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) Retrofit/Rectifying Unsafe Conditions in Existing Buildings
The need and practicality of separate requirements in the national model codes for renovation for existing buildings should be investigated

2.

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 doto I 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

NBCC 2005 Edition

Assembly Care or Detention

Comparison Of Occupancy Coverage

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

Residential Occupancies

Business and Personal Services Mercantile High, Medium, Low Hazard Industrial

COMPONENTS OF NFPA 101

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.

Chapts. 1-4, 6-10 Core Chapters Chapt 5 Performance-based Design Chapts. 11-42 Occupancy Chapters (New & Existing)

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
Rehabilitation work of existing facilities falls under one of the following:
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

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
1 (highest hazard) 2 3 4 (lowest hazard)

Occupancy Classification

High hazard contents Health care, detention and correctional, residential board and care Assembly, educational, day care, ambulatory health care, residential, mercantile, business, industrial, storage 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