[Pete Aalbers]

Below are comments relevant to this proposal and fire safety that could influence future OBC wording.  If you agree, feel free to submit similar wording, or create new comments stating your point of view.  Comments from multiple sources will have a greater influence than a single voice.

Comments RE:  Consultation Supporting Development of Four-Storey Townhouses

1.  I have concerns with the following portion of application statement 3.19.1.1(1)(e) each dwelling unit….(ii) contains sleeping accommodations for not more than 10 persons,….
The Ontario Building Code does not provide a method for enforcing the maximum of 10 people with sleeping accommodations once the building permit is closed.  Rooms of houses are often repurposed or renovated once the building is occupied.  If this occurs, and additional bedrooms are created, a building inspector has limited authority to enter and inspect.   The Ontario Fire Code permits a fire prevention officer the ability to enter and inspect but does not give them the authority limit the number of occupants in a single family dwelling unit (house).
I believe a 4 storey townhouse plus basement has the potential to have significantly more than 10 occupants and exceed the limited fire safety features permitted in a house.

2.  I have concerns with sentence 3.19.2.1(2) Floor assemblies, including floors over basements, that are entirely contained within each dwelling unit need not be constructed as fire separations or have a fire-resistance rating.
A townhouse compliant with OBC 3.19 has the potential to contain 5 storeys (1 basement level and 4 above ground levels) without fire separations between the basement and top floor.  This house could be constructed with a single open stairwell and various combinations of open-concept great rooms and up to 5 bedrooms on different levels.  A single stairwell would convey the smoke from a fire in the basement through the entire house and compromise the only exit (stair) from the upper floors.  This has the potential to trap occupants on upper floors without a viable means of escape and no area of refuge or safety.  On scene firefighters are required to rescue occupants.
Adding rated fire separation requirements to this proposal would slow smoke and fire spread through the house and provide an area of relative safety for occupants while firefighters attempt rescue.

3.  There is no mechanism in the proposal requiring a monitored fire alarm, etc. to ensure fire department notification occurs.  Delayed fire department notification will lead to occupants on upper floors needing to find refuge in areas of the house that are not tenable to human life.  Delayed firefighter response becomes more critical when considering that Sentence 3.19.2.1(2) Floor assemblies, including floors over basements, that are entirely contained within each dwelling unit need not be constructed as fire separations or have a fire-resistance rating.  Smoke and fire spread through a house constructed to this standard could compromise the single exit stair and prevent the safe evacuation of occupants.  On scene firefighters would be required to rescue trapped occupants.
Adding fire department notification requirements to this proposal would ensure prompt firefighter response and reduce the amount of time occupants are trapped and awaiting firefighter rescue.

4.  I have concerns with subsection 3.19.4.1. Automatic Sprinkler System (1) The building shall be equipped with an automatic sprinkler system designed, constructed, installed, and tested in conformance with NFPA 13D, “Standard for the Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes”….
While I agree an automatic sprinkler system significantly increases occupant survivability during a fire event, I suggest that NFPA 13R “Standard for the Installation of Sprinkler Systems in Low-Rise Residential occupancies” is the more appropriate standard.  NFPA 13R provides sprinkler system design requirements that are more specific and robust than NFPA 13D.  NFPA 13R provides an increased level of survivability to occupants of the unit experiencing the fire event, as well as reducing the likelihood of the fire extending to dwelling units beyond the unit of fire origin.
Fewer individual units in a townhouse complex would be affected by a single fire event if NFPA 13R is required.

Thanks,
Pete

[Pete Aalbers]

Oops.  You likely don’t have my email.  peter.aalbers@sarnia.ca

 

[Pete Aalbers]

Hi Vince.  Please email a copy of that posting to me also.

Thanks,  Pete

 

 

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