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LIFE SAFETY CODES AND STANDARDS ANNUAL REPORT MAY 2018

The following report is respectfully submitted to provide highlights on proposed BC Fire Code changes and highlight activities that are ongoing or have been completed in 2017 and 2018.

The Province adopted the 2013 NFPA 13 R standard on July 20, 2017; this standard will require sprinklers on all balconies of four storey wood frame buildings.

It should also be noted that adopting NFPA13 R 2013 requires changing the title of the current standard from ‘Standard for the Installation of Sprinkler Systems in Residential Occupancies Up to and Including Four Stories in Height’ to the title ‘Standard for the Installation of Sprinkler Systems in Low-Rise Residential Occupancies’.

The scope of the standard has been updated to state:

NFPA 13 R 2013 Scope. This standard shall cover the design and installation of automatic sprinkler systems for protection against fire hazards in residential occupancies up to and including four stories in height in buildings not exceeding 60 ft (18 m) in height above grade plane.

The Fire Chiefs’ Association of British Columbia (FCABC) also hosted a residential sprinkler symposium that was attended by more than 180 delegates. It should be noted that senior staff from NFPA attended the symposium and commented that this was one of the largest sprinkler symposiums that they have witnessed in North America; well done to all.

Changes are on the horizon with the adoption of the Fire Safety Act which will be replacing the Fire Services Act.

CLARIFICATION OF PROPOSED FIRE CODE CHANGES

Background

The British Columbia Fire Code (BCFC) is based substantially on the model National Fire Code of Canada (NFC). The NFC is updated about every five years and British Columbia adopts most of the NFC requirements into the next edition of the BCFC. The 2018 BCFC will be based on the 2015 NFC with some changes specific to British Columbia, as noted.

Proposed Changes

Find attached four 2018 British Columbia Fire Code Public Review of Proposed Changes:

May 2018 Annual Report – Life Safety Codes and Standards.

• Fire Alarm, Standpipe, and Sprinkler System CHANGE NUMBER: 2018-BCFC-01-Application – Fire Systems

• Emergency Lighting CHANGE NUMBER: 2018-BCFC-02-Emergency Lighting

• Smoke Alarm Standard CHANGE NUMBER: 2018-BCFC-03-Smoke Alarms

• Use of Elevators in Emergency CHANGE NUMBER: 2018-BCFC-04-Use of Elevators in Emergency

Justification/Explanation

Fire Alarm Standpipe, Sprinkler Systems

The purposed changes The BCFC points to the British Columbia Building Code (BCBC) (Division A, Part 1) to determine when requirements for the provision of fire alarm, standpipe, and sprinkler systems apply. It is not intended that these requirements be applied retroactively to existing buildings that do not conform to the current edition of the BCBC, unless the BCBC applies per Article 1.1.1.1. of Division A. Typically, this is when the building is renovated or is subject to an addition, or when building systems and components are voluntarily replaced.

However, Sentence 2.1.3.1.(1) as written, has been misinterpreted to apply to, and require the upgrading of existing buildings. The proposed wording of this sentence is intended to clarify that where fire alarm, standpipe, and sprinkler systems are NOT provided, it is not the purview of the BCFC to require them. The authority to require such systems resides in Article 1.1.1.1. of Division A of the BCBC. However, where such systems are provided in a building, they must conform to the BCBC and BCFC

Emergency Lighting

The BCFC points to the British Columbia Building Code (BCBC) (Division A, Part 1) to determine when requirements for means of egress lighting, emergency lighting, and exit signs apply. It is not intended that these requirements be applied retroactively to existing buildings that do not conform to the current edition of the BCBC, unless the BCBC applies per Article 1.1.1.1. of Division A. Typically, this is when the building is renovated or is subject to an addition, or when building systems and components are voluntarily replaced.

However, Sentence 2.7.3.1.(1) as written, has been misinterpreted to apply to, and require the upgrading of existing buildings and systems or components.

The proposed changes clarify:

• the application of lighting requirements includes lighting in means of egress as required by the BCBC, not just in exits;


• there is no requirement that existing signage be removed and replaced to current standards (e.g., removal of ‘EXIT’ signs and replacement with the ‘running man’ pictogram); and

• that Article 1.1.1.1. of Division A of the BCBC determines when requirements apply to existing buildings.

Smoke Alarm

The BCFC points to the British Columbia Building Code (BCBC) (Article 1.1.1.1. of Division A) to determine when requirements for smoke alarms apply. It is not intended that these requirements be applied retroactively to existing buildings that do not conform to the current edition of the BCBC, unless the BCBC applies per Article 1.1.1.1. of Division A. Typically, this is when the building is renovated or is subject to an addition, or when building systems and components are voluntarily replaced.

However, Sentence 2.1.3.3.(1) as written, has been misinterpreted to apply to, and require the upgrading of existing smoke alarms.

The proposed changes clarify:

• that Article 1.1.1.1. of Division A of the BCBC determines when requirements apply to existing buildings;

• it is not the intent of the BCFC to require existing smoke alarms be removed and replaced to current standards;

The BCBC contains the requirements for smoke alarms and their installation. The BCBC references the CAN/ULC S531 standard for smoke alarms and CAN/ULC S553 standard for their installation. The BCBC also defines where smoke alarms are required. This is repeated in the BCFC, but not completely, which may cause confusion on where smoke alarms are required; the intent of the BCFC is to ensure the effectiveness of smoke alarms, whether they conform to the current or previous editions of the BCBC.

Elevators

Posting a sign that a building’s elevator is not to be used in an emergency may delay evacuation for persons requiring an elevator due to sensory or physical limitations.

The required Fire Safety Plan is the appropriate mechanism to coordinate safe egress for all occupants. In some cases, where identified in the Fire Safety Plan, use of an elevator to evacuate a building may be appropriate. For persons with sensory or physical limitations the elevator may be the most practical and quickest way to evacuate a building.

This proposed change aligns the requirements of the BCFC with those of the NFC to enable greater consistency amongst provincial jurisdictions.


If the requirement for the sign is deleted from Sentence (4), the sign requirements in Sentence (5) will no longer be applicable.

Respectfully submitted, Assistant Chief Pat Walker Life Safety Codes and Standards Lead

2018 British Columbia Fire Code Public Review of Proposed Changes

PROPOSED CHANGE: Application to Fire Alarm, Standpipe, and Sprinkler Systems

CHANGE NUMBER: 2018-BCFC-01-Application – Fire Systems

CODE REFERENCE: 2015 National Fire Code - Division B - Article 2.1.3.1., Appendix Note A-2.1.3.1.

DESCRIPTION OF THE PROPOSED AMENDMENT:

It is proposed to further clarify that the British Columbia Fire Code (BCFC) is not intended to retroactively apply current requirements for the provision of fire alarm, standpipe, and sprinkler systems to existing buildings. Though this concept is addressed in the appendix, the associated code language has caused some confusion.

PROBLEM/BACKGROUND:

The BCFC is based substantially on the model National Fire Code of Canada (NFC). The NFC is updated about every five years and British Columbia adopts most of the NFC requirements into the next edition of the BCFC. The 2018 BCFC will be based on the 2015 NFC with some changes specific to British Columbia, as noted.

The language of this BCFC requirement has caused some confusion on the application of the BCFC to existing buildings. For this reason, it is proposed not to adopt the wording of the 2015 NFC, and to provide clarification on the intended application in the wording of the requirement, as well as in the appendix.

The code language shown below is the proposed final code language that will appear in the 2018 BCFC. Comments submitted should focus on the changes noted. The wording of the 2015 NBC is not shown.

2018 PROPOSED BRITISH COLUMBIA CODE LANGUAGE (Deleted text / Added text):

2.1.3.1. Fire Alarm, Standpipe and Sprinkler Systems

1) Except as otherwise provided in this Code, Ffire alarm, standpipe and sprinkler systems shall be provided in all buildings when where required by and in conformance with Article 1.1.1.1. of Division A the British Columbia Building Code.

A-2.1.3.1.(1)

The British Columbia Building Code is most often applied to existing buildings when an owner wishes to rehabilitate a building, change its use, or build an addition; or when an enforcement authority decrees that a building, or a class of buildings, be altered for reasons of public safety. It is not intended that either the British Columbia Building Code or the British Columbia Fire Code be used to enforce the retrospective application of new requirements in the British Columbia Building Code to existing buildings.

Building and Safety Standards Branch, Province of British Columbia Page 2 of 4

Although the British Columbia Fire Code could be interpreted to require the installation of fire alarm, standpipe and hose and automatic sprinkler systems in an existing building for which there were no requirements at the time of construction,before the British Columbia Building Code was issued, it is the intent of the Canadian Commission on Building and Fire Codes that the British Columbia Fire Code not intended that the code be applied in this manner to these buildings.

It is usually difficult to change structural features of an existing building when undertaking alterations or additions, but the installation of “active” fire protection systems, such as alarms, sprinklers and standpipes, in existing buildings may be possible. These systems may be considered as contributing to an adequate degree of life safety in cases where the structural features of a building do not conform to the British Columbia Building Code.

Sentence 2.1.3.1.(1) is intended to address the installation of fire alarm, sprinkler and standpipe systems in existing buildings presently not so equipped, and in existing buildings that do not provide an acceptable level of safety to meet the current installation standards specified in the British Columbia Building Code. Further, Iit is not intended that existing fire protection systems that provide an acceptable level of life safety be upgraded with each new edition of the British Columbia Building Code or in conjunction with the inclusion of new requirements not in force at the time that a building was constructed. The authority having jurisdiction is expected to use discretion in enforcing this requirement. The authority having jurisdiction may accept alternatives to strict compliance with the NBC as provided for in Clause 1.2.1.1.(1)(b) of Division A.

For buildings in which a sprinkler system is installed, Tthis provision is also intended to direct Code users to Part 1 of Division A for the application of the British Columbia Building Code and primarily to Subsection 3.2.5. of Division B of the British Columbia Building Code, which specifies NFPA 13, “Installation of Sprinkler Systems,” as the appropriate standard for the design and installation of automatic sprinkler systems and provides several exceptions and supplementary requirements (where, in certain cases, other provisions in the British Columbia Building Code may also apply). However, where a specific hazard, such as highly piled storage or the storage of flammable and combustible liquids or rubber tires, is not addressed in the British Columbia Building Code, the applicable NFPA standards that contain design criteria for the sprinkler system required can be found in the British Columbia Fire Code.

RATIONALE FOR CHANGE:

To clarify the application of the BCFC’s requirements for fire alarm, standpipe, and sprinkler systems.

JUSTIFICATION/EXPLANATION:

The BCFC points to the British Columbia Building Code (BCBC) (Division A, Part 1) to determine when requirements for the provision of fire alarm, standpipe, and sprinkler systems apply. It is not intended that these requirements be applied retroactively to existing buildings that do not conform to the current edition of the BCBC, unless the BCBC applies per Article 1.1.1.1. of Division A. Typically, this is when the building is renovated or is subject to an addition, or when building systems and components are voluntarily replaced.


However, Sentence 2.1.3.1.(1) as written, has been misinterpreted to apply to, and require the upgrading of existing buildings. The proposed wording of this sentence is intended to clarify that where fire alarm, standpipe, and sprinkler systems are NOT provided, it is not the purview of the BCFC to require them. The authority to require such systems resides in Article 1.1.1.1. of Division A of the BCBC. However, where such systems are provided in a building, they must conform to the BCBC and BCFC.


It is also intended to clarify that, as noted in the appendix, it is not intended that systems are required to be upgraded if they are already installed in a building and conforming to an older edition of the BCBC, unless Article 1.1.1.1. of Division A of the BCBC applies.

The exception noted, as is conveyed in the appendix note, is to address specific hazards, such as highly piled storage or the storage of flammable and combustible liquids or rubber tires that are not addressed in the BCBC.

The word “where” is change to “when” to reinforce that existing buildings or systems must only be upgraded when the BCBC applies. The phrase “in conformance with” is considered redundant as this is already a requirement of the BCBC.

The additional changes proposed in the Appendix further clarify:

• the BCFC provisions do not require upgrading of existing buildings or systems where the BCBC does not apply, but they are to apply to voluntarily provided systems, as well as systems that are required by the BCBC at the time of construction or at the time of further application of the BCBC, and



PROPOSED CHANGE: Emergency Lighting

CHANGE NUMBER: 2018-BCFC-02-Emergency Lighting

CODE REFERENCE: 2015 National Fire Code - Division B - Article 2.7.3.1., Appendix Note A-2.7.3.1.


It is proposed to further clarify that the British Columbia Fire Code (BCFC) is not intended to retroactively apply current requirements for means of egress lighting, emergency lighting, and exit signs to existing buildings.

PROBLEM/BACKGROUND:

The BCFC is based substantially on the model National Fire Code of Canada (NFC). The NFC is updated about every five years and British Columbia adopts most of the NFC requirements into the next edition of the BCFC. The 2018 BCFC will be based on the 2015 NFC with some changes specific to British Columbia.

The language of this BCFC requirement has caused some confusion regarding the application of the BCFC to existing buildings.

The code language shown below is the proposed final code language that will appear in the 2018 BCFC. Comments submitted should focus on the changes noted. Changes from the 2012 BCFC to the 2015 NFC are not identified.


2.7.3.1. Installation and Maintenance

1) Exit Means of egress lighting, exit signs and emergency lighting, exit signs and the location of exit signs in buildings shall conform to be provided in buildings in conformance with the British Columbia Building Code. (See Note A-2.7.3.1.(1).)

A-2.7.3.1.(1)

Subsections 3.2.7. and 3.4.5. of Division B of the British Columbia Building Code describe the requirements for the placement of exit signs and for emergency and non-emergency lighting.

It is not intended that existing buildings or their systems and components be required to be upgraded with each new edition of the British Columbia Building Code unless the requirements apply per Article 1.1.1.1. of Division A of the British Columbia Building Code. For example, newly installed or replaced exit signs must conform to the requirements of the current edition of the British Columbia Building Code, but other existing signs that complied when the building was constructed or previously altered are not required to be upgraded as a result (unless as a function of ongoing maintenance).



To clarify the application of the BCFC’s requirements for means of egress lighting, emergency lighting, and exit signs.


The BCFC points to the British Columbia Building Code (BCBC) (Division A, Part 1) to determine when requirements for means of egress lighting, emergency lighting, and exit signs apply. It is not intended that these requirements be applied retroactively to existing buildings that do not conform to the current edition of the BCBC, unless the BCBC applies per Article 1.1.1.1. of Division A. Typically, this is when the building is renovated or is subject to an addition, or when building systems and components are voluntarily replaced.

However, Sentence 2.7.3.1.(1) as written, has been misinterpreted to apply to, and require the upgrading of existing buildings and systems or components. The proposed changes clarify:

• the application of lighting requirements includes lighting in means of egress as required by the BCBC, not just in exits;

• there is no requirement that existing signage be removed and replaced to current standards (e.g., removal of ‘EXIT’ signs and replacement with the ‘running man’ pictogram); and



PROPOSED CHANGE: Smoke Alarm Standard

CHANGE NUMBER: 2018-BCFC-03-Smoke Alarms

CODE REFERENCE: 2015 National Fire Code - Division B – Table 1.3.1.2., Article 2.1.3.3.


It is proposed to further clarify that the British Columbia Fire Code (BCFC) is not intended to retroactively apply current requirements for smoke alarms to existing buildings.

PROBLEM/BACKGROUND:

The BCFC is based substantially on the model National Fire Code of Canada (NFC). The NFC is updated about every five years and British Columbia adopts most of the NFC requirements into the next edition of the BCFC. The 2018 BCFC will be based on the 2015 NFC with some changes specific to British Columbia.

The wording of this BCFC requirement has caused some confusion regarding the application of the BCFC to existing buildings.

The code language shown below is the proposed final code language that will appear in the 2018 BCFC. Comments submitted should focus on the changes noted. Changes from the 2012 BCFC to the 2018 NFC are not identified.


Table 1.3.1.2. Documents Referenced in the British Columbia Fire Code

Forming Part of Sentence 1.3.1.2.(1)

Issuing Agency Document Number(1) Title of Document(2) Code

Reference

ULC CAN/ULC-S531-14 Smoke Alarms 2.1.3.3.(1) ULC CAN/ULC-S553-14 Installation of Smoke Alarms 2.1.3.3.(3)

2.1.3.3. Smoke Alarms

(See Note A-2.1.3.3.)

1) Smoke alarms conforming to CAN/ULC-S531, “Smoke Alarms,” shall be installed in each dwelling unit and, except for care, treatment or detention occupancies required to have a fire alarm system, in each sleeping room not within a dwelling unit. and the installation of smoke alarms shall conform to the British Columbia Building Code.


2) Reserved. Smoke alarms within dwelling units shall be installed between each sleeping area and the remainder of the dwelling unit, and where the sleeping areas are served by hallways, the smoke alarms shall be installed in the hallways.

3) Reserved. Smoke alarms shall be installed in conformance with CAN/ULC-S553, “Installation of Smoke Alarms.”

4) Smoke alarms are permitted to be battery operated in

a) a building that is not supplied with electrical power,

b) a dwelling unit permitted to be constructed before March 31, 1979, or

c) locations within a dwelling unit where smoke alarms were not required by the British Columbia Building Code at the time of construction or alteration of the dwelling unit.1

A-2.1.3.3.

It is not intended that existing buildings or their systems and components be upgraded with each new edition of the British Columbia Building Code, unless the requirements apply per Article 1.1.1.1. of Division A of the British Columbia Building Code. For example, newly installed or replaced smoke alarms must conform to the requirements of the current edition of the British Columbia Building Code, but other existing smoke alarms that complied when the building was constructed or previously altered are not necessarily required to be replaced as a result. The extent to which the British Columbia Building Code applies in such circumstances will be determined based on the effect of newly installed or replaced smoke alarms in relation to the existing smoke alarms.


To clarify the application of the BCFC’s requirements for smoke alarms.


The BCFC points to the British Columbia Building Code (BCBC) (Article 1.1.1.1. of Division A) to determine when requirements for smoke alarms apply. It is not intended that these requirements be applied retroactively to existing buildings that do not conform to the current edition of the BCBC, unless the BCBC applies per Article 1.1.1.1. of Division A. Typically, this is when the building is renovated or is subject to an addition, or when building systems and components are voluntarily replaced.

However, Sentence 2.1.3.3.(1) as written, has been misinterpreted to apply to, and require the upgrading of existing smoke alarms. The proposed changes clarify:

• that Article 1.1.1.1. of Division A of the BCBC determines when requirements apply to existing buildings;

• it is not the intent of the BCFC to require existing smoke alarms be removed and replaced to current standards;

1 Sentence (2) is unique to the British Columbia Fire Code and is intended to be carried over in to the 2018 edition. This sentence has been included for reference, but is not subject to this public review.


• the BCBC contains the requirements for smoke alarms and their installation. The BCBC references the CAN/ULC S531 standard for smoke alarms and CAN/ULC S553 standard for their installation. The BCBC also defines where smoke alarms are required. This is repeated in the BCFC, but not completely, which may cause confusion on where smoke alarms are required;

• the intent of the BCFC is to ensure the effectiveness of smoke alarms, whether they conform to the current or previous editions of the BCBC.


PROPOSED CHANGE: Use of Elevators in Emergency

CHANGE NUMBER: 2018-BCFC-04-Use of Elevators in Emergency

CODE REFERENCE: 2015 National Fire Code - Division B - Article 2.8.2.7.


It is proposed to delete the requirement to post a sign that a building’s elevator is not to be used in an emergency.

PROBLEM/BACKGROUND:

The British Columbia Fire Code (BCFC) is based substantially on the model National Fire Code of Canada (NFC). The NFC is updated about every five years and British Columbia adopts most of the NFC requirements into the next edition of the BCFC. The 2018 BCFC will be based on the 2015 NFC with some changes specific to British Columbia.


The code language shown below is the proposed final code language that will appear in the 2018 BCFC. Comments submitted should focus on the changes noted. Changes from the 2012 BCFC to the 2018 NFC are not identified. This proposal is to delete the noted content, which is unique to the BCFC and is not based on the model NFC.


2.8.2.7. Posting of Fire Emergency Procedures

1) At least one copy of the fire emergency procedures shall be prominently posted on each floor area.

2) In every hotel and motel bedroom, the fire safety rules for occupants shall be posted showing the locations of exits and the paths of travel to exits.

3) Where a fire alarm system has been installed with no provisions to transmit a signal to the fire department, a sign shall be posted at each manually actuated signalling box requesting that the fire department be notified, and including the telephone number of that department.

4)-All buildings served by one or more elevators shall have, at each elevator entrance on each floor level, a permanently mounted fire safety sign or symbol indicating that the elevator is not to be used in case of fire.

5)-The sign or symbol required by Sentence (4) shall be at least 100 mm in height and width and shall be designed in accordance with NFPA 170, “Standard for Fire Safety and Emergency Symbols.”





The required Fire Safety Plan is the appropriate mechanism to coordinate safe egress for all occupants. In some cases, where identified in the Fire Safety Plan, use of an elevator to evacuate a building may be appropriate. For persons with sensory or physical limitations the elevator may be the most practical and quickest way to evacuate a building.

This proposed change aligns the requirements of the BCFC with those of the NFC to enable greater consistency amongst provincial jurisdictions.

If the requirement for the sign is deleted from Sentence (4), the sign requirements in Sentence (5) will no longer be applicable.