BCAB #1027 - Congregate Housing, Sentence 18.104.22.168.(1)
November 1, 1988
Re: Congregate Housing, Sentence 22.214.171.124.(1)
With reference to your letter of August 22, 1988 regarding the use of fire shutters to protect openings between public corridors and an atrium.
From the limited information provided you have, by definition, an interconnected floor space in a building which by agreement is a Group C occupancy. Sentence 126.96.36.199.(1) requires that openings through the floors terminate at a vertical fire separation, unless the floors are protected in conformance with the requirements in Articles 188.8.131.52. to 184.108.40.206. The exceptions stated for Sentences (4) to (8) do not apply, and while 220.127.116.11.(8) is mentioned we would point out that this is a Group C occupancy, not covered by the Sentence.
Various statements made both by yourselves and the authority having jurisdiction suggest that there are other considerations yet to be addressed, regardless of the issue with respect to acceptance of rolling steel shutters. We would emphasize that the question is not utilization of roller shutters to eliminate the requirements for interconnected floor spaces, but the use of shutters as an equivalent to the fire separations required by interconnected floor spaces, there is a considerable distinction.
On the matter of acceptance as part of a fire separation Article 18.104.22.168. applies, and the shutters must have been satisfactorily tested in accordance with CAN4-S104, "Standard Method for Fire Tests of Door Assemblies", plus the additional requirements in Article 22.214.171.124., which deal with a temperature rise factor not included in the standard. The listings for such shutters will include size restrictions, as the shutters are closures and the supporting structure must still be a fire separation; any necessary controls to ensure effective operation of the shutter would also need to be tested. Sentence 126.96.36.199.(4) requires that the roller shutters be installed in accordance with Chapters 2 to 13 of NFPA 80, which is very specific on structural provisions for the openings in which the shutters are to be installed.
To summarize, while we have no basic disagreement with the concept of using roller shutters, we are unconvinced as to the overall adequacy of your proposal.
J.C. Currie, Chair