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Most Common Problems with Places of Assembly | Greenlight Expediting

Most Common Problems with Places of Assembly

Emergencies requiring quick exit from a building can quickly turn catastrophic when there are many people on the premises.  As a result, the Department of Buildings holds buildings with a Place of Assembly permit to a high standard, and it’s easy to get written up.  Here are the most common problems throughout the PACO permit application process, as identified by the DOB:

Most Common Objections for Plan Exam:

  • The individual space, floor, or building does not provide the necessary egress to support the place of assembly (PA) activity.
  • The building’s Certificate of Occupancy does not reflect the correct use.
  • The travel distance between PA space and fire-rated safe area, such as a stairwell or outside, does not meet minimum Construction Codes requirements.
  • The separation between kitchen and PA space is not fire-rated according to Construction Codes requirements (only applicable for kitchens where cooking will occur).

Most Common Reasons for Failing PA Inspection:

  • Exit signs are not in the correct area (they do not comply with Construction Codes or do not match approved plans).
  • Failure to post occupancy sign indicating the maximum number of people allowed in the space.
  • Failure to produce Emergency Lighting Letter or TR1 Form.
  • Improper locking devices on doors (they do not comply with Construction Codes or do not match approved plans).

Even after a PA certificate is granted, the FDNY will still conduct periodic inspections to ensure the premises remains adherent to guidelines.  If problems are found, the FDNY will issue either a Notice of Violation for problems that are not imminently dangerous, or a Violation Order for imminent safety hazards.  Below are the most common reasons for each:

The Most Common Reasons Why FDNY Issues ECB Violations (NOVs):

  • Failure to post permits (e.g., PA, maximum occupancy sign, Certificate of Occupancy)
  • Failure to produce flame proofing affidavit
  • Valid Certificate of Fitness/Certificate of Qualification holder not on site (Only applicable for certain types of PA spaces such as banquet halls and cabarets
  • Missing or damaged lighting or exit signs

The Most Common Reasons Why FDNY Issues Violation Orders (VOs)

  • Approved floor plans or PA not on site
  • Plans not updated after major renovation
  • Operating contrary to Certificate of Occupancy (C of O)
  • Observed establishment name, owner name or use description does not match
  • records
  • Obstruction in travel path (path from PA space to fire-rated safe area, such as
  • stairwell or outside)
  • Egress blocked or locked
  • Overcrowding (more people in space than allowed by PA)


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