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Using NFPA 101

Bridging the Enforcement Gap

Sean Tracey
Canadian Regional Manager NFPA

Issues Raised by CCBFC/PTPACC


In the recent joint meeting they identified the
following policy issues:
1.

Renovation of Existing Buildings: (amounting to


50% of construction activity)

The need and practicality of separate requirements in the national model


codes for renovation for existing buildings should be investigated

2.

Retrofit/Rectifying Unsafe Conditions in Existing


Buildings

The development of an acceptable set of requirements in the NFC should be


considered in the context of the general move to restructuring the
National Fire Code.

The Enforcement Gap


Addressing Existing Occupancies
NBCC: It is not the intent that the NBCC be used to enforce
the retrospective application of requirements to existing
buildings, unless specifically required by local regulations
or by-laws.
NFCC: The application of the Code to the upgrading of
Application of NFPA 101 as a resource tool or even
existing facilities to provide an acceptable degree of life
by adoption provides necessary completion on
safety should be the judgment of the enforcing authority,
addressing life safety elements of existing
who must deal with each case on its merits.
occupancies. Provides required guidance or
So
how dotoI decide?
What resources
I have upon
direction
the enforcement
official do
developed
in a which to
make such
a decision?
consensus
process
and already widely accepted.

Existing Facilities
What to do when existing facilities do not meet a
reasonable degree of fire and life safety?
Just because a facility has been grandfathered does not
mean it should continue to operate below a level of
safety others should expect

How do I determine what a reasonable level is?


e.g. A community centre built in 1970 that has too large
of an occupancy load for current exits?
A seniors residence with occupants incapable of selfpreservation and no sprinkler system?
A bed and breakfast with an open stairwell?

How do I work with adaptations in


the field?
How do I handle imminent fire and life
safety hazards?
How much work should be required when
buildings are undergoing renovations?

Life Safety Code


Development

Developed by 14 Committees
Over 250 Volunteers
Every 3 years
1997, 2000, 2003, 2006, 2009
Source for many existing Canadian code
provisions for life safety

Life Safety Code Origins


1911 Triangle Shirtwaist
Fire
1912: Pamphlet Exit
Drills in Factories,
Schools, Department
Stores and Theaters.
1913: Committee on
Safety to Life Appointed.
First Few Years Studied
Significant Fires with
Loss of Life.

Life Safety Code Origins


 Coconut Grove Fire
(1942) and other
significant life loss
fires raised awareness
of adequate exits and
fire safety.
 1948: Work started to
rework the Code to
mandatory language.

Life Safety Code Refinement


over Time
Refinement over time
Reflects loss record
and latest
understanding of fire
science
Fire Investigations
input e.g. Forest Lane
Way and Meadowcroft
fires
Major evolutions in codes have been driven by
catastrophic events that were a betrayal of trust

Life Safety Code


Scope
Construction, protection and occupancy
features to minimize danger to life from fire
(smoke, fumes and panic)
Establishes minimum criteria for egress
Protective Features and Systems
Bldg Services
Maintenance
Staff Training, Emergency Planning, etc..

Use of NFPA 101 in Canada


Prince Edward Island
Newfoundland for Existing
Buildings for over 20 years
Copies of NL Fire Act can be made available

NFPA 101 is a First Generation Code Document

NFPA 101 Use Throughout Canada


Referenced in Alberta
Go to source for numerous Ontario
rulings
Used in many designs
Increased reference under
the new Objective-based Codes
Will be referenced in the 2005 NBC

NFPA 101 Use Throughout Canada


It is being promoted across Canada by
NFPA as a means to bridge the
enforcement gap a means to apply
minimum fire and life safety standards to
existing buildings

SCOPE of the
LIFE SAFETY CODE
 Addresses Life Safety from Fire and Similar
Emergencies.
 Addresses those Construction, Protection, and
Occupancy Features necessary to Minimize
Danger to Life from Fire, Smoke, Fumes, or
Panic.
 Identifies Minimum Criteria for the Design of
Egress Facilitates so as to Permit Prompt Escape
from Buildings or, when desirable, into Safe Areas
within the Building.

Life Safety Code


What are the Core Objectives?
Core Requirements of
NBCC

Safety
Health
Accessibility
Protection of Buildings

Core Requirements of
NFPA 101
Safe from fire &
Similar Emergencies
Crowd Movement
Occupant protection
Structural integrity
Systems effectiveness

How does it fit in with NBCC?


Not a building code*
Not a fire code*
Works with other building and fire codes
Conflicts resolved
through admin
provisions

How is the Life Safety Code


Complimentary?
Addresses Existing & New building
requirements
Same core objectives
Chapter 5 addresses how to present and
review alternative solutions
How to resolve conflicts
Compatibility between codes is an
administrative responsibility not regulatory

Comparison Of Occupancy
Coverage

NBCC 2005 Edition

Assembly
Care or Detention

Residential Occupancies

Business and Personal Services


Mercantile
High, Medium, Low Hazard
Industrial

NFPA 101 2009 Edition

Assembly
Detention & Correctional
Health Care
Ambulatory Health care
Residential Board and Care
One and Two Family Dwellings
Apartment Buildings
Hotels and Dormitories
Lodging or Rooming Houses
Business
Mercantile
Industrial
Educational
Storage
Mixed
Day Care

COMPONENTS OF NFPA 101

Chapts. 1-4, 6-10


Core Chapters
Chapt 5
Performance-based
Design
Chapts. 11-42
Occupancy Chapters
(New & Existing)

Fundamental or Core Chapters are


mandatory for all occupancies
Occupancy Chapters provide
detailed information specific to
that occupancy.
The annex materials provide
useful additional information
but are not mandatory
provisions.

Contents

CORE

Addressing Existing Buildings

NFPA 101 and Existing


Buildings
With NFPA 1/101 Existing Buildings are
NOT Grandfathered in for the Life of the
Building
The AHJ is Not Stuck with Hazardous
Conditions or Forced to Attempt to Prove
an Imminent Hazard
Existing Buildings Must meet a Reasonable
Level of Safety

NFPA 101 and Existing


Buildings
When addressing an Imminent Hazard,
NFPA 101 Provides Excellent Guidance
Used in the performance of life safety audits
NFPA 101A provides a framework to
address equivalencies for life safety in
existing structures.

Building Rehabilitation

Building Rehabilitation
Chapter 43
New Chapter 43 added to bring all info
together on building rehabilitation
Being promoted across Canada as a means
to reconcile with NBCC and NFCC and
address existing buildings
thanks to Newfoundland & Labrador who have
used this for 20+ years

Building Rehabilitation
Chapter 43

Repair
Renovation
Modification
Reconstruction
Change or Use or Occupancy
Classification
Addition
Historic Buildings

[43.3]
[43.4]
[43.5]
[43.6]
[43.7]
[43.8]
[43.10]

Extent of
scope of
work
increases

Rehabilitation work of existing facilities falls


under one of the following:

Definitions

Repair
Renovation
Modification
Reconstruction
Change of Use
Addition
Technically Infeasible

Applicable Requirements
Repair, renovation, modification or
reconstruction
Applicable section of Chapter 43

Change of Use or occupancy - Section 43.7


Addition Section 43.8
Historic buildings Section 43.10

Capacity of MOE
Shall meet the requirements of 7.3 unless:
Means are taken to prevent occupancy above
the capacity of the MOE, or
The MOE capacity was previously approved by
the AHJ as being adequate,

Multiple Rehab Categories


Provides clarification on how to deal with separate
work areas
Work of various categories can be lumped
together in the same type
Reasonable application of the requirements
Provisions allow for separate occupant spaces not
being affected by the rehabilitation work to be
exempt
Exceptions re healthcare occupancies

Compliance
Alternative solutions are permitted if
equivalent and acceptable to AHJ
If technically infeasible or undue hardship
then AHJ can accept alternatives
Components that exceed those for new
requirements can be modified but must
continue to meet the minimum new
requirements

Repairs
Use like
approved
materials
Shall not make it
less conforming

Renovations
Includes strengthening,
refurbishment or
upgrading
All new work meets the
requirements of NFPA 101
for existing buildings
Shall not be less conforming

Modifications
Reconfiguration of space or adding new
equipment.. E.g.
New components to meet new component
requirements
For extensive modifications Shall be
considered reconstruction except work that
is exclusively mechanical or electrical

Group Exercise
Scenario 1: Maintenance staff need to
replace an exit door that has been damaged
due to overuse.
Renovation

Scenario 2: Maintenance need to replace 5


ft2 of gypsum board in a corridor due to
damage.
Repair

Group Exercise
Scenario 3: A bar wishes to remove the
existing Class A rated textile wall covering
for or another Class A rated wall covering.
Renovation

Scenario 4: A school wants to convert two


existing classrooms into a day care facility.
There will be no changes to the exiting just
to the interior adjoining wall
Modification

Reconstruction

See definition 43.2.2.1.4

Reconstruction Requirements
Sets specific requirements
for:

Means of Egress
Fire and Smoke Barriers
Extinguishing Systems
Fire Alarm Systems - Smoke
Alarms
Elevators

Reconstruction Requirements
Means of Egress
General. Shall meet the applicable existing
occupancy requirements [Section __.2]
Illumination, & Exit Signage:
Must meet new requirements in the rehab area,
throughout the floor if >50% of floor area, and
throughout area if >50% of building.
Handrails, and Guards must be provided if an
egress path is to be used.
7.39

Reconstruction - Sprinklers

Reconstruction Requirements
Extinguishing Systems
If >50% of aggregate building area AS to be
provided if required in the new occupancy
section
If >50% of any storey then the sprinkler is
to be installed throughout that storey if reqr
by the new section.
Guidance given on standpipe systems and
fire pumps

Reconstruction - Sprinklers

Reconstruction - Sprinklers

Reconstruction Requirements
Fire/Smoke Alarm Systems
Specific guidance given on retrofit to new
requirements for residential occupancies as
well as board and care occupancies.

Additions

Meets new requirements for the addition


PLUS existing requirements for the
remaining portion.
If increasing areas entire area to be
protected by an AS

Change of Use or Occupancy


Classification
Change of Use
any work undertaken complies with
Chapt 43

Change of Occupancy Classification


Follow the table

New Hazard Classification Table


Table 43.7.3 Hazard Categories and Classifications
Hazard
Category

Occupancy Classification

1 (highest
hazard)

High hazard contents

Health care, detention and correctional, residential board


and care

Assembly, educational, day care, ambulatory health care,


residential, mercantile, business, industrial, storage

4 (lowest
hazard)

Industrial and storage occupancies with low hazard


contents

Hazard Classification Change


If in the same or to a lesser class:
To meet the existing occupancy requirements &
AS, detection, alarm and communications to
new occupancy requirements

If increasing hazard class:


Must meet new occupancy requirements

Group Exercise
Example 1 Owner wants to convert a
three storey residential apartment building
into a board and care facility
Example 2 Owner wants to convert a
store in a strip mall into a daycare centre.

Historic Properties
NBCC does not cover
historic properties
No Canadian federal
guidelines to address
rehabilitation of fire and life
safety systems
NFPA 914 Code for Fire
Protection of Historic
Properties is also a resource

Historic Properties
Evaluation required for modification,
reconstruction, addition or change of use
A written report presented to AHJ by a
registered design professional
knowledgeable of historic preservation
Balance the historical preservation needs
with public fire and life safety needs

Historic Properties
Repairs replacements not required to meet
the code
MOE judgement of AHJ if narrower than
capacity can be permitted [43.10.4.3.]
Other areas such as interior finishes, guards,
balanced assessment based on AHJ
judgement
AS can be required by the AHJ

Summary

Recommended Checklist/Review
Coincides with Sub-Sections in NFPA 101
1. What is the type of occupancy? Are there
multiple occupancies involved? If so are there
proper separations?
2. What is the calculated occupancy load? Verify
that these were done correctly.
3. Verify the means of egress
1.
2.
3.
4.
5.
6.
7.
8.

Proper number
Proper orientation
No obstructions
Travel path
Discharge
Illumination of exit path (if needed)
Emergency lighting (if needed)
Exit signage (if needed)

Recommended Checklist/Review
Coincides with Sub-Sections in NFPA 101
4. What is the interior finish?
5. Is there a detection means present? Is it to a
central station?
6. Extinguishing Systems
1.
2.

Is it sprinklered
Portable fire extinguishers as per NFPA 10

7. Are there any special hazards present?


8. Are there any special building services? Are
these in good repair and properly separated?
9. Are there any special operating conditions?
NOTE: Unless special conditions dictate we normally are
never more stringent than the current NBC.

Conclusion
NFPA 101 is an additional resource for building
and fire inspection community concerned with
providing fire and of safety beyond the absolute
minimum
Applicable to existing and new standards
Already successfully in use in a number of
jurisdictions in Canada.
By-law adoption to enable enforcement failing
that a resource/guide for use in existing facilities