Guide For Requesting Changes to the Fire Code

Suggestions for changes to the Fire Code can be made by any individual or group at any time. Requests for Fire Code changes will be processed for possible inclusion in the next edition of the (Ontario) Fire Code and will be shared for consideration in the development of the national model Fire Code of Canada. In some cases, interim amendments may be implemented as determined appropriate. To submit a request, please complete the information identified on the attached form and submit to the Office of the Fire Marshal. The following points will assist you in completing the form.
 

1. Background Information

   If you are identifying yourself as the voice of a business/organization/association, please ensure that you are authorized by the group to do so. If you do not have authorization to represent a group, please check box (a) ‘Myself’, even if you are a member of a larger group.

    

2. Fire Code Reference

   Identify the relevant Fire Code reference number for the existing provision that is the subject of the requested change. The identification must include the relevant Part, Section, Subsection, Article, etc. e.g. 9.5.3.7.(2)(a)(ii). Where the request involves a new requirement please indicate ‘New’.

    

3. Describe The Problem

   Identify the problem with the existing wording or Fire Code provision and why a change is necessary. Provide as much detail as possible. If requesting a new requirement, describe what is missing, why it should be regulated in the Fire Code and other rationale to support the change.

    

4. Describe The Proposed Change

   Be as specific as possible in describing the change that you would like to see. Provide exact wording whenever possible.

    

5. Identify Other Fire Code Provisions That May Be Affected

   Consider whether your proposal will have an effect on other existing Fire Code provisions. For example, a change to a defined term will affect the scope and application of requirements throughout the code where the term is used. Such a change could potentially have a significant impact on both existing and new operations unless limiting language is inserted to clarify the intent and scope where appropriate.

    

6. Describe The Expected Impact Of The Proposed Change

   Describe public safety benefits that can be expected if the change is implemented. Provide an estimate of the initial and long term costs and the persons that will be affected. Consider whether the requirement can be enforced utilizing existing resources and within the existing framework or will additional measures be necessary to accommodate your proposal.

    

7. Additional Information For New Requirements

   Division A of the Fire Code lists the applicable objectives and functional statements of the code. Each new requirement should be linked to at least one of the stated objectives and functional statements. In addition, please refer to subsection 12.(1) in the Fire Protection and Prevention Act, 1997 to confirm that there is authority for regulating the new requirement in the Fire Code. Generally speaking, the Fire Code only has authority to regulate matters that are directly related to fire safety. Finally, consider whether your request is consistent with requirements for new construction contained in the existing Building Code to avoid conflicts.

    

8. Additional Supporting Material

   Include any other documentation that supports the case that a change is needed and that your proposal is the correct approach for regulation. Documentation can include research, test results, fire experience, case studies, etc.