SB 326 – Phase 1 & Phase 2 Evaluation

Thank you for allowing us to complete a full evaluation of the exterior elevated element system in accordance with Senate Bill 326 (SB 326). This evaluation included both Phase 1 and Phase 2 and was performed with access sufficient to observe the system as required under the statute.

The evaluation consisted of a visual review of the exterior elevated elements and associated components to identify observable conditions that could affect performance or safety. Where conditions warranted, additional review was performed to further assess areas of concern identified during the initial evaluation.

This evaluation is intended to satisfy SB 326 requirements and to document observed conditions at the time of inspection. It does not include destructive investigation unless specifically noted, and concealed conditions may exist that were not observable during the evaluation.

The findings are provided to support compliance planning and to assist in determining appropriate next steps related to maintenance, repair, or further review, if required.

We appreciate the opportunity to assist with your SB 326 compliance efforts and are available to address any questions or discuss recommended next steps.

Conclusion & Next Steps

Please let us know whether you intend to proceed as a Do-It-Yourself (DIY) client or if you would like to engage our team under the Vendor Management Oversight (VMO) program. Both options require coordination with your local authority (AHJ – Authority Having Jurisdiction) and thorough documentation to ensure your fire escape system meets certification standards.

Option 1: DIY Path – You Manage the Process

If you plan to manage your own vendors and documentation, you are responsible for complying with all applicable fire, building, and EPA regulations. The following steps must be followed:

DIY Compliance Steps

1. Notify the City Official

Contact your local Fire Marshal or Building Department and:

• Inform them you’ve engaged a design professional (engineer, architect, or other acceptable party) to inspect and evaluate the fire escape.

• Request clarification on:

  • Whether they treat missing lights as a pre-existing, nonconforming condition, or if full egress illumination is required.

  • Whether permits are needed for restoration/repairs based on the findings.

  • Whether they wish to witness the inspection.

2. Inspection & Documentation

• Hire a licensed engineer, architect, or other AHJ-approved fire escape inspector.

• Vendors must conduct a full-system walkthrough, accessing every platform, tread, and connection.

• All deficiencies must be documented and a repair scope submitted to the owner and AHJ.

3. Scope Review & Permitting

• A design professional must review the repair scope and determine whether permits are required by the AHJ.

4. Designate a Responsible Party

• Notify the city who will supervise the repair process, ensuring work is performed in accordance with the approved scope (with or without permits).

5. Repair Restrictions (Lead Paint & EPA Compliance)

• Welding is strictly prohibited on fire escapes built before 1978.

• No field welding is permitted under any circumstances.

• Repairs must be bolted or shop welded and field-bolted.

• Violations may result in EPA fines exceeding $37,500.

Option 2: VMO Path – We Manage the Process for You

If you prefer a fully managed solution, our Vendor Management Oversight (VMO) program provides professional oversight, technical guidance, and final certification support.

What’s Included in VMO:

• Initial Evaluation Report & Photo-Video-Technical Repair Report

  • One-page summary indicating Pass, Fail, or Imminent Danger

  • Includes ground or physical findings, photos, and optional video

• AHJ Communication & Coordination

  • We notify the city and clarify inspection witness needs, lighting requirements, and permit conditions

• Daily Vendor Oversight

  • We review daily photos/videos from your vendor

  • Ensure repairs follow approved methods and meet IFC and IBC codes

  • Prevents illegal welding; ensures proper bolting and documentation

• Inspection Video Summary

  • Narrated walkthrough highlighting deficiencies and identifying components ready for load testing

• Final Report & Certification

  • 25-point confidence checklist with repair recommendations/requirements

  • Photographs and final walkthrough video by our inspector

  • Certification issued via Load Test or Other Evidence of Strength

• Password-Protected Webpage

  • Central hub for documentation such as: inspection report, inspection video(s), inspection photos

  • Easily shareable with AHJ, owner, property managers, and agents

Request for Proposal (RFP) Options. (Fees to be paid by owner/agent or vendor)

Following this initial inspection, the property owner has the option to either proceed as a Do-It-Yourself (DIY) client—managing their own outreach to local vendors—or enroll in our Vendor Management Oversight (VMO) or Project Management Oversight (PMO) programs, where we coordinate the process on your behalf. Regardless of your selection, all projects remain eligible for RFP distribution.

• For DIY clients, it's your responsibility to invite vendors to the property and provide access so they can walk through the fire escape system and prepare their own scope and quote. (We can provide additional information to your repair vendor at additional cost.)

  • Most vendors only provide 1 year warranty on work performed.

• For clients utilizing our VMO/PMO service, we simplify this process by issuing a detailed RFP package to our pre-screened vendor network. These vendors review our inspection photos, summary findings, and any available site data—allowing them to submit accurate preliminary bids without needing to visit the site, unless shortlisted. This minimizes disruptions and ensures that only cost-aligned, code-qualified bids move forward.

  • We provide a 15-25 year warranty on all work performed.

  • 25 year warranty provided with Corrosion Protection Plan.

  • Network partners / repair mechanics: 5-15 year warranties under VMO/PMO.

Whether you choose to manage the process independently or allow us to guide you through it, we ensure you have the tools and documentation to solicit and compare bids confidently—or, if you prefer, you can bypass the bid process entirely and engage our certified team based on trust, warranty, and proven experience.