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BCC Ruling No. 99-60-716

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BUILDING CODE COMMISSION DECISION ON B.C.C. #99-60-716

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

AND IN THE MATTER OF Article 3.2.9.1. of Regulation 403, as amended by O. Reg. 22/98, 102/98 and 122/98 (the "Ontario Building Code").

AND IN THE MATTER OF an application by Mr. David Malcolm, Purchasing Manager, Taylor Steel Inc., Stoney Creek, Ontario, for the resolution of a dispute with Mr. Henry Dekker, Chief Building Official, City of Stoney Creek, Ontario, to determine whether the proposed expanded steel manufacturing facility with a total building area of 22,135 m2 (238,267 ft2), that is not equipped with a standpipe and hose system, provides sufficiency of compliance with Article 3.2.9.1. of the Ontario Building Code at the Taylor Steel plant, 395 Green Road, Stoney Creek, Ontario.

APPLICANT

Mr. David Malcolm, Purchasing Manager
Talyor Steel Inc.
Stoney Creek, Ontario

RESPONDENT

Mr. Henry Dekker
Chief Building Official
City of Stoney Creek

PANEL

Mr. Roy Philippe (Chair)
Ms. Susan Friedrich
Mr. Robert De Berardis

PLACE

Toronto, Ontario

DATE OF HEARING

April 22, 1999

DATE OF RULING

April 22, 1999

APPEARANCES

Mr. David Malcolm
Taylor Steel Inc.
Stoney Creek, Ontario
The Applicant

Mr. Collin Potter
Plan Examiner
City of Stoney Creek
For the Respondent

RULING

  1. The Applicant

Mr. David Malcolm, Purchasing Manager, received a building permit under the Building Code Act, 1992, and is currently constructing an addition onto an existing steel processing plant at the Taylor Steel plant, 395 Green Road, Stoney Creek, Ontario. As well, the Applicant has recently applied for another building permit to construct a further addition to the subject building.

  1. Description of Construction

The Applicant is currently constructing phase one of a two stage expansion plan to their existing one storey steel processing plant with a building area of 6,132 m2. Phase one consists of a one storey, 7,472 m2 L-shaped addition that will be attached to the south and east portions of the existing building. Phase two, which is presently in plans review, proposes to construct a second one storey, 8,531 m2 addition that is to run almost the complete length of the southern exposing building face (which is currently being built in phase one).

The total building area when both phase one and two are completed would be 22,135 m2. The entire building, including the existing, under construction and proposed portions is of noncombustible construction. It is equipped with a fire alarm system and a standpipe and hose system, but the hose system is limited to the original building only. There is no sprinkler system in the building. The structure is classified as a Group F, Division 3 - Low Hazard Industrial occupancy.

The plant is to be used in the processing of cold, rolled steel. It will also be used for the storage of materials produced in the plant and elsewhere.

  1. Dispute

The issue at dispute between the Applicant and Respondent is whether the proposed expanded steel processing facility, with a total area of 22,135 m2, of which 16,003 m2 of building area currently being built and proposed to be built is not to be equipped with a standpipe and hose system, provides sufficiency of compliance with Article 3.2.9.1. of the Ontario Building Code. This provision requires that a building with an F3 occupancy exceeding 3,000 m2 must be equipped with a standpipe and hose system. The proposed expansions to the steel plant will make the building far larger than the maximum allowed in Article 3.2.9.1. The Applicant has, however, proposed sufficiency of compliance with this OBC provision by offering an enhanced fire alarm system.

  1. Provisions of the Ontario Building Code

Article 3.2.9.1. - Where Required

(1) Except as provided in Sentences (4) to (7), a standpipe system shall be installed in every building that;

(a) is more than 3 storeys in building height;
(b) is more than 14 m (45 ft 11 in) high measured between grade and the ceiling of the top storey, or;
(c) is not more than 14 m (45 ft 11 in) high measured between grade and the ceiling of the top storey but has a building area exceeding the area shown in Table 3.2.9.1. for the applicable building height if the building is not sprinklered.

(2) A standpipe system shall be installed in every basement of a building that requires a standpipe system above grade.

(3) A standpipe system shall be installed in every basement of a building that regulated by Sentence 3.2.2.15.(2).

(4) A standpipe system is not required to be installed in the lowest storey in a building if this storey is a service room which has an area not more than 50 m2 (538 ft2).

(5) A standpipe system is not required to be installed in a roof-top enclosure if this enclosure has an area not more than 50 m2 (538 ft2).

(6) A standpipe system is not required to be installed in a storage garage conforming to Article 3.2.2.83 provided the building is not more than 15 m (49 ft 3 in) high.

(7) A standpipe system is not required to be installed in a dwelling unit which;

(a) extends not more than 3 storeys above adjacent ground level;
(b) is completely cut off from the remainder of the building so that there is no access to the remainder of the building, and;
(c) has direct access to its interior by means of an exterior doorway located not more than 1 500 mm (4 ft 11 in) above or below adjacent finished ground level.

  1. Applicant's Position

The Applicant submitted that a standpipe and hose system, although required, may not be appropriate for the proposed building because it is, and will be, constructed entirely of noncombustible materials. He also indicated that the materials produced and stored in the facility are not combustible. The handling and shearing equipment, which is operated by electric motors and a propane-powered tow motor is combustible but this would only cause a very localized fire. As the Applicant noted, the risk of fire is low.

The Applicant argued, in fact, that the steel products and manufacturing equipment in the plant would be more severely damaged by water used for fire fighting purposes than by the heat created during a small fire. He was also concerned about accidental breakage of water pipes due to pipe rupture, etc. The Applicant stated that any uncontrolled introduction of water into the plant's manufacturing and storage areas would be catastrophic and would render the steel orthless.

In terms of providing sufficiency of compliance for the proposed omission of a standpipe and hose system, the Applicant is proposing three compensating measures. The first measure the Applicant intends to provide is a fire suppression system provided by a series of ABC type portable extinguishers located throughout the plant. The staff at the plant would be trained to check, service and use the fire extinguishers, as well as perform other fire procedures. Also, the plant is operated on a 24 hour basis and the Applicant indicated that they have never had a previous fire.

The second compensating measure that the Applicant is providing an access route around the entire plant for fire fighting purposes. He also noted that there is an adequate water supply to the site since there are three fire hydrants on the property, one located on the Applicant's property and two on the municipal street facing the plant. As well, there is a local fire hall only 5 minutes away.

The third measure proposed by the Applicant is a fire alarm system that includes heat detection devices, bells, pull stations and a system monitoring panel that is interconnected to the security system.

The Applicant asserted that their alternative fire safety measures provide sufficiency of compliance with OBC Article 3.2.9.1. In his view, these three compensating measures, the extinguishers, the fire fighting access routes, and the fire alarm system, compensate for not providing a standpipe and hose system.

  1. Respondent's Position

The Respondent submitted that as an F3 occupancy with a building area of 22,135 m2, the proposed structure is required to have a standpipe and hose system in accordance with Article 3.2.9.1. of the OBC. He noted that the two existing hose racks do provide some protection, but their coverage is poor considering the vastly expanded size of the plant. The Respondent indicated that he was concerned about future owners of the building and being able to require a standpipe system at a later date. He stated that registering the building's current use on title would be quite useful. This would allow the municipal building department an opportunity to review the building and assess whether a standpipe and hose system should be required of a potential future owner. Lastly, he noted that other steel plants in the area have sprinklered their entire building.

  1. Commission Ruling

It is the decision of the Building Code Commission that the expanded steel manufacturing facility with a total area of 22,135 m2 not equipped with a standpipe and hose system provides sufficiency of compliance with Article 3.2.9.1. of the Ontario Building Code provided:

(i) The use of the building is registered on title to ensure that the current use continues.
(ii) The fire access route is provided on the south face complying with Article 3.2.5.5.
(iii) A hydrant(s) is provided on the south access route in conformance with Article 3.2.5.7.

  1. Reasons

(i) The primary building use is for storage of cold rolled steel with a low fire load.
(ii) A monitored fire alarm system is provided.
(iii) All construction is non combustible.
(iv) Access and water supply for fire fighting is provided via access routes and additional hydrants.





Dated at Toronto this 22nd day in the month of April in the year 1999 for application number 1999-18.

____________________________

Mr. Roy Philippe, Chair

_______________________

Ms. Susan Friedrich

__________________________

Mr. Robert De Berardis