SCDF Fire Code 2023: the S$10,000 fine that lands on the director

An SCDF officer asks for the fire safety records for one wing of a care home. The building manager produces the maintenance file. The file is complete for the alarm system and thin for everything else, because the contractor who serviced the fire doors moved on and the paperwork went with him. The officer writes down what is missing. The director hears about it three weeks later, in a meeting that was supposed to be about occupancy.

That pattern is common in hospitals and care homes, where the people on site change shift by shift and the records live in three different places. The SCDF Fire Code changes building owners must plan for do not create that problem. They make it visible.

The owner carries the duty, not the contractor

The Fire Safety (Amendment) Act was passed by Parliament on 5 August 2019 and its provisions came into effect on 14 September 2020. It strengthened SCDF's regulatory and enforcement powers, and it clarified regulatory processes and requirements for the industry. For a portfolio manager, the practical reading is simple: the duty to maintain fire safety measures and keep the evidence rests with the building owner, and it does not transfer to whoever holds the maintenance contract.

In a hospital or care home, that matters more than in an office tower. You have patients and residents who cannot self-evacuate, staff on rotating shifts, and contractors who come and go. The inspector looks at whether the fire alarm, the hose reels, the escape routes and the door hardware are in a state that matches the records you produce. If the records and the building disagree, the building wins the argument.

What the amendments actually changed

The Act gave the Commissioner, SCDF the power to mandate building owners to install critical fire safety upgrades where public safety requires it. The examples given are fire alarm systems and fire hose reels. For an older care home or a hospital block that has been refurbished in stages, that is the clause to read against your capital plan, because a mandated upgrade is not a discretionary spend you can defer to the next financial year.

It also introduced new offences around non-compliant regulated fire safety products. It is an offence to supply or offer to supply such products, and an offence to install them or cause them to be installed. SCDF can direct the cessation of sale, recall, removal, disposal or rectification. If your maintenance contractor has been fitting parts from a source you have never checked, that is now your exposure as well as theirs.

The Act also expanded SCDF officers' powers to investigate fire safety violations, take statements where there is reasonable suspicion of an offence, and enter premises that may contain evidence. It allows SCDF to authorise third-party officers to conduct routine fire safety enforcement checks and building inspections. In practice, the person who arrives at your Jurong or one-north site may not be in SCDF uniform, and your front desk needs to know how to verify them.

The amendments to the Fire Code itself continue in batches, and the SCDF circular on the sixth batch of Fire Code 2023 amendments is the document to route to your consultants rather than skim yourself. The fifth batch circular sits alongside it, and both are published by SCDF as a member of the Home Team.

Where the penalty lands, and on whom

Penalties for five serious offences under the Act were increased. They relate mainly to unauthorised change of use of premises and to failures by Qualified Persons and Registered Inspectors to discharge their duties. The increases were aligned with similar offences under other Acts, such as the Building Control Act.

The more important change for a director is procedural. Previously SCDF had to issue a Fire Hazard Abatement Notice before taking prosecutorial action. The Act empowers SCDF to take immediate prosecutorial action against persons who cause fire hazards with serious fire safety risks. The examples given are causing or failing to prevent overcrowding, non-maintenance of fire safety measures, and obstruction of fire escape routes.

Read that list against a hospital corridor. A bed parked in an escape route during a busy shift is an obstruction. A fire door propped open because the staff need to move trolleys is a non-maintenance issue. Neither is malicious, and both are exactly what an inspector records. The notice-first step is gone for cases like these, which means the first letter you receive may not be a warning.

There is a cost recovery dimension too. The Act allows SCDF to regulate third-party fire alarm operators under a licensing framework and to impose a cost recovery fee on operators for false alarms that result in deployment of SCDF resources. It also makes it an offence for operators to fail to verify an activated alarm before cancelling the request for SCDF resources. In a hospital, where alarm activations are frequent and sometimes ambiguous, the verification step is worth confirming in writing with your operator.

What a portfolio manager should actually do

Start with the records, not the plant. For each hospital and care home in your portfolio, you should be able to produce, on request and without a phone call, the maintenance history for the fire alarm system, the hose reels, the escape routes and the fire doors, with the contractor, the date and the finding for each visit. If those records sit with three different contractors and one spreadsheet, you have a consolidation problem before you have a compliance problem.

Second, check who is authorised to sign. The Act increased penalties for failures by Qualified Persons and Registered Inspectors, so the people you rely on have their own reasons to be careful. Confirm that the QP and RI named on your current submissions are still the ones doing the work, and that their scope covers the buildings as they now stand, not as they were when the engagement began.

Third, walk one escape route in each building with the person who holds the records. Not a formal inspection, just a walk. You will find the propped door, the stored equipment and the missing sign faster than any report will tell you, and you will learn whether the person holding the file knows the building. For the wider liability picture across a Singapore portfolio, the piece on the four states that decide your fire safety liability is worth an hour of your time, and the S$10,000 fine for no FSM is the question your board will ask next.

Your 60-second self-check

• Could you produce the last twelve months of fire door and escape route checks today, for every hospital and care home you answer for?
• Do you know, by name, which QP and RI are currently engaged on each building, and whether their scope matches the building as it stands?
• Can your front desk verify an SCDF-authorised third-party officer without calling you?

The fastest way to answer those honestly is to send the free 5-minute Director's Risk Check to the colleague who actually holds the records, and ask them to run it. It comes back to you as a board-ready briefing on where the portfolio's breach exposure sits, with the official source behind each item, so the next conversation with your board starts from evidence rather than reassurance.

Herman's verdict

The certificate on the wall proves an inspection happened. The file in the drawer proves what you did about it, and that is the one the inspector will ask to see.

— Herman