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BCC Ruling No. 99-16-672

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BUILDING CODE COMMISSION DECISION ON B.C.C. #99-16-672

IN THE MATTER OF Subsection 24 (1) of the Building Code Act, 1992.

AND IN THE MATTER OF Article 3.7.1.5. and Sentence 3.2.4.5.(1) of Regulation 61, as amended by O. Reg. 400/91, 158/93, 160/93, 383/94, 20/95 and 395/96 (the "Ontario Building Code").

AND IN THE MATTER OF an application by Mr. Jim Whitehead, General Manager, Facility Development, YMCA of Greater Toronto, Toronto, Ontario, for the resolution of a dispute with Ms. Brenda Campbell, Chief Building Official and Director of Buildin g, City of Brampton, Ontario, to determine whether the fire alarm pull stations, installed at a height of 900 mm in accordance with Article 3.7.1.5., provides sufficiency of compliance with Sentence 3.2.4.5.(1) of the 1990 Ontario Building Code at the Bra mpton YMCA, 20 Union Street, Brampton, Ontario.

APPLICANT

Mr. Jim Whitehead, General Manager, Facility Development
YMCA of Greater Toronto
Toronto, Ontario

RESPONDENT

Ms. Brenda Campbell
Chief Building Official and Director of Building
City of Brampton

PANEL

Mr. Roy Philippe (Chair)
Ms. Susan Friedrich
Mr. Michael Steele

PLACE

Toronto, Ontario

DATE OF HEARING

March 11, 1999

DATE OF RULING

March 11, 1999

APPEARANCES

Mr. Peter Colquhoun
Principal, Arencon Inc.
Mississauga, Ontario
Agent for the Applicant

Ms. Lillyan McGinn
Manager, Plans and Permits
City of Brampton
For the Respondent

RULING

  1. The Applicant

Mr. Jim Whitehead, General Manager, Facility Development, YMCA of Greater Toronto, Toronto, Ontario, received a building permit under the Building Code Act, 1992 to construct a YMCA community centre and athletic facility at 20 Union Street, Brampton, Ontario.

  1. Description of Construction

The Applicant has recently constructed a two storey (plus basement), Group A - Division 2 YMCA community centre and athletic facility with a building area of 3,018 m2 (32,473.7 ft2). The building is of noncombustible construction and is equipped with a sprinkler system, a fire alarm system, but not a standpipe and hose system.

The construction in dispute is the mounting height of the manual pull stations for the fire alarm system, which were installed by the Applicant at 900 mm. Certain pull stations have also been equipped with a UL listed tamper-proof cover that makes a loud noise when the cover is lifted. The covered pull stations are located at the main entrance and immediately outside the daycare.

The building is designed to provide barrier-free accessibility.

  1. Dispute

The issue at dispute between the Applicant and Respondent is whether the manual pull stations, mounted at a height of 900 mm consistent with Article 3.7.1.5. of the 1990 Ontario Building Code, provides sufficiency of compliance with Sentence 3.2.4.5.(1). Article 3.7.1.5. stipulates that the installation of building services and safety devices, including fire alarm pull stations, in a barrier-free path of travel must be mounted at not more than 1,200 mm above the floor. Sentence 3.2.4.5.(1), on the other hand, requires that fire alarm systems, including pull stations, be installed according to CAN/ULC-S524-M91, "Standard for the Installation of Fire Alarm Systems". This standard, specifically in Clause 5.2.1., states that fire alarm pull stations must be placed between 1,200 mm and 1,400 mm above the floor. Located at 900 mm, the subject pull stations meet the Section 3.7 barrier-free requirements but not the referenced standards found in CAN/ULC-S524-M91.

  1. Provisions of the Ontario Building Code

Article 3.7.1.5. Controls

Except as provided in Article 3.7.3.5., controls for the operation of building services or safety devices, located in a barrier-free path of travel and intended to be operated by the occupant, including manual pull stations, electrical switches, thermostats and intercom switches, shall be accessible to a person in a wheelchair and shall be mounted at not more than 1.2 m (3 ft 11 in) above the floor.

Sentence 3.2.4.5.(1)Installation and Testing of Fire Alarm Systems

(1) Fire alarm and voice communication systems shall be installed in conformance with CAN/ULC-S524-M, "Standard for the Installation of Fire Alarm Systems".

  1. Applicant's Position

The Applicant submitted that mounting height of the fire alarm pull stations, as installed, meets the intent of Article 3.7.1.5. and therefore provides sufficiency of compliance with the OBC. He argued that since the building was designed to provide barrier-free accessibility, the provisions of Section 3.7 were applicable. In his view, Article 3.7.1.5. provides a maximum height above which the pull stations may not installed, but it does not indicate a minimum height. This implies that any height less than 1,200 mm is acceptable, as long as the height also meets the criteria of being "accessible to a person in a wheelchair" as well.

To support his assertion, the Applicant pointed to the diagrams in the Illustrated Guide of the current (1997) OBC. The Illustrated Guide, he noted, clearly describes 1,200 mm as a maximum mounting height. Further, the Applicant also pointed out that other building services and safety devices, such as elevator control buttons (e.g., stop and emergency buttons) must be located at the bottom of the elevator control panel and not less than 890 mm above the floor. In other words, the Applicant argued, these vital control buttons must be placed at or around the 900 mm level.

The Applicant cited Article 2.6.2.1., which states that "in the case of a conflict between the provisions of this Code and those of a referenced document, the provisions of this Code shall govern." Because Article 3.7.1.5. is an actual provision within the OBC, whereas the CAN/ULC-S524-M91 is an external standard referenced in the Code, Article 3.7.1.5. should take priority as the guiding requirement.

Lastly, the Applicant indicated that he had sought clarification regarding the appropriate mounting height from the municipality prior to their installation. He indicated his intention to install them at 900 mm. At that time, he was told that the pull stations must not be higher than 1,200 mm, which was consistent with Article 3.7.1.5. The Applicant took this as

confirmation of the proposed height and proceeded to set the pull stations at 900 mm. It was only during a later inspection that the municipality advised him that they were too low.

  1. Respondent's Position

The Respondent submitted that the pull stations, set at 900 mm, do not conform with the requirements of the OBC. While they recognize that two independent, and largely differing OBC requirements set out standards for pull station mounting heights, the two requirements are consistent in that they both allow a mounting height of 1,200 mm. At this height one can meet both Article 3.7.1.5. and the CAN/ULC-S524-M91 standard. In their view, therefore, 1,200 mm is the only acceptable mounting height in a building and that this mounting height is appropriate for both ambulatory and wheel chair users.

Moreover, the OBC does not contain any other acceptable benchmarks that establish specific minimum mounting heights for safety devices such as fire alarm pull stations, the respondent argued. In other words, no where in the Code does it specifically support a mounting of 900 mm, or anything less than 1,200 mm for that matter. With out a minimum height requirement, such as 1,200 mm, pull stations could be mounted dangerously low. They argued that even mounted at 900 mm, and especially since some of them are equipped with a tamper proof cover, occupants might not recognize the pull stations in the case of an emergency.

  1. Commission Ruling

It is the decision of the Building Code Commission that the fire alarm pull stations installed at a height of 900 mm in locations described in Article 3.7.1.5. of the Building Code provides sufficiency of compliance with Sentence 3.2.4.5.(1) of the Building Code on the provision that a directional sign is located directly above the pull station at a height of 1,200 to 1,400 mm.

  1. Reasons

i. The Building Code Article 3.7.1.5. is specific with respect to the maximum mounting distance from the floor level but does not specify a minimum distance. The 900 mm distance is consistent with universal access.

ii. The sprinkler heads in this fully sprinklered building are connected to the fire alarm system via flow switches which provides a level of detection over and above the coverage required for fire alarm systems under Section 3.2.4. of the Building Code.

iii. A directional sign is required above the pull stations at a height consistent with the installation requirements for pull stations not subject to the exemption of Article 3.7.1.5.

iv. The applicant provided evidence that the mounting height of 900 mm is consistent

v. with research which indicated that this is an acceptable height for ambulatory and wheelchair users, as also evidenced by the C.S.A. B.44 "Safety Code for Elevators" in serving its intended function.

Dated at Toronto this 11th day in the month of March in the year 1999 for application number 1999-05

Mr. Roy Philippe, Chair]

Ms. Susan Friedrich

Mr. Michael Steele