IR A-28 (Revised 08/20/24) Page 1 of 3
DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
IR A-28
FIRE ALARM SYSTEM CHANGES IN EXISTING BUILDINGS
Disciplines:
Fire and Life Safety History: Revised 08/20/24
Original Issue 04/27/10
Division of the State Architect (DSA) documents referenced within this publication are available
on the DSA Forms or DSA Publications webpages.
PURPOSE
This Interpretation of Regulations (IR) describes the DSA requirements for the complete or
partial change of a fire alarm (F/A) system in an existing building due to obsolescence,
catastrophic failure, voluntary upgrading, or as part of an alteration or modernization project.
BACKGROUND
Submittals for fire alarm system projects consist of detailed drawings, manufacturer’s installation,
testing, and maintenance documentation, listing documentation from a nationally recognized
testing laboratory (NRTL) and the California State Fire Marshal (SFM), and specifications for the
various components and devices intended for installation. Fire alarm system submittals related
to existing buildings may consist of total replacement, partial alteration affecting only a portion of
an existing system, or work necessary to effect emergency repair.
1. PROCESS
Other than routine maintenance or emergency repairs, all work on an existing fire alarm system
requires submittal to DSA for review and approval prior to performing the work. Upon
completion of the work, that portion of the fire alarm system in the scope of work shall be
inspected and subjected to reacceptance testing as outlined in Section 14.4 of NFPA 72 as
adopted and amended. Upon successful completion of the acceptance or reacceptance
inspection and testing, an NFPA 72 Record of Completion form shall be completed by the fire
alarm system contractor and a copy of the completed and signed form given to the architect or
engineer of record (EOR), the project inspector (PI), and the owner (school or community
college district).
1.1 Total Fire Alarm System Replacement
Fire alarm systems in existing buildings that are replaced in their entirety due to inability to be
repaired or obsolescence must be designed and installed compliant with current codes and
standards in effect at the time of submittal as adopted and amended, and include extension into
any previously unprotected areas.
1.2 Partial System Alteration
It is not required to upgrade an entire existing building or campus fire alarm system when not
totally replacing the system, but the plan submittal package must include assurance in the form
of a letter from the fire alarm system design professional certifying that all components and or
devices of the system are listed and compatible. All new or added components or devices must
meet current codes and standards as adopted and amended, including California Building Code
(CBC) accessibility requirements for approach (forward or parallel), reach range, and audible
and visual occupant notification in compliance with CBC Chapter 11B.
1.3 Emergency Repair
As systems and components age, fault conditions or component failure can occur. As a life
safety system, continued operation of the fire alarm system is critical in maintaining the level of
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IR A-28 (Revised 08/20/24) Page 2 of 3
DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
protection for building occupants, and in these situations the school district shall take such
actions as necessary to effect immediate repair to return the system to a normal operating state.
Emergency repair work does not require prior plan submittal or approval, but the design
professional shall submit to the DSA plans and associated documentation reflecting the nature
and extent of the repair work prior to performing required reacceptance testing.
2. DESIGN REQUIREMENTS
All areas undergoing alteration or modernization where the project scope affects the design of
existing fire protection and life safety systems shall maintain or enhance the level of protection
provided and are required to meet current code requirements with additional devices added to
those areas as necessary to maintain compliance with current adopted and amended codes and
standards.
2.1 Systems shall be designed in accordance with California Fire Code (CFC) Section 907,
and be installed in accordance with NFPA Standard 72, National Fire Alarm and Signaling
Code, as adopted and amended in CFC Chapter 80, and the manufacturer’s listing, installation,
and testing instructions.
2.2 Project submittals shall include complete information on drawings, floor plans, detail
sections, reflected ceiling plans (RCP), and site plans as necessary to clearly reflect the project
scope of work and the existing building configuration, current and complete manufacturer’s
product (cut) sheets, copies of listing documentation from a nationally recognized testing
laboratory (NRTL), and current California State Fire Marshal (CSFM) listing sheets. For
additional guidance refer to Guideline (GL) 2: Fire Alarm and Detection Systems.
2.3 Where manufacturer’s product (data) sheets include multiple models and or reflect multiple
operating voltages, the criteria for the specific model being installed shall be clearly identified.
3. VISUAL ALARMS
3.1 Visual alarm notification appliances shall be provided in accordance with CFC Sections
907.5.2.3.1 through 907.5.2.3.4.
3.2 Visual alarm notification appliances shall be provided as necessary to provide a level of
notification as required by those adopted codes and standards in effect at the time of project
submittal.
4. CHANGES TO SUBMITTED AND DSA APPROVED DOCUMENTS
Where construction plans and documents have been submitted and approved by DSA, but the
accepted fire alarm bid package includes a different manufacturer and or product model for the
fire alarm control unit (FACU), power extenders, notification appliances, initiating devices, etc.,
then the following shall apply:
4.1 Where the system design has not changed with respect to locations of appliances, routing
of wire, extension of circuits, etc., and the voltage demands of the substituted appliances and
devices are the same as or less than those approved, a construction change document (CCD-A)
shall be prepared in accordance with IR A-6: Construction Change Document Submittal and
Approval Process and submitted to DSA.
The architect or engineer in general responsible charge shall provide:
4.1.1 A letter from the fire alarm system design professional (subject to DSA review and
acceptance) certifying that the design and system requirements have not changed, and the
notification appliances and initiating devices have equal to or less voltage demands than those
originally submitted.
4.1.2 New component or device manufacturer’s product data sheets (cut sheets) and
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DIVISION OF THE STATE ARCHITECT DEPARTMENT OF GENERAL SERVICES STATE OF CALIFORNIA
associated CSFM listing sheets for each type and model of notification appliance, device, etc.
4.2 Where substantial changes are made to the design, or the voltage demands of the new
manufacturer’s equipment are higher than those originally approved, then a “revision” or an
“addendum” must be submitted to DSA for review and approval.
5. REPAIR AND MAINTENANCE
5.1 Repair is considered the replacement in kind of a defective component or device
necessary to maintain the level of protection and design operability. Replacement components
or devices must be CSFM listed and approved, and compatible with the existing FACU. Those
components previously having a CSFM listing for which a current listing is not available are
acceptable.
5.2 Repair of an existing inoperative fire alarm system is considered emergency work and does
not require submittal of plans, specifications, or other documents to DSA prior to performing the
work. Plans prepared as outlined in Section 2 above, shall be submitted to DSA as soon as
possible, and prior to performing reacceptance testing.
5.3 All repair work is subject to inspection and testing.
RESOURCES
The following resource documents are available on the DSA Publications webpage.
Project Submittal Guideline:
• GL 2: Fire Alarm and Detection Systems
DSA Interpretation of Regulations:
• IR A-6: Construction Change Document Submittal and Approval Process
• IR A-18: Use of Construction Documents Prepared by Other Professionals
REFERENCES:
2022 California Administrative Code (CAC), Section 4-215
California Building Code (CBC), Section 907
California Fire Code (CFC), Section 907
2022 NFPA Standard 72, as adopted and amended.
This IR is intended for us
e by DSA staff and by design professionals to promote statewide consistency for review and
approval of plans and specifications as well as construction oversight of projects within the jurisdiction of DSA, which
includes State of California public schools (K‒12), community colleges and state-owned or state-leased essential
services buildings. This IR indicates an acceptable method for achieving compliance with applicable codes and
regulations, although other methods proposed by design professionals may be considered by DSA.
This IR is subject to revision at any t
ime. Please check DSA’s website for currently effective IRs. Only IRs listed on
the webpage at www.dgs.ca.gov/dsa/publications at the time of pr
oject application submittal to DSA are considered
applicable.
