Recommendation
A recommendation is a finding recorded on a CAN/ULC-S536 inspection report or a CAN/ULC-S537 verification report that suggests an improvement to the system without asserting that anything fails to comply. It carries no obligation: the owner may read it, price it and decline it, and the system remains code compliant. That is the whole reason it is kept separate from a deficiency, which does create an obligation to rectify. Neither Ontario code uses the term, so the definition comes from the 2019 editions of the standards rather than from regulation.
What a recommendation is for
It is the place a technician puts professional judgment that is not a compliance finding. A public presentation on the 2019 standards delivered to the Building Officials Association of British Columbia in May 2023 describes the S537-19 definition as a proposal or suggestion as to the best course of action for improving system components, operation or installation, including safety considerations, and gives three examples: identifying antiquated or obsolete equipment, pointing out newer cost-effective technology, and suggesting alternate methods of detection. We paraphrase rather than reproduce, because the standard itself is paywalled.
Certi-Fire, a Canadian trade source, puts the same line more briefly: an improvement suggestion that does not prevent the system from meeting its required performance. If the system would still pass without it, it is a recommendation.
Which standard and which code provision
The term belongs to CAN/ULC-S536 and CAN/ULC-S537, both of which Ontario references at the 2019 edition, through Fire Code Table 1.2.1.A and Building Code Table 1.3.1.2 respectively. Since the 2019 editions the report forms sit in the body of the standards rather than an appendix, which makes the recommendations section part of a mandatory format rather than a suggested template.
No Ontario code provision mentions recommendations. Fire Code Article 6.3.2.2.(4) requires the record to indicate whether each device, component and circuit is in proper working order, which is deficiency language. Nothing in O. Reg. 213/07 obliges an owner to act on a recommendation, and nothing obliges a technician to make one.
Who writes it and what it obliges
The qualified person under Fire Code Division C, Article 1.2.1.2 writes it as part of the report. The owner decides. There is no rectification duty, no timeline, and no AHJ follow-up: Calgary Fire Marshal Bulletin 2025-001 sets a 10 business day reporting duty for deficiencies, and says nothing comparable about recommendations.
That asymmetry is the point of the distinction, and it is why moving a finding from one column to the other is not a cosmetic edit. See deficiency for the other half.
How often
Whenever there is something worth saying, on any report. There is no interval and no requirement to carry a recommendation forward, which is exactly why they tend to be repeated year after year with no record that the owner ever saw the first one.
What documentation it produces
A line in the recommendations section of the S536 or S537 report, and nothing else. It does not generate a work order, a permit, or a duty. Building owners and property managers reading a report should treat the two sections completely differently: see fire alarm compliance for building owners.
What goes wrong
The conflict of interest is structural. Two of the three examples the standard gives are, in practice, reasons to buy something, and the recommendation is written by the company that would sell it. That does not make recommendations improper, but it does mean an owner should ask which code provision a recommended item is required by, and accept "none, it is an improvement" as a legitimate answer.
Recording a genuine deficiency as a recommendation. This is the common direction of error and it matters, because it quietly moves a legal obligation off the owner. Accessibility, environment and mounting orientation problems are deficiencies under the 2019 definition even when the device works.
Recording a recommendation as a deficiency. Less common, and it creates an obligation the code does not impose, plus an argument with the AHJ about a system that complies.
Assuming the term list is settled. The site previously recorded a third term, Remark, alongside deficiency and recommendation. The best free evidence we can reach says "Remark" was deleted in the 2019 edition and replaced with "Comments." That entry sets out the evidence and the limits of it.
Fire Alarm Academy provides educational content only. It does not confer any certification, licence or credential, and it is not affiliated with, endorsed by, or accredited by the Canadian Fire Alarm Association, the Electrical Contractors Association of Ontario, ULC Standards, UL Standards and Engagement, CSA Group, the Electrical Safety Authority, any authority having jurisdiction, or any manufacturer. Always work from the edition of any standard adopted by your authority having jurisdiction.
Sources
- Changes to ULC Fire Alarm Standards: presentation to the Building Officials Association of BC, May 2023
- Certi-Fire: changes in CAN/ULC-S537-19 (Canadian trade source, secondary)
- Ontario e-Laws: Fire Code, O. Reg. 213/07 (full text, free)
- Calgary Fire Marshal Bulletin 2025-001: fire alarm reporting and deficiency timelines