Proposed Change 2161

Section 5.6. of the National Fire Code of Canada (NFC) provides requirements for construction and demolition sites. Sentence 5.6.1.9.(1) references CSA B139 Series, “Installation code for oil-burning equipment,” and CSA B149.1, “Natural gas and propane installation code,” as acceptable means of conformance for the installation of fuel supplies for heating equipment and internal combustion engines used on such sites.

Under the existing NFC reference, CSA B139 Series covers the installation of stationary oil-burning equipment, such as fixed heating appliances, fuel tanks, piping and control systems serving buildings or industrial facilities. CSA B149.1 covers the installation of natural gas and propane, including appliances, piping and venting systems.

The existing NFC provisions ensure that fuel-fired equipment installed on construction and demolition sites is designed, installed and operated in a manner consistent with recognized safety standards. The requirements aim to prevent fire hazards related to improper installation, fuel storage or operation of such equipment by requiring conformance to CSA B139 Series or CSA B149.1, as applicable.

However, the existing NFC provisions are limited in scope, as both CSA B139 Series and CSA B149.1 were developed primarily for permanent installations and do not specifically address portable or temporary fuel-burning equipment commonly used on construction or demolition sites. In fact, CSA B139 Series specifically excludes portable oil-burning equipment from its scope.

Consequently, the NFC does not currently include explicit requirements or referenced standards that address portable oil-burning heaters and associated temporary fuel equipment used on construction and demolition sites. This gap means the existing conformance options may not adequately reflect the operational conditions and safety considerations for portable and temporary equipment.

This proposed change would add a reference to CAN/CSA-B138.1-17/CAN/CSA-B138.2-17, "Portable oil-burning equipment - Packaged equipment requirements/Installation requirements," alongside the existing references to CSA B139 Series and CSA B149.1. CAN/CSA-B138.1/CAN/CSA-B138.2 is a newly developed standard that explicitly addresses the requirements for the installation, operation and maintenance of such equipment, including considerations unique to temporary site conditions.

Adding a reference to this standard would maintain the current level of safety and performance while enhancing clarity and consistency by ensuring that portable oil-burning equipment is regulated under a standard specifically developed for that purpose.

While NFC Section 5.6. does not directly address non-portable or permanent oil-burning equipment, facilities adjacent or related to a construction or demolition site may contain such equipment. As a result, the reference to CSA B139 Series remains necessary to ensure that these installations are covered in the NFC.

Currently, products associated with portable oil-burning equipment are certified in accordance with or have proof of compliance with CAN/CSA-B138.1/CAN/CSA-B138.2, reflecting this standard's applicability and recognition in industry practice.

This proposed change would also improve alignment with recognized national standards, provide clear guidance to users on applicable requirements, and support uniform application of safety provisions across jurisdictions.

The proposed change would not affect the existing intent or structure of NFC Section 5.6. Rather, it would supplement the list of referenced documents by adding CAN/CSA-B138.1/CAN/CSA-B138.2. This addition would provide clearer guidance to Code users by distinguishing the applicable requirements for portable equipment from those for stationary installations already covered under CSA B139 Series.

The overall level of safety and performance would remain consistent with current Code objectives. In fact, the inclusion of CAN/CSA-B138.1/CAN/CSA-B138.2 would enhance regulatory certainty by ensuring that portable oil-burning equipment used on construction and demolition sites conforms to a standard specifically developed to address such applications. The inclusion of this standard would reduce ambiguity and support consistent enforcement without increasing risk or lowering safety outcomes.

The proposed change is not expected to result in new compliance costs for the industry or regulators. The portable oil-burning products that are currently available on the Canadian market have already been certified or evaluated for compliance with CAN/CSA-B138.1/CAN/CSA-B138.2. As a result, the manufacturers, installers and certification bodies are already familiar with this standard. As such, this proposed change would formalize existing practice rather than introduce new requirements. Over time, this proposed change may reduce administrative or design-related costs by eliminating uncertainty regarding which standard applies.

This proposed change is not expected to pose enforcement challenges and is anticipated to have minimal procedural impact, while providing greater clarity, consistency and confidence in applying the appropriate standard for portable oil-burning equipment on construction and demolition sites.

This proposed Code change may affect a wide range of stakeholders involved in design, specification, manufacture, approval and construction, including designers, specifiers, manufacturers, building owners, contractors and building officials.

For Code users and authorities having jurisdiction, the addition of CAN/CSA-B138.1/CAN/CSA-B138.2 would improve usability and alignment between the NFC and recognized industry standards. Contractors, inspectors and designers would benefit from clearer direction on applying the appropriate standard for portable systems, which would support consistent interpretation, improved compliance efficiency, and enhanced safety outcomes on construction and demolition sites.