Hello all,
I have had many discussions with our building department about same and/or similar topic. As we all know it is the building department’s discretion to interpret the code and expect an owner to meet the current/new building code or not. Most often (I was told) if components of a system, and in this case it is the fire alarm (which should be in compliance with Part 9 of the fire code), are being replaced part for part, panel for panel (even though the new panel may come with more options or zones), device for device and wiring for wiring; the building permit is taken-out/issued to perform such work due to the system being “existing” (or legal non-conforming) because the system was designed to an earlier version of the OBC or could even pre-date the first edition of OBC from 1975. This is because the “existing” fire alarm system is meant to perform basic function of detecting, activating via pull station and alarming the occupants of a fire condition and be just “audible” in the building and not necessarily where people sleep behind closed doors. So essentially the work consists of swapping old, deteriorating devices/wiring with new devices/wiring to maintain the system in operating condition so the alarms devices are still “audible” to provide some sort of an alarm such as ringing bells in public corridors as originally designed 20-30 years ago to also meet OFC Part 9 requirements (the law). In that case your local, neighbourhood qualified fire alarm contractor will perform such work and will be happy to apply for the building permit; work gets done, third party contractor verifies work to ULC-S537 and life goes on. This is because the work performed to the system is not to extend the fire alarm coverage to cover new portions of the building that were not part of the original design (so it doesn’t matter if the replacement is done in different time intervals, it is all just replacement work) no need to comply with new/current OBC. However if the system is being expended (new detectors/audible devices are being installed in part of the building that were not protected) such work is subject to compliance of the new OBC as designed by qualified designer/engineer {this is what I was told by our building department}.
Now, when it comes to the fire alarm audibility upgrade, one would think that since new audible devices and new wiring are installed in areas of the building not previously covered by those devices, such as every single residential suite, that the new OBC would be triggered for such work; well this is where this topic becomes complicated and it really boils down to how the building department (the AHJ) interprets/handles this application for system alteration/modification work, based on reasons for such work, examples:
#1. Building owner is served with an Order issued under FPPA 21.(1)(f) by an FD to upgrade the fire alarm audibility because the existing alarm levels are low and it is not audible enough to be heard in all areas of the building such as bedrooms.
#2. Building owner wants to voluntarily perform the fire alarm audibility upgrade and applies for a building permit on their own because it is the right thing to do.
With example #1 the work to perform an alteration to the existing fire alarm system (even though it requires installation of new devices and new wiring) does not have to conform to the new/current OBC because of FPPA 22(2) {please read it carefully}; so whatever the audible level the FD specifies in the Order, the designer/engineer prepares the plans for expending the system to install new in-suite audible devices, maybe also a new panel is necessary to handle additional circuits because the old panel can’t handle more circuits and while they are at it, new smoke detectors are installed in the stairways and corridors because the engineer says it is a good idea; building permit is issued no problem and new OBC doesn’t have to be met because of FPPA 22(2). Does this make sense?
With example #2 however there is no FD Order; owner shows up at the building department and wants an application for the building permit to upgrade fire alarm audibility (which never happens by the way) because a friend of his/hers who also owns a building in a different municipality was just slapped with an FD Order and this owner doesn’t want that to happen to him/her so he/she wants to be ahead of the game, do the right thing, bite the bullet and upgrade the fire alarm audibility; so what do you think the building department will do? keeping in mind what I mentioned above about “system is extended to cover new portions of the building that were not part of the original system design should trigger compliance with new/current OBC” So shouldn’t the building department enforce the new/current OBC and require new audible devices to provide 75 dBA (in an unfurnished suite) just like the current/new edition of the OBC requires, and the same should be expected from a professional engineer designing this upgrade, right? design the new system audibility upgrade as per new/current OBC right? again there is no FD Order in example #2 so FPPA 22(2) doesn’t apply. Well the results may vary.
The end result in both examples will be virtually the same, where proper fire alarm audibility levels are provided inside suites and bedrooms where occupant can adequately hear the fire alarm levels which typically reaches approximately 65 dBA in furnished suites and 75 dBA in unfurnished suites (if you don’t believe me perform tests); but the process is vastly different because in example #2 FPPA 22(2) is not applicable, well if it is not applicable in example #2 why does it have to apply in example #1? Just because the FD writes and Order on discretionary basis? But wait, in both examples the owners are required to get a building permit and in both examples the results are the same?
Maybe FPPA 22(2) should not apply to fire alarm systems or maybe the Fire Code should include provisions for fire alarm audibility to be upgraded to OBC 1997 audibility levels?
One thing is certain replacement is not the same as an upgrade.
Thoughts?