For fifty-six years, Kenyan buildings were governed by a code written in 1968, a document that said essentially nothing about fire resistance ratings, evacuation routes, or detection systems.

That ended on 1 March 2025.

The National Building Code 2024, gazetted as Legal Notice No. 47 of 2024 and given a one-year transition period, is now in force. It repeals the 1968 code and, for the first time, sets out substantive requirements for fire resistance, firefighting provision and evacuation.

Most building owners in Nairobi have not caught up. Many are operating premises specified under a regime that no longer exists, with a fire alarm panel installed a decade ago that nobody has tested since, and no idea that a separate law has required an annual audit of that system since 2007.

This guide sets out what actually applies to your building, who enforces it, and what exposure you are carrying if it is not in place.

Two separate laws apply, and most people only know about one

This is the single most common misunderstanding, and it is expensive.

The National Building Code 2024 governs what gets built. It is a construction and design instrument, applied through approvals, and it deals with fire resistance of the structure, means of escape, compartmentation, firefighting provision, and detection.

The Occupational Safety and Health Act 2007, and the Factories and Other Places of Work (Fire Risk Reduction) Rules 2007 — Legal Notice No. 59 of 2007 — govern what happens in a building while people work in it. This is an occupational safety instrument, enforced by the Directorate of Occupational Safety and Health Services (DOSHS).

A building can pass its construction approvals and still be in breach of the Fire Risk Reduction Rules from the day it opens. The two obligations run in parallel and neither discharges the other.

The annual audit almost nobody schedules

Rule 36 of the Fire Risk Reduction Rules 2007 requires every occupier to have a fire safety audit of the workplace carried out at least once every twelve months by a DOSHS-approved fire safety auditor.

Read that again, because three things in it are routinely missed:

  • Every workplace. Not just factories. Offices, schools, hospitals, hotels, shopping centres, warehouses.
  • Every twelve months. Not once at handover. Not when something changes. Annually, without exception.
  • By an approved auditor. Your installer's own service report does not satisfy this. The auditor must be DOSHS-approved.

The audit report goes to DOSHS. The obligation sits with the occupier, which for a multi-tenant building means the position needs to be settled explicitly in lease and facility-management arrangements; otherwise everybody assumes somebody else is doing it.

What a compliant fire detection and alarm system involves

The specifics vary by occupancy type, building height and risk profile, and your design must be confirmed by a competent fire engineer against the current code. But every compliant installation deals with the same six elements.

1. Detection appropriate to the space. Smoke detection is not universally correct. Kitchens, plant rooms, loading bays, and dusty environments need heat or multi-criteria detection, or they will produce constant false alarms, and a system that cries wolf is a system occupants learn to ignore, which is a life-safety failure long before it is a compliance failure.

2. A control and indicating panel that someone can actually read. Addressable systems identify the specific device in alarm. Conventional zoned systems tell you only which zone. In anything larger than a small single-storey building, addressable is now the practical baseline; a fire brigade arriving at a tower does not have time to search a floor.

3. Manual call points on escape routes, at exits and on each storey landing, so that a person who sees fire before a detector does can raise the alarm immediately.

4. Alarm signalling that produces the right behaviour. This is where Kenyan practice most often falls short, and it is covered in detail below.

5. Standby power. The system must continue to function when mains fails. Battery capacity is specified in hours of quiescent operation plus a period in full alarm, and it degrades, which is exactly what an annual audit is meant to catch.

6. Documented cause and effect. A written, tested matrix defining what each detector triggers: which sounders, which zones, whether lifts recall, whether dampers close, whether doors release, whether the generator sheds load. Undocumented cause and effect is the most common serious defect found in commissioned systems.

Sounders or voice evacuation? The question worth getting right

A conventional alarm produces a tone. Everyone in the building hears the same sound and has to work out for themselves what it means and where to go.

A voice alarm (VA) system, sometimes called a public address and voice alarm or PAVA system, broadcasts intelligible spoken instructions, and can address different zones differently, evacuating the fire floor and the floor above while holding other floors in place, then moving them in a controlled sequence.

The evidence on human behaviour in fires is unambiguous and slightly uncomfortable: people do not evacuate promptly when they hear a bell. They stop, look for confirmation, ask colleagues, collect belongings, and frequently head for the entrance they came in through rather than the nearest exit. That delay, the pre-movement phase, is often a larger share of total evacuation time than the walking itself. Clear spoken instruction demonstrably shortens it.

Voice evacuation becomes the appropriate choice in:

  • High-rise buildings, where phased evacuation is the only workable strategy
  • Hospitals and care facilities, where movement is slow and staged
  • Shopping centres, hotels and transport terminals, where the public are unfamiliar with the building
  • Schools and large campuses, where controlled, instruction-led movement matters
  • Any building with a complex or non-obvious escape strategy

Where a voice system is specified, the equipment should be certified to the EN 54 series, EN 54-16 for the control equipment and EN 54-24 for the loudspeakers. That certification is not a marketing badge; it covers behaviour under fault conditions, backup power switching, and intelligibility. We explain what those standards actually require, and how to write them into a specification, in EN 54 Voice Alarm Systems Explained.

What non-compliance actually costs

The fine is the smallest part of it.

Enforcement. DOSHS can issue improvement and prohibition notices. A prohibition notice can stop you from occupying the premises. For a commercial landlord or a school, that is not a fine; that is a closure.

Insurance. Property and liability policies carry warranties requiring compliance with statutory safety obligations. After a fire, the first thing an assessor asks for is the fire safety audit history and the system service records. Gaps in that paperwork are a straightforward route to a reduced or repudiated claim, and the sums involved dwarf any regulatory penalty.

Personal liability. Duties under OSHA 2007 attach to occupiers and to individuals in management, not to an abstract corporate entity.

Tenancy and tenders. Multinational tenants, banks, diplomatic missions and donor-funded institutions increasingly require documented fire safety compliance as a condition of taking space. Non-compliance quietly removes you from consideration, and nobody tells you why.

And the actual reason. Buildings in Nairobi burn. Detection that works, alarms that are understood, and escape routes that are clear are the difference between an incident and a fatality.

A practical compliance checklist

Work through this for each building you are responsible for:

  • Is there a current fire safety audit by a DOSHS-approved auditor, dated within the last twelve months?
  • Have the findings from the last audit actually been closed out, with evidence?
  • Has the fire detection system been serviced and tested on schedule, with records?
  • Are standby batteries within life and tested under load?
  • Is there a documented, tested cause-and-effect matrix?
  • Are detector types matched to each space, or are you tolerating recurring false alarms?
  • Are escape routes clear, signed and emergency-lit?
  • Have fire drills been carried out and recorded, with evacuation times?
  • Are fire marshals trained and currently in post, including for shifts and after hours?
  • If the building was designed under the 1968 code, has anyone assessed it against current requirements?
  • In a multi-tenant building, is it written down who holds the occupier obligation?
  • Would your insurer be satisfied with the records you could produce today?

Any unticked box is a live exposure.

If you are refurbishing or fitting out

The cheapest moment to fix a fire system is during works that are happening anyway. Retrofitting detection, cabling and loudspeakers into an occupied, finished building costs substantially more and disrupts tenants.

Three things to get right at design stage:

Bring the fire strategy in early. Fire system design driven by an architect's ceiling layout rather than by a fire strategy produces coverage gaps that only surface at commissioning, when they are expensive.

Specify certification, not just equipment. "EN 54-16 certified voice alarm control equipment" is enforceable at handover. "Voice alarm system" is not, and you will be handed whatever is cheapest.

Insist on documented commissioning. Full device-by-device test records, a signed cause-and-effect verification, and, for voice systems, measured speech intelligibility. Without those, you have an installation, not a system, and your first annual audit will say so.

 

Book a fire safety systems assessment

Fiacin Solutions designs, installs, commissions and maintains fire detection and EN 54 certified voice evacuation systems for commercial, healthcare, education, government and industrial buildings across Kenya. We work from the fire strategy down,  not from a product catalogue up, and we hand over documented cause-and-effect and commissioning records that stand up at audit.

If you are unsure whether your building would pass an audit today, that is the question to start with.

Request a site survey — or see the fire and life-safety systems we design around.