510.5.3 Minimum qualifications of personnel. 

The minimum qualifications of the system designer and lead installation personnel shall include both of the following: 

1. A valid FCC-issued general radio operators license. 
2. Certification of in-building system training issued by an approved organization or approved school, or a certificate issued by the manufacturer of the equipment being installed.

These qualifications shall not be required where demonstration of adequate skills and experience satisfactory to the fire code official is provided.

Let’s break down the key elements of this language:

1. Qualifications of personnel means individuals. 
2. Requires qualification for system designer and lead installation personnel. The required skills are not limited to simple testing or maintenance. 
3. The language makes references to credentials that are only available to individuals: 
1. FCC GROL license 
2. Certification of in-building system training

Credentialing of Individuals Compared to Credentialing of Organizations

Some credentials are offered to individuals, and some credentials are offered to business or organizational entities. The following table illustrate examples of each. Think about each example and ask yourself: “Could I move any of the Individual Credential examples to the Organization column in the table below?”:

 The credentials associated to individuals listed above share several things in common:

• They require testing to validate competency. 
• Many require demonstration of practical skills (driving test, pilots licenses). 
• They result in the issuance of proof of certification (like a driver’s license, diploma, or similar). 
• Many have expiration dates that require renewal. 
• Some have the requirement for continuing education and continued evidence of competency. 
• They do not typically provide the ability to convey a license or certification to another individual. 

Should we certify companies or individuals for ERCES?

If a company has a top-level ERCES Designer and a top-level ERCES Level III Technician, you can say they have good internal competency. But if both professionals took jobs at another company and were never replaced, is the company still as competent as it once was?

It is essential to understand the qualitative difference between credentialing of individuals and credentialing of companies, and what you can assume or infer about the quality of work they do.

Are the Current Minimum Qualifications of Personnel Requirements for ERCES in IFC Adequate?

No. The weak link is the FCC General Radiotelephone Operator License (GROL). Following are the shortcomings:

Scope. The FCC describes the scope of the GROL as follows:

General Radiotelephone Operator License (PG): A PG is required to adjust, maintain, or internally repair FCC licensed radiotelephone transmitters in the aviation, maritime, and international fixed public radio services. It conveys all of the operating authority of the Marine Radio Operator Permit (MP). It is also required to operate the following:

• any compulsorily equipped ship radiotelephone station operating with more than 1500 watts of peak envelope power. 
• voluntarily equipped ship and aeronautical (including aircraft) stations with more than 1000 watts of peak envelope power 

These do not describe the kind of competency needed to design or install ERCES.

Pass a Test only. No experience Necessary. No Validation of Practical Skills

Written Examination Elements.

Element 1 - Basic radio law and operating practice with which every maritime radio operator should be familiar. To pass, an examinee must correctly answer at least 18 out of 24 questions.

Element 3 - General Radiotelephone. Electronic fundamentals and techniques required to adjust, repair, and maintain radio transmitters and receivers. The exam consists of questions from the following categories: operating procedures, radio wave propagation, radio practice, electrical principles, circuit components, practical circuits, signals and emissions, and antennas and feed lines. To pass, an examinee must correctly answer at least 75 out of 100 questions.

There are no questions on the GROL test specifically to do with ERCES, and there is no requirement for work experience or demonstration of practical skills.

No Continuing Education Requirements. The GROL is a lifetime license, with no requirement for continuing education.

What Is Better than GROL? 

The NICET In-Building Public Safety Communications (IB-PSC) Certification Program is specifically designed for engineering technicians engaged in the detailing and layout, installation, and maintenance, and/or designing of in-building public safety communication systems. Technical areas covered include knowledge of radio frequency theory, equipment mounting requirements, delivered audio quality scale, business software and mathematics, communications using project specifications and documents, site survey data and design tools, and interpretation and evaluation of surveys. The program has a three-level technician track and a one-level Design track that may be used independently or together to establish minimum qualifications for appropriate roles.

Successful candidates must:

• Pass an exam or exams. 
• Complete a work history description that documents and meets specific industry related experience. 
• Successfully perform key role specific activities. 
• Obtain a personal recommendation (Levels III and Design). 
• Once earned, certification must be maintained through Continuing Professional Development (CPD) and recertified every three years. 

Any credentialling program that focuses on compliance with NFPA or IFC standards and codes, without an assurance of compliance with FCC rules and the RF competency of individuals, is woefully inadequate to meet the rigorous demands of mission critical public safety RF systems.

The Root of the Problem: Fire Code vs FCC Rules

Fire and building codes focus on specific building infrastructure, enforced by Authorities Having Jurisdiction (AHJs). The education and training of these professionals are primarily with physical infrastructure within structures.

Fire codes and standards, with variations across jurisdictions, primarily address building infrastructure. In contrast, ERCES must achieve the expectations of adequate in-building coverage established by codes and standards, but must do so without causing harm to public safety radio networks operated under FCC authority.

Under FCC rules, no ERCES system rebroadcasting licensed public safety frequencies may operate without the express written consent of the Frequency License Holder. Recent codes and standards revisions aim to restore ERCES operation control to Frequency License Holders governed by FCC Rules.

Federal Communication Commission (FCC) rules, enforced by frequency license holders within jurisdictions, govern ERCES operation, making local fire and building codes secondary for ERCES. Jurisdiction's frequency license holders must oversee ERCES deployments.

As such, any credentialing program that focuses on compliance with NFPA or IFC standards and codes is woefully inadequate to meet the rigorous demands of mission critical public safety RF systems.

Programs that certify organizations instead of individuals not only fall only short of the requirements of the IFC Fire Code. They fall short of the obligation of jurisdictions to safeguard public safety radio networks.

What is the Best Program for Your Jurisdiction?

The various disciplines involved in the design, installation, testing, monitoring, and maintenance of ERCES demands credentialing of the competency of the specific individuals performing these tasks.

Even the International Fire Code demands this:

“The minimum qualifications of the system designer and lead installation personnel...”

What is the Foremost Competency Required for ERCES?

ERCES' purpose is to protect first responders, building occupants, and structures. Additional care is crucial for safeguarding public safety radio networks. The RF competency of individuals involved in ERCES design, installation, testing, and maintenance is central to this effort.

To date, the best-in-class program for ERCES that certifies the competency of individuals engaged in design, installation, testing, monitoring, and maintenance of ERCES is the NICET program.

Programs that certify organizations instead of individuals not only fall only short of the requirements of the IFC Fire Code. They fall short of the obligation of jurisdictions to safeguard public safety radio networks.

SBC Issues Position Paper on Minimum Qualifications of Personnel for ERCES

If you would like to know more about this subject, we invite you do download our position paper entitled SBC Position on Qualification of Personnel 

For your convenience, the entire text of that paper follows here:

Safer Buildings Coalition's Position Paper – Minimum Qualifications of Personnel

January 24, 2024

Only competent, independent organizations should evaluate and document the competency of individuals seeking qualification according to industry best-practice standards.

FCC rules and adopted codes and standards require that qualifications of personnel must focus on the training, experience, and verification of individuals, not the organizations they work for.

The continuing evolution of ERCES technology, best practices, codes, and standards require that programs affirming the qualifications of personnel must provide for continuous and ongoing validation to maintain efficacy throughout the qualification period which is vital for both AHJ’s and Frequency License Holders.

Key Points:

1. Emergency Responder Communications Enhancement Systems (ERCES) aim to protect first responders, building occupants, and structures. Additional care is needed for safeguarding public safety radio networks outside buildings. 
2. ERCES, a relatively new requirement, faces rapid growth due to code adoption and enforcement, potentially leading to confusion, policy conflicts, and unintended consequences. 
3. A significant lack of competency, especially in RF expertise, jeopardizes public safety radio networks. Essential training and qualification of personnel are necessary. 
4. Federal Communication Commission (FCC) rules, enforced by frequency license holders within jurisdictions, govern ERCES operation, making local fire and building codes secondary for ERCES. Jurisdiction's frequency license holders must oversee ERCES deployments. 
5. Qualifications of Personnel, mandated by both the FCC rules and the codes, rely on the skills, experience, training, and qualification of individuals, not organizations. 
6. RF concepts and skills are crucial for ERCES safety and efficacy. Organizations affirming individual knowledge must be competent, particularly in RF skills. 
7. Programs that do not continuously validate the competency of individuals and their direct association with their organization are inadequate to assure proper design and operation of ERCES and therefore do not meet the qualification of personnel requirement established in fire codes/standards. 
8. The ISO/IEC 17024:2012 standard contains principles and requirements for a body certifying individuals against specific requirements, and includes the development and maintenance of a best-practice certification scheme for these individuals.

Background:

The International Fire Code (IFC) outlines minimum qualifications for ERCES personnel, currently requiring a valid FCC-issued general radio operator's license (GROL) and documentation of in-building system training. These qualifications are earned by individuals, not organizations. Likewise, the FCC has a competency regime for licensing of individuals, one of which is the GROL.

Fire and Life Safety Systems demand competent personnel for designing, installing, testing, and maintaining systems to ensure reliable and effective performance when lives are at stake.

Systems such as fire and smoke protection, alarm systems, and sprinkler systems are vital for safeguarding building occupants and structures. ERCES, as part of fire and life safety systems, must be correctly installed to prevent risks to the building, occupants, and critical public safety radio networks.

Improperly functioning ERCES, operating via RF signals, can disrupt public safety radio operations for miles around the subject building.

Example: ERCES Disruption in Florida

In April 2015, an ERCES problem interfered with five public safety radio coverage areas in Florida, affecting Miami-Dade County, City of Miami, City of Hialeah, City of Aventura, Broward County, and the State of Florida radio systems. A 45-story building downtown had activated Bi-Directional Amplifiers (BDAs) causing issues. FCC field responders traced and resolved the problem.

Instances like these are increasing with the enforcement of IFC and NFPA codes, attracting inexperienced companies to the ERCES industry.

The minimum qualifications of personnel contained in the IFC is a good start, but the GROL is inadequate. While there is general RF knowledge covered in the GROL exam, there is no discussion of in-building public safety communications and other topic central to a competent ERCES design and deployment. A more robust credential is needed.

The demand for competent, certified staff capable of ERCES design, installation, testing, and maintenance has never been higher.

The Root of the Problem: Fire Code vs FCC Rules

Fire and building codes focus on specific building infrastructure, enforced by Authorities Having Jurisdiction (AHJs). The education and training of these professionals are primarily with physical infrastructure within structures.

Fire codes and standards, with variations across jurisdictions, primarily address building infrastructure. In contrast, ERCES must achieve the expectations of adequate in-building coverage established by codes and standards, but must do so without causing harm to public safety radio networks operated under FCC authority.

Under FCC rules, no ERCES system rebroadcasting licensed public safety frequencies may operate without the express written consent of the Frequency License Holder. Recent codes and standards revisions aim to restore ERCES operation control to Frequency License Holders governed by FCC Rules.

Appropriate Roles of AHJs and Frequency License Holders:

AHJs should:

• Determine if adequate, code-compliant public safety radio coverage exists in the building through proper RF evaluation best practices. 
• If inadequate, require the building owner to deploy a corrective solution. 
• Collaborate with Frequency License Holders and Industry Contractors to determine the best corrective solution. 
• Validate that competent and certified individuals currently work for system integrator on each project being designed, installed, or maintained in their jurisdiction. 
• Provide written guidance on local processes, adopted codes, and standards. 
• Collaborate in evaluating ERCES submittals. 
• Inspect deployed systems for compliance with codes and standards. 
• Inspect test results confirmed by Frequency License Holders. 
• Participate in periodic maintenance inspections. 
• Administer local policies and ordinances.

Frequency License Holders should:

• Establish necessary frequencies and radio performance criteria for ERCES. 
• Conduct RF testing and submittal reviews. 
• Provide final RF testing and documentation processes. 
• Collaborate with AHJs and Industry Contractors to determine the best corrective solution. 
• Validate that competent and certified individuals currently work for system integrator on each project being designed, installed, or maintained in their jurisdiction. 
• Issue documents providing provisional and operational permission for rebroadcasting licensed frequencies. 
• Maintain operational oversight and control of the radio network and the ERCES deployment process per FCC rules.

SBC Qualifications of Personnel Principles:

1. Adopted codes require qualifications of personnel, which means individuals, not organizations. 
2. ERCES are essential life-safety systems. The potential for these systems to cause disrupting interference to public safety communication networks demands that RF competency is paramount in determining qualifications of personnel. 
3. Bodies certifying the qualifications of individuals must be competent to do so. 
1. The minimum acceptable principles and requirements for a body certifying persons against specific requirements are detailed in the ISO/IEC 17024:2012 standard. 
2. The standard includes the development and maintenance of a certification scheme for persons. 
4. Competency of individuals must be evidence-based. 
1. Competency evaluation and validation process must be: 
1. Independent 
2. Objective 
3. Without conflicts of interest 
2. All submittals must be validated 
1. Skills performance 
2. Relevant work history 
3. Personal recommendations 
3. Minimum acceptable principles for knowledge test development are detailed in the ISO/IEC 17024:2012 standard. 
4. Direct observation of necessary practical skills is required. Acceptable methods: 
1. Practical skills demonstrated to and attested by a qualified reviewer. 
2. Manufacturer Hands-on Training and Certification. 
5. Credentials must be publicly accessible for inspection and verification, providing most current level(s), status, issued date, and expiration date. 
6. Bodies certifying qualifications of individuals should require continuing education, ensuring continued competencies and accomplishments that align with affirming organization’s requirements. 
7. Bodies certifying qualifications of individuals must utilize a discipline process to enable performance feedback and corrective action. 
1. Elements must include processes for complaint, review, appeal, revocation, and restoration.

ERCES' purpose is to protect first responders, building occupants, and structures. Additional care is crucial for safeguarding public safety radio networks. The RF competency of individuals involved in ERCES design, installation, testing, and maintenance is central to this effort.

SBC’s foundational principle of qualification of personnel for ERCES is intended to ensure the safety and efficacy of these systems, while providing assurance to all stakeholders that individuals engaged in ERCES work are continuously competent to do so.

Any lesser standard fails to comply with fire and building codes, FCC rules, and widely-accepted standards, jeopardizing the safety of first responders and the communities they protect.