Proposed Change 1998

The 2020 editions of the National Building Code of Canada (NBC) and National Fire Code of Canada (NFC) clarify, through an explanatory Note to the objectives, that in the definition of (sub-)objective OS1, Fire Safety, the term “person” refers to any individual in or adjacent to the building or facility, including emergency responders, including firefighters, when performing their duties. The explanatory Note also states that “certain technical requirements in the National Model Codes are intended to address the safety of emergency responders, including firefighters, when performing their duties.”

A code change request (CCR) was submitted by NRC in response to the federal mandate letter dated December 16, 2021 (https://www.pm.gc.ca/en/mandate-letters/2021/12/16/minister-innovation-science-and-industry-mandate-letter). The CCR provided an analysis on the intents and attributions (objectives and functional statements) of the existing Code requirements in the 2020 editions of the NBC and NFC to ascertain which requirements address the safety of emergency responders. The CCR analysis reveals that acceptable solutions with a documented intent to address the safety of emergency responders when performing their duties are only identifiable through the intent statements. There are 80 intent statements for requirements in the 2020 edition of the NBC, and 180 in the NFC, that refer to limiting the probability of harm to emergency responders.

The existing explanatory Note clarifies that “person” in sub-objective OS1 includes emergency responders, including firefighters, when performing their duties. The absence of an objective in the Codes for firefighter safety can lead to inconsistent Code development. When developing changes to the Code, the technical committees must consider the impact of the proposed changes relative to the attributed Code objectives. For example, proposed changes to a Sentence in the Code that has the OS1 sub-objective attributed to it would have an impact analysis that considers the impact of the proposed change on the safety of occupants, but consideration of the impact on firefighter safety has not been consistently included in these impact analyses even when the intent statements clearly show that firefighter safety is a consideration. By adding a specific objective for firefighter safety, future Code development would include impact analyses that consider the impact on all attributed objectives.

In addition, compliance with the Code is achieved by adhering to the acceptable solutions in Division B, or using alternative solutions that will achieve at least the minimum level of performance required by Division B in the areas defined by the objectives and functional statements attributed to the acceptable solution. An explanatory Note about Code compliance using an alternative solution highlights that, while intent statements clarify what undesirable results provisions are trying to prevent, the intent statements are not a legal component of the Code and are only advisory in nature. Correspondingly, intent statements are not included within the body of the Code, they are published separately as supplemental guidance.

The intent to address the safety of firefighters while performing their duties is not identifiable through the attribution of objectives and functional statements within the body of the Code because the term “person” used to describe the applicability of the OS1 Fire Safety sub-objective includes firefighters performing their duties and individuals (i.e., non-firefighters) and these two types of “persons” have different risk profiles. As a result, without reading the intent statements, a Code user would not understand the full breadth of the acceptable solution and the intended negative outcomes being mitigated. Specifically, not clearly identifying which provisions within the body of the Code address the safety of firefighters while performing their duties could result in that portion of the objective not being considered in the development or assessment of an alternative solution. Differing assessments of the attributions to be satisfied for alternative solutions could lead to different performance levels across jurisdictions or incomplete alternative solutions.

One example of a possible inconsistency in the consideration of firefighter safety could be through alternative solutions to NBC Sentence 3.4.4.1.(1), which requires a minimum fire-resistance rating for fire separations between exits and the rest of the building. The intent statements for Sentence (1) are as follows:

Intent 1:

To limit the probability that fire will spread into an exit, which could lead to delays in the evacuation or movement of persons to a safe place, which could lead to harm to persons.

Intent 2:

To limit the probability that fire will spread into an exit, which could lead to emergency responders being delayed in gaining access to floor areas, which could lead to delays or ineffectiveness in fire emergency response operations, which could lead to:

• delays in the evacuation or movement of persons to a safe place, which could lead to harm to persons including emergency responders, and
• the spread of fire to other parts of the building, which could lead to harm to persons.

The intent statements describe the need for a fire-resistance rating for the fire separation to allow enough time for occupants to evacuate the building, but the requirement for a fire-resistance rating also serves the purpose of allowing enough time for firefighters to safely perform their response operations. Alternative solutions for fire-resistance ratings for exits in some cases consider the time needed to safely perform firefighter operations, but in other cases alternative solutions only consider the evacuation of occupants. This inconsistency could be resolved by clarifying the objective of firefighter safety in the Codes. 

In late 1990s, when the National Model Codes were transitioning to the objective-based structure, the Canadian Commission on Building and Fire Codes (CCBFC), Standing Committee on Fire Safety and Occupancy (SC-FSO), and Task Group (TG) on Implementation  discussed potentially including firefighter safety as an objective or sub-objective.

An analysis was conducted of the requirements at that time, and the following was noted:

• “none of the requirements attributed to this objective [i.e., safety of emergency responders] is attributed uniquely to it,”
• “many of them are general fire safety provisions in Part 3 and Part 8 that … contribute to the safety of emergency responders as well as that of the general building occupants,” and
• “perhaps in many of these cases, ‘safety of emergency responders’ could have been treated as an ‘other benefit’ rather than as a root objective of these code provisions.”

When analyzing Part 9 provisions, it was also noted that “none of the requirements attributed to this objective [i.e., safety of emergency responders] is found in Part 9”, the rationale being that “in Part 9 buildings, firefighters should not count on the unit of fire origin to be a safe place for them to operate.”

The SC-FSO noted that “the reason it had never isolated [safety of emergency responders] as a lone objective was because of an earlier decision to always include property protection whenever [safety of emergency responders] was an objective. The role of emergency responders [would] be identified in either intent or additional benefit statements as appropriate.” The TG on Implementation recommended that the facilitation role of emergency responders be “captured in the intent statement; falling under a prime objective of safety and/or property protection as applicable” rather than using a separate objective. The CCBFC concurred with the TG's recommendation.

Since the introduction of the objective-based Codes in 2005, Code development has inconsistently attributed firefighter safety in the NBC and NFC, and this inconsistency is driving the need for a unique objective for firefighter safety. In addition to clarifying the objectives for firefighter safety, there is additional work needed to correct any existing inconsistencies in the Codes. While this proposed change intends to clarify the objective, it does not propose any changes to the objective attributions that would correct any inconsistencies. This technical work will be captured in a separate proposed change once more informed by ongoing research.

One example of a potential inconsistency in the consideration of firefighter safety is the difference between NBC Sentence 3.2.5.5.(1) and NFC Sentence 3.3.3.3.(1). NBC Sentence 3.2.5.5.(1), location of access routes in the NBC, uses the rationale that access routes must be placed in a specific location to reduce the risk of emergency responders being harmed due to excessive radiation exposure. NFC Sentence 3.3.3.3.(1), rubber tires, uses the same rationale as the previous example that access routes must be placed in a specific location, but in this example the objective is to limit damage to the building only without the OS objective. In this example, occupant and emergency responder safety is not a consideration in the intent statement. One could logically question why these two examples do not share the same objectives and intents given that the hazard (exposure to radiant heat) is the same.

The explanatory Note to the OS1 Fire Safety sub-objective, published in the NBC 2020 and the NFC 2020, explained that the NBC and NFC explicitly consider the safety of emergency responders, including firefighters, while performing their duties. This proposed change builds on that clarification and takes a step further by creating a new OS6 sub-objective. Separating firefighters performing their duties from "other persons" (including building occupants, other emergency responders, and firefighters not performing fire-related search and rescue, suppression or fire protection activities) through the creation of a new sub-objective would facilitate easy and clear identification of the requirements intended to address the safety of other emergency responders within the existing OS1 Safety sub-objective and the safety of firefighters within the proposed OS6 Firefighter Safety sub-objective. The attribution of the proposed OS6 Firefighter Safety sub-objective is intended to apply to search and rescue, and suppression activities, as well as other fire protection activities mentioned in the Codes to ensure firefighter safety is clearly and consistently addressed during Code development and by alternative solutions.

Future Code development would also benefit from the proposed OS6 Firefighter Safety sub-objective as future provisions would have separate objectives to clearly distinguish between the safety of persons and the safety of firefighters. Future proposed changes will need to be assessed by the relevant committee to determine if they are intended to encompass, in addition to OS1 occupant safety, firefighter safety in relation to the specific risks identified in the proposed OS6 sub-objective.

The work to address firefighter safety in the Codes is being undertaken as follows:

• Approval of the new OS6 sub-objective during the 2025 Code cycle: this work is being addressed by this proposed change.
• A research project underway to analyze the existing requirements, attributions and intent statements of the NBC and NFC in order to inform technical discussions to validate the attribution of the proposed OS6 sub-objective.

The addition of an OS6 Firefighter Safety sub-objective is not expected to entail any costs as it only clarifies what is already intended by the 2020 editions of the NBC and NFC. This proposed change has no impact on the existing acceptable solutions in Division B of the NBC and NFC. The proposed change does not introduce any new technical requirement related to firefighter safety in the Codes, nor does it attribute any existing requirement to the new OS6 sub-objective.

The benefit of separating OS6 Firefighter Safety from OS1 Fire Safety is that it would allow Code development efforts to more explicitly consider the attribution of firefighter safety in the development of acceptable solutions within the body of the Code.

Identifying the OS6 Firefighter Safety sub-objective would ensure consistent development and consideration of alternative solutions in the future by designers and authorities having jurisdiction by aligning the attributions with the intent statements.

This proposed change could be enforced by the infrastructure available to enforce the Codes without an increase in resources as this proposed change only reorganizes Code content. This proposed change does not introduce new technical content.

This proposed change to clarify firefighter safety in the NBC and NFC is intended to complement provincial and territorial Acts and regulations that are already in place to address the safety of firefighters.

Authorities having jurisdiction and designers will have a clear, common, basis for developing and reviewing proposed alternative solutions to satisfy fire safety requirements.

Firefighter organizations will be able to identify Code provisions intended to address firefighter safety while performing their duties allowing them to engage more effectively with the Code development system.

The separation of firefighter safety from other persons will help technical committees developing fire safety requirements explicitly consider which fire safety objective(s) should apply taking into account that different risk profiles may necessitate different solutions.