Case Studies
Natalie Valcourt
07/15/2026
FPPM requirements are written directly into NFPA 241, the Standard for Safeguarding Construction, Alteration, and Demolition Operations, yet they remain one of the most overlooked obligations on active construction sites. The standard requires every covered project to have a written Fire Prevention Program and a designated person to run it. That person is the Fire Prevention Program Manager, the FPPM. The role is named, the responsibility is clear, and still the position is left unfilled, handed off to someone already stretched thin, or reduced to a line on an org chart that nobody checks until something goes wrong.
That gap, between what the standard requires and what actually happens on site, is what this article is about.
NFPA 241 is the national standard for fire safety on construction, alteration, and demolition sites. Published by the National Fire Protection Association, it covers everything from hot work control and fire watch to impairment coordination and pre-incident planning.
Most U.S. jurisdictions adopt NFPA 241 by reference, either through NFPA 1 (the Fire Code) or the International Fire Code. Whether and how it applies to a specific project depends on what the local Authority Having Jurisdiction (AHJ) has adopted. The most recent published edition is the 2022 edition; a 2027 edition is currently in development. Confirm with your AHJ which edition governs your project.
Under NFPA 241, the owner of a building under construction, alteration, or demolition is responsible for fire protection on that site. That responsibility includes designating a specific person to develop, manage, and carry out the written Fire Prevention Program from start to finish. That person is the FPPM.
The FPPM is not an advisory role. The standard gives the FPPM the authority to enforce the provisions of NFPA 241 and applicable fire protection standards on the project. NFPA’s guidance on the FPPM role describes it as a boots-on-the-ground function, not an administrative one.
Many AHJs also call for one or more Alternate FPPMs, ensuring the program does not lapse when the primary FPPM is off site.
The owner is legally responsible for naming the FPPM. That accountability does not transfer to the general contractor or the site safety team by default.
The FPPM is not a title held in reserve for emergencies. The role carries active, ongoing responsibilities throughout the life of the project.
At the core of it is the written Fire Prevention Program itself. The FPPM develops it, manages it, and keeps it current as site conditions change. That program is not a one-time deliverable filed at the start of a job and forgotten. It is a living document that the FPPM is responsible for maintaining.
From there, the day-to-day work covers a wide range of operations. The FPPM oversees fire watch, ensuring it is in place when required, that personnel are properly trained, and that all activity is documented. Hot work is another major area of responsibility: welding, cutting, and grinding operations all require permits, and the FPPM manages that process. When fire protection systems need to be taken offline, the FPPM coordinates and documents those impairments. Daily site inspections are part of the job, as is fire prevention education for the workforce on the ground.
The FPPM also carries a planning and coordination function that extends beyond the site itself. That means developing and maintaining a pre-incident plan and serving as the primary point of contact for responding fire crews. It means working directly with the AHJ on compliance.
This is a full-scope program management role. It requires time, authority, and budget. A role without any of those three will not function as the standard intends.
Here is where most projects go wrong.
Fire watch is not a fire prevention program. Treating fire watch as the full extent of NFPA 241 compliance is one of the most common mistakes on construction sites. Fire watch is one piece of a larger, written program, not a substitute for it.
The same problem appears in how the FPPM role gets staffed. On many projects, the position is handed to the site safety lead, the superintendent, or another manager who is already carrying a full workload. Fire prevention becomes one more item on a list. The standard requires a real, resourced position with authority and budget. What many projects deliver is a name on a form.
Some AHJs have recognized this directly. The Boston Fire Department, for example, added a training and affidavit requirement for project FPPMs after observing that designated personnel frequently did not understand the responsibilities of the role. That is a significant indicator of how widespread the gap between designation and actual competency has become.
Compliance is a floor, not a ceiling. Meeting the minimum standard gets a project to the starting line. Treating compliance as the finish line creates exposure, to insurance consequences, AHJ stop work orders, project delays, and liability when something goes wrong.
NFPA research on construction fires shows that U.S. fire departments respond to thousands of fires in structures under construction each year. Construction sites are high-hazard environments: combustible materials, open flame operations, incomplete fire suppression systems, and daily changes to the physical layout all compound the risk.
When a project does not have a functioning FPPM, not just a named one, but an active one, the consequences run across several areas. Ignoring FPPM requirements does not just create a compliance gap, it creates direct exposure for the owner on insurance, stop work orders, project delays, and liability that traces back to the standards such as the following:
The cost of building a real program is known and manageable. The cost of not having one shows up at the worst possible time.
Start with the simplest question: is there actually a named FPPM on this project, or is fire prevention just something that got added to a safety manager’s already full plate? Those are not the same thing, and the standard does not treat them as equivalent.
If someone is designated, ask whether they know the full scope of what the role requires. Not a general familiarity with fire safety, but the specific responsibilities under NFPA 241: hot work permits, fire watch documentation, impairment coordination, pre-incident planning, daily inspections, and direct communication with the AHJ. If the person in the role could not describe those responsibilities without prompting, the designation is nominal, not functional.
Then look at the written Fire Prevention Program itself. Does it exist? Has it been updated since the project broke ground? A program written at the start of a project and never touched again is not a living document, it is a box that was checked once and forgotten.
Finally, consider authority. Can the FPPM stop a hot work operation without running it through three other people first? Can they call a fire watch on their own judgment? If the answer is no, or if the budget and staffing were never aligned with the responsibilities, the role does not have what it needs to function. And when the AHJ shows up, or something goes wrong, that gap will be visible.
Start with the written Fire Prevention Program. If one does not exist, that is the first deliverable. NFPA 241 outlines the required contents: site security, impairment coordination, housekeeping, smoking control, temporary heating and utilities, fire protection equipment, and pre-incident planning, among others.
From there, assess whether the current FPPM designation, if there is one, reflects a person who has the time, training, and authority to run the program. FPPM requirements do not stop at having a name on a form. The role demands someone who can act on it daily. If the designation does not reflect that, it needs to change. Check with your AHJ on any local training or affidavit requirements, which vary by jurisdiction.
The standard is clear on who owns this. If you are the owner or the GC working on the owner’s behalf, the obligation starts with you.
If your project needs support with fire protection systems, compliance documentation, or finding the right equipment to meet NFPA 241 requirements, FireAlarm.com’s consulting and design-build services are built for exactly this. Search by system type, confirm compatibility with your project specs, and get expert answers without the wait.
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