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Fire-code flexibility: Objective-based format better for firefighters

The new Ontario Fire Code, which comes into force on Nov. 21, represents more than 200 technical changes made through public consultation since 2003, and a radical change in fire- and life-safety policy from a strictly prescriptive format to one that is objective based. According to its press release, the Ontario Office of the Fire Marshal (OFM) believes that the new format will promote "greater flexibility and more uniform enforcement."

The new code still contains traditional prescriptive requirements, called "acceptable solutions," which the OFM states will "serve as benchmarks for compliance." The significant difference in the objective-based format, however, is in the addition of "alternative solutions," achieved by "linking each (technical) code provision to one or more explicitly stated objectives and functional statements." Acceptable solutions will be linked with alternative solutions through the OFM's Fire Code Supplement FCS-1 document "Objectives and Functional Statements Attributed to the Acceptable Solutions."

The new code is divided into three "divisions," which are, in turn, divided into various "parts." Division A contains general compliance provisions, together with both the objectives and functional statements tables. Division B contains the traditional prescriptive requirements, now known as "acceptable solutions." Division B looks most like the previous (1997) version of the code. Its nine parts contain acceptable solutions for, among others, flammable and combustible liquids (Part 4), hazardous materials, processes and operations (Part 5), and inspection, testing and maintenance of fire emergency systems in high buildings (Part 7). An example of an acceptable solution is found at Clause 4.11.3.4, which provides that, "During loading and unloading of a tank vehicle, trained personnel shall be in a position to shut off the flow of liquid in an emergency."

Division C outlines the administrative provisions of the new code.

Linking the acceptable and alternative solutions

The operating provision that connects the acceptable and alternative solutions is at Clause 1.2.2.1 (1)(b) of Division A. It states that compliance with Division B shall be achieved:

(a) by complying with the acceptable solutions [prescriptive requirements] in Division B; or

(b) by using alternative solutions that

(i) will achieve the level of performance required by the applicable acceptable solutions in respect of the objectives and functional statements attributed to the applicable acceptable solutions in OFM Fire Code Supplement FCS-1, "Objectives and Functional Statements Attributed to Acceptable Solutions."

An alternative solution must not contravene any other provision in Division B (see 1.2.2.1 (1)(b)(ii)), and it must be approved and implemented in conformance with Subsection 1.3.2. of Division C.

Consider the example discussed above on supervision of tank vehicles found at Clause 4.11.3.4 under Division B, Part 4, "During loading and unloading of a tank vehicle, trained personnel shall be in a position to shut off the flow of liquid in an emergency." This is the acceptable solution but it may not be our only choice for compliance. Pursuant to Clause 1.2.2.1(1)(b) of Division A, we can comply by either choosing the acceptable solution of having a trained person at a shut-off valve, or we can comply through an alternative solution. Let's suppose that we want to consider our alternatives for compliance.

The first step is to refer to the OFM Fire Code Supplement FCS-1, "Objectives and Functional Statements Attributed to Acceptable Solutions." FCS-1 contains nine tables of two columns each. The left column, acceptable solutions, lists particular provisions, i.e. clauses, in the new fire code. Each acceptable solution is contained within a separate row. If we follow the row for any individual acceptable solution across to the right column, there may be one or more corresponding functional statements and objectives from Division A of the new code.

It's important to note that acceptable solutions do not always have corresponding alternative solutions. If there is no alternative solution the left column will still list an acceptable solution but the right column will contain the word "note" with a superscripted number referring to a footnote. The footnotes state that, "Objectives and functional statements have not been attributed and the acceptable solution in Division B of the Fire Code applies."

This is provided for at Clause 1.2.2.1 (3) of the new code which states that, "The use of alternative solutions . . . is not applicable in respect of any acceptable solutions to which objectives and functional statements have not been attributed in OFM Fire Code Supplement FCS-1, "Objectives and Functional Statements Attributed to Acceptable Solutions"." The only way to comply with these provisions is to use the acceptable solution.

To determine whether an alternative solution is available in our example, we turn to Table 4, which correlates to Part 4 of Division B of the code, and look down the left column for the applicable acceptable solution in our case (Clause 4.11.3.4 – see above).

When we find it, we move across the same row to the right column to determine whether any objectives and functional statements have been attributed. In this case, we find that the objectives and functional statements [F44-OS1.1, OS1.2, OP1.1, OP1.2] have indeed been attributed to our acceptable solution. Therefore, we can consider the alternative solution of compliance by meeting those objectives and functional statements.

The next step is to reference the applicable objectives (in our example OS1.1, OS1.2, OP1.1, OP1.2) from Table 2.2.1.1 in Division A, Part 2 of the new fire code, and applicable functional statements (in our example F44) from Table 3.2.1.1 in Division A, Part 3. Functional statement F44 states: "To limit the spread of hazardous substances beyond their point of release." Below is a list of the applicable objectives:

Objective number OS

An objective of this Code is to limit the probability that, as a result of specific circumstances related to the building or facility, a person in or adjacent to the building or facility will be exposed to an unacceptable risk of injury.

Objective number OS 1

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:

Objective number OS1.1

Fire or explosion occurring.

Objective number OS1.2

Fire or explosion impacting areas beyond its point of origin.

Objective number OP

An objective of this Code is to limit the probability that, as a result of specific circumstances related to the building or facility, the building or facility will be exposed to an unacceptable risk of damage due to fire.

Objective number OP1

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, the building or facility will be exposed to an unacceptable risk of damage to due to fire.

The risks of damage due to fire addressed in this Code are those caused by:

Objective number OP1.1

Fire or explosion occurring.

Objective number OP1.2

Fire or explosion impacting areas beyond its point of origin.
Therefore, we have the option of developing a unique process for use during the loading and unloading of tank vehicles that may not necessarily require a trained person to be positioned at a shut-off valve because we have otherwise assured that no person, building or facility will be exposed to unacceptable risk from fire or explosion and that the spread of hazardous substances can be limited. Of course, our process must be approved and implemented in conformance with Subsection 1.3.2 of Division C.

The new fire code doesn't signal a departure from prescriptive policy as much as it signals a more progressive fire- and life-safety philosophy. It can be expected that transition to the new Code will be difficult for both users and enforcement personnel but the opportunity is for greater dialogue and co-operation as they seek to define the ways that processes and programs will achieve the Alternative Solutions. There is also an opportunity to reduce the need for judicial intervention.

With more quickly changing codes and standards, and the benefits of rapidly developing technology, the new Ontario Fire Code gives greater flexibility to industry and to municipal fire services involved in the fire prevention activities of their communities