Remark

Remark was a finding type on older CAN/ULC fire alarm report forms, used for contextual information that was neither a compliance failure nor a suggested improvement. On the best free evidence we can reach, the term was deleted in the 2019 edition of CAN/ULC-S537 and replaced with Comments, which means it is not current terminology in Ontario, where both codes reference the 2019 editions. You will still see Remarks blocks on legacy forms and in software written against an earlier edition. If you are writing a report today, the live distinction is between a deficiency and a recommendation.

What the term meant

On earlier report forms a remark was the catch-all: site conditions, restricted access on the day, a tenant who would not open a suite, a note that a section was completed under a different contract. Information the next reader needs, that is not a finding against the system. It sat below deficiency, which asserts non-compliance and creates an obligation, and recommendation, which suggests an improvement and creates none.

What changed in 2019, and how confident we are

This site previously recorded that the 2019 editions distinguish three terms, Deficiency, Recommendation and Remark. We went back to the sources and we no longer think that is right.

The clearest free Canadian evidence is a presentation titled Changes to ULC Fire Alarm Standards, delivered on 30 May 2023 to the Building Officials Association of British Columbia and carrying a UL copyright line, so it comes from the standards developer rather than a contractor. Its slide on documenting findings states that the new version of S537 gives more detailed explanations of how to document a deficiency against a recommendation or remark, and that the term "Remark" has been deleted and replaced with "Comments."

Two independent sources point the same way without addressing the change directly. Certi-Fire's public page on S537-19 defines only two terms, deficiency and recommendation, and its account of the report sections runs through system information, control units and transponders, field devices, power supplies, circuit fault tolerance, ancillary devices, interconnections, deficiencies and recommendations, with no remarks block. ULC Standards' training catalogue carries a course titled Deficiencies and Recommendations in CAN/ULC S536-19 and S537-19, naming two finding types.

Here is what we still cannot confirm. The sentence in the presentation names S537. The section it sits in is headed for S537 and S536 together and states that both forms are mandatory, so the same change very likely applies to the S536 inspection report, but that is inference and we are not going to state it as text. We also cannot confirm what the replacement block is actually headed on the printed form, or whether "Comments" is a defined term or just a field label, because both forms sit inside the paywalled standards and we will not reproduce them. If you hold a licensed copy of S536:2019 or S537:2019, the definitions clause and the report form settle it in about a minute.

Why it still shows up

Because forms outlive editions. Ontario referenced the 2013 edition of S537 until recently and moved to the 2019 editions through Fire Code Table 1.2.1.A and Building Code Table 1.3.1.2, so there are buildings whose file holds reports written under three different vocabularies. Inspection software is often slower still. Seeing a Remarks block on a report is not proof the report is wrong; it may be proof of which edition it was written against. See adoption gap and which edition applies.

What goes wrong

Using a Remarks block as a soft landing for a deficiency. Whatever the field is called, a finding that a device does not operate as intended, is not safely accessible, or is in an environment it is not rated for belongs in deficiencies.

Recreating an old form in your own software. Since 2019 the forms sit in the body of the standards rather than an appendix, which makes the format mandatory. Calgary Fire Marshal Bulletin 2025-001 states that tests or inspections may not be reworded or revised in order or format, that all sections must be completed, and that partial reports will not be accepted. Carrying a legacy Remarks heading forward is exactly the kind of rewording that gets a report rejected.

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