2015 Fire Code Violations

5 NOTABLE CHANGES From the 2015 NATIONAL Fire Code

Codes and Standards change and evolve. But they can’t keep pace with the rapidly developing world around us. As an owner or property manager, it is your responsibility to keep up with these changes: as it’s your responsibility to comply with the Code. 

I've been in the fire protection and life safety industry for over 20 years, and I find it challenging keeping up with the changing building and fire code requirements. Let me help you. 

This blog post is intended for owners (building & business), property managers, and facility managers. It identifies five changes in the 2015 National Fire Code of Canada that you may not be aware of. 

SUMMARY

1. Integrated Systems Testing of Fire Protection and Life Safety Systems

This testing must be performed on new construction and existing buildings in conformance with CAN/ULC-S1001, Standard for Integrated Systems Testing, and the National Fire Code. A qualified person known as an Integrated Testing Coordinator is required to oversee the testing. The ITC must prepare an integrated testing plan (ITP). The ITC must prepare an Integrated Testing Report upon completion of the tests.  

2. Testing of Fire Dampers and Fire Stop Flaps 

All fire dampers and fire stop flaps are required to undergo inspection and testing per NFPA 80. This includes inspection and test after installation, as well as 1 year after installation and every 4-years thereafter (except hospitals are permitted to test at 6-year intervals), and any time there is a repair. All inspections, tests, and repairs must be documented.

3. Inspection, Testing, and Maintenance of Exit Signs 

All exit signs are required to be tested at least annually. They must be tested for a minimum duration equal to the emergency power requirements for the building. Ie. 90 min, 60 min, or 30 min.

4. Exterior Exit Door Obstructions 

All exterior exit doors that may be subject to obstruction must be provided with signage or a physical barrier, or both to prevent obstruction.

5. Retention of Fire Safety Plans

Fire safety plans in certain occupancies must be posted at the principal entrance. In general, the following occupancies must post the fire safety plan at the principal entrance:  

• warehouse type storage, 

• occupancies where there is storage, handling, or use of flammable or combustible liquids, 

• occupancies where some processes or operations create a hazard to life safety, such as explosives, or high-flammability materials.  

Bonus - Emergency Crossover Access to Floor Areas

This was added as a bonus as it is a change to the National Building Code of Canada. Emergency crossover access to floor areas, aka “crossover floors” no longer only applies to buildings more than 6 storeys in building height. The requirements were revised to remove the building height restriction and to prescriptively allow the installation of electromagnetic locking devices, aka “maglocks”. The retroactive application of these requirements is subject to the interpretation by the local Authority Having Jurisdiction (AHJ). 

After writing blogs for the past two years, I’ve consistently received feedback on one specific item, readers like to know where and how to find the relevant Code requirements. Excerpts from the Codes are included at the end of the blog. 

For those inclined to dive deeper, keep reading for more in-depth information on the topics above.

Integrated Systems Testing of Fire Protection and Life Safety Systems

When a fire protection or life safety system is installed, it is tested to confirm that it is operational. There may be many interconnections between the various fire protection and life safety systems. The interconnection between a fire alarm system and a fire door is one connection. 

Some fire doors are held in the open position by an electronic hold-open device. The electronic hold-open device must be connected to the fire alarm system when they are used on a fire door. 

During the ongoing testing of the fire alarm system, the fire alarm technician is only required to ensure that the relay operates. They only check the electrical connection between the fire alarm relay and the fire alarm panel. They are not required to check and see if the door is released and that it self-closes and positively latches.  

The 2010 Editions of the National Codes (building and fire) contained new provisions for the “Commissioning of Life Safety and Fire Protection Systems.” While the intention of adding these requirements was good, they were incomplete and confusing. The term commissioning was used. Commissioning has a specific meaning in the context of the construction industry. Also, there was no referenced standard or guidance on who was qualified to "commission" systems. This confusion led to many questions and a lack of enforcement.  

The term "commissioning" was removed, and the wording was revised in the 2015 Edition of the National Codes. The updated requirements referred to the fact that testing of the interconnections between the fire protection and life safety systems was required. In addition, the Codes now referenced the CAN/ULC-S1001, “Integrated Systems Testing of Fire Protection and Life Safety Systems” standard for the testing. These revisions resolved two of the issues with the 2010 Codes. 

The last point of contention with the 2010 Codes was who was permitted to conduct this work. The 2010 Appendix stated,

“[u]ltimately, someone will have to ensure that the interconnected operation of all life safety systems within the building has been confirmed: this responsibility may fall on the designer, owner, contractor or a commissioning body. The NFC does not specify who must fulfill this role as this is an administrative issue.” 

A Note (the new term for the appendix material) was included in the 2015 Edition, which states, “[b]uilding owners must ensure that fire protection and life safety systems and their components, including their interconnections with other building systems, are functioning according to the intent of their design...”. There is no further guidance in the National Codes concerning qualifications, only that the building owner is responsible. 

The CAN/ULC-S1001 Standard identifies the role of an integrated testing coordinator (ITC) and that the ITC is responsible for preparing the integrated testing plan and integrated testing report. The Standard states that the ITC “shall be knowledgeable and experienced in the design, installation, and operation of fire protection and life safety system(s), and the fire protection and life safety functions of building systems.” 

The Appendix note states, “it was envisioned that the federal, provincial, territorial, or other governing bodies adopting this Standard will require that the integrated testing coordinator have qualifications as appropriate to their jurisdiction. However, these administrative requirements cannot be included in National Standards.” The question remains, who is qualified to perform the work? Ultimately, it’s up to the AHJ as to who they will accept as an ITC. 

ULC offers a course as well as an exam and provides a certificate “for each ITC verifying their competency in the CAN/ULC-S1001 standard and participation in the ULC Integrated Testing program.” 

It’s important to note that the integrated testing requirements are retroactively applicable under the NFC. If you are looking for more information about CAN/ULC-S1001? Check out this post Connecting the Safety Dots – CAN/ULC S1001 | Kilo Lima Code.  

Also check out the requirements from the City of Regina, Regina S1001 Advisory. 

Testing of Fire Dampers and Fire Stop Flaps

Fire dampers are installed where ducts penetrate a fire-rated assembly, and fire stop flaps are installed in a ceiling membrane that contributes to the overall fire resistance rating of a horizontal construction assembly. Both are designed to operate when the fusible link melts due to exposure to heat. Fire dampers and fire stop flaps close to prevent the further passage of heat. Both devices aid in maintaining the integrity of the fire separation. 

The 2010 Edition of the National Fire Code required that fire dampers and fire stop flaps be inspected annually. There were no requirements for the testing of either device. The 2015 Code was revised to include a new reference for testing fire dampers and fire stop flaps, as well as smoke dampers and combination smoke/fire dampers in conformance with NFPA 80, “Fire Doors and Other Opening Protectives.” 

NFPA 80 requires that fire dampers & fire stop flaps (ceiling radiation dampers in the NFPA codes and standards) be:

1. Inspected and tested after installation,

2. Inspected and tested 1-year after installation,

3. Tested every 4 years thereafter, unless it is a hospital in which case every 6 years thereafter, and

4. Inspected and tested after any repair.

All inspection, testing, maintenance, and operational procedures must be documented and maintained in conformance with the National Fire Code. See the last paragraph of this post for further guidance on the maintenance of documentation. 

If you want to know more about dampers, check out my post on fire dampers. 

Inspection, Testing, and Maintenance of Exit Signs

Exit signs are required to assist occupants in identifying their way out of a building or space. The codes require exit signs to be illuminated when a building is occupied. Before the 2015 National Fire Code, the code was silent on whether exit signs required any testing. The 2015 Edition of the Fire Code was revised to include a requirement to inspect, test and maintain exit signs. The new requirements include:

• Monthly test for all exit signs with battery backup to ensure that they are visible upon primary power failure,

• Annual test for exit signs with battery backup to ensure that exit signs will be visible for a duration equal to the design criterion upon failure of the primary power supply.

  • • • 2 hours for a high building,

      • 1 hour for Detention, Treatment, and Care occupancies,

      • 1 hour for 5- and 6-Storey Wood Buildings, and

      • 30 minutes for all other buildings.

• Annual test for all exit signs not provided with battery backup. 

As previously noted, documentation for the above tests is required to be prepared and maintained. Check out this blog post on Exit Lighting and Exit Signs if you want to dive further. 

Exterior Exit Door Obstructions

Means of egress have always been required to be “maintained in good repair and free of obstructions.” It is important to note that the term means of egress is often used in the codes and has a specific definition. The Code defines means of egress as 

“a continuous path of travel provided for the escape of persons from any point in a building or contained open space to a separate building, an open public thoroughfare, or an exterior open space protected from fire exposure from the building and having access to an open public thoroughfare. Means of egress includes exits and access to exits.”

This definition includes all points of travel from any point in a building through doors, corridors, and spaces to a protected area. The protected area can be a separate building or an open public thoroughfare, such as a street. However, fire inspectors and building safety professionals often see exterior exit doors obstructed by parked vehicles or stored materials. 

The 2015 Edition of the National Fire Code was revised to include specific requirements for exterior exit doors. The new requirements state that any exterior exit door that may become obstructed by vehicles or storage of materials must be provided with a visible sign or a physical barrier to prevent any obstructions.

Retention of Fire Safety Plans

The 2010 Edition of the National Fire Code required that fire safety plans be kept in the building, or onsite. High buildings were required to maintain a copy of the fire safety plan at the central alarm and control facility (CACF). The 2015 Edition of the Fire Code was revised to state that specific occupancies are required to maintain the fire safety plan at the principal entrance. 

Specifically, these occupancies are those to which the requirements of Sections 3.1., 4.1, and 5.1 apply.

• Section 3.1. generally applies to buildings with warehouse-type storage.

• Section 4.1 generally applies to any occupancies that store, handle or use flammable or combustible liquids.

• Section 5.1 generally applies to processes and operations that involve risk from explosion, high flammability, or related conditions that create a hazard to life safety.

These occupancies must maintain a copy of their fire safety plan at the principal entrance. 

Bonus - Emergency Crossover Access to Floor Areas

Emergency Crossover Access to Floor Areas was added as a bonus, as it was a change in the National Building Code rather than the Fire Code. 

The 2010 Edition of the National Building Code contained requirements for Emergency Access to Floor Areas, commonly called crossover floors. These requirements applied to buildings more than 6 storeys in building height. These requirements were revised in the 2015 Edition to change the name (adding “Crossover”), as well as to remove the building height requirement, and explicitly permit the installation of electromagnetic locking devices (“maglocks”) on these doors. 

Provisions for “Emergency Crossover Access to Floor Areas” now apply to all buildings regardless of a buildings height. In addition, there are now prescriptive requirements for maglock installations on these doors. 

It’s important to note that the NFC states that “[m]eans of egress shall be provided in buildings in conformance with the NBC.” As such, there may be some variation in the interpretation and application of the retroactive application of these requirements to existing buildings.   

Concluding Thoughts

One last point. Inspection, testing, and maintenance must be documented. Documentation is your key to compliance. 

The National Fire Code of Canada requires that documentation be retained for all tests, inspections, maintenance, and operational procedures performed on fire protection and life safety systems. The initial verification and acceptance test reports for each system must be maintained throughout the life of the system. 

In addition, all records of tests, inspections, maintenance, and operational procedures performed after the initial tests must be retained so that at least the current and immediately preceding records are available. No ITM record can be destroyed within two years of being prepared. 

This means that:

• ITM intervals of 1 year or less – records retained for at least 2 years

• ITM interval greater than 1 year – records retained so that the current and immediately preceding records are available

Most importantly, it is the owner’s responsibility to comply with the minimum requirements of the Code. Therefore, it’s the owner’s responsibility to maintain the appropriate documentation. 

2010 & 2015 NBC and NFC Excerpts

Owners Responsibility

2.2.1.1.(1) Unless otherwise specified, the owner or the owner's authorized agent shall be responsible for carrying out the provisions of this Code.

Integrated Systems Testing of Fire Protection and Life Safety Systems

• 2010 Fire Code 2.1.3.8. (1) Where life safety and fire protection systems are installed to comply with the provisions of this Code or the NBC, the commissioning of these integrated systems must be performed as a whole to ensure the proper operation and inter-relationship between the systems. (See Appendix A.)

• 2015 Fire Code 2.1.3.7.(1) Where life safety and fire protection systems are installed, they shall be tested in accordance with the NBC.

• 2015 Fire Code 6.8.1.1.(1) Interconnections between fire protection and life safety systems shall be tested and maintained in conformance with CAN/ULC-S1001, “Integrated Systems Testing of Fire Protection and Life Safety Systems.” (See Note A-6.8.1.1.(1).)

Fire Dampers, Smoke Dampers, Combination Smoke/Fire Dampers and Fire Stop Flaps

• 2010 Fire Code 2.2.2.4.(5) Fire dampers and fire stop flaps shall be inspected at intervals not greater than 12 months to ensure that they are in place and are not obviously damaged or obstructed.

• 2015 Fire Code 2.2.2.4.(5) Fire dampers, smoke dampers, combination smoke/fire dampers and fire stop flaps shall be a) inspected at intervals not greater than 12 months to ensure that they are in place and not obviously damaged or obstructed, and b) tested in accordance with NFPA 80, “Fire Doors and Other Opening Protectives.”

Exit Signs

• 2010 Fire Code 2.7.3.1.(3) Emergency lighting shall be maintained in operating condition, in conformance with Section 6.5.

• 2015 Fire Code 2.7.3.1.(3) Emergency lighting and exit signs shall be maintained in operating condition, in conformance with Section 6.5.

• 2015 Fire Code 6.5.1.8.

(1) Except as provided in Sentence (2), exit signs shall be inspected at intervals not greater than 12 months to ensure that the exit signs will be visible upon failure of the primary power supply.

2) Exit signs provided with a battery back-up shall be inspected at intervals

a) not greater than one month to ensure the exit signs will be visible upon failure of the primary power supply, and

b) not greater than 12 months to ensure the exit signs will be visible for a duration equal to the design criterion upon failure of the primary power supply.

Exterior Exit Door Obstructions

2015 Fire Code 7.1.8.(1) Where an exit door leading directly to the outside is subject to being obstructed by parked vehicles or storage because of its location, a visible sign or a physical barrier prohibiting such obstructions shall be installed on the exterior side of the door.

Retention of Fire Safety Plans

2010 Fire Code 2.8.2.5.

(1) The fire safety plan shall be kept in the building for reference by the fire department, supervisory staff and other personnel.

(2) The fire safety plan for a building within the scope of Subsection 3.2.6. of Division B of the NBC shall be kept at the central alarm and control facility.

2015 Fire Code 2.8.2.5.

Sentences 1 and 2 remain the same. Sentence 3 was added. 

(3) The fire safety plan for a building or facility within the scope of Sections 3.1., 4.1., and 5.1. shall be kept at the principal entrance to the building or facility.

Emergency Crossover Access to Floor Areas

2010 Fire Code 2.7.1.1.(1) Means of egress shall be provided in buildings in conformance with the NBC.

2010 Building Code 3.4.6.18.

(1) In a building more than 6 storeys in building height,

a) doors providing access to floor areas from exit stairs shall not have locking devices to prevent entry into any floor area from which the travel distance up or down to an unlocked door is more than 2 storeys,

b) doors referred to in Clause (a) that provide access into the floor area shall be identified by a sign on the stairway side to indicate that they are openable from that side, and

c) a master key to fit all door locking devices that are intended to prevent entry into a floor area from an exit stair shall be provided in a designated location accessible to firefighters, or the door shall be provided with a wired glass panel not less than 0.0645m2 in area and located not more than 300mm

from the door opening hardware.

2) If access to floor areas through unlocked doors is required by Clause (1)(a), it shall be possible for a person entering the floor area to have access through unlocked doors within the floor area to at least one other exit.

2015 Fire Code 2.7.1.1.(1) Means of egress shall be provided in buildings in conformance with the NBC.

2015 Building Code 3.4.6.18.

(1) Except as permitted in Sentence (2), doors providing access to floor areas from exit stairs shall not have locking devices to prevent entry into any floor area from which the travel distance up or down to an unlocked door is more than 2 storeys.

(2) Doors referred to in Sentence (1) are permitted to be equipped with electromagnetic locks, provided they comply with Sentences 3.4.6.16.(4) and (5).

(3) Doors referred to in Sentence (1) shall be identified by a sign on the stairway side to indicate that they are openable from that side.

(4) Locked doors intended to prevent entry into a floor area from an exit stair shall

a) be identified by a sign on the stairway side to indicate the location of the nearest unlocked door in each direction of travel, and

b) be openable with a master key that fits all locking devices and is kept in a designated location accessible to firefighters or be provided with a wired glass panel not less than 0.0645 m2 in area and located not more than 300 mm from the door opening hardware. 5) Where access to floor areas through unlocked doors is required by Sentence (1), it shall be possible for a person entering the floor area to have access through unlocked doors within the floor area to at least one other exit.

Maintenance of Records

2.2.1.2. Records(1) Where this Code requires that tests, inspections, maintenance or operational procedures be performed on a fire safety system, records shall be made and the original or a copy shall be retained at the premises for examination by the authority having jurisdiction. 2) The initial verification or test reports for each system shall be retained throughout the life of the systems. 3) Records of tests, inspections, maintenance or operational procedures undertaken after the initial tests referred to in Sentence (2) shall be retained so that at least the current and the immediately preceding records are available. 4) Notwithstanding the conditions stated in Sentence (3), no record shall be destroyed within two years of having been prepared.