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  • in reply to: Edwards Pull Station Glass Rod Replacement #14044
    Al BastienAl Bastien
    Participant

    Hi Denise.

    Two trains of thought on this:

    1. The device is ULC tested and listed with the “glass” rod inserted. They are shipped from the factory this way and replacements are easily available. In order to continue to be a “complete unit” as listed by ULC, the rod must form part of that assembly.

    2. The design of the manual station has remained relatively unchanged since the 1940’s and the rod existed as a means to identify which manual station was activated should it also have been reset before the fire department arrived. With the addition of addressable modules to the back of the device which provides to the point information, the rod is now redundant.

    The problem is that not all manual stations are addressable and in the case of the Edwards 270 series, both conventional and addressable look alike on the surface.

    From a regulatory perspective, I can say that CAN/ULC-S536 states:

    6.7.2.1 Each manual station shall be tested by actuating the device as intended.
    6.7.2.2 Each two-stage manual station shall be tested by actuating the device as intended so that the first and second stage functions are confirmed.

    “as intended” is the key to answering your question I believe.

    Edwards publishes the testing instructions on the inside of every manual station:

    “TO TEST
    REMOVE GLASS ROD AND SAVE. WITH PULL LEVER IN NORMAL POSITION, CLOSE STATION COVER AND ACTIVATE PULL LEVER TO INITIATE AN ALARM ON THE SYSTEM (WHEN PROVIDED TEST KEY SWITCH). OPEN THE STATION AND RETURN SWITCH AND PULL LEVER TO NORMAL POSITIONS. REPLACE GLASS ROD AND CLOSE STATION COVER. ”

    If you don’t remove the glass rod, or more importantly, don’t replace it after testing the manual station, how did you test it “as intended”?

    My personal leaning is towards thought #1 not only because of the status at the time of listing, but also because of what the testing Standard requires. I also think that since the glass rod is an indicator of an activation should the device have been reset, which takes nothing more than a terminal driver and a “flip of the switch” so to speak it could also be considered “important”.

    Hope that provides some additional information for you to consider.

    Al

    in reply to: Standpipe and Sprinkler Systems #13179
    Al BastienAl Bastien
    Participant

    With any luck, the recent statement from the OFM that they are looking to harmonize with the National Fire Code will simplify matters greatly. The NFC makes it very clear with a simple sentence for all water-based fire protection systems:

    6.4.1.1. Inspection, Testing and Maintenance
    1) Water-based fire protection systems shall be inspected, tested and maintained in conformance with NFPA 25, “Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems.” (See Note A-6.4.1.1.(1).)

    I’ve always hated the fact that companies and owners can skirt around things because of the ambiguity of having two possible paths – the requirements of the OFC or being deemed in compliance if the system is tested to NFPA-25. My believe is that if you’re wanting to go the route of NFPA-25 (which we all know is more stringent), then you go all the way. Unfortunately this comes coupled with the whole reference to NFPA-1962 for fire hose testing. Hopefully the OBC will forgo the requirement for hose cabinets and look at the way other provinces do it with hookups in the stairwells to allow for better staging before breeching a door into the floor area. Or just eliminate the requirement for the cabinets to actually have unused (and almost always improperly inspected) hoses in them. Waste of time, space and money. My two cents worth.

    in reply to: Annual Smoke Alarm Testing During Lock-down #12855
    Al BastienAl Bastien
    Participant

    Alberta Municipal Affairs issued a Standata for their province that might give you some ideas:

    MA Fire Code Bulletin 19-FCB-003

    It talks about what an owner might be permitted to do. Focus on the first three pages probably.

    Although not exactly addressing your concern, I think it does give some potential options.

    Stay safe!

    in reply to: Dates for 2021 Annual Fire Alarm Inspections #12834
    Al BastienAl Bastien
    Participant

    Thank you for the replies. I felt the same way and also like Doug’s approach of considering the history of the owner and the building from a compliance standpoint. I think that makes sense where the owner has a history of being non-compliant or the building is known to have issues on a regular basis or is in the process of being brought into compliance.

    Service companies often do push dates due to availability and customers often push dates for a myriad of reasons. Does either excuse the building missing the annual inspection – no. Is it the reality of the real world – absolutely. Although the “intent” or reason behind the delay isn’t an excuse, I appreciate that the AHJs do take it into consideration.

    Thank you again for the input. I’m glad to know we’re on the same page.

    in reply to: Clearance around and in front of an electrical panel #11357
    Al BastienAl Bastien
    Participant

    Hi Julien.

    Hope this helps:

    The Ontario Electrical Code:

    Rule 2-308 Working space around electrical equipment
    (1) A minimum working space of 1 m with secure footing shall be provided and maintained about electrical
    equipment such as switchboards, panelboards, control panels, and motor control centres that are enclosed
    in metal, except that working space is not required behind such equipment where there are no renewable
    parts such as fuses or switches on the back and where all connections are accessible from locations other
    than the back.

    (2) The space referred to in Subrule (1) shall be in addition to the space required for the operation of drawout-
    type equipment in either the connected, test, or fully disconnected position and shall be sufficient for
    the opening of enclosure doors and hinged panels to at least 90°.

    (3) Working space with secure footing not less than that specified in Table 56 shall be provided and maintained
    around electrical equipment such as switchboards, control panels, and motor control centres having
    exposed live parts.

    (4) The minimum headroom of working spaces around switchboards or motor control centres where bare live
    parts are exposed at any time shall be 2.2 m.

    in reply to: can/ulc s-524 #11030
    Al BastienAl Bastien
    Participant

    Good morning everyone.

    As a member of the ULC committee I can’t condone sending around copyright material, but I’m happy to help by addressing specific needs and can include references from the standard to support any answers I provide.

    Aside from that, Joe is correct. You can sign up for a free account and view any ULC standard online. The link he posted is for CAN/ULC-S536-13 but you will need your own account to view it. This is not the edition that we use in Ontario however either. We must still use CAN/ULC-S536-04.

    Remember also that the editions of the ULC standards for all building permits that are taken out after Jan 1, 2020 fall under newer ULC editions (CAN/ULC-S524-14 and CAN/ULC-S537-13). These are still not the latest but are to be used moving forward. All work that were taken out under permit prior to January 1 will still follow the 06 & 04 editions so we’re going to have to be mindful of determining the permit date to ensure we’re following the correct edition during installation and verification.

    Also, under the amended Building Code an integrated systems test must be performed in accordance with CAN/ULC-S1001 so you will need to see that report as well.

    The 19 editions of the CAN/ULC-S524, S537 and S536 are not to be used in Ontario at this time. In Ontario, the fire code still references the 04 edition of CAN/ULC-S536, so we need to keep using it until the Fire Code changes its reference which I suspect we’ll see soon.

    Have a great day everyone! Enforcement is the key to compliance. Thanks for what you do.

    in reply to: Edwards Heat Detector Recall #10966
    Al BastienAl Bastien
    Participant

    I agree Jon, that the FPPA and the Fire Code may address the issue. That is exactly why I made the statements I did.

    There was a question posed as to what the technicians and service companies were doing about it. There is nothing in the Standard that the device fails, so we can do nothing.

    Enforcement as you know falls to the AHJ. The requirements of the Fire Code can’t be applied by a technician or a service provider.

    I’m all for the AHJ forcing the device out of a building if they have a concern. I do however question one part of how you would apply 1.1.1.2.(3). It states

    “(3) Any appliance, device or component of a device that does not operate or appear to operate as intended when checked, inspected or tested as required by this Code shall be repaired or replaced if the failure or malfunctioning of the appliance, device or component would adversely affect fire or life safety.”

    You can’t test if it operates because it would be a destructive test. You can’t look at it and state that it does not appear that it would operate as intended because not all of them would fail the destructive test. The ones that pass and the ones that fail the destructive test look identical. If as the AHJ you feel it would stick if appealed – you’ve got my vote – Write the order. The AHJs are the only ones who can force the building owner to remove these devices.

    As to the failure rate, my understanding is that because a few tests of the devices (as ordered by an AHJ who wanted to enforce the appendix in CAN/ULC-S536) indicated that some didn’t activate, it prompted the requirement to notify Health Canada and the recall was issued. My understanding is also that this failure was self reported by the manufacturer to Health Canada.

    in reply to: Edwards Heat Detector Recall #10961
    Al BastienAl Bastien
    Participant

    As a service company representative, I want to share a couple of things from this side of the issue.

    A heat detector is not a life safety device and they are not intended for the purpose of life safety. They are for the detection of a fire for property protection. Every one of them has clearly labelled on it “This is not a life safety device”. There are only a handful of situations where a heat detector would be deemed to be performing a life safety function. I would point out that Joseph’s quote supports this position. Additionally, it is not every detector that may not operate.

    One would be as permitted by the Ontario Building Code in Sentence 3.2.4.12.(7) – Fire detectors are permitted to be installed in lieu of the smoke detectors required by Sentence (5) in Group F occupancies where the smoke detectors may be subjected to false alarms due to the activities in the building.

    Another might be in an older building that still has heat detectors installed at the top of the stairwells or elevator shaft as was permitted by the building code of the day.

    It also needs to be noted that the service companies cannot write the existence of these devices up as deficiencies. When we are performing an annual inspection under CAN/ULC-S536-04, there is no test or inspection criteria that the device would fail. Bear in mind that the only way to prove the fixed temp portion of a heat detector works is to perform a destructive test. Some of the detectors under the Health Canada alert also have a rate-of-rise detection capability and this is tested annually. The fixed temperature is never tested, but the electrical circuit that the activation shorts is tested annually.

    I sit on the CAN/ULC-S500 working groups for S536, S537 and S524 and have submitted a proposal to ammend the standard to reflect recalled devices already. We’ll see where that goes.

    15 year lot testing of fixed temp heat detectors is addressed in CAN/ULC-S536, but only in the informative index:

    “G2.2 Non-restorable heat detectors may be replaced or tested on an annual lot sampling basis with the initial test following 15 years of service. The results of the initial tests and examination for deterioration will determine the frequency of subsequent tests. Sample sizes of one unit for lots of 20 or less, two units for lots of 21 to 99, and 2% for lots exceeding 99, are recommended as a minimum. Selected samples should be subjected to the Operating Temperature Test detailed in the Standard for Heat Actuated Fire Detectors for Fire Alarm Systems, CAN/ULC-S530. When failures are encountered, the lot sample size should be determined in accordance with normal quality plans.”

    Because the statement exists outside the body of the standard (which it has to under Canadian Standards Council requirements and the nature of the statement), it is not required for a service company to perform or a building owner to abide by.

    Rather than simply “ordering the detectors out”, I might suggest using the following from an bulletin ULC issued in 2006 (email me if you want a copy):

    “The AHJ may enforce some or all portions of the Preface or any informative appendix”

    Issue an order that the building owner have lot testing of the devices done (and this would include any and all fixed temps that exist and are not ever tested). For the number that exist in the building, it would likely be cheaper to replace them all then the cost of having ULC or another agent perform the testing.

    Suddenly putting nearly every building in Ontario which has these devices on a fire watch for a potential failure of devices that have existed for decades seems a bit extreme for a “maybe it won’t work”. Issue the order to have them tested. It gives them 30 days to decide what to do. That seems like a more balanced approach to me. My opinion only of course.

    Al BastienAl Bastien
    Participant

    I do know that there is a built in light sensor in the Kidde smoke alarms. The “intent” is that the unit learns over a period of time when to dim the power on light during the night. I do wonder if this feature somehow has something to do with it causing problems during the night time more often then not.

    I can tell you that I installed my units myself in my own construction and the power up cycle was followed…still had them go off in the night.

    Here’s what the manual for the unit says:

    Ambient Light Sensing
    During low light ambient conditions, the green LED will reduce in brightness and intensity. The unit samples the ambient light conditions of the alarm’s location and, if possible, determines a Night/Day cycle.

    A valid Night/Day cycle will inhibit Low Battery chirps at night. It will also inhibit End of Unit Life chirps at night if the unit is within the first 30 days of the End of Unit Life period. After 30 days, the chirps will not be inhibited.

    in reply to: fire alarm upgrades #10787
    Al BastienAl Bastien
    Participant

    Hi Nicholas.

    This is a fairly common line of questioning I get from AHJs and even fire alarm technicians.

    When an area of the building is renovated, or added on, the engineer would have needed to have that section meet the current requirements of the building code for the fire alarm system, but unless they or the AHJ determines some reason as to why the entire system needs to be brought to current code, only those sections of the building that fall under the building permit would be upgraded.

    The main requirements regarding visual signals is found in the Ontario Building Code 3.2.4.19.(4) which states:

    3.2.4.19.

    (4) Except as permitted by Sentence (6), visual signal devices shall be installed in addition to audible signal devices,
    (a) in a building or portion of a building intended for use primarily by persons with hearing impairment,
    (b) in a public corridor serving a Group A, B, C, D or E occupancy,
    (c) in a corridor used by the public and in a floor area or part of a floor area where the public may congregate in a Group A occupancy,
    (d) in not less than 10% of the suites of a hotel or motel,
    (e) in a washroom for public use described in Sentence 3.8.2.3.(2), (3), (4) or (6), and
    (f) in the living space in a suite of residential occupancy in a Group C major occupancy apartment building.

    The code then goes on to discuss a few more requirements/exceptions in Sentences (5) and (6)
    (5) Visual signal devices are permitted to be installed in lieu of audible signal devices in the compartments referred to in Article 3.3.3.6.

    (6) Visual signal devices required by Clauses (4)(b) and (c) are not required in,
    (a) a classroom, and
    (b) a Group B, Division 3 occupancy that contains sleeping accommodation for not more than 10 persons and not more than six occupants require assistance in evacuation in case of an emergency.

    A couple of other locations are found in: 3.2.4.20. Audibility of Alarm Systems

    (7) Fire alarm audible signal devices shall be supplemented by visual signal devices in any floor area in which,
    (a) the ambient noise level is more than 87 dBA, or
    (b) the occupants of the floor area,
    (i) use ear protective devices,
    (ii) are located within an audiometric booth, or
    (iii) are located within sound insulated enclosures.

    (8) Sentence (7) shall also apply in an assembly occupancy in which music and other sounds associated with performances could exceed 100 dBA.

    Essentially, 3.2.4.19.(4)(b) would have required visual signals in the corridors that were renovated, and (e) for universal washrooms, but the remainder of the building would have been permitted to remain as is unless the engineer designed the system to be entirely renovated and upgraded in the building.

    Of course, (and as always) the AHJ gets the final determination of what is deemed acceptable or not, so the plans reviewer and the CBO for the municipality would have made the call on what, if anything they wanted to see upgraded in the school. There may have been a reason they didn’t make them install the visual signals in the renovated areas.

    Al BastienAl Bastien
    Participant

    Hi Del,

    I can definitely tell you two stories…

    A buddy of mine is in construction and used the BRK 710BSL in his home three years ago. He told me the story of in the middle of the night having them go off and no indication of what caused it and didn’t know how to identify which one had gone into alarm. This model is already discontinued.

    I just built a home two years ago and have a total of eight of the Kidde P4010ACLEDSCO-2 and P4010ACLEDSCA interconnected alarms installed. Just two and a half weeks ago, I had mine go off in the middle of the night. This model is normally green when it is normal but if you look at each one, it will blink from green to red once every 16 seconds to indicate that it has been activated. You push the test button (which sets them all into test) to clear it. It was in my 10 year old daughters room and no indication as to why.

    So yes…there is something amiss with these units I suspect.

    All of that being said, I railed against these units when the Ontario Building Code adopted them and after having experienced exactly what I said was going to happen first hand, I can tell you that there ought to be an allowance to remove the strobe component. 177cd in the middle of the night flashing out of sync for up to 45 seconds, while trying to find your way out of your bedroom and up the stairs to your children’s rooms where they are panicking because they are temporarily blinded by the light flashing in their dark room is absolutely ridiculous. Much more effective methods of waking those that are hearing impaired.

    We did the math at one point – we took the most recent available number of fatal residential fires in Ontario (the only province that requires them BTW) x Percentage of fires that occurred between 10pm and 6am (which is why they wanted them for when people were sleeping) x Percentage that occurred where a working fire alarm was found in the home upon responding x percentage of the population that are said to be hearing impaired in Canada = 0.7 lives.

    Now that is assuming that the person that we’re looking at in this formula doesn’t become a fatality for any other reason other than they didn’t hear the smoke alarm activate (smoke inhalation, trip and fall, instantaneous death due to the origin of the fire, etc.). Is that truly worth the risk to the majority of the population who are forced to put these in their homes by the building code and then maintain them for the rest of their lives under the fire code? It is going to be far more likely to cause fatalities (children hiding from the light, disorientation, etc) for residents plus the fact the suppression crew must face a potential disco in the smoke on arrival.

    I’m not saying that every life doesn’t count – but that’s precisely my point – every life should be taken into account before mandating items like these.

    I’m curious if any others have the same concerns.

    in reply to: Residential Sprinklers? #10461
    Al BastienAl Bastien
    Participant

    I’m not aware of any jurisdiction that requires them and I don’t think there will be any change until the insurance industry changes their mindset first. I just built a new home a year and a half ago. I wanted to install sprinklers and was told my premiums would go up if I did. They are more concerned about water damage than smoke damage and because they insure the property have no consideration of the occupants. It’s unfortunate and hopefully this will change.

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