Fire Code Change Request
Ontario’s Fire Code is a living document that gets refined and updated by Fire Code change requests which can come from anyone, any time, and the request will be processed for possible inclusion in the next iteration of Ontario’s Fire Code. While in some cases Code change requests can be implemented as an interim amendment nearly immediately (if determined appropriate), most Code change occurs during the cyclical review process. As Canada begins to harmonize the various provincial and territorial Codes over the coming years, the cyclical review of Fire Code change requests will likely take longer than we are historically used to.
In response to this process change, the Canadian Automatic Sprinkler Association (CASA) met with the Ontario Association of Fire Chiefs (OAFC) Board of Directors to discuss potential Fire Code changes to strengthen the qualifications and enforcement aspect of the Sprinkler & Fire Protection Installer Trade, that we would like to see implemented before the cyclical review process is updated. While at the same time, our Fire Prevention and Public Education Committee was working to strengthen the enforcement language of Section 9.3 of the Ontario Fire Code, Boarding, Lodging and Rooming Houses.
As such, the OAFC Board of Directors supported the recommendation from the OAFC Fire Prevention Public Education Committee, the Ontario Municipal Fire Prevention Officers Association (OMFPOA), and the Ontario Association of Fire Educators (OAFE), to submit three Fire Code Change Requests.
On July 27, 2021, the OAFC formally submitted three Fire Code Change Requests. The three Code Change Requests were supported by over 100 different fire related individuals accross Ontario.
To view a copy of the letter submitted to the Ontario Fire Marshal: 2021-07-27 - OAFC Fire Code Change Requests Final Letter
To view a copy of the OFMEM acknowledgement letter: FM Response OAFC
Strengthening the Qualifications for Fire Protection Systems
On January 1, 2014, Ontario became the first province in Canada to require the retrofit of all vulnerable occupancies to include the installation of automatic sprinkler systems. On February 2, 2017, in response to the amended Fire Code, and with the support of the OAFC, the Ontario College of Trades made sprinkler and fire protection installation a compulsory trade under O/Reg 275/11, s.41. This Regulatory change meant that those working on sprinkler systems must be properly trained, certified, and be College of Trades members in good standing under the following criteria:
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Apprentices Class;
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Journeyperson Candidates Class; or
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Journeypersons Class (Certificate of Qualification/ Provisional Certification of Qualifications issued by the college).
Only those certified in the above classes and are College of Trades members in good standing may practice the sprinkler and fire protection installer trade, be employed to work on sprinklers and fire protection installation, and use the trade title to describe themselves. Individuals qualified by the College of Trades are registered through the College’s Public Register located at https://www.skilledtradesontario.ca/public-register/.
One long-standing area of concern with this legislation is the enforcement aspect of qualified Sprinkler & Fire Protection Installers. It has been noted that once the fire service has identified a potentially non-compliant installation of sprinkler systems, there is confusion over how to proceed. Compounding the issue is the fact that many fire personnel feel the enforcement aspect lacks teeth – no one has the actual authority to enforce compliance. This is caused in part due to the disconnected nature of Ontario’s Fire Code with Ontario’s College of Trades regulatory requirements, specifically with Sections 6.4, 6.5, 6.6, 6.8 with Division C, Subsections 1.2.1 and 1.2.4 of the Ontario Fire Code.
Currently, the options for enforcement are extremely limited in Ontario’s current Fire Code to ensure that those conducting work, or installing these sprinklers, meet the requirements outlined by the College of Trades. It is our belief that this needs to be corrected. Allowing unqualified individual(s) to conduct this work negates our efforts to improve the life safety of residents in Ontario and specifically undermines the intent of O. Reg. 150/13: Fire Code, which requires the installation of working sprinklers in vulnerable occupancies.
To view a copy of the submission please click: Fire Code Change Request 633
NFPA 25 Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems
Confusion currently exists in these sub-sections because compliance with NFPA 25 is limited to the items explicitly outlined in the Ontario Fire Code and does not allow for the standard to be adopted across the full spectrum of the system, e.g., when deficiencies and impairments are identified, supply valve status testing, and forward testing of back flow preventors.
The OAFC recommendation is to update the language to be consistent with the National Fire Code, specifically section 6.4.1.1 that states inspection, testing and maintenance of water-based fire protection systems shall be done in conformance with NFPA 25, “Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems”.
To view a copy of the submission please click: Fire Code Change Request 634
Section 9.3 of the Ontario Fire Code, Boarding, Lodging and Rooming Houses
For a number of years fire departments have identified Section 9.3 Boarding, Lodging, and Rooming Houses, of the Fire Code as being especially problematic to enforce. Difficulties arise because it is the living arrangements themselves and the type of occupancy, which are often the intrinsic fire risk in these types of living arrangements. Most individuals living in these types of homes are unaware of their fellow occupants’ day-to-day activities, whereabouts, and live independently of the rest of the members of the building.
The current language for Section 9.3 of the Fire Code is problematic in a few instances as some requirements such as fire alarm and detection only apply to individual units within the building, not the entire building itself. Revising the language would help bring Section 9.3 in line with 9.5 and 9.6 and allow for the most restrictive requirements to apply in a building where there may be more than one residential occupancy regulated under Part 9. Updating the language in Article 9.3.2.4 which speaks to interior wall separations and fire-resistance ratings, will address, and fix the issues arising from the current language, which has resulted in an interpretation whereby there are no requirements for a fire separation between each room, between rooms and adjacent corridors, or other rooms and areas (such as laundry, kitchen/dining, bathrooms, etc.). The proposed change will address these shortcomings and provide a greater degree of fire compartmentations.
Further proposed changes to this section of the Fire Code speak to providing clarity for owners, ensuring that all fuel-fire appliances are installed properly, harmonizing the fire-resistance rating throughout the structure at a 30 minute fire resistance rating, updating Subsection 9.3.3 Mean of Egress to make the safety requirements equivalent to those in similar buildings that are classified in Section 9.5 of the Fire Code, ensuring a smoke alarm for each sleeping room, and requiring an early warning detection system.
The proposed updated Section 9.3 will also include a definition of a “Kitchen facility” to aid owners in determining what is permitted within a room in boarding, lodging, and rooming houses and what is not. The definition will also aid inspectors in determining occupancy and the ability to differentiate between a sleeping room and a dwelling unit.
Finally, we are proposing to add a new subsection to 9.3 of the Fire Code entitled 9.3.5 Suppression which speaks to automatic sprinkler protection in accordance with NFPA 13R “Standard for the Installation of Sprinkler Systems in Residential Occupancies up to and Including Four Stories in Height”.
To view a copy of the submission please click: Fire Code Change Request 635