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BCC Ruling No. 99-31-687

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BUILDING CODE COMMISSION DECISION ON B.C.C. #99-31-687

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

AND IN THE MATTER OF Sentence 3.2.8.4.(4)and Clause 3.4.2.5.(1)(b) 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 Ms. Elizabeth Lavery, Facility Manager, Ontario Realty Corporation, 1 Stone Road West, Guelph, Ontario, for the resolution of a dispute with Mr. Bruce Poole, Chief Building Official, City of Guelph, Ontario to determine whether the travel distances on the second to fifth floors ranging from 53 to 56 m, in a structure with interconnected floor space due to the full height atrium, provides sufficiency of compliance with Sentence 3.2.8.4.(4) and Clause 3.4.2.5.(1)(b) of the Ontario Building Code at the OMAFRA Head Office building, Guelph, Ontario.

APPLICANT

Ms. Elizabeth Lavery, Facility Manager
Ontario Realty Corporation
Guelph, Ontario

RESPONDENT

Mr. Bruce Poole
Chief Building Official
Town of Erin

PANEL

Mr. Kenneth Peaker (Chair)
Mr. James Lischkoff
Mr. Stuart Smith

PLACE

Toronto, Ontario

DATE OF HEARING

May 13, 1999

DATE OF RULING

May 13, 1999

APPEARANCES

Mr. Jon Winton, Sr. Associate
Leber/Rubes Inc.
Toronto, Ontario
Agent for the Applicant

Mr. Rob Reynen
Sr. Building Inspector
City of Guelph
The Respondent

RULING

  1. The Applicant

Ms. Elizabeth Lavery, Facility Manager, has received a building permit under the Building Code Act, 1992, to construct a head office building to accommodate the Ontario Ministry of Agriculture, Food and Rural Affairs at 1 Stone Road West, Guelph, Ontario.

Ms. Elizabeth Lavery, Facility Manager, Ontario Realty Corporation, 1 Stone Road West, Guelph, Ontario, for the resolution of a dispute with Mr. Bruce Poole, Chief Building Official, City of Guelph, Ontario to determine whether the travel distances on the second to fifth floors ranging from 53 to 56 m, in a structure with interconnected floor space due to the full height atrium, provides sufficiency of compliance with Sentence 3.2.8.4.(4) and Clause 3.4.2.5.(1)(b) of the Ontario Building Code at the OMAFRA Head Office building, Guelph, Ontario.

  1. Description of Construction

The Applicant has recently constructed a new, six storey, Group D - business occupancy (office), with a building area of 12,000 m2. The building will be of noncombustible construction and will be equipped with a sprinkler system, fire alarm system and standpipe and hose system.

An atrium separating the building into north and south wings extends from the ground floor to the fifth. The atrium creates an interconnected floor space. Both wings on floors two to five are served by three exits each, except for the north wing on the second floor which has four exits. The occupant load per floor ranges from 688 persons on the second floor to 479 on the fifth. On each floor the north wing contains a somewhat higher occupant load than the south wing.

The construction in dispute involves the travel distances on the second to fifth floors, which from the most remote areas on these levels ranges from 53 to 56 m (13 to 16 m beyond the permitted distance). The travel distances on all interconnected north wing floors are 53 m. In the south wing the travel distances on the second, third and fourth floors are 55 m, whereas the fifth floor travel distance is 56 m.

Travel distances became an issue when partitions and furniture were installed in the recently completed building. The floor areas had originally be designed and built as open floor areas. The travel distances had been calculated on a straight line basis from the most remote point to the nearest exit. With the furniture and partitions the egress routes were no longer straight and therefore increased beyond the maximum allowed in the OBC.

  1. Dispute

The issue at dispute between the Applicant and Respondent is whether the as built travel distances, ranging from 53 to 56 m on floors two to five, in a structure considered to have interconnected floor space due to the atrium, provides sufficiency of compliance with Sentence 3.2.8.4.(4) and Clause 3.4.2.5.(1)(b). This latter provision of the OBC stipulates a maximum travel distance of 40 m to an exit from a floor area that is required to have more than one exit. At issue therefore, are the travel distances that exceed the 40 m maximum by as much as thirty to forty per cent longer than allowed by the OBC.

  1. Provisions of the Ontario Building Code

Sentence 3.2.8.4.(4) Exits

(4) Except where exits serving the floor area are at ground level, the increased travel distance to exits permitted by Clause 3.4.2.5.(1)(c) shall not apply to a floor area within an interconnected floor space.

Sentence 3.4.2.5.(1) Location of Exits

(1) Except as permitted by Sentences (2), (3) and 3.3.2.4.(6), if more than one exit is required from a floor area, the exits shall be located so that the travel distance to at least one exit shall be not more than

(a) 25 m (82 ft) in a high hazard industrial occupancy,
(b) 40 m (131 ft 3 in) in a business and personal services occupancy,
(c) 45 m (147 ft 8 in) in a floor area that contains an occupancy other than a high hazard industrial occupancy, provided it is sprinklered,
(d) 105 m (344 ft 6 in) in any floor area, served by a public corridor, in which rooms and suites are not separated from the remainder of the floor area by a fire separation, provided
(i) the public corridor is not less than 9 m (29 ft 6 in) wide,
(ii) the ceiling height in the public corridor is not less than 4 m (13 ft 1 in) above all floor surfaces,
(iii) the building is sprinklered, and
(iv) not more than one half of the required egress doorways from a room or suite open into the public corridor if the room or suite is required to have more than one egress doorway,
(e) except as permitted by Sentence (5), 60 m (196 ft 10 in) in any storage garage that conforms to the requirements of Article 3.2.2.83., and
(f) 30 m (98 ft 5 in) in any floor area other than those referred to in Clauses (a) to (e).

  1. Applicant's Position

The Applicant submitted that while the second to fifth floor travel distances do exceed the 40 m maximum allowed in the OBC the actual exit time from the floor areas is not increased and therefore does not constitute a risk to life safety. He indicated that his primary argument to support this assertion and thereby demonstrate sufficiency of compliance is based on a timed exit analysis. The Applicant provided a description of the timed egress analysis employed.

The timed exit analysis was based on the methodology set out in the SFPE Handbook of Fire Protection Engineering, 2nd Edition. The analysis was done for all floors in the OMAFRA building in which the travel distance exceeds 40 m. The study measured how long it would take to get through a door at the given width, how long it would take to get to that door, etc. A comparative analysis was also performed for a hypothetical floor area that complies with the OBC.

The Applicant indicated that the range of times he calculated it would take to travel across the floor area and to enter the exit stair enclosure was 1.68 minutes on the south wing of the fifth floor which has the lowest occupant load at 198 persons of the disputed floors areas to 2.63 minutes for the second floor of the north wing which has the highest occupant load of 422. The Applicant noted that the queue that would form at the exit door would be the bottleneck in the exit path. The time that it would take to get to the exit door is minor compared to the time it would take to get through the door itself. However, even though the travel distance exceeds the 40 m, since they have provided more than the required exits, this means that the occupants have more exit options and the queues at each door would be less, thereby facilitating quicker exiting.

In comparison, he noted that the travel time for a Code complying structure, in which exit stairs are provided based on the exit requirements of calculated occupant load, is 3.23 minutes. The Applicant argued that this higher time results from the larger and longer queues at these exits because there are less of them than in the OMAFRA building. He noted that even the slowest exit times in the OMAFRA building are significantly lower than that permitted by the OBC.

The Applicant concluded by stating that since the travel distance times are lower than those permitted by the OBC that sufficiency of compliance has been achieved and that the subject building does not pose an increased life safety risk.

  1. Respondent's Position

The Respondent indicated that his position was clear. The Code requires that the travel distance in the subject building be limited to 40 m. He noted that in all disputed floor areas the travel distance is exceeded by at least thirty per cent and in at least one case it is forty per cent over the 40 m maximum distance allowed.

The Respondent also indicated that there are no specific provisions in the OBC that would allow him to accept a timed exit analysis or other such studies as an equivalent under the Code to the permitted 40 m travel distance. He noted that they do not have strong objections to the Applicant's arguments.

  1. Commission Ruling

It is the decision of the Building Code Commission that the travel distance on the second to fifth floors ranging from 53 to 56 m, in a structure with interconnecting floor space due to the full height atrium provides sufficiency of compliance with Sentence 3.2.8.4.(4) and Clause 3.2.8.5.(1)(b) of the Ontario Building Code at the OMAFRA head office building, 95 Stone Road West, Guelph, Ontario.

  1. Reasons

(i) Excess stair capacity provides sufficiency of compliance.

(ii) Timed exit analysis shows time taken for all occupants to exit is no longer and is in fact less than that for a Code complying building.

Dated at Toronto this 13th day in the month of May in the year 1999 for application number 1999-17

Mr. Kenneth Peaker, Chair

Mr. James Lischkoff

Mr. Stewart Smith