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PUBLIC CONSULTATION ON
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| Example:
OS1 Fire Safety
An objective of this Code is to limit the probability that, as a result of a) activities related to the construction, use or demolition of the building or facility, b) the condition of specific elements of the building or facility, c) the design and construction of specific elements of the facility related to certain hazards, or d) inadequate built-in protection measures for the current or intended use of the building, a person in or adjacent to the building or facility will be exposed to an unacceptable risk of injury due to fire. The risks of injury due to fire addressed in this Code are those caused by –
OS1.1 fire or explosion occurring OS1.2 fire or explosion impacting areas beyond its point of origin OS1.3 collapse of physical elements due to a fire or explosion OS1.4 fire safety systems failing to function as expected OS1.5 persons being delayed in or impeded from moving to a safe place during a fire emergency
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Functional Statements Functional statements translate objectives into operational terms. They describe the general conditions to be achieved. There may be several functional statements related to any one objective. Alternatively, any one functional statement may be related to several objectives.
A functional statement:
· is expressed in qualitative terms; and
· describes the outcome required but not how to achieve that outcome.
Functional statements are likely to be useful in the evaluation process when an alternative solution or equivalent material, system or building design is proposed.
Functional statements in a specific code are also a subset of a master list of functional statements for the Ontario Fire Code and the Ontario Building Code. All functional statements are not used in each code. Therefore, for a specific code, there may be gaps in the numbering sequence.
| Example:
. . . F03 To retard the effects of fire on areas beyond its point of origin. . . .
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The objectives describe an undesirable situation or result that the code seeks to avoid (e.g., persons being delayed in moving to a safe place during an emergency), while their functional statements describe conditions in the building that help to avoid the potential for those situations or consequences to occur. (e.g., the provision of means of egress). |
| Example:
OS1 Fire Safety
An objective of this Code is to limit the probability that, as a result of a) activities related to the construction, use or demolition of the building or facility, b) the condition of specific elements of the building or facility, c) the design and construction of specific elements of the facility related to certain hazards, or d) inadequate built-in protection measures for the current or intended use of the building, a person in or adjacent to the building or facility will be exposed to an unacceptable risk of injury due to fire. The risks of injury due to fire addressed in this Code are those caused by –
OS1.1 fire or explosion occurring OS1.2 fire or explosion impacting areas beyond its point of origin OS1.3 collapse of physical elements due to a fire or explosion OS1.4 fire safety systems failing to function as expected OS1.5 persons being delayed in or impeded from moving to a safe place during a fire emergency
F03 To retard the effects of fire on areas beyond its point of origin.
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Acceptable Solutions The term “acceptable solution” describes a minimum Ontario Fire Code provision or set of code provisions. Under the new code structure, the current prescriptive and performance requirements contained in the Ontario Fire Code will become “acceptable solutions” in the next edition of the code. The acceptable solutions are a benchmark against which other means of meeting the code’s intent will be assessed or compared.
For the most part, the Ontario Fire Code provisions, contained in Division B, will not be rewritten to conform to the objective-based format. They will look the same in the objective-based code, but will be renamed from “minimal requirements” to “acceptable solutions” to reflect their position as one of the possible solutions afforded under the objective-based code format.
It is expected that new acceptable solutions beyond those in the current code will be added over time through the normal process of technical assessment by code committees and public review. As was the case for the current acceptable solutions, intent and application statements will be developed for the new acceptable solutions, and objectives and functional statements will be attributed to them, if applicable. As stated previously, all proposed new acceptable solutions need to address one of the objectives of the code.
Later in this document we will discuss alternatives to acceptable solutions.
The acceptable solutions are found in Division B.
Example:Clearance for stickered lumber piles3.2.2.5.(1) Stickered lumber piles in lumber storage yards shall be located at least 15 m from property lines and buildings.[F03]
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Intent statements may also provide an explanation of the link between an acceptable solution in Division B and the objective or objectives to which it is attributed and the functional statement to which they are linked.
Intent statements will not be part of the regulation adopting the Ontario Fire Code but are advisory in nature. They will be available as a separate document.
View the Ontario Fire Code Prototype Intent Statements Database
| Example:
Code Unit:
OFC-3.2.2.5.(1)-02
To reduce the probability that a fire involving the lumber piles will spread to a building on the same property, causing harm to persons.
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Like intent statements, application statements will not be part of the regulation adopting the Ontario Fire Code but are advisory in nature.
View the Ontario Fire Code Prototype Intent Statements Database
| Example:
Code Unit:
OFC-3.2.2.5.(1)
Application: Minimum clearance of stickered lumber piles in lumber storage yards from property lines and buildings.
This applies to the outdoor storage of lumber and other forest products.
Exceptions: except as stated in:
1. Article 3.2.2.1., which applies to: - existing situations that are approved and do not endanger life safety, or - approved alternative measures to the requirements set out in Subsection 3.2.2. that are taken to provide life safety 2. Article 1.1.6.1., which applies to farm buildings with a certain occupant load, and premises on a farm used for farming purposes; and 3. Article 1.1.6.2., which applies to buildings containing a hotel.
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We invite you to test drive the proposed objective-based version of the existing Ontario Fire Code (the “proposed code”) through the links at the end of the explanatory text below.
The proposed code is partial, in that while Divisions A and C is essentially complete, Division B contains selected partial text of the Ontario Fire Code and all its applications.
You will be able to view the objectives and functional statements attributed to each requirement by clicking on a link in the tables at the end of each Part.
See if the attributed functional statements and sub-objectives are consistent with your understanding of what the provisions are there to achieve. If you’ve been considering proposing an alternative solution to something in the Ontario Fire Code or if you’ve been called on to evaluate someone else’s alternative solution, review the functional statements and sub-objectives attributed to the relevant provisions in Division B and see if they would help you in determining the acceptability of that alternative solution.
Please note that the links provided as part of the consultation makes it easy for code users to “test-drive” the objective based format. Ultimately, the legally printed version of the Ontario Fire Code adopted in Ontario may look somewhat different from this electronic version.
Recall the issues we asked you to consider in your review –
· how the added information assists in better understanding the Ontario Fire Code’s current requirements
· whether the proposed structure provides a logical approach for considering and evaluating alternative solutions
· whether the proposed functional statements provide an appropriate and effective link between the objectives and acceptable solutions
· whether the proposed structure will facilitate more uniform application of the code, and at the same time provide a useful framework for accommodating technical innovation
· the degree to which the objectives and functional statements are correctly attributed to the sections of the codes with which you are most familiar
· ways to increase harmonization with the National Fire Code acknowledging that variances may be necessary to address unique Ontario issues.
View Proposed Objective-Based Version of the Existing Ontario Fire Code
Questions about Now, that you have taken an initial look at the proposed
the Proposed Format code, please consider these questions about the objective‑based format below. You will be asked to provide your answers to these questions in the questionnaire (Objective-Based Codes Feedback) appearing at the end of this document.
Navigation and Structure
1. Did you find the information (objectives, functional statements etc.) easily?
2. Is the information organized in a logical way?
3. How would you improve the layout and organization of the objective-based codes?
Content
4. Do the objectives attributed to the technical provisions of Division B seem logical?
5. Do the functional statements attributed to the technical provisions of Division B seem logical?
6. Do the objectives for a particular provision help you understand and interpret the provision?
7. Do the functional statements for a particular provision help you understand and interpret the provision?
Anticipated Use
8. Will the new information facilitate design flexibility?
9. Will the objective-based code help to reduce disputes related to the interpretation and application of the
code?
10. How will the new information change the way you use and rely on the code?
We would value your opinion on how well we did in linking functional statements and third level objectives to the Division B provisions.
If you review the tables listed at the end of each part of Division B or those sentences with which you are most familiar, please let us know if you find some attributions that may be incorrect or not appropriately linked to a provision.
Many provisions in Division
B serve as pointers to other relevant provisions or serve other clarification
or explanatory purposes. In most cases, no objectives and functional
statements have been attributed to such provisions.
For provisions that serve as pointers to other referenced provisions and that
have not been attributed any objectives and functional statements, the
objectives and functional statements that should be used are those attributed
to the provisions they reference.
An asterisk (*) marked beside a group of functional statements and objectives
indicates that the group applies only to a portion of the provision. The
targeted portions of text will be stated explicitly in the tables of
attributions in the published codes.
Questions about
Attributions Please consider the questions below. You can provide answers in the questionnaire (Objective-Based Codes Feedback) appearing at the end of this document.
Division B Links to Division A
This section discusses different methods of assessing compliance with the objective-based code. The objective-based code provides for greater flexibility and better accommodates innovation.
Typical Code Users Code users who rely on the acceptable solutions outlined in Division B, as contained in the current Ontario Fire Code should experience little change from the way the code is used today. Satisfying the provisions of the Division B acceptable solutions will constitute full and sufficient compliance with the code, since these are benchmarks. This will automatically satisfy the objectives and functional statements of Division A.
However, in situations where clarity is needed to apply an Ontario Fire Code provision to a specific solution, code users will be able to refer to objectives and functional statements of Division A related to the provision under consideration or in dispute.
Question About Please consider the questions below.
Typical Code Use
Typical Code Use
13. When you “test drove” the objective-based code, could you use it with the same ease as you are accustomed to? If not, what did you find difficult?
Alternative Solutions Under an objective-based code, a material, system or design that differs from the acceptable solutions in Division B will be treated as an alternative solution or equivalent. The new format of the code should prove most useful when proposing or evaluating alternative solutions; when someone wishes to do something different from the acceptable solutions, and needs to know what an alternative solution must accomplish to satisfy the Ontario Fire Code.
The process used to evaluate alternative solutions would be very similar to those used under the equivalency provisions of the current code. The objective-based code’s objectives and functional statements are intended to make the evaluation process much easier, for both the proponent and the regulatory official.
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Evaluation of Alternative Solutions - how to use the additional information provided by the objective-based code format Example: A lumber storage yard owner has a problem storing increasing inventory and is searching for an alternative solution that would allow stickered lumber piles to be placed closer to a building on the property than permitted by OFC Sentence 3.2.2.5.(1). The owner was already considering sprinklering the building to obtain a reduction of insurance premiums and now hopes that the installation of sprinklers might also convince the local fire authorities to allow the stickered lumber piles to be stored closer to the building. The piles will meet the requirements for distance from property lines. Procedure:
Step 1: Read the OFC’s basic acceptable solution
Ontario Fire Code Division B Acceptable Solutions Part 3 Property Protection for Industrial and Commercial Occupancies
Clearance for stickered lumber piles 3.2.2.5.(1) Stickered lumber piles in lumber storage yards shall be located at least 15 m from property lines and buildings. [F03] . . .
Step 2: Go to the table of attributions at the end of the Part
A table located at the end of each Part in Division B contains a list of the objectives and functional statements attributed to each acceptable solution in that Part. For the purpose of this example, the owner would consult Table 3.8.1.A. at the end of Part 3 of Division B.
Ontario Fire Code Division B Acceptable Solutions Part 3 Property Protection for Industrial and Commercial Occupancies Objectives and Functional Statements
3.8.1.1. For the purposes of compliance with this Code as required in Article 1.2.1.3. of Division A, the objectives and functional statements attributed to the acceptable solutions in this Part shall be the objectives and functional statements listed in Table 3.8.1.A. (See Appendix Notes A-1.2.1.2. and 1.2.1.3.)
Table 3.8.1.A. Forming Part of Article 3.8.1.1.
Step 3: Go to Division A and look up the referenced functional statements
In this example, the functional statements attributed to Sentence 3.2.2.5.(1) is F03 (see Step 2). Now look up the definition of F03 in Article 3.2.2.1. of Division A.
Ontario Fire Code Division A Compliance, Objectives and Functional Statements Part 3 Functional Statements
3.2.1.1. Functional Statements 1) The objectives of this Code are achieved by measures, such as those described in the acceptable solutions in Division B, that are intended to allow the building or facility or its elements to perform the following functions (see Appendix A):
At this point in the example, it is unclear whether the Code is concerned with · the effects of a fire originating in the building on the materials stored outside, or · the effects of a fire originating in stored materials on the building and its occupants.
Step 4: Look up the referenced objectives in Division A. The intent statements in the Intents Database may also be reviewed.
In this example, the two sub-objectives and two related third-level objectives attributed to Sentence 3.2.2.5.(1) are (see Step 2):
Sub-objectives Third-level objectives OS1 Fire Safety OS1.2
OP3 Protection of Adjacent OP3.1 Buildings or Facilities from Fire
Now go Article 2.2.1.1. of Division A and look up the meaning of these sub-objectives and third-level objectives
Ontario Fire Code Division A Compliance, Objectives and Functional Statements Part 2 Objectives
Objective: OS1 Fire Safety An objective of this Code is to limit the probability that, as a result of a) activities related to the construction, use or demolition of the building or facility, b) the condition of specific elements of the building or facility, c) the design and construction of specific elements of the facility related to certain hazards, or d) inadequate built-in protection measures for the current or intended use of the building, a person in or adjacent to the building or facility will be exposed to an unacceptable risk of injury due to fire. The risks of injury due to fire addressed in this Code are those caused by— . . . OS1.2 fire or explosion impacting areas beyond its point of origin . . .
To reduce the
probability that a fire involving the lumber piles will spread to a
building on the same property, causing harm to persons [F03-OS1.2].
Objective: OP3 Protection of Adjacent Buildings or Facilities from Fire An objective of this Code is to limit the probability that, as a result of a) activities related to the construction, use or demolition of the building or facility, b) the condition of specific elements of the building or facility, c) the design and construction of specific elements of the facility related to certain hazards, or d) inadequate built-in protection measures for the current or intended use of the building, adjacent buildings or facilities will be exposed to an unacceptable risk of damage due to fire. The risks of damage to adjacent buildings and facilities due to fire addressed in this Code are those caused by—
OP3.1 fire or explosion impacting areas beyond the building or facility of origin . . .
To reduce the
probability that a fire involving the lumber piles will spread to an
adjacent building or facility (on the same or other property), causing
damage to property [F03-OP3.1].
Step 5: Put it all together
It is now clear that the Code is concerned with a fire originating in the stored materials and its effect on the building and its occupants. Installing sprinklers in the building would have little impact in addressing this concern. However, a "dry" sprinkler system placed outside the building so as to protect the exterior wall facing the stored materials could contribute to satisfying the objectives and functional statements.
The Code is also concerned about the potential of the lumber piles impacting on adjacent properties. However, in this case, the lumber piles will meet the clearance to property lines prescribed in Division B. Therefore, the alternative solution does not need to directly address this issue.
Step 6: Decide
In accordance with the procedures described in Division C of the Code, the alternative solution proposal must be reviewed and approved by the Chief Fire Official. Documentation under the seal of a professional engineer or architect must identify the provision(s) of Division B that the alternative solution applies to and describe how the solution achieves at least the minimum level of performance intended by the provision(s) in Division B.
In this case, the documentation should include a detailed design of the “dry” sprinkler system taking into account a number of factors including the configuration of the exposing building face and the fire load of the product stored outside the building. Where not specifically addressed in Division B, the proposal must also include criteria for the maintenance of special components and systems.
Note too that, even if this alternative solution is approved and the separation requirement of 3.2.2.5.(1) is waived, other provisions, such as the fire department access provisions of Article 3.2.2.12.or the obstruction of exit requirement of Article 2.7.1.7. may still restrict the lumber storage. These other applicable provisions must also be satisfied, either by direct compliance or additional alternative solutions.
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– Performance The objectives and functional statements in Division A are qualitative and therefore do not provide quantitative performance criteria that are needed in assessing compliance. It is for that reason that objective-based codes follow this principle: Division B’s acceptable solutions provide the quantitative performance benchmark against which to compare a proposed alternative solution. Assessing compliance cannot be based on the objectives and functional statements alone.
Many acceptable solutions in Division B are not framed in precise measurable terms, with specific methods for evaluating performance. Nonetheless, proponents will be required to show that an alternative solution will perform as well as the applicable acceptable solution(s). It will not be good enough to simply demonstrate the design performs “well enough”. It must perform “as well as” the acceptable solution(s) it is replacing in the areas of performance defined by the linked functional statements and third level objectives.
– Level of Performance When Division B offers a choice between several possible designs, it is likely that these designs may not all provide exactly the same level of performance. Among the number of possible designs satisfying the acceptable solutions contained in Division B, the benchmark against which to measure a proposed alternative solution is the one providing the minimum acceptable level of performance. It will be up to the proponent to determine and seek approval of the minimum acceptable benchmark from the regulatory official.
Sometimes a single design will be used as an alternative solution to several different sets of acceptable solutions. In this case, the alternative solution will be expected to provide a level of performance at least equivalent to the overall level of performance of the individual solutions it is intended to replace.
In many cases, establishing an overall level of performance may not be as straightforward as it sounds due to individual acceptable solutions having differing functionalities. In these cases, a more practical approach would be to establish that the alternative solution meets or exceeds the level of performance of the individual acceptable solutions it is intended to replace.
– New Tools When thinking about the effectiveness of the new code format, code users should remember:
· More information regarding the intent and application of the acceptable solution has been made available so that the regulatory official and the proponent can more easily identify the objectives and functional statements that a proposed alternative solution must satisfy.
· Generic, (i.e., non-proprietary) alternative solutions intended for use across Canada can be reviewed by the CCBFC’s standing committees, subject to provincial/territorial and public review, and potentially added to the relevant national core code as acceptable solutions.
· A national or provincial repository of alternative solutions previously accepted by local authorities or by the individual provinces and territories is contemplated. Under this proposal, there would be more information available online and less “reinventing the wheel,” with the goal of speeding up evaluations. It would be easier for proponents and authorities having jurisdiction to investigate what has previously been accepted by other jurisdictions and under what limitations. There are many issues to be addressed before such a repository could become a reality – liability of listing authority, obligation or pressure imposed on other authorities, disclosure of proprietary information, etc. Your views on the utility of such a repository are welcome.
Questions about
Alternative
Solutions and New Tools Please consider the questions below. You can provide answers in the questionnaire (Objective-Based Code Feedback) appearing at the end of this document.
Alternative Solutions
14. Will it be easier to propose or evaluate an alternative solution using the objective-based code?
Why or Why not?
15. If you are a regulatory official, do you think there will be more proposals for alternative solutions once objective-based codes are adopted?
Why or why not?
16. If you are a designer or manufacturer, do you think the objective-based code will encourage you to propose alternative solutions more often than you do now?
Why or why not?
New Tools
17. What is needed to support an easy and effective transition to objective-based codes? (e.g. training, user guides, tools, etc.)
Conclusion
18. Does the objective based code meet your expectations?
Why or Why not?
19. Do you have any other comments or suggestions?
Code users have expressed their desire to have training programs available to prepare them for the use of objective-based codes. In keeping with the co-ordinated development of these new codes, Ontario, along with other provinces and territories and the CCBFC are jointly developing training and education for objective-based codes. The training will address the needs of building, fire and plumbing regulatory officials and will be made available to other practitioners including designers, constructors, manufacturers and suppliers. It is anticipated that although nationally developed, the training and education will address the specific content and process needs of Ontario’s building, fire and plumbing practitioners.
A critical initial step in the development of objective-based codes training and education material is the identification of users’ training needs. A training needs assessment questionnaire is being developed to parallel this consultation and is expected to be available by the end of February 2003. In the meantime, here is a list of some of the proposed topics to be addressed in the questionnaire.
1. The nature and scope of training you may need to:
a. Apply the new code terminology, structure, format and organization
b. Navigate through the structure and organization of the code content
c. Apply the new code in the context of plans evaluation and inspection
d. Apply Objectives, Functional Statements and Intent Statements
e. Evaluate Alternative Solutions, including the practical application of the provisions permitting alternative solutions;
2. Your training delivery preferences including classroom, web or independent learning-based;
3. Whether you will require recognition for the training, such as continuing education credits for professional certification, and if so, the form of recognition;
4. Your training supplier preference including, professional association and community college
5. Potential tools and support materials that might be of benefit to you in the application of the codes including flow charts or protocols for processing and evaluating alternative solutions
Please complete the on-line training needs assessment. Alternatively you may download the assessment in file format and send us your comments by mail, fax or e-mail as described below.
Online Version - Click here to complete the questionnaire online.
Microsoft Word - Click to download questionnaire in Word format.
Corel Word Perfect - Click to download questionnaire in Word Perfect format.
Your response is needed by May 12, 2003.
We encourage you to provide your feedback to us by using the on-line questionnaires (Objective-Based Codes Feedback). However, if you prefer, you may send us your comments by mail, fax or e-mail. For your convenience, Microsoft Word and Corel Word Perfect file format questionnaires are available for downloading.
All comments related to provincial codes, specific provincial/ territorial requirements, or national core codes, no matter where they are sent, will be shared by the Ministry of Public Safety and Security with the Canadian Commission on Building and Fire Codes (CCBFC) and the provincial and territorial authorities.
Mailing Address
2003 Ontario Codes
Consultation
599-B Yonge Street
Suite 359
Toronto, ON
M4Y 1Z4
Facsimile/Fax
(416) 327-0412
For any other information not related to this consultation or for general Ontario Fire Code inquiries, please contact us by telephone or visit our main site.
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