Proposed Change 2256

Article 6.3.1.3. of the National Building Code of Canada (NBC) currently requires storage garages to have a mechanical ventilation system designed to limit the concentration of carbon monoxide or nitrogen dioxide by using monitoring devices when a continuous supply of outdoor air is not provided at an acceptable rate. However, the NBC does not contain a provision requiring these monitoring devices to meet minimum performance requirements by conforming to a National Standard of Canada.

This proposed change introduces a requirement in Article 6.3.1.3. for acceptable monitoring devices for carbon monoxide or nitrogen dioxide in storage garages to comply with CAN/ULC 588:2024A, “Gas and Vapour Detectors and Sensors, Including Accessories.” Previous Canadian standards have applied to carbon monoxide alarms rather than carbon monoxide detectors.

CAN/ULC 588 requires toxic combustible gas and vapour detectors to be able to connect to a power source, signaling circuits and optional remote control circuits. Additional features, such as a heat detector, heat sensor, smoke detector, smoke sensor, or audible signaling appliance/device, are permitted to be incorporated into the toxic combustible gas and vapour detector assembly. However, these features must be evaluated in accordance with their respective applicable standards.

This proposed change requires monitoring devices used in storage garages to conform to CAN/ULC 588. This proposed change would create uniformity in the minimum performance requirements, which is critical for ensuring that such monitoring devices function reliably, especially in industrial and commercial applications like storage garages.

This proposed change enhances existing provisions in the NBC by requiring certain monitoring devices, which are used to control the ventilation of storage garages, to conform to CAN/ULC 588. This proposed change would improve the reliability, accuracy and system integration of these monitoring devices while protecting occupants from hazardous levels of exposure.

This proposed change should improve the safety and performance of monitoring devices, may improve the reliability of monitoring devices, and would better integrate monitoring devices conforming to CAN/ULC 588 into building systems while maintaining compliance with the NBC.

There are already combustible gas and vapour monitoring devices on the market that are tested in conformance with other standards, such as ANSI/UL 2075, “Gas and Vapor Detectors and Sensors.” Assuming there are no differences in the product technology or the listing process, this proposed change is not expected to increase the cost of the required monitoring devices in Canada.

Requiring carbon monoxide monitoring devices and nitrogen dioxide or other acceptable monitoring devices to conform to a National Standard of Canada would provide certainty for building officials, designers, specification writers, contractors and manufacturers regarding the minimum performance requirements of the NBC.

The proposed change could be enforced without requiring additional resources. However, since CAN/ULC 588 is a standard that has not been previously referenced in the NBC, regulators may need to become familiar with this standard to facilitate enforcement of the requirement.

Stakeholders such as designers, specifiers, manufacturers, building owners, building officials and contractors may need additional training to become familiar with, understand and apply the requirements of CAN/ULC 588 in order to design or install acceptable monitoring devices.

Manufacturers may need to adapt their products to meet the new regulatory requirements.

Building owners may need training to better understand the operating mechanisms of all the monitoring devices installed in their buildings.