The OFM provides clarifications and opinions on Ontario Fire Code (OFC) matters to assist users in understanding the requirements and their intended use. The Chief Fire Official is not obligated to abide by these opinions. The Chief Fire Official of the municipality has the authority to enforce the OFC within the jurisdiction and should be contacted prior to implementing the provisions of any of these opinions.
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4.1.1.2.(2) Application
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Q1. Does Part 4 apply to a gasoline tank farm since the Gasoline Handling Act applies to them? Does the word "and" mean that the Gasoline Handling Act and the Energy Act both must apply? A1. If the gasoline tank farm falls under the Gasoline Handling Act then Part 4 does not apply. The word "and" was not meant to imply that a facility was exempt from Part 4 only when both statutes applied. Q2. Who has jurisdiction over piers and wharves located in a municipality? A2. If a municipality has a pier or wharf where flammable or combustible liquids are transferred, it is necessary to determine if the facility is under federal jurisdiction prior to enforcing Part 4 of the Fire Code at these facilities. Each site needs to be evaluated individually. The two agencies of the federal government that need need to be contacted are:
These agencies are currently undergoing a divestiture program, where the administration and ownership are being handed over to the municipalities. This may already have occurred in a municipality or it may be in the process. In either case, the following questions must be asked of the two agencies listed above:
In consultation with your municipal solicitor, you may wish to confirm the outcome of the discussions in writing and provide the agency an opportunity to respond confirming the jurisdictional issue. If the answer to any one of the above questions is YES, then the federal agency would appear to have jurisdiction. Confirm your discussions in writing with the agency that provided the information. Indicate your understanding is that the facility is under the federal jurisdiction, that Part 4 of the Fire Code does not apply and the municipality will not be enforcing the code provisions. If the answer is NO to all questions, then it would appear that the facility is not under federal jurisdiction. Confirm your discussions in writing with the agency that provided the information. Indicate your understanding that the facility is not under federal jurisdiction, that Part 4 of the Fire Code would apply and that the owners of the facility will be informed of their legal obligation to comply. If the answers are not clear, then you may wish to write to the agencies and request a response in writing to confirm who has jurisdiction with respect to enforcing the fire safety legislation. Also indicate to the agencies that until the jurisdictional issue is resolved, the owners of the facility would be informed of their legal obligation to comply with the Fire Code. Q3. Most bulk plants are regulated by the Gasoline Handling Act and are therefore exempted from complying with the Fire Code through Clause 4.1.1.2.(2)(d) . Does this exemption include a laboratory associated with a bulk plant? (also see 4.12 Q2) A3. No. The Fuel Safety Engineering division of the Technical Standards and Safety Authority does not consider the laboratory to be part of the bulk plant. The laboratory must still comply with all applicable requirements in Part 4 including Sections 4.1, 4.2 and 4.12. If there is a conflict between general requirements in 4.1 or 4.2 and the specific requirements in 4.12 then the specific requirements override the general. Q4. Is it acceptable to order a property owner to comply with Part 4 of the Fire Code in a general compliance statement and then put the onus on the owner to prove compliance? (i.e. with an Engineers Audit). If so, would a general compliance statement in an inspection report be enforceable if the matter were to be taken to court? Also, have you received information from other municipalities indicating that they intend to follow this course of action? A4. We do not recommend issuing a general compliance order for complying with Part 4. It is the owners responsibility to comply with the Fire Code. However, if the Chief Fire Official, on inspection finds that an owner is in violation of any provision of the Fire Code, they have the authority to charge the owner for non-compliance with the specific provision. A general compliance statement in an inspection report would not be enforceable. In court, it is always the responsibility of the person or persons laying the charges to prove that the owner is not in compliance with the Fire Code. Q5. Does the exemption for farms in Clause 4.1.1.2.(2)(h) include dwelling units on the farm? A5. No. This exemption does not exclude dwelling units from complying with Part 4. Dwelling units on the farm property must comply with Subsection 4.2.4. and any other applicable requirements in Part 4. Not including dwelling units or other residential occupancies as part of the farm is consistent with previous interpretations of Article 1.1..6.1.., which deals with farm buildings. (also see 4.2.4. Q & A) |
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4.1.1.3. Compliance |
Q1. What action may be taken where an inspection reveals a hazard that is not addressed in a Part 4 requirement that has a future compliance date? A1. The hazard may already be addressed in regulations made under the Occupational Health and Safety Act. Therefore, it may be appropriate to call the local office of the Ministry of Labour to request an inspection. Where the hazard is less serious, it may be appropriate to inform the owner, in writing, that the deficiency must be corrected by the compliance deadline set out in Part 4 of the Fire Code. Owners should be encouraged not to wait until the compliance deadline to correct hazards that may endanger workers, the community and the environment. Q2. Can an Inspection Order (formerly called a Fire Marshals Order) be issued to require compliance with Part 4 before the dates specified in the Fire Code? A2. No. An Inspection Order cannot be used to enforce requirements that are more stringent than the Fire Code. The compliance date is part of the Fire Code requirements. By requiring an earlier compliance date than the Fire Code stipulates, you are, in effect, trying to enforce a more stringent requirement. Q3. Can Immediate Threat to Life provisions be used to require compliance with Part 4 before the dates specified in the Fire Code? A3. The general principle is that an Inspection Order cannot be used to require compliance with Part 4 before the dates specified in the Fire Code. However, this does not apply where the situation is sufficiently hazardous to justify using the Immediate Threat to Life provisions. This situation should not occur. One criterion for selecting the compliance dates for the various provisions in Part 4 is the effect compliance with the provision has on life safety. Where it is appropriate to use Immediate Threat to Life provisions such a situation would most likely need to have been in compliance by August 21, 2000. In this case there is no impediment to using the Immediate Threat to Life provisions of Section 15 of the Fire Protection and Prevention Act provided it can be shown that there is an immediate threat of fire and that human life will be placed at risk. (See OFM Guideline OFM-TG-01-1999 Orders, Orders to Close and Immediate Threat to Life for additional information about the use of Immediate Threat to Life provisions.) |
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4.1.1.4. Compliance Schedule
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Q1. How do you apply an Article that references another Article that has not yet come into force? A1. If one Article with a compliance date of August 21, 2000 makes reference to another Article with a compliance date of August 21, 2002, it can be argued that the reference permits a longer time to comply. Therefore, where no options are provided, those requirements that make reference to provisions that have later compliance dates must be in compliance until the most distant compliance date. However, where a requirement provides several options for compliance and one or more of those options involve provisions with later compliance dates, it is expected that the option with the earliest compliance date apply. The owner has the option of complying with any one of the options, as long as compliance is achieved by the earliest date. It should be noted that the owner is not forced to comply with the option that has the most distant compliance date. If the owner is permitted to comply with options at the later compliance dates, the original intent of the requirements would not be met and inconsistent levels of fire safety will result. |
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4.1.1.5. Compliance equivalency
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Q1. How should a compliance equivalency be evaluated? A1. The content of a compliance equivalency may be highly technical, thus, difficult for a lay person to assess. This was part of the reason for limiting persons who could submit these requests to engineers or architects (Article 4.1.1.5.). Both engineers and architects are governed by regulating bodies that can remove their license to practice in Ontario where they err or operate unethically. The compliance equivalency process is set out in Article 4.1.1.6. The key point in evaluating these submissions is to ensure that the report adequately covers the fire safety issues that vary from Part 4. The reports must adequately address all issues and clearly state that the protection afforded by the proposed alternative is equal to or better than that provided in Part 4. These reports must be signed and sealed by an engineer or architect licensed in Ontario. Q2. Regarding Article 4.1.1.5., is there an annual listing of architects or engineers? A2. Both the Ontario Architects Association and Professional Engineers Ontario publish an annual list of their members, which is usually available in the local library. The relevant associations may also be called to confirm licensing. The addresses of three organizations (PEO, CEO, and OAA) are posted on the OFM Website. Q3. Does the engineer or architect who develops and submits the compliance equivalency have to supervise any work required to implement the equivalency? A3. The engineer or architect who submits the compliance equivalency does not necessarily have to be the person who implements it but precautions must be taken to ensure the work that is done matches what was approved. The fire department can state this concern as a condition for acceptance. |
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4.1.1.6. Compliance equivalencies |
Q1. Sentence 4.1.1.6.(1) requires that a proposal for a compliance equivalency be approved prior to the compliance date set out in Article 4.1.1.4. This Article requires that all installations made after August 21, 1998 must be in compliance with all of Part 4. Does this mean that compliance equivalencies cannot be approved for new installations? A1. Article 4.1.1.5. permits compliance equivalencies and makes no mention of dates. It is important to note that Sentence 4.1.1.6.(1) applies only to existing facilities (i.e. existing on November 21, 1997). This limitation was imposed to prevent possibly serious deficiencies from continuing indefinitely while owners "negotiated" compliance alternatives with the Chief Fire Official. A proposal for a compliance alternative for a new installation may be made at any time prior to installation provided that the lead times are adequate to permit review approval prior to start-up (work being done). |
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4.1.2. Flammable and Combustible Liquid Classifications |
Q1. Is it correct to classify aerosols as Class I flammable liquids for determining warehouse storage requirements? A1. Aerosols do not fall within the scope of Part 4. In the absence of municipal by-laws, it is recommended that Subsection 3.3.5. of the National Fire Code of Canada be used as a guideline. Q2. Is Butane a flammable liquid? A2. Yes. Butane will be classified as a flammable liquid under the Ontario Fire Code. Butane has a vapour pressure of 254.55 kPa (absolute) (36.9 psi (absolute)) at 37.8oC (100 oF) and a flash point of -60oC (-76oF). Any flammable liquid with a vapour pressure not exceeding 275.8 kPa (absolute) at 37.8oC and having a flash point less than 37.8oC is considered a flammable liquid under the Fire Code. With a boiling point of 0.5 oC , butane is classified as a Class IA liquid. Butane has a lower explosive limit of 1.9%; and an upper explosive limit of 8.5%, and its Autoignition temperature is 405oC (761oF) |
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4.1.2.3. Waste Oil |
Q1. Does Part 4 apply to waste oil? A1. Yes, in some cases. Article 4.1.2.3. states how to classify used lubricating oil drained from motor vehicles. However, Clause 4.1.1.2.(2)(d) states that Part 4 does not apply to "the storage, handling, transportation and use of flammable and combustible liquids to which the Gasoline Handling Act and the Energy Act apply." The Gasoline Handling Act applies to gasoline and associated products. Associated products include waste oil such as used engine oil, lubricating and gear oil. Section 11 of the Gasoline Handling Code is exclusively devoted to the handling of used oil. The Gasoline Handling Act is applied to locations that have waste oil and where gasoline or diesel fuel is dispensed at the location. TSSA confirms that used oil is classified as a Class III liquid under the Gasoline Handling Code. However, the Gasoline Handling Act does not apply to locations which have waste oil, such as mercantile locations or repair garages, where gasoline or diesel fuel is not dispensed at the location. (See also Q2 for 4.2.3.1.) Finally, where waste oil is used as a fuel in an appliance, the Energy Act and the Fuel Oil Code apply. (See also 4.3.11., Q1 and 4.2.3.1., Q2) |
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4.1.4.1. Electrical Installations |
Q1. Regarding Subsection 4.1.4., "Electrical Installations", who makes the assessment as to whether Division I or II electrical equipment is required? A1. The Fire Code references the Electrical Safety Code (ESC), which is enforced by the Electrical Safety Authority (ESA). The Electrical Inspector makes the final decision. The ESA should be consulted to designate classified areas per the ESC. The owner may be asked to provide credible proof that their installation conforms to the ESC. Such proof may be a verification certificate from a qualified electrician or from the ESA. Q2. What electrical classification applies to an area that only stores flammable liquids? A2. Where flammable liquids are stored and no dispensing operations are involved, the electrical classification is Class I, Division 2 (Zone 2) where the storage is predominantly flammable liquids. The extent of the classified electrical equipment may be limited to 3 or 4 feet above the floor level depending on the configuration of the room, provision for ventilation (both normal and emergency), spill control and clean up features, size of containers stored. Where the flammable liquids are stored as part of a general-purpose warehouse and the quantity of flammable liquids is a small part of the overall storage, the electrical classification may be ordinary. (See also 4.1.5.3., Q3) |
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4.1.5.1. Fire Extinguishers |
Q1. Article 4.1.5.1. requires extinguishers to be in accordance with Section 6.2. If they are not, should charges be laid under Article 4.1.5.1 or Section 6.2. A1. The specific Article, Sentence or Clause in Section 6.2 with which the owner is not in compliance should be referenced if laying charges. |
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4.1.5.3. Ignition Sources |
Q1. Does Article 4.1.5.3. prohibit the use of gas unit heaters in either:
If Article 4.1.5.3. prohibits gas unit heaters in the above locations, why does the Natural Gas Installation Code permit unit heaters in storage garages if they are 18 in. above the floor and repair garages if they are 4.5 ft. above the floor? A1. This was discussed with the Technical Standards and Safety Authority (TSSA) who enforce the Natural Gas Installation Code CAN/CGA-B149.1. According to TSSA, sections 3.16.2 and 3.16.3 permit regular unit heaters (i.e. not certified for hazardous locations) in storage and repair garages as long as the correct height above the floor is maintained. This envisions that only small amounts of flammable vapour may be released on an occasional basis. Almost all flammable vapours are heavier than air and there should be no build-up of dangerous concentrations above the specified heights. (i.e. the units are installed not less than 1400 mm (4.5 ft) above the floor.) The reason for the difference in height in a storage garage and a repair garage is that vapours could be released near floor level in a storage garage but could be released at workbench height in a repair garage. The above does not apply in a situation where vehicles are being refueled. In this situation there is a much greater probability that flammable vapours will be present and the unit heaters are required to be certified for installation in a hazardous location in accordance with 3.9.2 of the Natural Gas Installation Code. When the installation complies with the following it is considered to be "controlled in a manner that will not create a fire or explosion hazard" and meets the intent of Article 4.1.5.3. of the Fire Code.
Q2. Can Article 4.1.5.3. be used to require an anti-sparking floors in a flammable liquids room? A2. This Article could be used to require a spark resistant floor if the conditions warranted. However, it is not appropriate to use it to require a spark resistant floor in a flammable liquids room with a concrete floor. We have no documented evidence to support the theory that a spark from a concrete floor could ignite the vapours from flammable liquids. This situation would not meet the requirement that a fire or explosion hazard would be created and, thus, it would not be appropriate to use Article 4.1.5.3. There may be some (relatively rare) circumstances where Article 4.1.5.3. could be used to require a spark resistant floor e.g. a flammable liquids room with a steel floor. Even in these circumstances it would be necessary to show that
Clause 22(2)(e) of R.R.O. 1990 Reg. 851 for Industrial Establishments made under the Occupational Health and Safety Act has a requirement for a "spark resistant floor." A MOL inspector should be contacted to determine if they will be enforcing this requirement in your specific circumstances. Q3. Does Article 4.1.5.3. only permit EE rated fork lift trucks? If not, what general guidelines should be followed in determining when an "EE" rated forklift is required in an occupancy? A3. No. Article 3.4.1.1. of the Fire Code regulates the designation, use and maintenance of industrial trucks by reference to NFPA 505. NFPA 505 permits judgement to be exercised in certain circumstances. The following examples provide guidance in exercising such judgement.
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4.1.5.9. Basement Storage |
Q1. How much gasoline can a homeowner store in the basement of a home? A1. Not more than 10 L (4.2.4.5.). Although Article 4.1.5.9. specifically addresses basement storage and limits basement storage of a Class I liquid to 5 L when stored in a "Safety Container" conforming to ULC/ORD-C30, this Article exempts dwelling units from these requirements by referring to Article 4.2.4.5. (See also 4.2.4. for other home storage requirements) However, homeowners should be strongly discouraged from storing any flammable/combustible liquids below grade due to the poor ventilation usually afforded in these spaces and the proximity of ignition sources (e.g. pilot lights). Metal sheds that are detached from the home provide a suitable alternative for storage of small quantities of gasoline in approved containers. |
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4.1.6. Spill Control and Drainage Systems |
Q1. Are there guidelines or requirements for how staff is trained in spill control procedures? A1. No. The content and extent of the training will vary depending on the type and quantity of flammable or combustible liquid involvedd. Appendix A of the "Part 4 Commentary" describes a model spill control procedure. Q2. Are the requirements of Articles 4.1.6.1. to 4.1.6.3. for spill control and drainage systems applicable to all occupancy classifications regardless of the volume of liquids stored on site? A2. Yes, these requirements apply to all occupancy classifications. Although the wording does not specify a volume threshold over which the requirements take effect, the requirements are intended to apply to situations involving significant quantities of flammable and combustible liquids. However, as discussed in the "Part 4 Commentary" (revised in 2000), the spill control and drainage requirements are intended to prevent flammable and combustible liquid spills from reaching waterways, potable water supplies, fire department access routes, neighboring properties, etc. As such, the requirements refer to flammable and combustible liquid volumes that would pose such fire/environmental threats. Q3. What guidelines are available to assist the fire service in reviewing plans submitted by owners in complying with Subsection 4.1.6. of the Fire Code? A3. The Commentary on Part 4 (revised in 2000) now includes guidance on compliance with Subsection 4.1.6. |
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4.1.6.1. Spill Control |
Q1. Does Part 4 apply to fuel oil tanks? Do they need to be diked? A1. No. Part 4 does not apply to fuel oil storage tanks regulated under the Gasoline Handing Act or the Energy Act. Yes, the tanks need to be diked. The diking requirements in the Fuel Oil Regulation (made under the Energy Act) are comparable to those in the Fire Code. Q2. Clauses 4.1.6.1.(1)(a) and (b) specify requirements for containment and drainage of spills. Are these Clauses intended to apply to all occupancies, such as retail establishments, etc., which may have a supply of liquids on display in a public area? Also, is there a minimum amount of liquid that can be contained with absorbent material or socks without having to meet the specific requirements of Clauses 4.1.6.1.(1)(a) and (b)? A2. Yes, Article 4.1.6.1 is intended to apply to all occupancies. In order to assist Code users, guidance on compliance with Subsection 4.1.6. is now included in the Part 4 Commentary (revised 2000). When the total quantity stored is less than 5000 L, any credible spill including potential release from fire involvement could be handled with judicious use of absorbent materials, portable dykes and manhole covers. |
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4.1.6.2. Drainage Systems |
Q1. A drainage system incorporates a sloping floor in the storage area to a catch basin connected by piping to a dry sump. The outflow is arranged such that the water will flow out of the sump and flow into a impounding area. Will such a system meet the Fire Code? If so, is the dry sump required to comply with Section 4.3? A1. Yes. Such a system will meet the intent of the Fire Code, provided the drainage system is designed to handle the maximum design discharge of the sprinkler and suppression combined. The dry sump need not conform to Section 4.3 of the Fire Code provided the water entering will only be permitted to discharge from outlets specifically designed for it. The walls of the dry sump must not be permeable to the flammable liquid(s) under consideration. In addition, a fire safety plan must be developed in consultation with the fire department to address specific conditions at the site. Such conditions may include, but are not limited to, the use of portable booms, manhole covers for the sewers, provisions for liquid pump out, periodic checks of the drainage system and training of employees. Spill control in accordance with Article 4.1.6.4. must also be developed. |
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4.1.8.1 Containers and Storage Tanks |
Q1. Can bonding of containers be waived when dispensing into small containers? A1. Bonding can be waived for non-conducting containers provided measures are taken to ensure static charge development is minimized. Clause 4.1.8.1.(1)(b) permits measures be taken to minimize static electric charge to develop for non-conducting containers. A Sslow filling rate and the small quantity being filled is will likely to achieve meet this objective. However, for metal containers, Clause 4.1.8.1.(1)(a) requires that both containers must either be bonded or they both rest on a metal conducting plate. The manner in which the small container is filled also has a bearing on the potential for static discharge should it develop on the container during the dispensing operation. The owner has the option of conducting a compliance equivalency study under Article 4.1.1.5. to address any non-compliance issues. |
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4.2.1.1. Pharmaceuticals |
Q1. How is "pharmaceutical" product defined? Is it regulated by the Food and Drug Act? A1. The Fire Code does not define "pharmaceutical" product, therefore the dictionary meaning of the word may be used. The products that are regulated by the Food and Drug Act can be considered pharmaceutical products. However, other products that are not so regulated but commonly used as pharmaceutical products, may be considered pharmaceuticals for the purpose of Clause 4.2.1.1.(2)(d). The intent of this exemption is to acknowledge the reduced hazards presented by the mostly water-soluble or low hazard medicinal products packaged in small containers. This exemption is not intended to apply to large quantities of medicinal products or raw materials stored in drums or 20 L pails. The fire hazards presented by large quantities of such products must be appropriately addressed through applicable provisions of Section 4.2. |
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4.2.1.1. Small Appliances |
Q1. Are snow-blowers, lawnmowers or any other maintenance equipment normally powered and filled with gasoline, limited or prohibited in buildings through the requirements in Sections 2 or 4, Subsections 9.5, 9.6 and/or 9.8 in the Fire Code? A1. No. The storage of fuel contained in such small equipment inside a building is regulated by Clause 4.2.1.1.(2)(b), which states "Section 4.2 does not apply to liquids in the fuel tank of motors or engines". However, there are a number of scenarios where such storage would present a fire safety concern. They include:
Refueling operations and leaking containers release vapour into a confined space. These hazards can be addressed through appropriate ventilation in accordance with Subsection 4.1.7. Correcting an improperly fitting cap can be addressed through the application of Sentence 4.1.8.1.(2). Storage in close proximity to incompatible chemicals can be addressed through the issuance of an Inspection Order under the FPPA. (See also 4.2.4. Q8) Q2. Does the fuel in an engine of a piece of equipment need to be considered when determining the maximum quantities permitted? A2. The fuel contained in an integral tank associated with an engine is not included when determining the maximum quantities permitted by Part 4. Q3. Can plastic ULC or CSA listed jerry cans be stored inside a building? A3. Yes, provided the quantity limitations are met and container openings are tightly closed so that vapor is not released (complying with the definition of a closed container) during storage. This is consistent with the requirements of the Gasoline Handling Code. |
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4.2.2.1. Storage location |
Q1. Sentence 4.2.2.1.(1) specifies that flammable and combustible liquids shall not be stored adjacent to exits or principal routes that provide access to exits. Is there a minimum distance that the liquids shall be stored away from these areas? (i.e. rack storage with access aisles- usually the aisle itself is, or may be, an access to exit). Also, does this requirement pertain only to liquids stored outside of an approved cabinet? A1. The intent of Sentence 4.2.2.1.(1) is to ensure that a fire involving storage located in close proximity to exits and access to exits will not hinder safe evacuation of the occupants. The second objective is to ensure that the location of the storage will not obstruct the exits or their use. Therefore each situation must be evaluated on its own merit. Generally, dispensing operations should be conducted at least 10 feet from an exit. Other storage should be so located that the containers are not likely to be damaged by fork lift trucks or other machinery that may move through the exit and access to exit. Storage should be such that the egress doors can be operated freely. This Article applies to all storage whether in a cabinet or not. |
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4.2.2.3 Separation of Dangerous Goods |
Q1. Sentence 4.2.2.3.(1) references the NFC for the separation of flammable and combustible liquids from other dangerous goods. Table 3.2.7.6. of the NFC states that oxidisers are not allowed in the same fire compartment as flammable liquids. Is it the intent that a large retail hardware type store that sells pool chemicals as well as some flammable liquids cannot have these chemicals and liquids in the same retail area or warehouse? A1. The strict interpretation of Sentence 4.2.2.3.(1) would indicate that the two products cannot be stored in one fire compartment. However, it was not the intent to prohibit the storage of flammable liquids and pool chemicals in the same fire compartment of a retail occupancy. It was the intent that pool chemicals and flammable or combustible liquids not be stored in close proximity to each other such that a spill of either product could contaminate the other and create a significant fire hazard. Further precautions shall be taken to ensure that should a spill occur, such spills would not contaminate the other product. |
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4.2.3.1. Containers |
Q1. The container commonly used in service stations and dealerships when changing the engine oil in automobiles is a drum approximately 60 L in size (although some are larger) with a funnel or drip pan on the top into which the oil is drained. It is not built in conformance with any of the standards listed in Article 4.2.3.1. Is such a container acceptable? A1. Part 4 of the Fire Code does not specifically address this type of container or this type of operation. In practical terms we do not consider this type of operation to present a significant fire risk if some very simple precautions are observed. This type of operation can be most appropriately regulated under Subsection 4.2.8., Incidental Use, in particular Article 4.2.8.3. Given the small quantity involved, a special drainage system does not need not to be provided, however, there must be sufficient absorbent materials readily available to contain and clean up a spill. Normal shop ventilation is considered adequate. Inherent in this concept is the requirement that the containers not be significantly larger than necessary to contain the oil from one days operation and the containers must be emptied into a proper bulk tank at the end of every day. (See also Q1 for 4.1.2.3.) Q2. Is it safe to assume that pre-packaged containers that are typically found in wholesale or retail establishments meet the TDG (Canada) regulations for approved containers since they have already been transported at some previous point in time? If not, should there be some type of label or marking on approved containers, regardless of size, to indicate that they do meet the specified regulations? A2. Pre-packaged containers that are typically found in wholesale or retail establishments would have been transported from the manufacturer and, therefore, should be in compliance with TDG Regulations. OFM has developed a draft guideline on this subject, which is available on request. |
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4.2.4. Residential Occupancies |
Q1. Can you stop a person from bringing flammable liquids into a high rise apartment building? A1. No. The Fire Code limits the quantity that can be stored within a dwelling unit, but does not prohibit storage or movement of the liquids into the building. Article 4.2.4.4. prohibits the storage of flammable or combustible liquids on exterior balconies. Q2. Does the Gasoline Handling Act restrict storage of gasoline to less than 10 L in homes? A2. The Gasoline Handling Act does not regulate the storage of gasoline in residences. It regulates the containers that can be filled at the service station. According to TSSA, if called into a home, their inspector would look for listed containers, but NOT the quantity of storage. Q3. Does the Part 4 quantity restriction of 10 L of Class I liquids include or exclude gasoline storage? A3. Because the Gasoline Handling Act does not regulate residential occupancies, the Fire Code applies. The 10 L limit for Class liquids includes gasoline. Q4. Article 4.2.4.6. stipulates the maximum quantities that can be stored in a "garage or shed attached to a dwelling unit." Does this mean that the garage must be attached to a dwelling unit or only the shed? A4. The phrase "attached to a dwelling unit" applies to both the garage and the shed. Q5. What quantity of flammable or combustible liquids is permitted to be stored in a garage or shed which is not attached to a dwelling unit? A5. The Fire Code has no specific requirements for the quantity of flammable or combustible liquids stored in a garage or shed which is not attached to a dwelling unit. However, Section 4.2, Subsections 4.1.6., 4.1.7. and 4.1.8. and Article 4.1.4.1. can all be applied to this situation. The Part 4 Commentary (revised 2000) provides some recommended guidelines. Q6. I have obtained a small electrical generator for my residence. What quantity of gasoline am I permitted to store and what precautions must I take? A6. Gasoline is a Class 1 flammable liquid. If it is being stored in the actual residence or dwelling unit, then Article 4.2.4.5. restricts the quantity that can be stored to not more than 10 L. If it is being stored in a garage or shed attached to a dwelling unit, then Article 4.2.4.6. restricts the quantity that can be stored to not more than 30 L. See the Part 4 Commentary (revised 2000) for recommended guidelines. Q7. Are the requirements of the Fire Code consistent with requirements set out in the Gasoline Handling Act and regulations? A7. Yes. The Gasoline Handling Code, Subsection 8 (13) states that "No Class 1 product shall be stored, dispensed or transferred within a building at a facility unless the building meets the requirements of the Ontario Fire Code." Although the term "facility" is not a defined term in their legislation, it is interpreted to include residential buildings, including homes. This section of their legislation is currently under review to ensure clarity and consistency with Part 4. Q8. Can Article 4.2.4.4. be used to prohibit the storage of an outboard motor on a balcony? A8. No. Clause 4.2.1.1.(2)(b) states that Section 4.2 does not apply to the "liquids in the fuel tanks of motors or engines." Thus, the fuel in the tank of an outboard engine is not regulated by Subsection 4.2 and there is no prohibition on storing it on a balcony. This would apply if the fuel tank was integral to the outboard motor or a separate container attached to the motor (when in use) by a flexible fuel line. |
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4.2.4.2. Maximum Quantities |
Q1. Is it acceptable to store 10 L of Class I liquid, 100 L of Class II liquid and 400 L of a Class IIIA liquid in an assembly occupancy? A1. According to Article 4.2.4.2. the maximum total permitted quantity is calculated as follows:
 This total exceeds 1. Thus, the quantities of the liquids are too large and would have to be reduced so that the total does not exceed 1. For example, if the quantities were reduced to 10 L of Class I liquid, 40 L of Class II liquid, and 250 L of Class IIIA liquid, the calculation now becomes:
 This total is acceptable. |
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4.2.5. Mercantile Occupancies |
Q1. Do "Big Box" stores need to comply with Subsection 4.2.5.? A1. Yes. When dealing with Big Box type stores where the warehouse and retail areas are in the same fire compartment, the entire building is classified as a mercantile occupancy. The maximum quantities of flammable liquids stored and other associated provisions in Subsection 4.2.5. apply. In addition the general provisions of Section 4.1, Subsections 4.2.1., 4.2.2., 4.2.3., 4.2.9., 4.2.10. and 4.2.11 apply as appropriate. For the storage of other products, appropriate provisions of Part 3 of the Fire Code apply. Where such stores have a back area storing significant quantities of flammable or combustible liquid, Subsection 4.2.7. applies to the storage area. An NFC task group is currently undertaking a review of Big Box stores to develop appropriate provisions to address fire safety and operational issues. Until their work is completed and the Fire Code provisions amended, the current provisions of the Fire Code apply. The owner has the option of conducting a compliance equivalency study under Article 4.1.1.5 to address any non-compliance issues. Q2. In a retail occupancy, is liquid that is displayed on a shelf in a public area also defined as "stored", or is the term "stored" intended to refer to the warehouse area of a retail establishment? A2. Subsection 4.2.5. refers to storage in the retail area accessible to the public. If the mercantile occupancy has a warehouse area, storage in that area would have to meet the provisions of Subsection 4.2.7 or 4.2.9. |
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4.2.5.2. Storage in Mercantile Occupancies |
Q1. Sentence 4.2.5.2.(2) states that containers cannot be stacked higher than 1.5 m on floors, or 1 m high on individual fixed shelves. Does this mean containers cannot be stacked more than 1 m high on each shelf if there are several shelves or is this the total height? A1. The 1m height restriction applies to each shelf and is there to address storage stability. |
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4.2.7.3. Industrial Occupancy Fire Compartments |
Q1. Does a "fire compartment" always have to be separated from the remainder of the building area by a fire-rated separation? A1. Yes. In an industrial occupancy under Subsection 4.2.7., a fire compartment can be an enclosed room separated from the remainder of the building by a 2 hr. fire-rated separation or it can encompass the entire area of a plant. A single-tenanted building may be treated as a single fire compartment. Q2. What constitutes the "remainder of the building"? If there is a small office related to the handling/processing of the flammable liquids does this need to be separated? If not, where do we draw the line? A2. The "remainder of the building" refers to an operation that is different from what is under consideration. Therefore, a small office directly related to the handling/processing of the flammable liquids can be considered to be part of that operation and need not be separated. However, an office associated with the entire plant would not be considered part of the flammable liquid processing and handling operation and would need to be separated. |
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4.2.7.4. Dispensing in a Paint Spray Booth |
Q1. Where a small auto body shop uses cabinets that conform to Subsection 4.2.10. as permitted by Article 4.2.7.2., (i.e. they do not have a flammable/combustible liquids storage room) is it permissible to dispense and mix their Class I paints in their paint spray booth? A1. Most of the requirements for a dispensing room could be provided in a paint spray booth except for explosion venting. Few if any, spray booths are likely to have acceptable explosion venting as required by Article 4.2.9.6. However, if it is feasible to store the flammable liquids in a cabinet then it is likely that the quantity of flammable liquids involved is low. The primary purpose of an auto body shop is to repair vehicles. The handling of flammable liquids is just one small part of that operation and can be considered "incidental use" which is regulated under Subsection 4.2.8. Article 4.2.8.3. permits dispensing in areas which do not conform to Subsection 4.2.9. provided the requirements of Article 4.2.8.3. are met. It is quite feasible to meet these requirements in a paint spray booth. In a larger operation where the quantity of flammable liquid is high, a proper storage and dispensing room which complies with Subsection 4.2.9. should be constructed. |
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4.2.7.7. Protection for Class IIIB liquids |
Q1. Will protection requirements for rack storage of Class IIIB liquids change to more stringent NFPA 30-1996 requirements (the standard presently referenced in the Fire Code is NFPA 30-1993) by the time Article 4.2.7.7. becomes effective (August 21, 2000)? A1. The Fire Code is silent on protection requirements that are specific to Class IIIB liquids. It is not possible at this time to indicate specific requirements that may be introduced into the Fire Code that would apply to Class IIIB liquids or to provide a timetable when such requirements would be enacted. |
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4.2.8. Incidental Use
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Q1. Can storage and dispensing of flammable liquids at an industrial facility whose principal function is to dip metal parts into a nonflammable chemical bath be treated as incidental use? A1. The Fire Code deals with flammable and combustible liquids in industrial occupancies in two ways. The first deals solely with buildings whose primary function and design is for storage and dispensing of flammable and combustible liquids. Article 4.2.7.5. of the Fire Code pertains to these facilities. The second way treats flammable and combustible liquids as "incidental use", as their use is deemed secondary to the principal function of the building. "Incidental use" includes flammable and combustible liquids located within production areas or where mixed with general storage in warehouse areas. The vast majority of situations dealing with flammable and combustible liquids in industrial occupancies are deemed "incidental use". Subsection 4.2.8. of the Fire Code deals with "incidental use". As the facility in question is clearly not being used primarily to store or dispense flammable and combustible liquids, the storage, dispensing and use of these liquids in this facility is deemed as "incidental use". As such, Sentence 4.2.8.2. of the Fire Code allows the greater of 600 L (with a limit of 100 L of Class 1A) or one days use of flammable or combustible liquids to be located in the plant area in closed containers. Q2. What is the occupancy classification for a small autobody shop? A2. A typical autobody shop that performs collision repairs is usually classified as a Group F, Division 2 occupancy. Where the paint spraying operations form the bulk of the operation, the occupancy classification may become Group F, Division 1. However, most small autobody shops will be F2 with an ancillary F1 use. For the purpose of Part 4, autobody shops would be industrial occupancies (Subsection 4.2.8.). |
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4.2.8.2. Maximum Quantities |
Q1. Are the maximum quantities permitted in Article 4.2.8.2. dependent upon whether the liquids are dispensed or not? A1. This Article does not apply to dispensing operations. The intent of Sentence (2) is to permit more than 600 L to be located outside of storage rooms when required for normal plant activity but not more than the amount for one day of normal operation. However, this is an exception only for the quantities specified in the original requirement in Sentence 4.2.8.1. (1). The flammable liquid must still be stored in closed containers. When dispensing occurs the facility must conform to Article 4.2.8.3., which has five requirements that must be met to permit dispensing outside of a room designed for this purpose. Q2. Are the quantities specified by Article 4.2.8.2. also appropriate for dispensing operations of flammable liquids in the plant area? A2. The same quantities would also apply to containers of flammable liquids used for dispensing operations if protected as per Sentence 4.2.8.3.(1). Q3. Are the quantities of "incidental use" flammable and combustible liquids located outside designated storage areas, as stated in Sentence 4.2.8.2.(1), the maximum allowed in the building? A3. No. Sentence 4.2.8.2. (1) specifies quantities of flammable liquids storage per fire compartment, if not kept in flammable liquids storage rooms or storage cabinets. However, two "fire compartments" may be created with a required fire-rated separation between. The required rating of the fire separation should be based on the occupancy. In industrial occupancy the rating would be 2 hr. This allows the doubling of the overall quantities of flammable liquids specified in Sentence 4.2.8.2.(1), as long as the specified maximums are not exceeded in each fire compartment. |
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4.2.8.4. General storage area |
Q1. What is the maximum amount of Class IA liquid permitted to be stored in an area referenced in Sentences 4.2.8.4.(4) and (5)? A1. Article 4.2.8.4. gives exemptions to the maximum quantities permitted in Sentence 4.2.8.2.(1) under various circumstances. Because Article 4.2.8.4. does not contain any exemption for Class 1A flammable liquids, the maximum amount of Class IA liquid permitted to be stored in an area referenced in Sentences 4.2.8.4.(4) and (5) would be 100 L as permitted in Clause 4.2.8.2.(1)(a). |
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4.2.9. Storage and Dispensing Rooms |
Q1. Can a foam system be used to protect the mixing room that supplies paint to a paint spray booth? A1. Yes. The mixing room is regulated by Subsection 4.2.9. for areas where dispensing takes place or by Subsection 4.8.3. for process areas. Subsection 4.2.9. specifies the maximum storage densities and quantities of flammable and combustible liquids permitted to be stored in the room under Table 4.2.9.A. It also permits these densities and quantities to be doubled provided the room is protected by an automatic suppression system in conformance with Article 4.2.7.7. Subsection 4.8.3. requires that an evaluation of the fire and explosion risk be undertaken and appropriate protection provided. Article 4.2.7.7. in turn references NFPA 30, "Flammable and Combustible Liquids Code", as well as the protection requirements in Section 6.8 of the Fire Code. Sentence 6.8.1.1.(1) permits the installation of special extinguishing systems that are in conformance with various NFPA standards. The standards referenced are NFPA 11, NFPA 11A, NFPA 12, NFPA 12A, NFPA 12B, NFPA 15, NFPA 16, NFPA 17, NFPA 17A and NFPA 18. Regardless of what any specific standard requires, Article 4.1.1.5. of the Fire Code permits the Chief Fire Official to accept a compliance equivalency provided that it can be justified by actual test information. |
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4.2.9.6. Explosion venting |
Q1. Sentence 4.2.9.6.(2) refers to the "Regulations for Industrial Occupancies". Who is the enforcement agency for these regulations? What type of Industry is regulated by this legislation? A1. The Ministry of Labour under the Occupational Health and Safety Act enforces the "Regulation for Industrial Establishments". Their legislation contains a definition of Industrial Occupancies. Please refer to the Occupational Health and Safety Act and its regulations to confirm the application of its legislation referred to in Sentence 4.2.9.6.(2). |
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4.2.10. Storage Cabinets |
Q1. Could you provide advice on safe handling of flammable and combustible liquids associated with storage cabinets? A1. The Part 4 Commentary (revised 2000) provides guidance on this issue. Q2. Where can a safety cabinet be purchased? A2. Most safety supply companies handle them. |
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4.2.10.3. Fire Compartments for Safety Cabinets |
Q1. What is the required fire resistance rating for the fire compartment referred to in Article 4.2.10.3.? (In the Fire Code, by definition, a fire compartment must have a fire resistance rating.) A1. The intention was that this fire separation be un-rated. The assigned fire-resistance rating, therefore, can be taken as zero. |
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4.2.10.6. Cabinet venting |
Q1. Does a cabinet used for the storage of laboratory chemicals need to be vented? A1. Part 4 of the Fire Code does not specifically require a cabinet to be vented, as venting has not been demonstrated to be necessary for fire protection purposes. However, when cabinets are vented for other reasons such as health and safety, the openings shall be protected to ensure that the temperature rise inside the cabinet will not exceed the value (139oC) specified in the ULC standard under external fire exposure. The Fire Code does not place any restrictions on the use of a fan to ventilate the cabinet, nor which vent opening may be used for such ventilation. However, if a fan is used, it must meet the electrical classification based on the environment in which it is placed as per Article 4.1.4.1. Cabinets permitted by the Fire Code for storing flammable and combustible liquids are tested with the ventilation openings closed to meet the ULC- C1275. Therefore, these openings must be protected with material that will maintain its integrity under fire exposure in order to meet the performance level required by the Fire Code under Article 4.2.10.5. For further guidance on this subject, please refer to Appendix A-4-3.4. of NFPA-30 (1996 edition) and Flammable and Combustible Liquids Handbook by NFPA. Q2. Is Schedule 40 Black Iron pipe acceptable for venting Cabinets used for the storage of flammable or combustible liquids? A2. Yes. The wall thickness (.154 to .22 inches) of the pipe is adequate to provide a level of protection equivalent to the cabinet construction that will maintain the integrity of the openings under fire conditions. Q3. Is it acceptable to vent a flammable liquids cabinet into the duct system for a fume hood? A3. Yes. Venting a flammable liquids cabinet into the duct system for a fume hood is not prohibited by the Fire Code. In our opinion such a system would be acceptable provided the following conditions are met:
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4.3 Storage Tanks |
Q1. Are the requirements for storage tanks also applicable to process tanks or are the two types of tanks considered to be unrelated? A1. Where a tank is used for the storage of a product, the appropriate provisions of Section 4.3 would apply. However, if a tank or vessel is used for processing, then that equipment may be subjected to higher temperatures or pressures than storage tanks and, therefore, must be designed, installed and operated in accordance with Section 4.8. |
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4.3.1.1. Storage Tanks for Waste Oil |
Q1. How are waste oil storage tanks dealt with in facilities whose primary function is "quick change" lubrication of automotive vehicles (i.e. Rapid Lube)? A1. These facilities have automotive service areas principally for oil and filter changes, lubrication and some minor repairs (such as tire changes) and servicing. The occupancy is considered to be Group F, Division 2. Service bays are usually provided with lubricating oil pits to allow access below the vehicles being serviced. Handling of combustible liquids is limited to draining waste oil (Class IIIA combustible liquid) from the bottom of a vehicles engine, transmission or differential to a waste oil tank. The vehicle is refilled with new oil (Class IIIB) pumped through a manually operated oil-dispensing nozzle or by individual litre cans. Small open vehicle service pits can generally be considered part of the first floor. However, large covered below-grade service areas, such as ones that could be used to service transport trucks would be of sufficient size to be considered a basement under the Fire Code definition. Waste oil storage tanks under these conditions would have to be located in a fire compartment conforming to Subsections 4.3.12. and 4.3.13. of the Fire Code and provided with automatic fire protection in conformance with Article 4.2.7.7., due to the potential for flammable or combustible vapours to accumulate in the pits. It is not appropriate to apply Subsection 4.2.8. Incidental use, because the handling of this combustible liquid is the primary purpose of this type of facility. It may also be appropriate for the Chief Fire Official to accept compliance alternatives per Article 4.1.1.5. of the Fire Code. Compliance alternatives may allow a means to avoid placing below-grade waste oil storage tanks in fire separated compartments with automatic fire suppression. Conditions under which compliance alternatives could be accepted are:
Where Class IIIA oil storage tanks are located on the first floor, Sentence 4.3.12.4.(2) of the Fire Code permits them to be sized up to 50,000 L without being in a fire compartment and without automatic fire protection. It is recommended, however, that the storage tank be vented in conformance with Subsection 4.3.5. Article 4.3.13.4. of the Fire Code requires all similar vehicle oil change facilities to be provided with hose stations conforming to Article 6.2.6.6. of the Fire Code and fire extinguishers. |
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4.3.2.4 Fire Department Access |
Q1. Sentence 4.3.2.4.(1), requires storage tanks to be "accessible for fire fighting purposes". How is this determined? A1. This is a judgement call on the part of the fire department. Assessment should take into account factors such as the size of the tank, the characteristics of the flammable or combustible liquid in the tank, the equipment and personnel needed to fight the fire and the method of attack. Q2. Sentence 4.3.2.4.(2) requires that access routes be provided so that fire department vehicles can approach to within 60 m of any storage tank. Where there are a group of tanks, does this mean that the vehicles only have to be able to approach within 60 m of any one of the tanks or all of the tanks? A2. The vehicles must be able to approach within 60 m of every tank. |
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4.3.7.2.(1) Secondary Containment |
Q1. What material and construction is acceptable for secondary containment walls.? A1. The materials and construction methods that are acceptable for secondary containment walls are stated in Clause 4.3.7.2(1)(b) of the Fire Code. The walls must
The acceptability of a particular non-combustible material for the construction of a secondary containment will depend on the type of liquid contained in the storage tank, and certain physical properties of the secondary containment material. Some of the materials commonly used by industry for the construction of secondary containment for storage tanks containing flammable and combustible liquids are:
Where the wall of a secondary containment is constructed of concrete block, the interior surface must be lined or coated using a sealant to achieve the desired permeability stipulated in Clause 4.3.7.2 (1) (b). There are a number of products available as coating material for concrete. The coating applied to concrete block must have the following performance features:
The acceptability of a particular coating or lining material as a sealant for concrete block walls will depend on the type of liquid in the tank, and certain physical properties of both the liner (or coating), and the concrete block/mortar assembly. The manufacturer of such coatings should be able to assist in selecting the appropriate material for the application in question. It should also be noted that in most applications, where concrete block is used, it will form the vertical wall of the secondary containment system. Any breach in permeability of the wall is easily detectable and appropriate corrective action taken prior to product escape. |
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4.3.12.2. Stationary Combustion Engines |
Q1. Most stationary engines inside buildings are diesel driven. Diesel fuel is Class II. This Article only deals with Class I liquids. How do you treat diesel engines? A1. Part 4 has no specific requirements for diesel engines inside buildings. . Clause 4.1.1.2.(2)(c) states that the Fire Code does not apply to appliances and their ancillary equipment (burning hydrocarbons) to which the Energy Act applies. The Fuel Oil Code is a regulation under the Energy Act. It references CSA B139 "Installation Code for Oil Burning Equipment " which states specifically in the Scope that it applies to "a fuel supply, piping, and tanks for diesel-engine driven emergency generators" Therefore, a diesel-engine driven emergency generator is not regulated by Part 4 of the Fire Code. |
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4.4.7.6. Piping in Service Tunnels |
Q1. Article 4.4.7.6. prohibits piping for flammable or combustible liquids in any tunnel used for pedestrian traffic. Does this include service personnel? A1. No. Service personnel must use all tunnels at some time or another. To prohibit piping in tunnels used by service personnel would, in effect, be a prohibition on piping in all tunnels. This Article was meant to prohibit piping for flammable or combustible liquids in tunnels routinely used by people to get access from one part of the plant or property to another to prevent them from being exposed to a hazard they may not even be aware exists. Service personnel who are in a tunnel to work on the piping should be aware of the associated hazard. Q2. What constitutes a tunnel? Must it be underground? A2. Although many people think of a service tunnel as being underground this is not always the case. One of the definitions of a tunnel in Webster's Ninth New College Dictionary is "a covered passageway; specif: a horizontal passageway through or under an obstruction". The hazard that this Article is addressing is the collection of flammable or combustible vapours in the tunnel if there is a leak in the piping. The collection of vapours is almost a certainty if the tunnel is below grade but it can also happen in above grade tunnels that are not well ventilated. Therefore, for the purposes of this Article, a service tunnel could be any enclosed passageway used primarily for routing pipes, ducts or electrical conduit from one building or part of a building to another where there is potential for vapours to accumulate if there is a leak in the piping. |
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4.4.7.8.(2) Piping under Combustible Flooring |
Q1. Sentence 4.4.7.8.(2) prohibits the installation of piping for flammable or combustible liquids under combustible flooring. Does this include mezzanine flooring? A1. This Sentence is intended to apply to flooring that is over a trench or crawl space. It is not intended to apply to combustible mezzanine flooring. Overhead piping may be located under a combustible mezzanine floor. |
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4.4.8.6. Isolation of Cast iron Meters |
Q1. Part 4 requires that all valves used in piping for flammable and combustible liquids conform to ULC-C842 "Valves for Flammable and Combustible Liquids". Why does Article 4.4.8.6. require that the valves used to isolate cast iron meters be steel rather than just any valve that meets the standard? A1. Cast iron is susceptible to damage by impact or shock. The Code provision is attempting to emphasize the importance of valves required to isolate the meter in the event of a failure. |
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4.8 Process Plants |
Q1. Are the requirements for storage tanks also applicable to process tanks or are the two types of tanks considered to be unrelated? A1. See the answer for Q1 in 4.3. |
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4.10.1.1. Withdrawal of Storage Tanks from Service |
Q1. If a gasoline tank sits idle for more than 2 years, can Section 4.10 be used to get the tank removed? How about a fuel tank? A1. No. According to the TSSA, the Gasoline Handling Act applies to an idle gas tank after 2 years (regardless of whether the site is in use or has been abandoned), so Part 4 of the Fire Code cannot be used. The Gasoline Handling Act requirements to withdraw tanks from service are similar to those in the Fire Code. Similarly, the Fuel Oil Regulation (Reg. 329), under the Energy Act regulates removal of fuel tanks. Q2. How do you deal with a gas tank installation that is no longer being inspected by Ministry of Labour? A2. This is not a Fire Code issue. Contact the TSSA and Ministry of Labour to determine authority. |
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4.10.2.1. Underground storage tank out of service |
Q1. Clause 4.10.2.1.(2)(b) states that a tank out of service for more than 180 days shall be refilled with a Class II or Class IIIA liquid, or with dry ice. Is it permissible to refill the tank with water? A1. Article 4.10.2.1 applies when an underground tank is temporarily out of service up to 2 years. Clause 4.10.2.1.(2)(b) applies when the tank is expected to be out of service between 180 days and 2 years. The intent of this Clause is to minimise the fire and explosion hazard by replacing any Class I liquids with a Class II or III liquid. Since water is less hazardous than a Class II or III liquid, it would be permissible to refill the tank with water. However, the owner may wish to consider in his/her decision disposal costs for contaminated water and internal corrosion of the tank, prior to re-introducing flammable liquid. |
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4.11. Tank Vehicles |
Q1. Does Article 4.11.2.4. apply to an unattended loaded tank vehicle parked on a property or on the side of a road? A1. Article 4.11.2.4. applies where a tank vehicle is parked on the side of a private road or parking lot located on a premises regulated by the Fire Code. The Fire Code would not apply when the tank vehicle is parked on a public road. The federal Transportation of Dangerous Goods (TDG) Regulations apply from the time a tank vehicle is being loaded until it is unloaded (either inside or outside a building, on public or private property). Clause 4.1.1.2.(2)(a) states "Except as specifically provided elsewhere in this Part, this Part does not apply to the transportation of flammable or combustible liquids to which the TDG Act and its regulations apply." However, by virtue of the specific overriding provision in Article 4.11.1.1., the requirements of Section 4.11., can be applied to a tank vehicle located on a property (building or premises) regulated by the Fire Code. Q2. Does the Fire Code apply to a tank vehicle when a requirement in Section 4.11. is in conflict with the TDG Act and its regulations? A2. No. Fire Code does not apply to a tank vehicle when a requirement in Section 4.11. of the Fire Code is in conflict with the TDG Act and its regulations. |
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4.12. Laboratories |
Q1. What is the definition of a laboratory? A1. The Fire Code does not have a legal definition of "laboratory". It is generally interpreted as being any space, room or building that is used for experiments or research and where chemicals are handled in small quantities on a non-production basis. Q2. Does Section 4.12. apply to quality control offices/labs in plants? A2. Each situation must be assessed on its own merits, to determine the actual laboratory use. One of the reasons a research laboratory may be considered hazardous is that, because of the nature of the work, a potential exists for unexpected reactions to take place. This element of the unknown or unexpected is one reason for requiring that special precautions be taken. On the other hand, in a quality control laboratory it is customary for the same experiments or tests to be conducted repeatedly. The anticipated results of the tests will usually be known within a narrow range. The probability of an unexpected event occurring is much less. If the hazard presented by the laboratory is no greater than the hazard presented by the process or warehouse operation with which it is associated then it could be treated as part of that operation rather than as a separate laboratory. Q3. Does Section 4.12. apply to laboratories associated with oil refineries or with bulk fuel locations? A3. Yes. The Gasoline Handling Act regulations do not apply to the laboratories at these facilities. Section 4.12 of the Fire Code can be applied to laboratories in both types of facilities.( Also see Q3 of 4.1.1.2.(2)). Q4. Article 4.12.2.1. requires that a laboratory be separated from the rest of the building by a fire separation having a fire-resistance rating of not less than 1 hr. Does this apply even if the laboratory is sprinklered? i.e. would hr plus sprinklers be acceptable? A4. Part 4 does not have any specific provisions for reducing the fire-resistance rating if a laboratory is sprinklered. However, this is something that could be accepted under Article 4.1.1.5. if the Chief Fire Official thought it was justified. Q5. Which Section of Part 4 should be used to address dispensing operations that are carried out in a laboratory? A5. A typical dispensing operation that occurs in a laboratory involves the filling of a small beaker from a four-litre glass bottle. In a laboratory, all dispensing of flammable and combustible liquids should be done in a fume hood. Section 4.12. sets out the design requirements for fume hoods as well as general laboratory room ventilation. If containers are made of metal, grounding and bonding should also be used in conformance to good engineering design. Article 4.12.4.1. requires that laboratory personnel be trained in the safe handling of flammable and combustible liquids. This training should cover the emergency plan and spill control (Article 4.12.5.1.). Where rooms are used to store quantities of flammable and combustible liquids in excess of those permitted to be stored in a laboratory, these rooms may be used for dispensing provided they conform to Subsection 4.2.9. Q6. Does Article 4.12.8.2. apply to laboratories in schools? A6. Yes. Any school laboratory in which flammable or combustible liquids are used or stored fall within the scope of Section 4.12 . This includes the preparation rooms where chemicals are stored and decanted or experiments are prepared, as well as the lab/classroom used for instruction. Article 4.12.8.2. applies to any new ventilation system being installed in a laboratory in a school. Note that some of the ventilation requirements in Subsection 4.12.8. are "grandfathered" and, specifically, that Sentence 4.12.8.1.(2) states existing ventilation systems need not conform with Article 4.12.8.2.
Q7. Should a classroom used for demonstrations involving flammable or combustible liquids be classified as a laboratory? A7. Yes. However, where an individual classroom is used for occasional demonstrations and total quantities of flammable and combustible liquids handled do not exceed 1L, it need not be classified as a laboratory under the Fire Code. Q8. Is a 20 minute rated door acceptable for a laboratory in a school? Does the door require a self-closing device? A8. In an existing fire separation for a laboratory regulated under Section 4.12, a 20 minute rated door is acceptable, since existing lath and plaster or gypsum board is acceptable to meet the 1 hour fire separation. Yes, a self-closing device is required to ensure the integrity of the fire separation. Q9. When conducting an inspection of a laboratory contained within another occupancy, does Part 4 in its entirety apply to the Lab, or only Subsection 4.12? (i.e. When a lab is located within an industrial occupancy does only 4.12. apply to the lab while Part 4 in general applies to the remainder of the Industrial Occupancy?) A9. Part 4 is uniquely organised such that Sections 4.1, 4.3, 4.4, 4.10, 4.11, Subsections 4.2.1, 4.2.2, 4.2.3, and 4.2.10 apply to all occupancies as applicable, except as modified by the specific occupancy sections. Therefore Section 4.1, Subsections 4.2.1, 4.2.2, 4.2.3, 4.2.10 and Section 4.12 would apply to the Laboratory laboratory located in a processing plant. |
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