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)