Ontario Healthcare Facility Fire Code Compliance: What Hospitals, Long-Term Care Homes, and Clinics Must Know in 2026

Healthcare facilities present the most demanding fire safety environment of any occupancy type in Ontario. Hospitals, long-term care homes, retirement residences, and ambulatory care clinics house residents and patients who may have limited mobility, cognitive impairments, or be dependent on life-sustaining equipment. Rapid evacuation — the standard response to fire in most buildings — is often not possible. Fire safety in these settings is not primarily about getting everyone out quickly. It is about preventing fire from spreading to occupied areas, protecting residents in place, and ensuring that systems function reliably when they are needed most.

The Ontario Fire Code, O. Reg. 213/07, classifies hospitals and long-term care homes as Group B occupancies — Care and Treatment Occupancies and Care Occupancies respectively. These classifications carry the highest fire protection obligations of any occupancy type under the Ontario regulatory framework. The 2026 Ontario Fire Code amendments introduced under O. Reg. 87/25, effective January 1, 2026, have added new requirements that affect fire alarm inspections, carbon monoxide detection, integrated systems testing, and documentation standards across all healthcare occupancy types.

This guide is written for healthcare facility managers, directors of plant operations, long-term care administrators, and the property management professionals who support them. It covers the key fire protection obligations that apply to Ontario healthcare facilities in 2026 and the consequences of non-compliance in an environment where the stakes could not be higher.

Why Healthcare Facilities Face Elevated Fire Safety Obligations

The elevated fire protection requirements that apply to hospitals and long-term care homes in Ontario reflect a fundamental reality: in these facilities, fire safety cannot rely on occupant self-rescue.

Patients in acute care settings may be sedated, immobilized, or connected to equipment that cannot be quickly disconnected. Long-term care residents often have mobility limitations, dementia, or other conditions that prevent independent evacuation. In both settings, staff must be the primary means of protecting occupants during a fire emergency — which means that fire protection systems, staff training, and facility design must work together to contain fires, maintain tenable conditions in occupied areas, and support a defend-in-place strategy.

The Ontario Fire Code and the Ontario Building Code reflect this through specific requirements that do not apply to other occupancy types: mandatory fire compartmentalization on resident sleeping floors, specific sprinkler coverage requirements, more stringent fire alarm system standards, mandatory fire safety plans with staff-specific response procedures, and more frequent inspection and testing obligations for critical systems.

Fire Alarm Systems: 2026 Standard Changes

The most significant change for Ontario healthcare facilities in 2026 is the adoption of the updated CAN/ULC-S536:2019 standard for annual fire alarm system inspections, effective January 1, 2026.

The new standard is substantially more comprehensive than the previous edition. It expands from 44 pages to 73 pages, adds over 100 new inspection items, and requires standardized report forms. For healthcare facilities, which typically have large, complex fire alarm systems with multiple alarm zones, nurse call integration, elevator recall, smoke control interconnection, and emergency lighting coordination, the practical impact is significant. Annual fire alarm inspections conducted under the new standard will be more thorough and more time-consuming than in previous years.

Every fire alarm inspection conducted in Ontario after January 1, 2026 must comply with CAN/ULC-S536:2019. Inspection records using the older standard forms are not acceptable for post-2026 inspections. Healthcare facility managers should confirm with their fire protection contractor that all forthcoming inspections will use compliant report forms and methodology.

For new or significantly modified fire alarm systems in healthcare facilities, the companion standard CAN/ULC-S537:2019 (Verification of Fire Alarm Systems) also applies and must be performed by a qualified technician at the time of installation or modification.

Integrated Systems Testing

The 2026 Ontario Fire Code amendments place new emphasis on integrated systems testing — the verification that interconnected building systems respond correctly when the fire alarm activates. In healthcare facilities, integrated systems typically include:

• Fire alarm and detection
• Automatic sprinkler systems
• Smoke control and pressurization
• Emergency power systems (generator and UPS)
• Elevator recall
• Fire door hold-open and release devices
• Nurse call and staff alerting

Under the updated requirements and the CAN/ULC-S1001 integrated testing standard, buildings with interconnected systems should demonstrate through periodic testing that the entire system chain functions correctly together. In healthcare facilities, this integrated function is critical — a fire alarm that fails to trigger elevator recall or smoke door closure can directly compromise the defend-in-place strategy that protects immobile patients.

The standard testing cycle for integrated systems in complex buildings is typically five years, with annual verification of critical interfaces. Healthcare facility managers should ensure that their fire protection service contractor is coordinating integrated systems testing with their building automation provider and elevator contractor to ensure complete coverage.

Sprinkler Systems

Sprinkler systems in Ontario healthcare facilities are subject to the inspection, testing, and maintenance requirements of NFPA 25 — Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems — as referenced by the Ontario Fire Code. These requirements include:

Weekly

Visual inspection of system control valves to confirm they are in the open position and properly supervised.

Monthly

Visual inspection of gauges, waterflow alarm devices, and accessible components.

Quarterly

Testing of waterflow alarm devices, inspection of control valves, and testing of supervisory signal devices.

Annually

Full inspection of all accessible sprinkler heads, pipes, fittings, and hangers. Inspection of all control valves. Testing of all alarm devices. Review of all maintenance records.

Five Years

Internal inspection of piping for signs of obstruction or corrosion. Testing or replacement of all pressure gauges. Obstruction investigation where risk factors are identified.

Healthcare facilities typically have wet pipe sprinkler systems throughout occupied areas and may have pre-action or dry pipe systems in areas where accidental discharge could damage sensitive equipment or patient care areas. Pre-action and dry pipe systems have additional testing requirements that must be addressed by a TSSA-authorized contractor.

Carbon Monoxide Detection

The 2026 Ontario Fire Code amendments significantly expanded carbon monoxide alarm requirements for care occupancies. Healthcare facilities that operate gas-fired equipment — boilers, kitchen ranges, emergency generators, or other fuel-burning appliances — are subject to CO detection requirements that expanded substantially under O. Reg. 87/25.

The specific CO detection requirements for a given healthcare facility depend on the type of fuel-burning equipment present, the ventilation configuration, and the occupancy classification. Areas outside sleeping rooms in care and treatment occupancies must be assessed for CO alarm coverage based on proximity to fuel-burning appliances and air handling pathways.

Healthcare facility plant operations departments should conduct a facility-wide CO risk assessment and confirm current CO alarm coverage against the 2026 requirements. Where gaps exist, additional CO alarms must be installed and incorporated into the facility's fire safety plan and monthly inspection program. CO alarms in care occupancies should be hardwired with battery backup where feasible; battery-only units are acceptable as an alternative where hardwiring is not practical.

Fire Safety Plans

Every Ontario healthcare facility is required to maintain a current Fire Safety Plan under the Ontario Fire Code. In care and treatment occupancies and care occupancies, the Fire Safety Plan carries additional obligations that distinguish it from the plans required for other building types.

The Fire Safety Plan for a healthcare facility must include:

• Emergency procedures specific to the defend-in-place strategy applicable to the facility
• Staff responsibilities during a fire emergency, including room-by-room and floor-by-floor assignments
• Procedures for the evacuation of patients or residents who can be moved and the protection-in-place of those who cannot
• The location and operation of all fire protection systems
• Contact information for the fire department and all system contractors
• Procedures for calling the fire department, operating manual pull stations, and using portable fire extinguishers

The Ontario Fire Code requires that the Fire Safety Plan for care occupancies be reviewed and updated annually, or whenever there is a significant change in the building, its systems, its occupancy, or its staffing structure. This annual review obligation is more frequent than the review cycle required for most other occupancy types.

Staff training and drills are a mandatory component of Fire Safety Plan implementation in healthcare settings. The Ontario Fire Code requires that all staff who may be present during a fire emergency receive training on the Fire Safety Plan and participate in drills at a frequency that ensures all shifts are covered. Training records must be maintained and available for inspection by the Authority Having Jurisdiction.

Fire Compartmentalization and Door Hardware

The Ontario Building Code requires that floors containing patients' or residents' sleeping rooms in hospitals and long-term care homes be divided into fire compartments of no more than 1,000 square metres, each separated by fire-rated assemblies. This compartmentalization is the structural foundation of the defend-in-place strategy — it limits fire spread and allows portions of the facility to remain occupied while others are cleared.

The integrity of fire compartmentalization depends on fire doors functioning correctly. Fire doors in healthcare facilities must:

• Close and latch completely when released from hold-open devices
• Have no gaps, damage, or missing hardware that would compromise their fire rating
• Have functioning door closers and latching mechanisms
• Be free of wedges, props, or other devices that prevent them from closing

The Ontario Fire Code requires that fire doors be inspected annually. Healthcare facility managers should confirm that fire door inspection is included in their annual fire protection service scope and that all deficiencies are corrected promptly. A propped-open or damaged fire door in a care occupancy is not a minor deficiency — it can directly undermine the compartmentalization that protects non-ambulatory residents.

Emergency Lighting and Exit Signs

Healthcare facilities in Ontario must maintain emergency lighting and exit signage throughout all occupied areas and all means of egress. Emergency lighting must provide sufficient illumination for staff to navigate and perform their duties during a power interruption.

Testing requirements for emergency lighting units include a 30-second functional test monthly and a full 30-minute duration test annually. All tests must be documented. In healthcare facilities, where power interruptions require continued patient care operations, emergency lighting reliability is directly linked to patient safety and should be treated accordingly.

Exit signs must be continuously illuminated during all occupied hours — which in a 24-hour care facility means continuously — and must remain illuminated on backup power during power interruptions.

Portable Fire Extinguishers

Healthcare facilities must maintain portable fire extinguisher coverage throughout the premises in accordance with the Ontario Fire Code. Extinguishers must be appropriate for the fire hazards present — Class K units in commercial kitchen areas, and Class ABC units throughout clinical and administrative areas.

Annual inspection and servicing by a licensed technician is required, along with documented monthly visual checks by facility staff. In healthcare environments, extinguishers must be accessible to staff at all times and must not be blocked by equipment, furniture, or other materials.

Healthcare facilities that use CO2 or clean agent extinguishers in sensitive areas such as server rooms or imaging suites have additional maintenance considerations and should confirm that their service contractor is certified to service the specific extinguisher types present.

What to Expect During a Healthcare Facility Fire Inspection

Municipal fire prevention officers and the Ontario Fire Marshal's Office conduct fire inspections of healthcare facilities on a routine basis, and targeted inspections may also occur in response to incidents or complaints. During an inspection of a healthcare facility, the officer will typically review:

Fire Safety Plan

Currency, completeness, staff-specific procedures, and training records for all shifts.

Fire Alarm System Records

Annual inspection records compliant with CAN/ULC-S536:2019, documentation of any deficiencies and corrective actions, and verification records for any system modifications.

Sprinkler System Records

NFPA 25 inspection and testing records for all required intervals.

Fire Door Condition

Physical inspection of fire doors throughout the facility for damage, improper wedging, or failed hardware.

Emergency Lighting and Exit Signs

Functional inspection and test records.

Extinguisher Records

Annual service tags and monthly inspection documentation.

CO Alarm Coverage

Verification that CO alarms are installed in required locations and that monthly inspection records are maintained.

Staff Training Records

Documentation of fire safety training and drill participation for all staff shifts.

A fire prevention officer who finds a healthcare facility with lapsed inspection records, a stale Fire Safety Plan, or untrained staff has grounds to issue Orders to Comply with mandatory correction timelines. In serious cases, the fire department may restrict or prohibit occupancy pending compliance — a consequence with direct implications for patient care continuity.

Common Deficiencies Found in Ontario Healthcare Facility Inspections

• Fire Safety Plan not updated following staffing or operational changes. Plans prepared years ago that no longer reflect current staff assignments, zone configurations, or system locations.
• Staff training records incomplete or missing. All shifts must be covered — overnight and weekend staff who may never attend scheduled training sessions are a consistent gap.
• Fire alarm inspection records not compliant with the 2026 standard. Post-January 2026 inspections must use CAN/ULC-S536:2019 forms. Records from prior inspections using older forms remain valid for those inspection dates but cannot be used for current compliance.
• Fire doors propped open or with failed hardware. A systemic problem in busy care environments where doors are frequently held open for patient transport.
• Emergency lighting units failing monthly or annual tests. Battery degradation in units that are present but not being tested.
• CO alarm gaps following 2026 expansion. Facilities that had compliant coverage under the pre-2026 requirements may now have gaps under the expanded standard.
• Sprinkler system records missing quarterly or five-year inspection documentation. Annual inspection records are often in order while quarterly test records are absent.

Choosing a Fire Protection Contractor for Healthcare Facilities

Healthcare facilities require a fire protection contractor with specific experience in care and treatment occupancy compliance. The regulatory environment is more complex than for most other building types, the inspection standards are more stringent, and the consequences of deficiency are more serious.

When selecting or evaluating a contractor for a healthcare facility, confirm that they:

• Hold all required TSSA authorizations for sprinkler system inspection and maintenance
• Are CFAA-certified for fire alarm inspection under CAN/ULC-S536:2019
• Have direct experience with Group B occupancy fire protection requirements under the Ontario Fire Code
• Can coordinate integrated systems testing with other building system contractors
• Provide detailed inspection reports that identify deficiencies separately from recommendations
• Maintain technician attendance logs and provide signed inspection certificates with each service visit

A contractor who cannot demonstrate healthcare-specific experience may produce inspection records that satisfy a standard commercial building inspection but fail to address the additional obligations that apply to care occupancies under the Ontario Fire Code.

First National Fire Protection: Healthcare Facility Fire Protection Across Ontario

At First National Fire Protection, we understand the unique fire protection obligations that apply to Ontario hospitals, long-term care homes, retirement residences, and ambulatory care facilities. Our CFAA-certified technicians provide comprehensive fire protection services for healthcare occupancies throughout Toronto, the GTA, and Ontario — including annual fire alarm inspection under CAN/ULC-S536:2019, sprinkler system inspection and maintenance under NFPA 25, portable extinguisher service, emergency lighting testing, fire safety plan development and review, and CO alarm assessment under the 2026 expanded requirements.

We work with facility managers, directors of plant operations, and healthcare administrators to ensure that every system in the building is properly inspected, documented, and compliant — so that when the fire department walks in, your records are complete and your facility is protected.

If your fire alarm inspection records need to be updated to reflect the 2026 standard, or if you have not conducted an integrated systems test in the past five years, contact us today. In a healthcare facility, a lapsed inspection is not just a regulatory problem — it is a direct risk to the people in your care.