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BCC Ruling No. 96-11-494

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BUILDING CODE COMMISSION DECISION ON B.C.C. #96-11-494

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

AND IN THE MATTER OF Sentence 3.4.6.15.(1) and Clause 3.4.6.15.(4)(c) of the Revised Regulation of Ontario 1990, Regulation 61, as amended by O.Regs. 400/91, 158/93, 160/93, 383/94 and 20/95 (the "Building Code").

AND IN THE MATTER OF an application by Mr. Ron Villeneuve, Vice- President, Cosmic Adventures Inc., Gloucester for the resolution of a dispute with Ms. Elizabeth Hilfrich, Chief Building Official, City of Gloucester, concerning: i) whether electromagnetic locking devices on five exit doors must release immediately upon activation of door release hardware in accordance with Sentence 3.4.6.15.(1) of the Building Code; and, ii) whether the installation of two manual pull stations for a fire alarm system incorporating electromagnetic locking devices beyond the maximum allowance of 600 mm from the door will provide sufficiency of compliance with Clause 3.4.6.15.(4)(c) of the Building Code, at Cosmic Adventures Inc., 1373 Ogilvie Road, Gloucester, Ontario.

APPLICANT

Mr. Ron Villeneuve
Vice-President
Cosmic Adventures Inc.
Gloucester, Ontario

RESPONDENT

Ms. Elizabeth Hilfrich
Chief Building Official
City of Gloucester

PANEL

Mr. Roy Philippe, Chair
Mr. Demir Delen
Mr. Remus Tsang

PLACE

Toronto, Ontario

DATE OF RULING

April 16th, 1996

APPEARANCES

Mr. Ron Villeneuve
Cosmic Adventures Inc.
Gloucester, Ontario
The Applicant

RULING

  1. The Applicant

Mr. Ron Villeneuve, Vice-President is the recipient of an order to comply under the Building Code Act, 1992 requiring: i) deactivation of electromagnetic locking devices on five exit doors equipped with panic type hardware when a force of not more than 90 N is applied to the panic hardware; and, ii) relocation of manual pull stations for the fire alarm system within 600 mm of the two gates equipped with electromagnetic locking devices.

  1. Description of Constrution

The subject building is a two storey noncombustible building with a building area of 2,531 m². The building has two tenants. Methot Mermaid Pools occupies 975 m² of the ground floor and 197 m² of the second floor. Cosmic Adventure Indoor Play centre occupies 1,556 m? of the ground floor and 337 m² of the second floor. A two hour fire separation is provided between the two tenants. The building is provided with a fire alarm and detection system and a sprinkler system, but not a standpipe and hose system.

The main function of the Cosmic Adventure Indoor Play Centre is to provide supervised recreation and learning for children of all ages. To provide security against unauthorized entry and exit, electromagnetic locking devices have been installed on all exit doors of the tenant space.

  1. Dispute

The dispute between the Applicant and Respondent concerns an interpretation of Sentence 3.4.6.15.(1) and sufficiency of compliance with the technical requirements of Clause 3.4.6.15.(4)(c) of the Building Code. At issue is: i) whether electromagnetic locking devices on five exit doors must release immediately upon activation of door release hardware; and, ii) whether the installation of two manual pull stations for a fire alarm system incorporating electromagnetic locking devices may be located beyond the maximum allowance of 600 mm from the door.

  1. Provision of the Building Code

Sentence 3.4.6.15.(1) Door Release Hardware

  1. If a door is equipped with a latching mechanism, a device that will release the latch and allow the door to swing wide open when a force of not more than 90 N (20 lb) is applied to the device in the direction of exit travel shall be installed on

    1. every exit door from a floor area containing a Group A occupancy having an occupant load of more than 100 persons,
    2. every door leading to an exit lobby from an exit stair shaft, and every exterior door leading from an exit stair shaft in buildings having an occupant load of more than 100 persons, and
    3. every exit door from a floor area containing a Group F, Division 1 Occupancy.

Clause 3.4.6.15.(4)(c)

4. An electromagnetic locking device that does not incorporate latches, pins or other similar devices to keep the door in the closed position is permitted to be installed on an exit door, other than an exit door serving an elementary or secondary school or leading directly from Group F, Division 1 occupancy

(c) if a manual pull station for the fire alarm system is located on the wall not more than 600 mm (23 5/8 in) from the door.

  1. Applicant's Position

i. Concerning sufficiency of compliance with Clause 3.4.6.15.(4)(c):

The Applicant requested permission to relocate two pull stations for the fire alarm system, beyond the maximum allowance of 600 mm from the door. This would only apply to the electromagnetic locking devices installed at the reception desk exit gates. The Applicant submitted that the gates and walls that separate the inside area from the outside area are only 900 mm high and the staff have problems keeping children from hopping over them at the best of times let alone if there was an emergency. The new placement would put the devices 1 metre away on the inside face of the counter, near the public address system of the emergency control centre. This area is manned during all hours of operation by trained personnel.

The Applicant submitted that the requirements of the Building Code locates the fire alarm pull station within easy reach of the average, inquisitive, impatient and excited 5 or 6 year old. The Applicant further submitted that in a test conducted on site, a dummy pull station was activated five times over a weekend despite increased awareness of the problem by staff.

The Applicant submitted that the reason for the appeal is simply a desire to reduce the possibility of accidental or malicious false alarm while providing maximum protection to our guests.

ii. Concerning an interpretation of Sentence 3.4.6.15.(1):

The Applicant submitted that if the panic type hardware is required to immediately disengage the electromagnetic locking devices it would be tantamount to having no egress security what so ever and invites the opportunity of a child wandering out unnoticed or even worse may create fertile ground for an abduction.

The Applicant submitted that they have taken the added precaution of installing an electromagnetic locking device de-activation keypad or a push button at each electromagnetic locking device location and in the event of an emergency a trained staff member would be responsible for releasing them should all other safe guards fail.

The Applicant also requested consideration to use a fifteen second time delay in the panic hardware to allow staff time to respond to the door in question.

  1. Chief Building Official's Position

The Respondent submitted that Sentence 3.4.6.15.(1) of the building code requires exit doors to open when door release hardware is activated.

The Respondent submitted that Clause 3.4.6.15.(4)(c) of the building code requires a pull station to be located within 600 mm of a door equipped with an electromagnetic locking device.

The Respondent further submitted that the Applicant's proposals do not comply with the building code.

  1. Commission Ruling:

i. It is the decision of the Building Code Commission that the installation of electromagnetic locking devices (EMLD) on required exit doors equipped with release hardware (i.e. panic type hardware) provides sufficiency of compliance with Article 3.4.6.15. of the Building Code provided that:

a. A force of not more than 90 N applied to the door opening hardware initiates an irreversible process that will release the locking device within 15 seconds and will not relock until the door has been opened.

b. A deactivation key pad is installed at every door with EMLD which will release the EMLD immediately.

c. A legible sign is permanently mounted on the exit door to indicate that the locking device will release within 15 seconds of applying pressure to the door release hardware.

d. The EMLD is installed as an ancillary device to the fire alarm system and the installation, activation and resetting shall comply with the requirements of Sentence 3.4.6.15.(4) of the Building Code.

e. Emergency lighting is installed in accordance with the Building Code at the exit doors with EMLD's to illuminate door signage.

f. The EMLD's are not connected before a Fire Safety Plan is approved by the Chief Fire Official which identifies the installation of the EMLD's.

g. All EMLD's will be capable of being released immediately from the emergency control centre which is continuously attended.

ii. In addition, it is the decision of the Building Code Commission that the relocation of two pull stations to the reception desk exit gates at one metre away on the inside face of the counter of the emergency control centre provides sufficiency of compliance with Clause 3.4.6.15.(4)(c) provided the location is continuously attended.

  1. Reason:

It is the opinion of the Building Code Commission that the conditions imposed above provide sufficient safeguards with respect to life safety recognizing the security needs of this particular use.

Dated at Toronto, this 19th day, in the month of April, in the year 1996, for application number 1996-08.

Roy Philippe

Demir Delen

Remus Tsang