RECOMMENDATION LETTER FIRE SAFETY IN GOA BY SPEED POST/EMAIL

RECOMMENDATION LETTER

FIRE SAFETY IN GOA BY SPEED POST/EMAIL

Recommendations to Incorporate Stringent Regulatory Compliance Governing Fire Prevention and Life Safety Measures in the State of Goa.

Aparajitha, a leading compliance service provider in India, has forwarded a letter of recommendation to the State Government of Goa, regarding the fire legislations on how we can strengthen the fire safety.

1. Currently, at the state level, the following legislations have been enacted by the State government with respect to fire safety:

• • The Goa, Daman and Diu Fire Force Act, 1986 ( “Act”) (Act No. 9 of 1986) published in the Official Gazette, Series I No. 31 dated 30-10-1986 and came into force w.e.f. 1-2-1987.
  • The Goa State Fire Force (Amendment) Rules, 2009, (“Rules”)published in the Official Gazette, Sr. I No. 9 dated 27-5-2010 and came into force at once.
  • Notification No. 3/5/97-HD (G) Part/3934 dated 26-12-2014 u/s 13(1) of Goa Fire Force Act, 1986 published in the Official Gazette, Sr. I No. 39.
  • Notification No 3/14/2024-HD(G)/1652 dated 23-06-2025
  • Circular DFES/FP/CIRCULAR/25-26/268 dated 10-12-2025

2. Upon reviewing these State legislations, we have observed that the Act has been in force for almost 40 years now. The fire safety and fire prevention compliance are imposed through various notifications and circulars issued while the Act and its corresponding Rules are yet to be updated or amended. In a place such as Goa, it becomes even more crucial to ensure that the regulatory framework concerning fire safety is not just regularly updated but also enforced in its true intent and spirit. Attracting national as well as international tourists throughout the year, the State of Goa should ensure that the safety of such tourists, as well as the locals, is taken care of.
3. The Goa, Daman and Diu Fire Force Act, 1986 is the primary legislation governing fire services and fire safety administration within the State of Goa. The Act primarily provides for constitution and maintenance of the State fire force, appointment of fire officers and personnel, powers and duties of fire service authorities, as well as certain preventive provisions enabling the government to require fire precautions in identified classes of occupancies. While the Act lays down foundational legal framework for fire services in Goa, its overall focus remains largely on operational and administrative matters. However, seeing the current legislations across the nation, there still seems to be a scope to comprehensively address fire safety and fire prevention measures, including detailed occupancy based safety standards, periodic inspection, duties and liabilities of owners and occupiers, and structured penalty mechanism for non-compliance with the Goa, Daman and Diu Fire Force Act, 1986.
4. Though fire safety in Goa is primarily governed by State legislations, at central level, the Bureau of Indian Standards has issued the National Building Code (“NBC”), which was recently revised in 2016. The NBC prescribes detailed standards and guidelines relating to fire prevention, fire protection systems, and life safety requirements for buildings. Notably, Part 4 of the NBC specifically addresses “Fire and Life Safety”. Additionally, the Ministry of Urban Development has issued Model Building Bye-Laws, 2016 which serves as a guiding framework for the State Governments, Urban Local Bodies, Town Planning Authorities, and other relevant authorities for drafting, updating and harmonizing their respective building bye-laws.
5. The Ministry of Home Affairs, recognizing the evolving role of fire and emergency services and increasing complexities of fire safety challenges, revised the earlier Model Bill titled “Maintenance of fire force of the State” 1958 and introduced a revised Model Bill titled “Model Bill to provide for the Maintenance of Fire and Emergency Services for the state” in 2019. The Model Bill 2019 was approved by the Ministry of Home Affairs in consultation with the Ministry of Law and Justice and was subsequently circulated to all the states and Union Territories, with the request to review, revise and enact their respective fire safety and fire services legislation in alignment with the provisions of the Model Bill.
6. Updating the Act in alignment with Model Bill would provide Goa an opportunity to modernize its existing fire safety framework and further enhance the fire safety regulations in the State. Additionally, updating or amending the Fire safety framework will provide reassurance to the investors and tourists approaching Goa, of the proactive measures being taken by the State Government.

In the light of the foregoing, the following recommendations have been proposed:

• • Each state in India uses different terminology for fire safety approvals, such as fire license or no objection certificates. In the Model Bill, the term Fire Safety Certificate has been used and accordingly various states adopted this term. To bring uniformity and alignment with national standards, the term “Fire Safety Certificate” can replace the existing terminology i.e., No Objection Certificates (NOC) or licenses. Subsequently, a standard provision for issuance for fire safety certificate can be included in the Act.
  • Further, the Model Bill also prescribes the appointment of fire safety officer for certain buildings and premises by every owner and occupier. Considering the recent fire incidents, appointment of designated fire safety officer in certain high risk occupancies can be mandated by amending section 13 of the Act. Furthermore, appointing a fire safety officer for every such building or premises, will ensure that the responsibility of any untoward incident can easily be placed on the person responsible. It will also increase the awareness in every establishment towards fire safety regulations.
  • Additionally, the Model Bill provides a comprehensive provision regarding inspection powers, enabling the Director of the Fire Department and the fire officers to inspect premises on 3 hour notice to ensure fire safety and fire prevention. It also prescribes duties upon owners and occupiers to facilitate such inspections without any hindrances. Incorporating this into the Act will strengthen the fire safety compliance and enforcement in Goa, by ensuring that at any given time, the occupier and the owner are aware and updated with the fire compliances in their own premises.

In addition to the above, considering the high foot fall of hospitality and entertainment sector in Goa, and the risks associated with them, further recommendations have been proposed:

• • Certain occupancies such as night clubs, pubs, live performances, resto-bars and bars with dance floors (“High Risk Entertainment Occupancies”) can be recognized as a separate occupancy category under the Act. Further, additional fire safety measures, fire prevention compliance and emergency management can be imposed upon such occupancies time to time by the State Government. Additionally, in the application to NOC made by these High Risk Entertainment Occupancies, the maximum number of people allowed inside the premises should be given. By doing so, the places would not result in overcrowding, and in case any unwanted fire instance happens, proper procedure for evacuation could be followed.
  • While the Notification 3/14/2024-HD (G)/1652 dated 23.06.2025 extended the No Objection Certificate renewal to 5-years for both low-risk and high-risk buildings as defined in Notification 21/1/TCP/2020/GLDBCR/489 under the Goa Land Development and Building Construction (Amendment) Regulations, 2022 (Official Gazette, Series 1 No. 1 dated 07.04.2022), this frequency is protracting, considering the operational risks involved in High Risk Entertainment Occupancies. We recommend that the Rules and Notifications be amended to issue risk-based No Objection Certificate. An annual renewal of No Objection Certificate for High Risk Entertainment Occupancies may serve as a more appropriate alternative.
  • Additionally, any structural and interior modifications that might affect the effective functioning of the existing fire safety and fire prevention measures should trigger fresh fire safety clearance from the concerned local authorities. In addition, event-based fire safety clearance can be mandated for distinctive events involving occupant capacity above the prescribed capacity, use of fireworks, elaborate décor arrangements that are flammable.
  • Lastly, apart from the owner and person in charge of such occupancies, the designated officer or managerial personnel of the establishment may also be held responsible in cases involving fire accidents and non-compliance with fire preventive measures. This would ensure that accountability is maintained at all circumstances and there is always an identifiable person responsible for compliance and safety obligations.