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Opinions & Applications for the Fire Code (1997 edition) (revoked November 21, 2007)

9.2.4.1. FIRE ALARM AND DETECTION

9.2.4.1.

  

"(1) Fire alarm and detection systems shall be installed in compliance with Subsection 3.2.4., excluding Article 3.2.4.7. of the Building Code. (2) Notwithstanding Sentence (1), existing fire alarm systems may be approved where the system reliability and performance will not increase the risk of life safety."

Intent:

  

This Article is intended to require the installation of a fire alarm system that complies with the Building Code, in buildings with specified assembly occupancies.

Sentence (2) gives the Chief Fire Official discretion to accept an existing system provided the system reliability and performance will not increase the risk of life safety.

Other Resources:

   OBC 3.2.4.

Application:

  
Q1   Must a fire alarm system be installed in a small restaurant?
A1   The Building Code identifies that a restaurant designed to accommodate not more than 30 persons consuming food or drink is permitted to be classified as a Group E major occupancy. To be consistent with the Building Code, such a restaurant would not be required to comply with Subsection 9.2.4., or any other requirements of Section 9.2.


Q2   Is a fire alarm system required when a building receives a temporary LLBO licence?
A2   The requirement for a fire alarm system stems from Subsection 9.2.4., not from the licencing requirements. The need for a fire alarm system is influenced by the occupant load (see also Question 3).


Q3   Does the requirement for a fire alarm system "when the occupant load exceeds 150 in licensed restaurants and beverage establishments" apply to community centres, etc., where special occasion permits are issued?
A3   Since the Fire Code does not specifically refer to frequency of use in relation to application of legislation, even one-time use of a building may be sufficient grounds to apply Retrofit. However, the Fire Code also allows the Chief Fire Official discretionary authority in Articles 9.1.2.4. and 2.1.2.2.. Where other compensating features are put into effect (e.g. having a fire watch, altering the fire safety plan and procedures to identify how occupants will be alerted to emergencies, placing limitations on the frequency of the events, number of occupants, etc.) something less than full compliance could be appropriate.

Where discretion is exercised, the reasons and any qualifying conditions should be documented. This documentation can also put an owner on notice that, if any conditions change, full compliance would be required.


Q4   Does the occupant load of the worship area of a church contribute to the determination for fire alarm requirements?
A4   Retrofit does not apply to areas of worship, as noted in Clause 9.2.1.1.(1)(k), "halls in religious establishments excluding areas of worship". Accordingly, the occupant load calculated to determine the need for a fire alarm system does not include the occupant load of the worship areas.


Q5   Must a fire alarm system be extended to small meeting rooms located adjacent to the area of worship in a church?
A5   If rooms located adjacent to the area of worship are used for prayer meetings, serve as a vestry, etc. then these rooms might properly be considered areas of worship.

The usage of the rooms must be specified to determine the need for fire alarm coverage.

Where discretion is exercised, the reasons and any conditions attached should be documented. This documentation can also put an owner on notice that, if any conditions change, provision of a fire alarm system could be required.

Where possible, extension of the fire alarm system into the worship areas, in light of general life safety concerns, should be considered. Owners who wish to extend the system into worship areas should not be discouraged from doing so.

Q6   Does an owner of a theatre with a seating capacity greater than 300 have any options besides installing a fire alarm system?
A6   Any options are discretionary on the part of the Chief Fire Official. Practically, however, the owner may restrict the occupant load to less than 300 persons. This could be accomplished as follows:
  1. remove all seats in excess of 300, or
  2.  
    1. be licenced for 300 persons or less under the Theatres Act, and;
    2. post an occupant load sign, in accordance with the licence, in a public area such as the lobby, and;
    3. provide a letter of commitment indicating that he/she will not sell admissions in excess of the licence limit in (i).

Where such options are exercised, conditions of acceptance should be documented. The responsibility for continued compliance rests with the owner.


Q7   If barn buildings are being used for assembly purposes, must a fire alarm system be installed?
A7   Yes, barn buildings used for assembly purposes described in Subsection 9.2.1. are required to have a fire alarm and detection system as described in Article 9.2.4.1..

Where the occupant load is limited to a number that eliminates the requirement for a fire alarm system, it is advisable to have associated details documented, as noted in previous question responses.


Q8   Must a fire alarm system be connected directly to the fire department?
A8   No. A Building Code requirement associated with transmission of signals to the fire department is not included in Article 9.2.4.1..