s of Fire Prevention, Engineering, Enforcement and Education (United States Fire

Administration [USFA], 2002). When GCFES initiated their apartment inspection program, they

included all three E’s with a focus on Fire and Life Safety code compliance within the apartment

communities (B. Mitchell, Personal Communication, August 11, 2011).
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       A preliminary site visit is scheduled that includes an inspector from the Special

Enforcement Section, a fire educator from Community Risk Reduction and an invitation to the

local engine company for preplanning purposes (B. Mitchell, Personal Communication, August

11, 2011). Prior to the inspection, the property representative is asked to complete an Inspection

Consent Form (Appendix I). During the inspection, enforcement activities are conducted by the

inspector, a community educational assessment is conducted by the fire educator and the

suppression personnel update preplans and conduct building familiarization (B. Mitchell,

Personal Communication, August 11, 2011). Any additional inspections that need completion

due to notices of non compliance are conducted by the inspectors.

       The inspectors are part of the Special Enforcement Section of the Fire Marshall’s office

which was created in late 2009 to address the increase of apartment fires and civilian casualties

(J. Yoder, personal communication, July 13, 2011). The section consists of one Captain and three

inspectors (M. Phillips, personal communication, August 8, 2011). Their main responsibility is to

inspect all of the apartments as well as the complaints received throughout the county (M.

Phillips, personal communication, August 8, 2011).

       When an apartment inspection is completed, any notices of non compliance are filled out

and the complex is rated by a color score of Red, Yellow or Green. Red will have an inspection

rescheduled within 6 months, Yellow within one year and Green will have the lowest priority

(M. Phillips, personal communication, August 8, 2011). An average inspection takes

approximately three hours while a reinspection is quicker (M. Phillips, personal communication,

August 8, 2011). To date since January, 2010, 136 of the county’s 200 complexes have been

inspected with an expected initial inspection completion period of fall 2011 (B. Mitchell,

Personal Communication, August 11, 2011).
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         The inspectors utilize an apartment inspection form (Appendix L) and complete an

inspection of all the common areas, mechanical rooms if they are outside of a dwelling unit,

attics and draft stops. Grounds are inspected and spot checks are conducted on fire hydrants.

Knox box activation of the complex gates is verified. Required annual fire alarm, fire

extinguisher, sprinkler inspection, and fire hydrant test certificates are checked. Upon arrival at

the complex, the inspector requests a list of vacant units and inspects each one. Previous

inspections have found occupants illegally staying in the units (J. Yoder, personal

communication, July 13, 2011). As of August 1, 2011, 42 citations have been issued to apartment

complexes and $32,485 has been collected (B. Mitchell, Personal Communication, August 11,

2011).

         Another feature of Gwinnett’s apartment inspection program is the requirement of a Fire

Emergency Planning Guide. This requirement is based on the interpretation of the International

Fire Code, section 408.9 which requires owners and managers of rental properties to develop a

specific Fire Emergency guide (Gwinnett County Department of Fire and Emergency Services

[GCFES], 2010). A fire educator will meet with the apartment management to assist with the

creation of the guide. In return, the department requests the guide to be included with the lease

agreement and is displayed at the leasing office (B. Mitchell, Personal Communication, August

11, 2011).

         When reviewing the literature, several sources agree with the concept of public education

and enforcement. The NFPA clearly recommends that “…more widespread public safety

education is needed on how to prevent fires and how to avoid serious injury or death should a

fire occur” (National Fire Protection Association [NFPA], 2008, p. 20-39). The editors of

Firehouse magazine agree that since inspectors cannot inspect individual apartment units, then
                                                               Apartment Inspection Program         22



community education and awareness is the best strategy (Inspections - which do we do first,

2007). Karter (2010} further adds that fire safety education that is brought to the home is still the

best method to reduce the overall casualty rate in residential fires. The International Fire Code

(IFC) does state in section 408.9 that an emergency guide shall be created, maintained and

distributed to each tenant prior to initial occupancy (International Code Council, 2006).

       Since January 1, 2010, the program has inspected 68% of the complexes in the county

(B. Mitchell, personal communication August 11, 2011). The inspections are scheduled to be

completed prior to the end of 2011. It is expected that after the wave of initial inspections,

reinspections should occur faster and a goal of annual inspections will be achieved (M. Phillips,

personal communication, August 8, 2011). “From a liability standpoint, it is better for inspectors

to conduct fewer, but more thorough inspections and to follow up on all violations than to

perform more frequent inspections in a haphazard, incomplete, or negligent manner”

(International Fire Service Training Association [IFSTA], 2009, p. 29). A contrary opinion

offered by the Fire Protection Research Foundation found that completing many inspections was

more effective the completing fewer inspections with a higher quality (The Fire Protection

Research Foundation, 2008). The reasoning is that lower fire incident rates have been attributed

with more frequent inspections (The Fire Protection Research Foundation).

       In summary, Gwinnett County’s apartment inspection program encompasses inspection

of the common areas, any unoccupied apartments and attic areas. The inspector reviews all

required annual inspection documentation and spot checks hydrants and any mechanical systems

outside of the dwelling unit. Enforcement is obtained with issuances of notices of non

compliance and citations if needed. In addition, the program has a public safety effort with a

needs assessment completed in the complex and the requirement for management to create and
                                                             Apartment Inspection Program         23



display a Fire and Emergency guide. The program also includes suppression personnel to

conduct building familiarization, pre planning, and to conduct public relations. The program

since inception has completed approximately 2/3 of the complexes in the county.

Causes of Apartment Fire casualties in Gwinnett County

       “Analyzing fire data is an important initial step in determining what risks the community

is facing due to fire” (Newby, 2008). Crawford (2005) expands this further and feels that EMS

reports and other data should also be used when designing a fire prevention program. With that

thought, it is imperative to determine the most common causes of apartment fires in Gwinnett

County.

       When reviewing queries of NFIR reports from the previous four years (Appendix J),

cooking fires are almost as frequent as structure fires. During the four year period 2007–2010,

392 apartment structure fires occurred and 356 apartment cooking fire occurred. When reviewing

a query of NFIR reports listing casualties for the same time period (Appendix K), structure fires

caused 31 casualties and cooking fires caused 12 casualties. Six fatalities occurred and were

attributed to structure fires. A summary of the NFIR reports are available in Appendixes B and

C

       When reviewing the causes of the fatalities, all were listed as undetermined. One life

threatening injury was reported with an undetermined cause. Major injuries were attributed to

three cooking fire incidents, three heat from operating equipment incidents and one

undetermined cause. Three severe injuries were reported. One was due to cigarettes, one was

spontaneous combustion and one was heat from operating equipment. The majority of injuries

reported were minor. Cooking was attributed to 5 injuries. Heat from operating equipment
                                                              Apartment Inspection Program       24



attributed to 12 incidents, followed by undetermined at five incidents. Cigarettes and candles

were attributed to 2 minor injuries each.

       In Gwinnett County, cooking fires are a frequent cause of apartment fires. During 2009,

107 cooking fires occurred which was the greatest cause of apartment fires. FEMA concurs with

this finding and explains that cooking fires account for the majority of apartment fires. (Federal

Emergency Management Agency [FEMA], 2010). Ahrens (2011) reports that nationally, 64% of

apartment fires are caused by cooking fires. Cooking fires are twice as likely to occur in

apartments as in one or two family residences (NFPA, 2008).

       When reviewing casualties tied to apartment fires in Gwinnett County, 8 are attributed to

cooking fires. 17 were caused by heat from operating equipment, 3 by cigarettes, 2 by candles,

and 1each due to fireworks and spontaneous combustion. Four were undetermined. Gwinnett

County has shown an increase in casualties due to both apartment structure fires and cooking

fires during the last two years. During 2009-2010, 16 injuries occurred in structure fires

compared to 15 for 2007–2008. Injuries from cooking fires increased from 2 during 2007–2008

to 10 from 2009-2010. There were 6 fatalities during the last 2 years in apartment fires compared

to zero during the 2007–2008 time period.

       Karter (2010) found a 19% increase in apartment fire fatalities in 2009 compared to 2008.

FEMA (2010) reports an average of 0.3 fatalities per 100 fires and 2.9 injuries per 100 fires

during the three year period of 2005-2007. In Gwinnett County, during the four year period of

2007-1010, 0.75 fatalities per 100 fires and 5.6 per injuries per 100 fires were reported.

       The data also shows that a majority of apartment fires occur in the occupied parts of the

structure. When a fire is unconfined and becomes a structure fire, 32.1% of those fires originate
                                                              Apartment Inspection Program         25



in the kitchen, followed by bedrooms at 15.8%, and family rooms at 7.0% (FEMA, 2010). The

least common area of origin is the exterior balcony or porch at 3.6% (FEMA).

       Cooking fires are a major contributor to apartment fires in Gwinnett County.

Additionally, the majority of apartment fires occur in the occupied part of the structure.

Compared to the national averages, Gwinnett County far exceeds the national average in both

casualties and fatalities per 100 apartment fires.

                                             Procedures

       The purpose of this applied research paper was to determine if the department’s current

apartment inspection program will decrease the dollar loss and civilian casualties attributed to

apartment fires. The procedures undertaken include a query of population and housing

demographics of the 13 county fire districts in Metropolitan Atlanta and interviews with either

the Fire Marshall or a Fire Inspector in each districts department.

       The U. S. Census Bureau Fact Finder website was accessed to determine population and

housing data for each county in Metropolitan Atlanta (Appendix M). Queries were completed for

the City of Atlanta, Cherokee, Clayton, Cobb, DeKalb, Douglas, Forsyth, Fulton, Gwinnett, Hall,

Henry and Rockdale Counties. Fayette County was deleted from the study because the county

did not have any multifamily dwelling units within its jurisdiction. Using the researcher’s

knowledge of the jurisdictional boundaries of the fire service in Metropolitan Atlanta, it was

determined whether or not the county fire jurisdictions listed above included both incorporated

and unincorporated portions of the county.

       Clayton County, Cobb County, DeKalb County, Douglas County, Fulton County, Hall

County and Henry County all had incorporated cities in their jurisdictions that provided city fire

services. Each of these cities identified had their own fire prevention bureau and provided
                                                               Apartment Inspection Program       26



inspections within their city limits. The researcher queried these cities on the U. S. Census

Bureau Fact Finder website and subtracted the population and multifamily housing units listed

for each city from the totals listed on the county query.

       When querying the data for Clayton County, the City of Morrow’s data was subtracted.

When querying the data for Cobb County, the Cities of Marietta and Smyrna’s data was

subtracted. When querying the data for DeKalb County, the City of Decatur’s data was

subtracted. When querying the data for Douglas County, the City of Douglasville’s data was

subtracted. When querying the data for Fulton County, the Cities of Alpharetta, Atlanta, College

Park, East Point, Roswell, Sandy Springs and Union City’s data was subtracted. When querying

the date for Hall County, the City of Gainesville’s data was subtracted. When querying the data

for Henry County, the City of McDonough’s data was deleted. The results of this quantitative

data are shown in the population and multifamily housing unit’s columns in Appendix A.

       Based on the literature review of research question 1, the researcher then developed a

questionnaire (Appendix D) to be utilized to interview either the Fire Marshall or Fire Inspector

of the county fire jurisdictions in Metropolitan Atlanta. The questionnaire was designed to be

short and determine if other local county jurisdictions complete apartment inspections, the

frequency of inspections, what areas of the building are inspected, and who completed the

inspections. The results of the interviews are shown in the apartment inspection program,

frequency of inspections, and company or field inspector’s columns in Appendix A.

       Each jurisdictions Fire Marshall office was contacted by phone to determine an email

address and contact information for the questionnaire recipient. During this initial phone call, all

but Cherokee and Hall County were able to provide the information by phone during the initial

contact. Members of Cherokee and Hall County’s prevention office were identified and the
                                                                Apartment Inspection Program      27



questionnaire was emailed to those individuals. The notes of the interviews are located in

Appendix E.

       Personal interviews were then conducted with members of the Gwinnett County

Community Risk Reduction (Appendix F), Special Enforcement Division (Appendix G), and the

Assistant Fire Marshall (Appendix H) of the departments Fire Marshall Office. The Assistant

Fire Marshall was chosen due to his tenure in the division and was able to provide a historical

perspective of events leading up to the creation of the program. The Special Enforcement

Divisions Captain was interviewed due to his duties of managing the operation of that division.

The supervisor in charge of the Community Risk Reduction Division was able to provide insight

on how that program interrelates with the enforcement divisions operation during an Apartment

Inspection.

       Quantitative data was developed from a NFIR query of causes of multifamily fires in

Gwinnett County for the period 2007-2010 (Appendix J) and used to produce the chart

multifamily incident types in Appendix B. Quantitative data was developed from a NFIR query

of type of casualty due to apartment fires in Gwinnett County for the period 2007-2010

(Appendix K) and used to produce the chart multifamily casualties in Appendix C.

Limitations

       The researcher chose to limit the questionnaire to departments in Georgia due to the

restrictions of state law. State fire codes vary from state to state. Therefore, the design of

inspection programs due to legal restrictions also vary. The researcher chose to limit the

interviews to county departments due to similarities between those departments and GCFES.

Most county departments in Metropolitan Atlanta are responsible for the protection of a larger

geographic area, larger population and more housing units than a smaller city. The exception to
                                                              Apartment Inspection Program       28



this was the City of Atlanta and it was included in the research due to its population and number

of multifamily residential units.

        The researcher chose to select the specific county departments within Metropolitan

Atlanta because they consist of career personnel and protect a mix of either urban or suburban

populations with a portion of the population residing in multifamily housing. Those

demographics are similar in nature to the demographics of Gwinnett County and allow a valid

comparison.

        During the research, one member of the Fire Marshall’s office resigned and data obtained

from that individual could not be validated and had to be discarded. The researcher had to limit

the history of the NFIR queries due to a change in the NFIR software reporting program during

2006.

Assumptions:

        The literature and information obtained during the interviews was assumed to be factual,

objective and unbiased. The researcher did have a professional relationship with members of the

GCFES Fire Marshalls office.

Definition of Terms:

Apartment Building:

Those structures containing three or more living units with independent cooking and bathroom

facilities, whether designated as apartment homes, tenements, condominiums, or garden

apartments (NFPA, 2008, p. 20-37)

Housing unit:

A house, an apartment, a mobile home or trailer, a group of rooms, or a single room occupied as

separate living quarters, or if vacant, intended for occupancy as separate living quarters. Separate
                                                              Apartment Inspection Program        29



living quarters are those in which the occupants live separately from any other individuals in the

building and which have direct access from outside the building or through a common hall. For

vacant units, the criteria of separateness and direct access are applied to the intended occupants

whenever possible (U. S. Census Bureau, 2010, glossary).

Multi-unit structure:

A building that contains more than one housing unit such as an apartment building (U. S.

Census Bureau, 2010, glossary).

                                              Results

Research Question 1:

       Gwinnett County’s apartment inspection program is restricted in several ways by both

state and local law. OCGA Section 25-2-12 (a) (1) allows the county to adopt the minimum state

fire safety standards and any revisions (Regulation of Fire and Other Hazards to Persons and

Property Generally, 2006). Section 25-2-12 (2) (a) allows GCFES to enforce the codes and

standards within its jurisdiction and conduct inspections of existing buildings (Regulation of Fire

and Other Hazards to Persons and Property Generally). These two laws allow GCFES to adopt

and enforce the state fire code.

       OCGA 25-2-13 (b) (1) (A) allows the application of state fire codes to any building or

structure more than three stories tall with the exception of individually owned residential units in

the building (Regulation of Fire and Other Hazards to Persons and Property Generally, 2006).

Section 25-2-13 (b) (B) allows the application and enforcement of the state fire code to any

apartment building three or more stories in height but does not allow enforcement in any

individually owned residential unit within the building (Regulation of Fire and Other Hazards to

Persons and Property Generally). These laws allow GCFES to enforce state fire codes to any
                                                                Apartment Inspection Program        30



apartment building three or more stories in height but cannot enforce the code in any individual

residential unit.

         OCGA 25-2-40 (a) (2) requires the installation of a smoke detector by the owner of a

multifamily building and requires the occupancy of any dwelling unit to maintain the detector in

operating condition (Regulation of Fire and Other Hazards to Persons and Property Generally,

2006). Section 25-2-40 (f) (1) further clarifies that an inspection official is not required to inspect

each smoke detector in a dwelling unit unless there is reasonable cause to suspect other building

or code violations (Regulation of Fire and Other Hazards to Persons and Property Generally).

This provision of the law requires the installation and maintenance of smoke detectors in

residential occupancies but does not mandate the inspection of those detectors. Unless an

inspector has probable cause due to another fire safety or code violation, the inspector cannot

enter a dwelling unit without permission of the owner.

         Further state mandates clarify building height and what is considered a story for code

purposes. State Minimum Fire Safety Standards Section 120-3-3-.03 defines a story as a level

that is occupied on a regular basis (Rules and Regulations for the State Minimum Fire Safety

Standards, 2010). Section 120-3-3-.03 (8) defines the primary level of exit discharge must be at

or above ground level, 50% of that level must be above finish grade, and any level below the

level of primary exit discharge shall not count as a story when considering building height (Rules

and Regulations For the State Minimum Fire Safety Standards). These sections clarifies what is

considered a story and how building height is determined. The language states that in order for a

building to be considered three stories, all three stories must consist of occupiable space, the first

level is considered the main level of discharge, and that level is at least 50% above the finished

grade.
                                                              Apartment Inspection Program        31



       Section 120-3-3-.04 (b) (2) modifies the application and enforcement of the International

Fire Code 2006 to apartment buildings to within the definitions of the state fire code (Rules and

Regulations for the State Minimum Fire Safety Standards, 2010). Section 120-3-3-.04 (e) (6)

addresses the same definitions to the Life Safety Code (Rules and Regulations for the State

Minimum Fire Safety Standards). These revisions modify the difference between R1 and R2

structures but do not affect the R2 listing of apartment buildings.

       Section 46-26 of the Gwinnett County Ordinance mandates the adoption of the

International Fire Code as amended by the state (Gwinnett County Ordinance, Chapter 46, Fire

Prevention and Protection, 2006). Section 46-28, 46-29 and 46-30 provides the authority to

enforce the code and fine offenders by the Fire Marshall, fire prevention section of the Fire

Marshall’s office and any local police authority within Gwinnett County (Gwinnett County

Ordinance, Chapter 46, Fire Prevention and Protection). These code sections allow GCFES

inspectors the power to apply and enforce the state fire safety standards within Gwinnett County.

       Section 46-40 specifies that apartments are not required to be sprinkled as long as each

dwelling unit maintains a 1 hour fire rating as required in section 46-42 (Gwinnett County

Ordinance, Chapter 46, Fire Prevention and Protection, 2006). This provision in the local code

will allow a builder to either build an apartment building without sprinkler protection and allow a

an existing building being remodeled to remove a sprinkler system if each unit is a one hour

rated assembly (J. Yoder, personal communication, July 13,2011).

Research Question 2:

       The data from the interviews provided the results for research question 2. The responses

to the interview questions are listed in Appendix E. Appendix A provides the results of the

questionnaire. The City of Atlanta and DeKalb County do not conduct apartment inspections.
                                                               Apartment Inspection Program         32



Chief Gregory Favors with Atlanta Fire advised that his department has not undertaken that

project and there were no plans to start an inspection program in the near future. Chief Wayne

Wright with DeKalb Fire advised he did not currently have a program in place. His inspection

division is busy with state mandated inspections such as existing schools, personal care homes

and daycare centers. Additionally, new inspection requests have recently increased. His division

has received a personnel cut due to early retirements and there currently a freeze on new hires.

       All the other jurisdictions contacted did conduct apartment inspections. All jurisdictions

verified that they conduct a life safety inspection that consists of the common areas, club house,

leasing office and exterior portions of each apartment building. None of the jurisdictions

conducted inspection of occupied living units. Below is a summary of the differences of how

inspections are completed by different jurisdictions.

       Both Clayton County and Fulton County conduct apartment inspections and utilize

suppression personnel. Chief Jack Butler with Fulton County Fire advised that each company is

given an inspection list of apartment complexes in their first in territory. The inspections are

completed annually and the inspection forms are sent to the fire prevention office. In Clayton

County, Lieutenant Mitch Griffin supervised the apartment inspection program. The inspections

are assigned to fire companies by their first in territory. Each complex is inspected annually.

Visual inspection is completed of each sprinkler riser. If a code violation is found, then one of

six inspectors is available to meet with the Engine Company or management of the complex.

       Cherokee County and Rockdale County both complete apartment inspections with fire

prevention inspectors but utilize a time frame of greater that one year. Chief Rick Ruh with

Cherokee County Fire has a time frame of 12 to 24 months to complete inspections. His division

has gone through a 50% reduction in work force and had completed inspections of all complexes
                                                              Apartment Inspection Program         33



within the last two years. Chief Ruh did advise that they will spot check vacant apartments as an

inspection is being conducted. Chief Bill Norton with Rockdale County Fire schedules apartment

inspections with a 12 to 18 month window to completion. Rockdale County uses field inspectors

but only has two inspectors currently assigned. Besides the standard life safety inspection, his

inspectors also check inspection records for fire extinguishers, sprinkler systems and alarm

system tests if the building is so equipped.

       Douglas County completes apartment inspections but also checks handicap access.

Captain Thomas Furr advised that the inspections are completed annually but his jurisdiction is

only responsible for eight complexes. One inspector in his division is assigned to maintenance

inspections.

       Henry County utilizes field inspectors and inspects their complexes annually. Lieutenant

O’Brien advised that they are responsible for 10 complexes and one inspector is assigned to

maintenance inspections which includes apartments.

       Hall County has a goal to complete apartment inspections annually but that is not the

reality. Captain Scott Cagle explained that his division was cut from 6 inspectors to 2 inspectors.

One inspector is assigned to maintenance inspections and mainly handles mandatory inspections

and high hazard inspections. Some examples include schools, daycare and hi hazard businesses.

Captain Cagle advised that they are only responsible for 8 complexes in their jurisdiction.

       Forsyth County completes apartment inspections annually. The complexes are divided up

by zone to 1of 5 inspectors. Captain Kevin Wallace advised that each inspector was responsible

for new and maintenance inspections in his zone and could schedule the inspections as time

permits. Besides the common areas, the inspectors also key in on grills on balconies since that
                                                               Apartment Inspection Program        34



has been the cause of several fires in his jurisdiction. Captain Wallace advised they had 10

complexes in their jurisdiction.

       Cobb County completes apartment inspections and utilizes one inspector. Inspector Nate

Thomas is assigned to all maintenance inspections in the county and completes them annually.

He advised that he is responsible for 200 complexes and utilizes spot checks of the common

areas and an extensive review of the required alarm system, fire extinguisher, sprinkler test, and

fire hydrant test records that are maintained by management.

Research Question 3:

       Interviews with GCFES fire prevention personnel were conducted to determine what

procedures GCFES follows when conducting apartment inspections. A summary of the

interviews will be presented here. Each interview is documented in the appendices.

       The interview with Assistant Fire Marshall Jeff Yoder occurred on July 13, 2011

(Appendix H). Jeff Yoder has been assigned to the fire prevention division for 6 years. Prior to

2007, inspection priority went to new inspections. After the negative press in early 2007 about

missing school inspections, the Fire Marshall’s office was reorganized and a maintenance

division was created. As the economy weakened in 2008, inspection requests decreased and

more inspectors were available for maintenance inspections. During 2009, several apartment

fires occurred that caused loss of lives. At the same time, a need was evident for the inspection

of night clubs and the enforcement of illegal occupancy changes.

       During January, 2010, a Special Enforcement Section was created to inspect all

apartment buildings consisting of three units or greater. The decision was made to go strictly

with those criteria. The inspection completed is a common life safety inspection and utilizes a

standard sheet (Appendix L). Due to 4th amendment issues, individual occupied apartment units
                                                               Apartment Inspection Program          35



are not inspected. If the unit is vacant, then it is owned by the management company and is not

considered occupied. Therefore, any vacant unit can be inspected. In addition, attic draft stops

and any required fire walls that are accessible from the common areas are inspected. Right now

the inspections are taking longer than anticipated. But once all complexes have been inspected,

then reinspections are expected to be much quicker and each complex should be inspected

yearly. Jeff Yoder also advised that the apartment inspection program also consisted of a public

education element that was currently being organized by Safety Educator Brandy Mitchell

       Captain Matthew Phillips is the supervisor in charge of the Special Enforcement Unit. He

was able to provide some clarifying information about the staffing, procedures and timeframe to

completion (Appendix G). Captain Phillips advised that currently there are 3 inspectors assigned

to the unit. The inspectors are charged with apartment inspections as well as handling any

complaints. Captain Phillips also advised that as a complex is inspected, it is given a potential

hazard rating code of Red, Yellow or Green. Red is considered poor and should be reinspected

within 6 months, yellow is average and should be inspected annually and green very good and

can be inspected less that annually. Logs are not maintained on how long each inspection takes

but the average for the initial inspection is 3 hours. Currently, 68% of the complexes have been

inspected.

       Fire Educator Brandy Mitchell was contacted to provide some information on the public

safety aspect apartment inspections program (Appendix F). Brandy Mitchell makes the initial

contact with the complex and schedules the initial site visit. In addition to the enforcement

aspect of the inspection, a fire safety educator is present to assess the educational needs of the

apartment management and the occupants of the complex. Additionally, suppression personnel
                                                                Apartment Inspection Program        36



from the first due stations are invited to take part in preplanning, territory familiarization and to

make contact with the apartment management.

       During the public education needs assessment, assistance is provided in developing a Fire

Emergency Planning Guide. Once this guide is produced, it is requested that the guide is given to

any new lessee and made available to current occupants.

       The interviews show that Gwinnett County’s apartment inspection program includes

enforcement and public education. The inspections are completed by field inspectors and consist

of a standard life safety inspection and an inspection of all common areas. Vacant apartment are

inspected and have been found to contain illegal occupants. In addition, suppression personnel

are invited to conduct territory familiarization, preplanning, and make contact with apartment

management. The inspections of all complexes are scheduled to be completed by fall of 2011

which would be within 2 years. It is the goal of Captain Phillips to inspect all apartments based

on a hazard rating which would include a variable inspection interval.

Research Question 4:

       When determining the most common causes of apartment fire casualties in Gwinnett

County, data from NFIR reports queries (Appendix J and K) were obtained from departmental

incident reports. The quantitative data for those reports are displayed in Appendix B and C.

During the four year period from 2007-2010, 392 apartment structure fires occurred and 356

cooking fires occurred. During that same time period, 31 casualties occurred due to structure

fires and 12 casualties occurred due to cooking fires. There were 6 fatalities in apartment

structure fires during the 2007-2010 time periods.

       When reviewing the causes of the fatal fires, all were coded undetermined. Additionally,

one life threatening injury was caused by a fire of undetermined origin. Severe injuries were
                                                               Apartment Inspection Program          37



limited to 3 and were caused by cigarettes, spontaneous combustion and heat from operating

equipment respectively. Major injuries were attributed to 3 cooking incidents, 3 heat from

operating equipment and 1 undetermined cause.

       The majority of injuries in apartment fires were minor. Cooking attributed to 5 injuries

and heat from operating equipment caused 12 injuries. The listing undetermined was attributed to

5 injuries. Cigarettes and candles contributed to 1 minor injury each.

       In Gwinnett County, a high percentage of fires in apartment buildings are attributed to

cooking fires. FEMA (2010) reports similar findings with cooking fires accounting for the

majority of apartment fires. Casualties from cooking fires have increased. During the 2009-2010

time period, 10 injures have occurred due to cooking fires compared to 2 injuries for the 2007-

2008 time period.

        Overall, the casualty rate and fatality rate in apartment fires in Gwinnett County exceeds

the national average. During the 4 year time period of 2007-2010, 0.75 fatalities have occurred

per 100 fires and 5.6 injuries per a 100 fires have been reported. FEMA (2010) reports an

average of 0.3 fatalities per 100 fires and 2.9 injuries per 100 fires nationwide.

       When reviewing the causes of apartment fires and apartment fire casualties in Gwinnett

County, the data shows that the majority of fires start in the occupied portions of the structure.

FEMA (2010) confirms this trend with approximately 32% of uncontained apartment structure

fires originating in the kitchen, followed by the bedroom at 15% and family rooms at 7%

                                             Discussion

       Gwinnett County, as other jurisdictions in Metropolitan Atlanta, is legally restricted by

state and local law. Diamantes (2007) clarifies that local governments only have the powers that

state constitutions, statuettes or charter allow. In Georgia, OCGA Title 25 Chapter 2 section 12
                                                                Apartment Inspection Program         38



and the subsections provides local counties and city governments with a minimum population of

45,000 the mandate to adopt the minimum state fire codes, the ability to impose these mandates

and the ability to conduct inspections of existing buildings and structures (Regulation of Fire and

Other Hazards to Persons and Property Generally, 2006).

       OCGA 25-2-13 (b) (1) (a) allows local governments to apply and enforce the minimum

state fire codes to buildings more than three stories tall unless the building is a private residence

(Regulation of Fire and Other Hazards to Persons and Property Generally, 2006). The code has a

slight change in wording if the building is an apartment building. Section 25-2-13 (b) (B) allows

the state fire code to be applied to an apartment building three or more stories in height but the

code cannot be enforced in any individually owned unit in the building (Regulation of Fire and

Other Hazards to Persons and Property Generally). This ruling has been interpreted by Gwinnett

County Government to allow inspections of apartment buildings within the jurisdiction with the

exception of individual dwelling units. The law clearly states the building must be three or more

stories in height. Further State Mandate clarifies what is considered a story.

       Chapter 120-3-3-.03 defines a story as a level of a building normally occupied by people

on a regular basis (Rules and Regulations for the State Minimum Fire Safety Standards, 2010).

This section defines what is considered a story and will qualify the difference between a 2 story

and 3 story building. Further clarification concerning building height and the affect of code

restrictions is provided in section 120-3-3-.03 (8) and (10). These sections both state that the

ground level is either the level or primary exit discharge or the level than has 50% of its area

above ground level (Rules and Regulations for the State Minimum Fire Safety Standards). The

importance of this code is the requirement to change occupancy requirements to a high rise if an
                                                               Apartment Inspection Program       39



apartment building is greater than 75 feet high at its level of discharge and each level above

grade is an occupiable level.

       The state codes provide guidance with the apartment building inspections. The buildings

must be below 75 feet in height from the primary exit discharge grade. The buildings must be a

minimum of three stores high. The code clarifies, for enforcement purposes, a story must be an

occupiable level. This provision clarifies that the common 2/3 split apartment building (2 stories

in the front, 3 stories in the rear) falls under the code requirements. What the state code does not

allow, in this researchers opinion, is the enforcement or inspection of two stories or less

apartment buildings.

       Section 120-3-3-.04 modifies the application of the International Fire Code 2006 in

reference to apartments and the separation of R2 and R1 occupancies (Rules and Regulations for

the State Minimum Fire Safety Standards, 2010). This section does allow an authority having

jurisdiction to require management of apartment complexes to provide residents a fire safety

guide (GCFES, 2010). This guide will provide education to the occupants of apartment

buildings.

       OCGA 25-2-40 mandates the installation of smoke detectors in all dwelling units per the

requirements of NFPA 72 but requires the occupant to maintain the detector (Regulation of Fire

and Other Hazards to Persons and Property Generally, 2006). Regulation of Fire and Other

Hazards to Persons and Property Generally also mandates that inspectors are not required to

inspect the smoke detectors in individually owned units. State codes also do not mandate the

frequency of inspections. Diamantes (2007) agrees in that model codes include residential

occupancies within their scope but do not mandate an inspection frequency.
                                                              Apartment Inspection Program        40



       Local County Fire Ordinances regulate the authorities and specific building restrictions in

Gwinnett County. Section 46-26 of the Gwinnett County Ordinance mandates the adoption of the

International Fire Code and amended by the state code (Gwinnett County Ordinance, Chapter 46,

Fire Prevention and Protection, 2006). Sections 46-28, 46-29 and 46-30 provide the Fire

Marshall, fire prevention officers and local police the authority to enforce the county ordinance

(Gwinnett County Ordinance, Chapter 46, Fire Prevention and Protection).

       Section 46-40 allows the deletion of sprinkler protection in an apartment building as long

as each unit has a 1 hour fire resistive rating. This code applies to both new construction and

remodeling. In the researcher’s opinion, especially with the restrictions to enter individual

apartment units to verify compliance, this code prevents the installation of an automatic

engineering suppression device that also contacts the fire department upon activation. The

researcher feels that this code section should be amended to allow sprinkler protection only.

       Additional restrictions on inspectors are imposed due to tenant law. A lease is a binding

contract between the apartment buildings management and the renter. In exchange for rent, the

occupant can “use, occupy and enjoy the premises in accordance with the lease or rental

agreement” (Georgia Legal Services Program, Inc., 2011, p. 5). The management of residential

rental property can be regulated by local codes (Georgia Legal Services Program, Inc.), The

possibility exist, via changes to local codes, that language concerning apartment inspections,

maintenance of 1 hour fire rated enclosures, and/or interconnected alarm systems can be placed

in either the local housing codes or lease agreements to allow further enforcement or engineering

practices to lessen the likelihood of uncontained apartment fires.

       In summary, Georgia State Code provides the minimum standard for fire protection in the

state. State code gives Gwinnett County the ability to inspect the common areas of apartment
                                                                 Apartment Inspection Program         41



buildings with three occupiable stories. Local code has the capability to require stricter standards

if the need is evident. Local codes can be modified via enforcement, engineering and education

requirements to allow more effective apartment inspection and more effective fire prevention

efforts.

           When reviewing what procedures other county fire departments in Metropolitan Atlanta

use to complete apartment inspections, common traits exist. There were also some alarming

differences. Neither the City of Atlanta nor DeKalb County conducts apartment inspections.

Neither jurisdiction had any future plans to conduct them. Atlanta is the 4th most populous

jurisdiction in the metropolitan area with 486,411 citizens (U. S. Census Bureau, 2010). The city

contains 119,586 dwelling units, which is the highest number of multifamily dwelling units in

the area (U. S. Census Bureau). DeKalb County is the 2nd most populous jurisdiction with

691,893 citizens and protects 105,013 multifamily units (U. S. Census Bureau). The numbers

show that the greatest potential for fire or life loss in apartment fires is the two jurisdictions that

do not complete inspections. To Chief Wayne Wright’s credit, he advised that the need is there

but with staffing cuts, only mandatory maintenance inspections are being completed at this time

(W. Wright, personal communication, August 3, 2011). The researcher feels that this situation

should be monitored and a great opportunity exists for future study to see the impact on

monetary loss and civilian casualties when comparing DeKalb County and the City of Atlanta to

similar jurisdictions that conduct apartment inspections.

           The rest of the jurisdictions contacted did complete life safety apartment inspections.

The main variables were the frequency of inspection, the number of complexes that needed

inspecting, who completed the inspections, and how the specific prevention office was

organized. Both Fulton and Clayton Counties utilized suppression units to conduct the
                                                              Apartment Inspection Program         42



inspections. In both jurisdictions, apartment complexes were assigned by station territory. Both

departments complete their inspections annually. Clayton County protects a population of

259,424 and 28,609 multifamily dwelling units (U. S. Census Bureau, 2010). Fulton County

protects a population of 82, 844 with 18, 330 multifamily dwelling units (U. S. Census Bureau).

       The use of suppression personnel can be an effective way to increase the number of

apartment inspections (Perez, 2008). Both (Gillettee, III, 2001; Webb, 2008) agree that properly

trained suppression personnel can be utilized as fire inspectors. Diamantes (2007) cautions that

the work of an untrained inspector is not noticed until a disaster occurs. Clayton County makes it

a point to visually inspect each sprinkler riser in a complex (M. Griffin, personal communication,

August 8, 2011). Clayton County and Fulton County rank 5th and 6th in multifamily housing

unit’s protected and complete annual inspections. Both departments provide fire prevention

inspectors to clarify and support any issues found during the inspections. It appears that using

suppression personnel has been effective for these two jurisdictions.

       Cherokee and Rockdale Counties complete apartment inspections with fire inspectors but

do not conduct them annually. Both departments have suffered personnel cutbacks. Rockdale

County had two inspectors assigned, one for new construction and one for maintenance

inspections (B. Norton, personal communication, August 3, 2011). Bill Norton (personal

communication, August 3, 2011) added that when an inspection is completed, all inspection

records for required inspections by management were checked. Rockdale protects a population

of 85,215 and has 4918 multifamily units in its jurisdiction (U. S. Census Bureau, 2010).

Cherokee County protects a population of 214,346 and inspects 7,663 multifamily units (U. S.

Census Bureau). Chief Rick Ruh (personal communication, August 7, 2011) advised that his

staff was reduced by 50% to 4 personnel. He did add that when an inspection is completed, they
                                                               Apartment Inspection Program       43



spot check vacant apartments for compliance and only have inspectors assigned to maintenance

inspections (R. Ruh, personal communication, August 7, 2011).

         Douglas, Henry and Hall Counties all have a population of approximately 200,000 or less

and are responsible for 6000 or less multifamily housing units (U. S. Census Bureau, 2010).

Douglas and Henry County inspects apartments annually and utilizes one field inspector that is

assigned to maintenance inspections. Douglas County also checks handicap access during

apartment inspections (T. Furr, personal communication, August 2, 2011). Hall County has a

goal of inspecting apartments annually, but due to one inspector assigned to maintenance

inspections, prioritizes state mandated inspections (S. Cagle, personal communication, August

17, 2011). Scott Cagle (personal communication, August 17, 2011) admits that this goal is

currently unattainable.

         Forsyth County divides the county into zones and each inspector assigned to a zone is

required to complete new and maintenance inspections (K. Wallace, personal communication,

August 2, 2011). Apartment inspections are completed annually and the inspector schedules the

inspections between mandatory and new inspections. Smith (2006) aggress with this policy in

that it allows flexibility to conduct maintenance inspections while scheduling new work Forsyth

County is similar to Douglas and Henry counties in which the population is less than 200,000

and the jurisdiction protects less than 6000 multifamily housing units (U. S. Census Bureau,

2010).

         Cobb County was the only jurisdiction that has an inspector that is solely assigned to

apartment inspections. Nate Thomas (personal communication, August 3, 2011) conducts

inspections annually and is responsible for 200 complexes. Cobb County is the third most

populous jurisdiction is Metropolitan Atlanta with 575,519 citizens and 41,262 multifamily
                                                                Apartment Inspection Program        44



housing units within its jurisdiction (U. S. Census Bureau, 2010). When asked how he completed

so many inspections annually, he advised that his inspection consisted of reviewing required

documentation maintained by the management company of the annual sprinkler inspection

certificate, annual alarm testing certificates, fire extinguisher inspection reports and fire hydrant

testing reports (N. Thomas, personal communication, August 3, 2011). Nate Thomas (personal

communication, August 3, 2011) also advised that he spot checks common areas during his

inspections. What is interesting to note is Cobb County is the only jurisdiction with more than

40,000 multifamily housing units that completes annual inspections. Even though it appears that

the inspections completed are not as in depth as other jurisdictions, all of the engineering

protections are verified via required mandatory inspections by private contractors. This

researcher at first disagreed with this theory and the literature is mixed. The Fire Protection

Research Foundation (2008) states that at times performing more inspections is more effective

than fewer detailed inspections. IFSTA, (2009) counters that to reduce liability, it is better to

conduct more in depth inspections with follow up inspections than to conduct frequent

incomplete inspections.

       In summary, two jurisdictions in Metropolitan Atlanta do not complete apartment

inspections and the remaining complete a life safety inspection that includes the common areas

of the complex. None of the jurisdictions questioned inspected occupied apartments. Diamantes

(2007) aggress that it is common practice not to inspect private dwellings. Two jurisdictions

utilize suppression personnel with annual inspections, and the remaining departments utilize fire

prevention inspectors. Three Departments, Cherokee, Hall and Rockdale complete apartment

inspections less than annually. Each department has 8000 or less multifamily units to inspect.

Diamantes (2007) explains that the model codes do not establish the frequency of inspections.
                                                                Apartment Inspection Program         45



        Not requiring a frequency of inspection is in the best interest of fire departments in the

State of Georgia and reduces a potential burden if a requirement was mandated. Douglas, Forsyth

and Henry counties complete annual inspections but have less than 7000 multifamily dwelling

units in their jurisdiction. Cobb County, with greater than 40,000 multifamily units, utilizes an

inspector that is dedicated to apartment inspections and inspections are completed annually.

Cobb county is the only jurisdiction utilizing one fire prevention inspector with greater than

7,000 multifamily units that complets annual inspections. If the goal of a department is to

conduct annual inspections, then the research shows that either a dedicated apartment inspector

or the utilization of suppression personnel will assist with that goal.

       When reviewing Gwinnett County’s apartment inspection procedures, there are several

similarities and difference with the rest of Metropolitan Atlanta. Gwinnett County has the most

populous jurisdiction in Metropolitan Atlanta with 805,321 citizens and it protects 53,042

multifamily dwellings, which is the third most in the metropolitan region (U. S. Census Bureau,

2010). Gwinnett County completes apartment inspections utilizing field inspectors assigned to

the Special Enforcement Unit (J. Yoder, personal communication, July 13, 2011). The unit is

staffed with three inspectors and one Captain and are tasked with apartment inspections and

handling complaints (M. Phillips, personal communication, August 8, 2011).

       Prior to starting the inspection, a preinspection agreement form is given to management

clarifying the inspection and obtaining permission to inspect the premises (Appendix I). As with

other jurisdictions, the inspectors utilize a check sheet and complete a standard life safety

inspection of the common areas and verify required documentation of the annual fire alarm, fire

extinguisher, sprinkler inspection and fire hydrant inspections. In addition, inspections are

completed of attics, attic draft stops, any exterior mechanical areas that can be reached from the
                                                               Apartment Inspection Program          46



common area, a visual inspection of balconies for grills and vacant apartments (J. Yoder,

personal communication, 2011). After the inspection, which normally takes 3 hours to complete,

any needed notice of non compliance are issued and the complex is given a color rating of Red,

Yellow or Green (M. Phillips, personal communication, August 8, 2011). The purpose of the

rating is to prioritize future inspections after any reinspections are completed. The objective is

twice annual inspections for red properties, annual inspections for yellow properties, and

biannual inspections for green properties (M. Phillips, personal communication, August 8, 2011).

        Due to the complexity of the inspections, the initial phase of inspection process has been

delayed with the hopes of completing that phase during the fall of 2011 (B. Mitchell, personal

communication, August 11, 2011). As the properties become more compliant, it is expected that

the inspections process will become faster. Some of the violations have been significant and to

date, 42 citations have been issued and fines of $32,485 has been collected (B. Mitchell, personal

communication, August 11, 2011). Diamantes (2007) states it is “better to do less inspections,

than less than-adequate inspections” (p24). Even though other literature had different opinions

(The Fire Protection Research Foundation, 2008), this researcher agrees that a more complete

inspections, especially initially, is a better practice.

        Two unique elements not found in other departments in Metropolitan Atlanta was the

inclusion of a public education aspect and suppression personnel being invited to the inspection.

During the initial site visit, a fire educator meets with management to conduct a needs

assessment of the complex and occupants (B. Mitchell, personal communication, August 11,

2011). At the same time, management is assisted in developing a Fire Emergency Planning

Guide per Gwinnett County’s interpretation of the International Fire Code in section 408.9

(GCFES, 2010). The International Fire Code (IFC) does state in section 408.9 that an emergency
                                                               Apartment Inspection Program        47



guide shall be created, maintained and distributed to each tenant prior to initial occupancy

(International Code Council, 2006). Several sources of literature (Karter 2008; NFPA 2008)

agree that public education that is brought to the home is the best method to reduce residential

fires and casualties.

        By including the local suppression personnel during the initial inspections, you are

benefitting from territory familiarization and preplanning combined with public relations

between the property owners and suppression personnel. The suppression personnel are exposed

to the functions of the fire prevention division and the aspects of apartment inspections. As

(Diamantes, 2007) stated:

        The opportunity to preplan hazards, provide building familiarization, and the chance to

        establish cordial relations with the community can literally make in-service inspections

        the excuse that every chief wants to advertise the department. Training for company

        inspections should be prefaced with the fact that the goals of the in-service inspection

        program are building familiarization to increase firefighter safety, fire and hazard

        reduction, and community relations-in that order. (p19)

        What Gwinnett County is accomplishing with their apartment inspection program is the 3

E’s of fire prevention, Engineering, Enforcement and Education (USFA, 2002). The education

aspect, tied to enforcement, appears to be unique for the Atlanta area. A disadvantage to the

program to date is the timeframe to completion, with only 68% of the complexes being inspected

(B. Mitchell, Personal Communication, August 11, 2011).

        The purpose of this research paper was to determine if the GCFES current apartment

inspection program will decrease dollar loss and civilian casualties attributed to apartment fires.

In order to determine this, one must determine the common causes of apartment fires in Gwinnett
                                                              Apartment Inspection Program        48



County. Crawford (2005) and Newby (2008) agree that analyzing data must be completed to

determine community risk and while designing a fire prevention program.

       After reviewing NFIR queries for the time period 2007-2010, the data clearly shows that

in Gwinnett County; nearly as many contained cooking fires occur as apartment structure fires.

Specifically, 393 apartment structure fires occurred and 356 contained cooking fires occurred.

Ahrens (2010) confirms that nationally, 64% of apartment fires are caused by cooking fires. The

literature shows (FEMA 2010; NFPA 2008) that cooking fires are more likely to occur in

apartments than single family dwellings.

       When reviewing casualties in Gwinnett County, the results are even more alarming.

During the four year period, 2007-2010, 0.75 fatalities per 100 fires and 5.6 injuries per 100 fires

have occurred. FEMA (2010) reports a nationwide average of 0.3 fatalities and 2.9 injuries per

100 fires respectively. Gwinnett County’s rate is near double of the national average. Six

fatalities occurred during 2009-2010. Karter (2010) found a 19% increase in apartment fire

fatalities during 2009 compared to 2008.

       When reviewing the causes of casualties during apartment fires, all 6 fatalities and 1 life

threatening injury were coded undetermined. Severe injuries were reported at 3 and included

cigarettes, spontaneous combustion and heat from operating equipment. Seven major injuries

were reported. They were broken down as 3 from cooking, 3 from heat from operating

equipment and 1 undetermined.

       The remaining 23 minor injuries reported were 12 from properly operating equipment, 5

from cooking, 5 undetermined and 1 each due to candles and cigarettes. What is interesting to

note is that all reported casualties with a determined cause originated inside the dwelling and

outside the scope of the common life safety inspection for apartments. FEMA (2010) confirms
                                                               Apartment Inspection Program          49



this and explains that 54% of uncontained apartment structure fires occur in the kitchen,

bedroom or family room. FEMA (2010) continues by stating less that 4% of apartment structure

fires start on an exterior balcony or porch.

       The data is clear yet alarming. In Gwinnett County, as is the case nationwide, the

majority of apartment fires occur in occupied areas of apartment buildings. In Georgia,

Metropolitan Atlanta, and Gwinnett County, these areas are outside the scope of apartment safety

inspections. The restrictions to inspect occupied apartment units stem from fourth amendment

rights and model codes exempting the requirement to inspect dwellings routinely (Diamantes,

2007). State code also does not mandate the inspection of private dwelling units (Rules and

Regulations for the State Minimum Fire Safety Standards, 2010).

       State code also clearly defines what multifamily structures can be inspected. Rules and

Regulations for the State Minimum Fire Safety Standards (2010) clearly state that the structure

must contain 3 occupied levels. This researcher’s opinion is, with a strict interpretation of this

law, any 2 stories or less apartment building cannot legally be inspected.

       The authority having jurisdiction can enact more stringent local codes with the approval

of the governing body. I feel that the opportunity exists for Gwinnett County to enact stricter

engineering controls such as mandatory sprinkler requirements for apartments, fire suppression

hood systems, or enact local housing codes that provide language in lease agreements to provide

access to inspect fire rated assemblies and mechanical rooms.

       When reviewing the way inspections are conducted in Metropolitan Atlanta, the use of

suppression personnel seems a viable option. This option is especially viable for Gwinnett

County since suppression personnel are already attending the initial inspection visits. This

researcher feels, with a minimum of training and experience, suppression personnel can be
                                                                Apartment Inspection Program           50



utilized to conduct follow up inspections in apartment complexes when reinspections are

scheduled in the future. I feel this option is especially valid with properties that are rated green

and yellow. This option will also allow the Special Enforcement Division of the fire prevention

office to inspect other high risk occupancies such as extended stay motels and personal care

homes. As a note, if this option was to be valid, then the local Gwinnett County code must be

modified to allow company inspections (Gwinnett County Ordinance, Chapter 46, Fire

Prevention and Protection, 2006).

       If local codes can be modified to allow either more stringent engineering protection or

enforcement, then the researcher feels that both dollar loss and civilian casualties attributed to

apartment fires can be reduced. In the researcher’s opinion, combing both public education and

enforcement together with preplanning and building familiarization is unique and probably

currently the best option for Gwinnett County. The researcher feels that this concept should be

shared with other jurisdictions nationwide and can be modified to meet the local need.

                                         Recommendations

       The purpose of this research paper was to determine if the GCFES current apartment

inspection program will decrease dollar loss and civilian casualties attributed to apartment fires.

The literature clearly showed that the GCFES apartment inspection program was restricted due

to Georgia State Law and Gwinnett County Code. Two main issues identified were the

inspection of individual dwelling units and local code not requiring mandatory sprinkler

protection in apartment buildings. Further, the researcher identified that the majority of

apartment fires in Gwinnett County started in occupied apartments and are outside the scope of

the inspection program.
                                                               Apartment Inspection Program           51



      With the current restrictions noted, I recommend the following: (a) Modify the Gwinnett

      County Code to mandate fire sprinkler protection in all apartment buildings per the

      applicable NFPA 13 standard, (b) modify the Gwinnett County Code to read in lee of

      sprinkler protection in existing apartment buildings, mandate the installation of a

      residential hood fire extinguishing system in all apartment buildings, (c) Modify the

      Gwinnett County Code to allow apartment inspections by properly trained suppression

      personnel, (d) develop a partnership with local apartment management groups to provide

      educational opportunities for management and residents, (e) work with the partnership

      and the local housing code to allow inspections of fire rated assemblies and mechanical

      rooms in individual apartment units.(f) train and utilize suppression personnel to conduct

      apartment safety inspections under the supervision of a prevention fire inspector, (g)

      clarify the legality of apartment inspections in 2 story or less apartment buildings, (h)

      conduct an impact analysis of the apartment inspection program biannually, benchmark

      the results to other jurisdictions in the Atlanta area, and share the results with other fire

      departments.

      “A fire that does not occur is the one that is most easily controlled” (IFSTA, 2009, p. 13).

The researcher hopes that this research will provide recommendations for all fire departments to

       utilize by reducing the likely hood of apartment fires and their related casualties.
                                                               Apartment Inspection Program    52



                                             References

Ahrens, M. (2011). Home structure fires [White paper]. Retrieved June 7, 2011from National

       Fire Protection Web Site: http://www.nfpa.org/assets/files/PDF/OS.Homes.pdf

Crawford, B. A. (2005). Reducing fire risk for the poor. Fire Engineering. Retrieved June 7,

       2011 from: http://www.fireengineering.com/index/articles/generic-article-tools-

       template/_saveArticle/articles/fire-engineering/volume-158/issue-1/features/reducing-

       fire-risks-for-the-poor.html

Diamantes, D. (2007). Fire prevention inspection and code enforcement (3rd ed.). Clifton Park,

       NY: Thomson Delmar.

Diamond, L., & Stanford, D. D. (2006, February 17). Fire inspectors skipped 30 schools-missed

       checks lead to department shake-up. The Atlanta Journal-Constitution, p. J1.

Federal Emergency Management Agency. (2010, May). Multifamily residential building fires

       (FEMA). Emmitsburg, MD: FEMA.

Georgia Legal Services Program, Inc.. (2011). Georgia Landlord Tenant Handbook (10 ed.)

       [Brochure]. Atlanta, GA: Author.

Ghirardini, J. (2006, July 7). Fire officials taking report to heart. The Atlanta Journal-

       Constitution, p. J1.

Gillettee, J. K., III (2001). Criteria for selecting program guidelines for engine and medic

       company fire inspections. Unpublished manuscript, National Fire Academy, Emmitsburg,

       MD.

Gwinnett County Department of Fire and Emergency Services. (2010). Fire safety handbook for

       apartment managers [Brochure]. Lawrenceville, GA: Author.
                                                               Apartment Inspection Program       53



Gwinnett County Department of Fire and Emergency Services. (2011). Fire F.A.C.T.

       Lawrenceville, GA: Author.

Gwinnett County Department of Planning and Development. (2011, July). Gwinnett County 2010

       population, households, and housing unit estimates. Lawrenceville, GA: Planning data

       services section.

Gwinnett County Ordinance, Chapter 46, Fire Prevention and Protection, Gwinnett County GA

       § Chapter 46 (2006).

Hunt, A. (2011, August 13). DeKalb envisions bank for struggling properties. The Atlanta

       Journal-Constitution, pp. B1, B3.

Inspections - which do we do first? Past incidents in your district build a foundation for strategic

       planning. (2007). Firehouse.com. Retrieved June 7, 2011from:

       http://www.firehouse.com/topic/fire-prevention-and-investigation/inspections-which-do-

       we-do-first

International Code Council. (2006). International fire code. Country Club HIlls, IL: Author.

International Fire Service Training Association. (2009). Fire inspection and code enforcement (7

       ed.). Stillwater, OK: Author.

Karter, M. J. (2010, August). Fire loss in the United States during 2009. Retrieved June 7, 2011

       from : http://www.nfpa.org/assets/files/pdf/os.fireloss.pdf

Myers, B. (2003). Non-emergency medical transport and the gwinnett county department of fire

       and emergency services. Unpublished manuscript, National Fire Academy, Emmitsburg,

       MD.

National Fire Protection Association. (2008). Fire protection handbook (20 ed.). Quincy, MA:

       Author.
                                                             Apartment Inspection Program        54



Newby, S. J. (2008). Developing a residential risk reduction program for the Wichita Fire

       Department. Unpublished manuscript, National Fire Academy, Emmitsburg, MD.

Perez, W. (2008). Possible solutions to increase the number of residential fire inspections

       completed in three family and greater residential dwellings. Unpublished manuscript,

       National Fire Academy, Emmitsburg, MD.

Regulation of Fire and Other Hazards to Persons and Property Generally, 25 GA Code § 2

       (2006).

Rules and Regulations For the State Minimum Fire Safety Standards, 120-3-3 GA Safety Fire

       Commissioner § 120-3-3 (2010).

Smith, D. (in press). Inspector accountability: Managing inspections in an expanding

       community. Fire Engineering. Retrieved July 8, 2011, from

       http://www.fireengineering.com/index/articles/generic-article-tools-

       template/_saveArticle/articles/fire-engineering/volume-159/issue-1/features/inspector-

       accountability-managing-inspections-in-an-expanding-community.html

The Fire Protection Research Foundation (2008). Measuring the effectiveness of fire prevention.

       Retrieved June 7, 2011from:

       www.nfpa.org/assets/files//Metro%20Chiefs/ResearchFoundation.ppt

U. S. Census Bureau (2010). American Fact Finder [White paper]. Retrieved June 7, 2011 from

       factfinder.census.gov: http://factfinder.census.gov/home/saff/main.html?_lang=en

U. S. Fire Administration/National Fire Data Center (2009, October). Fire in the United States

       2003 - 2007 [White paper]. Retrieved June 7, 2011 from:

       http://www.usfa.dhs.gov/downloads/pdf/statistics/fa_325.pdf
                                                            Apartment Inspection Program     55



United States Fire Administration. (2002). 1947 Fire prevention conference [Fact sheet].

       Retrieved June 7, 2011 from http://www.usfa.dhs.gov/about/47report.shtm

United States Fire Administration. (2005). Executive leadership (5th ed.). Emmitsburg, MD:

       Author.

United States Fire Administration. (2011). Executive fire officer program applied research

       guidelines. Emmitsburg, MD: Author.

Webb, J. Q. (2008). An inspection and prevention program for multi-family dwellings in the town

       of Derry, New Hampshire. Unpublished manuscript, National Fire Academy,

       Emmitsburg, MD.
                                                                                                                         Apartment Inspection Program                                   56



                                                                               APPENDIX A

                                                        Results of Inspection Questionnaire




                                                                                           Suppression or




                                                                                                                                                                             Housing Units
                                                             Frequency of




                                                                                                                                                               Multifamily
     Jurisdiction




                                                                             Inspections




                                                                                                                      Inspectors?




                                                                                                                                                  Number of
                                                                                                                                     Population
                    Apartment

                                Inspection

                                             Program?




                                                                                                              Field
    Atlanta                        No                                       N/A                               N/A                   486,411                   119,586

Cherokee County                  Yes                       12 to 24 month                      Field Inspector                      214,346                    7,663

Clayton County                   Yes                                 Annual                             Suppression                 259,424                   28,609

 Cobb County                     Yes                                 Annual                    Field Inspector                      575,519                   41,262

DeKalb County                      No                                       N/A                               N/A                   691,893                   105,013

Douglas County                   Yes                                 Annual                    Field Inspector                      103,388                    2,699

Forsyth County                   Yes                                 Annual                    Field Inspector                      175,511                    2,050

 Fulton County                   Yes                                 Annual                             Suppression                 82,844                    18,330

Gwinnett County                  Yes                      12 to 18 Months                      Field Inspector                      805,321                   53,042

     Hall
                                 Yes                       Undetermined                        Field Inspector                      143,277                    2830
    County

 Henry County                    Yes                                 Annual                    Field Inspector                      203,922                    6104

                                                                   12 to 18                                   Field
Rockdale County                  Yes                                                                                                85215                      4918
                                                                    Months                                  Inspector
                                                      Apartment Inspection Program   57



                                   APPENDIX B

                     Causes of Apartment Fires in Gwinnett County




            120

            100

              80
Number




              60

              40

              20

                 0
                        2007             2008             2009            2010
         Structure       98               88              100             106
         Cooking         69               90              107              90
         Other           15               11              19               11
                            Apartment Inspection Program   58



          APPENDIX C

Apartment Fire Casualties by Cause
                                                             Apartment Inspection Program        59



                                         APPENDIX D

                  Interview Questions for Metropolitan Atlanta Fire Marshalls

Good afternoon,
I am currently completing a research paper on fire code/safety inspections of existing apartment
buildings. If you could please return this information within the next two days, it would be
appreciated. If you have any questions, I can be reached by email or the cell phone number listed
below.
1. Does your department complete existing fire code/safety inspections of existing apartment
buildings?
2. How often are the units inspected?
3. What areas of the building do you inspect?
4. Who completes the inspection? Personnel assigned to apparatus or dedicated fire inspectors?
5. If available, could you please provide a copy of the inspection form currently used by your
department?
Thank you,
Ken Chadwick
                                                               Apartment Inspection Program        60



                                          APPENDIX E

                     Interview Responses from Metropolitan Fire Marshalls

       As the researcher called each jurisdictions Fire Marshalls office to obtain contact

information, most respondents preferred to answer the questionnaire by phone.

       Interviews are listed below:

Phone conversation with City of Atlanta, August 2, 2011:

Chief Gregory Favors advised that the city does not conduct inspections and does not have a plan

to conduct inspections in the future. He also advised that Dallas, Texas had a good program.

Phone conversation with DeKalb County, August 3, 2011:

Chief Wayne Wright advised that he does not conduct apartment inspections. His division has

lost personnel due to an early retirement offer and he is under a hiring freeze. All available

personnel are either conducting new inspections or required maintenance inspections.

Phone conversation with Fulton County, August 2, 2011:

Chief Jack Butler advised that each engine company is assigned inspections of apartment

complexes in their first in territory. The inspections are completed annually. After the inspection,

the forms are submitted via interdepartmental mail. If a situation occurs that cannot be handled

by the company officer, an inspector is available for assistance. The inspection is a standard life

safety inspection is performed of the common areas. A standard form is used and was emailed to

the researcher.

Phone conversation with Clayton County, August 2, 2011:

Lieutenant Mitch Griffin supervised the apartment inspection program. The apartment

inspections are assigned to each engine companies first in territory. Each complex is inspected

annually. A standard life safety inspection is completed and each building that is equipped with
                                                             Apartment Inspection Program         61



sprinklers has the riser checked. Only the common areas are inspected. If a code violation is

found, then one of six inspectors is available to meet with the engine company.

Phone conversation with Fayette County, August 2, 2011:

The researcher was advised that Fayette County did not have any apartment buildings in their

jurisdiction and ended the conversation prior to getting contact information.

Phone conversation with Douglas County, August 2, 2011:

Captain Thomas Furr advised that apartment inspections are completed and are done annually. A

standard life safety inspection is conducted and handicap access is checked also. Only the

common areas are inspected. The department does not use a standard sheet and one inspector is

assigned to all maintenance inspections. Captain Furr also advised that they are only 8

complexes in his jurisdiction.

Phone conversation with Forsyth County, August 2, 2011:

Captain Kevin Wallace advised that apartment inspections are completed annually, a standard

life safety inspection of the common areas is conducted and a visual check from the common

areas of balconies is completed. The county is divided up into 5 zones and each inspector is

responsible for both new and existing maintenance inspection in that zone. This allows his

inspectors to schedule inspections as time permits. He also advised that they do use a standard

form and his jurisdiction is responsible for 10 complexes.

Phone conversation with Rockdale County, August 3, 2011:

Chief Bill Norton advised that 2 inspectors are assigned to his division. One handles new

inspections and the other handles existing to include apartments. Inspections are scheduled to

occur every 12 to 18 months but are a lower priority than required mandated inspections. A

standard life safety inspection of the common areas is completed. Additionally, the inspector will
                                                              Apartment Inspection Program      62



also check the required paperwork reference mandatory sprinkler letters, smoke detector and fire

extinguisher tests that should be conducted by management of the occupied apartments.

Phone conversation with Cobb County, August 3, 2011:

Inspector Nate Thomas is responsible for and completes all apartment inspections. He advised

that he inspects 200 complexes a day. He utilizes a check list from a tablet and conducts a

standard life safety inspection. His inspection includes a review of all required inspections

maintained by management of the protective devices such as sprinklers, fire extinguishers, alarm

systems and fire hydrants. He conducts spot checks of common areas during the inspections. He

also advised that he is a very busy man.

Phone conversation with Henry County, August 3, 2011:

Lieutenant O’Brien advised that one inspector handles maintenance inspections in the county and

conducts annual inspections of apartment complexes but they are only responsible for 10

complexes. A standard life safety inspection is conducted of the common areas and the

clubhouse.

Cherokee County Replied by email on 8/7/11: All contact information has been removed by the

researcher

 Please see my comments in red below.
Rick Ruh, CFPS
Division Chief
Fire Marshal
Fire Marshal’s Office
1130 Bluff’s Pkwy
Canton, GA 30114

Good afternoon,
I am currently completing a research paper on fire code/safety inspections of
existing apartment buildings. If you could please return this information within
the next two days, it would be appreciated. If you have any questions, I can be
reached by email or the cell phone number listed below.
                                                            Apartment Inspection Program      63



   1. Does your department complete existing fire code/safety inspections of
      existing apartment buildings?
      We currently make every effort to conduct annual inspection of all
      apartment building in the county. All apartments were inspected 2 years
      ago.

   2. How often are the units inspected?
      Every two years (manpower permitted) Note: Fire Marshal’s Office has gone
      through a 50% reduction in workforce.

   3. What areas of the building do you inspect?
      All common areas and some of available vacant units.

   4. Who completes the inspection? Personnel assigned to apparatus or dedicated
      fire inspectors?
      Certified Fire Inspectors (state and nationally certified)

   5. If available, could you please provide a copy of the inspection form
      currently used by your department?
      We don’t use forms per se, our data base has drop down menus and each
      report is basically a unique report for the occupancy.

Thank you,
Ken Chadwick

Hall County also replied by email on 8/17/11. Note that all contact information was removed by
the researcher.

Good morning Captain Cagle,
This is a follow up to a phone message I left you yesterday.
I am currently completing a research paper on fire code/safety inspections of existing apartment
buildings. If you could please return this information within the next two days, it would be
appreciated. If you have any questions, I can be reached by email or the cell phone number listed
below.
1. Does your department complete existing fire code/safety inspections of existing apartment
buildings? Yes
2. How often are the units inspected? Try once a year but may move this type of occupancy to
once every two years due to lower staff
3. What areas of the building do you inspect? Common areas (egress corridors, laundry facilities,
pools, exercise rooms etc)
4. Who completes the inspection? Personnel assigned to apparatus or dedicated fire inspectors?
Fire Inspectors
5. If available, could you please provide a copy of the inspection form currently used by your
department? See attached

Thank you,
Ken Chadwick
Battalion Chief Ken Chadwick
                                                Apartment Inspection Program   64




From: Ken.Chadwick@gwinnettcounty.com
[mailto:Ken.Chadwick@gwinnettcounty.com]
Sent: Wednesday, August 17, 2011 1:04 PM
To: Scott Cagle (Fire Services)
Subject: RE: inspection questions

Thank you so much Scott for your reply. Two additional questions.

1. Very rough estimate, approximately how many complexes do you have in the
county that you inspect?
2. Are the inspections divided up by zone, by inspector, or are certain
inspectors assigned only to apartments.

Thanks again,
Ken

Battalion Chief Ken Chadwick
Gwinnett County Department of Fire & Emergency Services Battalion 5 C Shift

LOL! My staff has went from 6 to 2!

So:
- one person does all new construction (50%, 80% and 100% inspections)

- the other does all maintenance/annual inspections...or tries too! In the
real world I know one person cannot do all 6,000 businesses in Hall County.
So, we do the schools, daycares, and other high -hazard or high-occupancy
buildings every year. The rest...we do the best we can.

- I do all plans review, lead on all investigations, handle complaints, and
"other duties" as needed.

I am guessing we only have around eight or fewer. Most of the apartment
complexes are in the city of Gainesville's jurisdiction because they want on
sewer...so the city deals with most of them.

Capt. Scott Cagle
Hall County Fire Marshal
Hall County Fire Services
P.O. Box 907730
Gainesville, GA 30501
                                                            Apartment Inspection Program     65



                                          APPENDIX F

                                   Email from Brandy Mitchell

         This email was in response to general discussion about community risk’s involvement in

the apartment inspection program. This email was received on August 11, 2011

Chief,

Here is some information as of 08-05-2011 for the year of 2011 only. I

put hotel info in there for a comparison if needed. I could elaborate on

ANYTHING you need. I would have added more info if I knew the specifics.

Sorry! Let me know if I can be of anymore help!

The Apartment Inspection Program focuses on Fire and Life Safety Code

compliance within apartment communities in Gwinnett. The program is

comprised of:

1. Preliminary visit from deputy fire marshals, fire educators, and

field personnel to conduct compliance inspections, educational needs

assessments, and perform pre-plan activities

2. Subsequent inspections are conducted to achieve compliance

The program is projected to complete the initial compliance inspections

for all Gwinnett apartment complexes by Fall of 2011.

(59% completion as 1st quarter 2011)



Internal restructuring has expanded enforcement efforts in detection of

Fire and Life Safety Code violations in existing commercial occupancies.

The numbers of documented violations have increased by 50% in the first

quarter comparison of 2010 to 2011. Strategic efforts to enforce the

Gwinnett County Safety Ordinance continue with night inspections and

collaborations with other local government agencies.
                                                             Apartment Inspection Program    66



The following program update was attached to the email above.

Community Risk Reduction Program Update 05-10-11

Apartment Inspection Program
Total Apartment Complexes                                   200
Total Apartment Complexes inspected                         136
Total Apartment Complexes in compliance                     74
Total Apartment Complexes issued citations                  28


Apartment Complexes complete                                68%
Apartment Complexes in compliance                           54%
Apartment Complexes with citations                          20%


Total inspections performed on apartment complexes          5115
(Includes pre-inspection meetings, inspections, re-inspection, court inspections, & report
reviews)


Goals:
Initial inspections                                         09/2011
Annual inspections                                          2012
Annual Apt Manager Conference                               June 2012
Fire F.A.C.T.                                               (Pending)
                                                               Apartment Inspection Program     67



                                           APPENDIX G

                                  Email Chain from Matt Phillips

        The following email was received with specific questions about the enforcement section

of the apartment inspection program.

From: Chadwick, Ken
Sent: Sunday, August 07, 2011 9:27 PM
To: Phillips, Matthew
Subject: number of inspectors completing the apartment inspections
Hey Matt,
I have a couple of quick questions.
1. Could you please provide me the number of inspectors that you use for the apartment
inspections?
2. Do you have any idea how many man hours were dedicated to the program both during 2010
and so far this year?
3. Do you have a dollar amount of fines that you have collected during 2010 and so far during
2011?
I was going to do a quick cost/benefit analysis if those figures are available.
Thanks for all your help,
Ken
From: Phillips, Matthew
Sent: Mon 8/8/2011 07:48
To: Chadwick, Ken
Subject: RE: number of inspectors completing the apartment inspections

Chief Chadwick,
   1. There are currently three inspectors and one captain assigned to our Special Enforcement
        Section. We are responsible for inspecting all of the apartments as wells as the
        complaints received throughout the county. We utilize color coding to determine the
        potential hazard that exists. Green being very good, Yellow being average, and Red being
                                                               Apartment Inspection Program       68



       poor. Our goal is to inspect green at close to a one year increment, yellow annually, and
       red every 6 months.
   2. We don’t record our hours spent on each inspection. However, on average it is about 3
       hrs. We typically start about 0900hrs and conclude around lunch. Obviously this will
       depend if I have all of my inspectors, or if it’s like today and I am the only one here.
   3. This I will have to get to you hopefully tomorrow. It is available, but the person who
       tracks these numbers is not in today.
Matthew Phillips
Special Enforcement Captain




From: Chadwick, Ken
Sent: Monday, August 8, 2011 8:41 AM
To: Phillips, Matthew
Subject: FW: number of inspectors completing the apartment inspections plus a few other things
Hi Matt, sorry to bother you again. A couple of short items:
1. If you can get the dollar amount of fines you collected, that would be great.
2. I was also wondering the total number of apartment complexes you have listed that need
inspection in the county?
3. You also mentioned the color coding system. I'm assuming that apartment complexes are
"green" rated? Thus the goal for 'near annually"
4. Who would have an organizational chart of the CRR section and a listing of personnel in each
division? I just need it for the background section of the paper.
Thanks for all your help. I'll stop pestering you next week.
Sincerely,
Ken
                                                                Apartment Inspection Program    69




From: Phillips, Matthew
Sent: Mon 8/8/2011 09:10
To: Chadwick, Ken
Subject: RE:



I am still waiting for the fines and dollar amount, but the rest is:
   1. 178 apartments (that we know of) in Gwinnett County
   2. Green (the very few and the proud): 18months-24months, Yellow: annual, Red: every 6
       months
   3. The org chart could be obtained from Chief Yoder.
Ultimately, we would like to do the vast majority of apartments annually. I think there might
have been a dozen that got a green tag, but the vast majority is yellow and probably 2 dozen that
need constant attention.
Matthew Phillips
Gwinnett County Community Risk Reduction
Special Enforcement Captain
                                                              Apartment Inspection Program         70



                                          APPENDIX H

                    Interview notes with Assistant Fire Marshall Jeff Yoder

       This interview took place on July 13, 2010. The subject was chosen due to his tenure in

the Gwinnett County Fire Marshall office and had information concerning the evolution of the

program.

       1. What prompted the initiation of the apartment inspection program?

           The inspection program got its roots from the fall out of the missed school inspections

           that occurred in 2006. After the reorganization of the Fire Marshalls office in 2007,

           an Assistant Fire Marshall Position was established and tasked with maintenance

           inspections. The first priority was schools. During 2007 and early 2008, the schools

           became more compliant and inspectors were available for other inspections. At the

           same time, the economy slowed and new construction slowed. During 2009, early

           retirements and a work force reduction were put into place. Many of the new

           construction inspectors were available for reassignment. Hence the office was

           reorganized again and the Special Enforcement division was created in mid 2009. At

           first the design was to check night clubs and handle complaints throughout the county

           in addition to mandatory inspections. During 2009, we had several high profile

           apartment fires with several fatalities. The need became apparent that apartment

           inspections were needed and hence the organization of the program.

       2. How are the inspections conducted?

           The inspections use a standard life safety inspection form that is loaded on the tablets.

           Captain Matt Phillip is supervising the program and has three inspectors under him.
                                                       Apartment Inspection Program        71



   They are currently tasked with the apartment inspections, investigate any complaints,

   and assist other inspectors if the need arises.

3. What is inspected during an inspection?

   All the common areas are inspected including the clubhouse, office and laundry

   facilities if they are separate from the apartments. Due to 4th amendment rights, we do

   not inspect individual apartments. We also, especially on the initial inspection, try to

   inspect any accessible mechanical room and check attic draft stops. We also inspect

   any vacant apartments because we have had several incidents of squatters staying in

   those units. We also try to visualize the porches and decks to check for BBQ grills.

   Part of the safety inspection includes checking mandatory alarm test records,

   sprinkler test records, fire extinguisher test records and hydrant test records.

4. How is enforcement handled?

   The inspectors issue a notice of noncompliance unless the issue is an immediate life

   threat. A reinspection is scheduled within 14 days. If the issued is not resolved, then

   the inspector has the discretion to cite the offender. Due to current language in the

   Gwinnett County Code that reference the National Fire Code instead of the

   International Fire Code, some cases in the County Court system have been thrown

   out. Most of the city courts have ruled favorably. The current County Code is due to

   be revamped and a new code should be approved in early 2012.

   5 Is there anything else you would like to add?

   Community risk reduction is working with enforcement during the apartment

   inspections and offering education to both managers and tenants. A new supervisor

   will soon be in that position and they can provide you with more information. One
                                                   Apartment Inspection Program    72



thing they are doing is requiring management to produce a fire safety emergency plan

for their complex. The requirement is in the International Fire Code and we have just

started enforcing it. I also have been told that involving the local suppression

personnel has been very successful.

I ended the interview with the acknowledgement that I head good things about the

program and the inspections would soon be starting in my Battalion. My personnel

were looking forward to partake in the inspections.
                              Apartment Inspection Program   73



             APPENDIX I

Gwinnett County Inspection Consent Form
Apartment Inspection Program   74
                                    Apartment Inspection Program   75



                   APPENDIX J

GCFES NFIR Query Incident by Property Type 2007-2010
Apartment Inspection Program   76
Apartment Inspection Program   77
Apartment Inspection Program   78
                                      Apartment Inspection Program   79



                    APPENDIX K

GCFES Incident Query Causality by Heat Source 2007-2010
Apartment Inspection Program   80
Apartment Inspection Program   81
Apartment Inspection Program   82
                         Apartment Inspection Program   83



         APPENDIX L

GCFES Apartment Inspection Form
Apartment Inspection Program   84
                                                              Apartment Inspection Program       85



                                          APPENDIX M

                            U.S. Census Bureau Fact Finding Website

The website address is http://factfinder.census.gov/home/saff/main.html?_lang=en Each

jurisdiction identified was entered into the fast access to information portion of the website. The

data was then analyzed as stated in the procedures section.

				
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