Proposed Change 1965

The term "storage tank" was introduced in Part 3 of Division B of the NBC 2010, when Subsection 3.3.6. was also introduced. At that time, the definition was justified because the term was used in many of the referenced standards related to fuel tanks. As a result, Article 3.1.1.3. of the NBC 2020 currently defines "storage tank" for the purposes of Part 3.

However, Part 3 of the NBC does not contain any prescriptive requirements that specifically mention storage tanks or any other references to this term. As such, it was suggested that Article 3.1.1.3. be removed. Keeping it could potentially lead Code users to misinterpret the requirements as being more stringent than intended.

This proposed change deletes the definition of "storage tank" for the purposes of Part 3 by removing Article 3.1.1.3., on the basis that there are no references made to this term in Part 3.

Defining a term for the purposes of Part 3 and then not referring to that term anywhere in the Part could cause confusion for Code users when they try to understand and apply the requirements related to tanks. Retaining the definition could potentially lead to the requirements being misinterpreted as being more stringent than otherwise intended (also resulting in increased costs).

Furthermore, as flagged by Alberta Municipal Affairs, removing Article 3.1.1.3. eliminates a technical variation between the NBC and the National Building Code - Alberta Edition, which does not include this definition.

This proposed change would clarify existing Code provisions and facilitate enforcement.

There is no increase in construction costs anticipated as there is no change to the intent or application of the Code provisions regarding tanks.

The clarification of current Code provisions facilitates consistent interpretation and enforcement by regulators.

There will be less confusion for or potential misinterpretation by regulators as they enforce the Code.

Builders, consumers, manufacturers, regulators and designers.