Structural Fires and Cultural Resources
A structural fire is a fire that originates within or on a building and involves components of that building in combustion. The NPS cares for over 27,000 historic structures that all may be damaged by structural fire. Museum collections, including archival collections, are another cultural resource that may be affected by structural fire. While structural fires may occur at any time, good management and vigilance can minimize the threat of fire in historic buildings and buildings housing museum collections.
NPS DO #58: Structural Fire Management (.pdf) and RM–58: Structural Fire Management (.pdf) provides guidance on all types of structural fires and specifically addresses cultural resources. DO #58 requires that buildings with museum collections be provided with early warning detection and suppression systems based on National Fire Protection Association (NFPA) safety codes and standards, and Department of the Interior (DOI) and NPS policies.
This section of the Cultural Resources and Fire module provides guidance for park structural fire coordinators (PSFCs); cultural resource managers in parks, regions, and centers; Section 106 coordinators; and park superintendents to ensure that cultural resources are fully considered and evaluated when developing and implementing structural fire management plans. Integration of cultural resources into the planning process will ensure that they are better protected during structural fires.
Employee and public safety is the first priority in every management activity. All planning and implementation activities must reflect this commitment. A job hazard analysis should be prepared for each incident activity.
Structural Fire Management Planning
Structural fire management planning involves cultural resources at multiple points of intersection, as structures that may themselves be historic properties may house museum collections. Installation of fire detection and protection systems may alter the historic fabric of buildings; NHPA Section 106 compliance may be necessary when installing safety systems in historic buildings.
Structural Fire Management Plans
Protection from structural fire requires a comprehensive fire strategy that calls for the reduction of risk of ignition, installation of sprinkler and early detection systems, and notification and training of firefighting units. Every park unit must develop and update a structural fire management plan. The plan is derived from and reflects goals of the park's general management plan (GMP) or foundation document (FD). The document is based on professional structural fire management expertise; knowledge of park resources, including cultural resources; and assessment of the park's structural fire assets, liabilities, and operations.
The structural fire management plan implements the guidance and objectives described in higher-level park planning efforts (the GMP/FS and resource plans), and ensures that structural fire management activities are integrated into other park activities and furthers park stewardship goals. Elements of the structural fire management plan include:
- All known fire and life safety conditions at the park;
- Structural fire management objectives to protect life, property, and resources including cultural resources, in that order;
- Documentation of installation, inspection, testing and maintenance of all fire protection systems and equipment in accordance with Department of Interior and NPS policies;
- Inspection schedules;
- Documentation that all alterations, modifications and changes to historic structures have included review and consultation with State or Tribal Historic Preservation Office (SHPO/THPO) as required by National Historic Preservation Act (NHPA) Section 106, Executive Order 13175, and the DOI Policy on Consultation with Indian Tribes;
- Documentation of treatment to meet the Secretary of the Interior's Standards for the Treatment of Historic Properties (.pdf).
The Secretary of the Interior's Standards for the Treatment of Historic Properties are Federal regulations for the preservation, maintenance and rehabilitation of our nation's heritage. Federal undertakings are required to adhere to the standards when planning and implementing treatments for cultural resources that are listed, eligible to be listed, or potentially eligible to be listed on the National Register of Historic Places (National Register).
Cultural Resource Implications
Cultural resource managers in parks, regions, and centers are familiar with the contents of park structural fire management plans and are proactively involved in its development and periodic updates. Cultural resource protection is identified as a management objective in the structural fire management plan. Cultural resource managers in parks, regions, and centers work closely with the park structural fire coordinator (PSFC) to insure that the structural fire management plan addresses protective measures for historic buildings and museum collections. Updates on the status of historic structures and housing for museum collections are reflected in the structural fire management plan.
Installation and updating of fire detection and suppression systems that trigger compliance requirements of Federal cultural resource laws, policies, and Executive Order 13175 are addressed in building management plans and other planning documents. The cultural resource manager and PSFC works with the park or regional Section 106 coordinator to ensure that alterations, modifications, and changes to historic structures have complied with NHPA, Executive Order 13175 and the DOI Policy on Consultation with Indian Tribes, and that the consultations have been documented.
Fire Management and Cultural Resource Laws provides more guidance on requirements of Federal resource laws, DOI and NPS policies, and Executive Order 13175.
Coordination with Fire-Fighting Units
Few parks maintain professional firefighting units that respond to structural fires, and most rely on the expertise of community fire stations. NPS Management Policies 220.127.116.11 (2006) require that park and local fire personnel be advised of the locations and characteristics of cultural resources threatened by fire, and of any priorities for protecting them during structural fires. Park fire personnel are required to receive cultural resource protection training.
It is important that firefighters have access to the information necessary to protect park cultural resources in the event of a structural fire. Good communication with the PSFC and responder fire-fighting units is established to define fire protection needs and joint stewardship responsibilities for cultural resources.
Cultural Resource Implications
Cultural resource managers meet with firefighting units on a regular basis to update firefighters about museum collection locations and changes in the status of historic buildings. Park staff invite representatives from the fire department to visit and conduct pre-plan walk-throughs to inspect historic properties and museum storage and exhibit spaces. They encourage firefighters to ask questions and make recommendations to improve safety and protection.
Information provided should include:
- A list of structures eligible or listed on the National Register;
- Museum collection repository floor plans, and historic property floor plans, showing utility shut-offs, access points, and locations of collections and objects to be protected in the event of a fire;
- Any changes to the locations or status of historic structures or collections facilities;
- Any restrictions concerning structures and collections, including reminders that theft of cultural resource items is a Federal offence under the Archaeological Resources Protection Act (ARPA);
- A list and map of hazardous materials and their locations, such as cellulose nitrate film or chemicals;
- Interpretation of the resources, as a value-added education opportunity to help firefighters to be better stewards of cultural resources in the park.
NPS DO #58 requires that buildings with collections be provided with early warning detection and suppression systems based on NFPA codes and standards and DOI and NPS policies.
Most building and fire safety codes have made special exemptions for cultural resources because of the challenges of integrating fire suppression systems and other protective measures with cultural resource preservation goals. The safety codes give the NPS regional director (as the authority having jurisdiction) authority to grant variances from full application of the codes.
The National Fire Protection Association (NFPA) safety codes Part 909-Code for the Protection of Cultural Resource Properties—Museums, Libraries, and Places of Worship and 914-Code for Fire Protection of Historic Structures describe a process to help resolve conflicts between safety and preservation goals to better insure the safety of people and preservation of property. Treatment measures must meet the Secretary of the Interior's Standards for Treatment of Historic Properties. If fire and life safety concerns cannot be properly mitigated because doing so would alter the historic fabric of a building, then the use of the building must be altered.
Interdisciplinary Process Teams for Altering Historic Fabrics
Fundamental to a successful fire protection project involving alteration to the fabric of a historic building is the establishment of an interdisciplinary process team, as specified by the NFPA safety code Parts 909 and 914. The size and composition of the team may vary depending on the complexity of the project and the significance of the cultural resource.
In general, the process team follows these general protocols in planning and implementing alterations to historic properties:
The process team conducts a project assessment, which includes a historic property assessment and/or a collection assessment. The building survey determines and prioritizes the primary and secondary significance of all historic elements, spaces, and features. The goal of the assessment is to limit modifications or additions to the structure to less visible areas. Modifications and additions may be permitted in primary areas only when all other options, including variances, have been exhausted.
For treatments beyond emergency stabilization, the NPS requires that a Historic Structures report be completed as well. A complete project assessment includes an operations assessment and a fire safety assessment.
- The process team evaluates the individual assessments and determines fire protection goals and objectives. Structures that are found to have life safety deficiencies and preservation needs will need a plan of correction. The fire safety and historic property assessments may establish additional property protection goals beyond the minimum life safety requirements.
- After the plan of correction has been formulated, the process team coordinates the design and implementation of the project.
Inspections of Historic Structures and Collections
Regular inspections ensure that structural fire best management practices are being followed. There are two relevant aspects of inspections: what is being inspected, and how often inspections occur. The PSFC conducts yearly safety inspections, but cultural resource managers can inspect historic buildings and buildings housing museum collections more frequently.
Cultural resource managers work with the PSFC to establish a supplemental inspection schedule for regular internal inspections of historic buildings and structures housing museum collections. Fire detection, suppression, and notification systems should be frequently inspected to ensure that they are in good working order at all times. Cultural resource managers can also check electrical equipment and outlets. Working fireplace chimneys should be frequently inspected and cleaned. All flammable materials should be properly stored, and no-smoking rules enforced. Ignition sources inside of buildings should be minimized. Fireplaces and other open fires should be closely monitored. Historic properties that are undergoing rehabilitation should be inspected daily at the end of the work period. Hazard of fire is increased when buildings are being renovated.
Cultural Resource Implications
Cultural resource managers ensure that an annual inspection schedule for historic structures and collection facilities is included in the structural fire management plan. Every national park unit contains unique historic properties and/or museum collections that will require individualized inspection checklists. The NPS Conserve O Gram Number 2/23—Fire Safety 101 (September 2005) contains a Fire Safety Self-Inspection Checklist that can be adapted for the needs of specific parks. Cultural resource managers work with the PSFC to develop a checklist for individual units.
For museum collections storage and exhibit areas, cultural resource managers maintain current information on structural fire protection using the NPS Checklist for Preservation and Protection of Museum Collections (.pdf) available through the Automated Checklist Program (ACP) of the Interior Collections Management System (ICMS).
Despite safeguards, structural fires can and do occur. Water is the primary means of extinguishing fires, and, especially if sprinkler systems have functioned properly, there may be a considerable amount of water applied.
Historic properties that have been damaged by fire, smoke, or water must be assessed by a preservation professional who meets qualifications listed in the Secretary of the Interior's Standards for Treatment of Historic Properties. A post-fire assessment of affected cultural resources is critical for developing a plan for collection conservation treatment and building repair. Assessment and mitigation, potentially consisting of documentation by a qualified professional, is needed before any demolition.
Regional museum collections staff are notified as soon as possible after a structural fire involving a museum collection. An NPS Museum Emergency Response Team (MERT) can play a critical role in post-fire recovery efforts after a fire has affected museum collections.
Much information about planning for and responding to disasters, including structural fires, is available on the National Center for Preservation Technology and Training website.