Purpose of This Brief:To help GSA employees and contract personnel achieve fire safety while preserving the character of historic properties in compliance with the National Historic Preservation Act of 1966, as amended (NHPA).

How Does Fire Safety Relate to NHPA? Any alterations planned by a Federal agency for a historic property, including the addition of fire safety systems, must comply with Section 106 of the National Historic Preservation Act (NHPA).

Who Needs This Information? GSA staff, A/E's, and their consultants involved in creating fire safety assessments, Building Evaluation Reports, fire safety retrofitting projects, and related activities.

Your Responsibility: Apply the policies, standards, and guidelines below when contracting/developing fire safety assessments, Building Evaluation Reports, fire safety retrofitting projects, and related activities.

• GSA Policy: Fire Safety Retrofitting in Historic Buildings (August, 1989)
• Department of the Interior's Federal Standards
• Character-Defining Original Building Materials and Spaces
• Fire Safety Retrofitting Methodology

GSA Policy: Fire Safety Retrofitting in Historic Buildings (August, 1989)

In August 1989, GSA published Fire Safety Retrofitting in Historic Buildings in cooperation with the Advisory Council on Historic Preservation. This document provides guidance to ensure that fire safety retrofitting has minimal impact on the historic features of the property. Excerpts follow:

Protection and preservation of significant features can be accomplished by applying the following standards:

• Creativity to ensure the consideration of all possible alternatives that would balance the needs to protect life and property with the overall preservation objectives

• Flexibility to apply and adapt fire safety codes of risk reduction requirements to achieve historic preservation objectives

• Practicality to resolve conflicts between fire safety and historic preservation objectives creatively and flexibly

The purpose of the Fire Safety Assessment is to determine how best to correct deficiencies in a manner that both ensures fire safety and preservation of historic features. Critical to this assessment is the understanding that building codes and life safety codes are guidelines, not prescriptions, for the fire safety retrofitting of historic buildings. Strict application of the codes may result in the destruction of highly significant features and must be avoided through creative and flexible application of codes.

The decision making process for fire safety retrofitting in historic buildings:

1. Assessment of historic significance (Historic Structure Report/Building Preservation Plan) and fire safety risks
2. Evaluation of objectives for fire safety and historic preservation
3. Selection of proposed solutions: appropriate fire safety hardware and historic preservation techniques
4. Review of proposed solutions with authorities having jurisdiction
5. Implementation including verification of original intent

Department of the Interior's Federal Standards for Implementation of National Historic Preservation Act of 1966, As Amended

Excerpts from the Secretary of Interior's Standards for Rehabilitation

(Federal standards used for review of projects under National Historic Preservation Act of 1966, as amended)

The Department of Interior standards and guidelines that apply to fire safety retrofitting are listed below.

2. Retain and preserve the historic character of the property. Avoid removing historic materials or altering features and spaces that characterize the property.

5. Preserve distinctive features, finishes, and construction techniques or examples of craftsman that characterize the historic property.
6. Retain rather than replacing historic materials. Where the severity of deterioration requires replacement of a distinctive feature, the new feature shall match the old in design, color, texture, and other visual qualities, and where possible, materials. Replacement of missing features shall be substantiated by documentary, physical, or pictorial evidence.

9. Alterations shall not destroy historic materials that characterize a property. The new work shall be compatible with the massing, size, scale, and architectural features to protect the historic integrity of the property.

Department of Interior Guidance for Applying the Secretary's Standards to Health and Safety Requirements:

• Work with officials to investigate alternative life safety measures or variances so that alterations and additions to historic buildings can be avoided.

• Upgrading historic stairways and elevators to meet health and safety codes in a manner that assures their preservation, i.e., so that they are not damaged or obscured.

• Installing sensitively designed fire suppression systems instead of applying fire-resistant sheathing to character defining features.

Here are examples of original spaces and materials where creative and flexible approaches to fire safety retrofitting are needed. For building specific identification of significant spaces and materials, see the individual building's Historic Structure Report or Historic Building Preservation Plans.

Roofs Stone
Entrances Brick
Walls/Windows
Site/Landscaping

Fire Safety Retrofitting Methodology

Excerpts from Fire Safety Retrofitting:

It is vital that each project team utilize a design process that will successfully integrate the contemporary needs of fire safety into the building with minimal effect on significant historic features...Both historic preservation and fire safety issues require specialists to properly research, document, and then recommend solutions for a given project. Because of these special requirements, it is necessary that consultation and project coordination occur at the earliest possible time so that individual project objectives can be shared and developed into mutual objectives.

Sequence for Successful Fire Safety Retrofitting

1. Fire safety assessment - Contracting for Concept:

• Retain a specialist to identify original spaces and materials affected & develop creative solutions. (Note: this individual may be a preservation consultant or a fire safety engineer specializing in historic preservation projects. The Regional Historic Preservation Officer must verify the preservation consultant's qualifications for performing this work prior to award of contract for services)

2. Fire safety assessment - Developing Concept Recommendations:

• Develop creative solutions to minimize impact on historic character
• Initiate Section 106 review of design concept - receive and respond to comments
• Prepare budget based on preservation/fire safety design concept review

3. Fire safety retrofitting - Development of Construction Documents

• Retain a historic preservation team member consultant (HPTM) using standard scope of work provided in Preservation Note 9, revised September 1995, to develop the design concept
• Have HPTM prepare Section 106 project documentation for submission by the Regional Historic Preservation Officer, WPTP to State Historic Preservation Office (SHPO) and Advisory Council on Historic Preservation (ACHP).
• Receive notification of completion from the RHPO of NHPA Section 106 design review by the SHPO and ACHP

4. Fire safety retrofitting - Construction

• Prior to contract award, use the HPTM consultant to review technical qualifications of prospective construction contractors for each specialty restoration work
• Use HPTM to review proposed methods for protecting historic materials during construction
• Use HPTM to review samples of new materials to be installed in restoration and rehabilitation zones, as defined in Historic Structure Report/Historic Building Preservation Plan
• Use HPTM to review on-site sample to assure that specialty restoration work meets contract performance criteria