BCAB #1274 - Water Heating Coil in Solid Fuel Stove - Articles 220.127.116.11., 18.104.22.168. & 22.214.171.124.
March 24, 1992
Re: Water Heating Coil in Solid Fuel Stove - Articles 126.96.36.199., 188.8.131.52. & 184.108.40.206.
The item is question is the RSF Energy Ltd. Model SHW1 water pre-heater coil installed in a certified RSF Energy Ltd. wood burning space heater, Model HF-050. The coil heats the water before it enters the standard, stand alone, domestic hot water tank.
Reason for Appeal
Article 220.127.116.11. does not permit the heating coil of a service water heater to be installed in the flue or combustion chamber of a boiler or furnace heating a building. Article 18.104.22.168. requires solid fuel burning add-on heating systems to conform to the "Installation Code for Solid Fuel Burning Appliances and Equipment", CAN3-B365. Article 22.214.171.124. requires space heaters burning solid fuel to conform to the "Standard for Space Heaters for Use with Solid Fuels", ULC S627/CSA B366.2.
The appellant contends that the supplemental water heating coil is not part of a service water heater so Article 126.96.36.199. does not apply and it is not an "add-on heating system" so Article 188.8.131.52. does not apply either. The coil's manufacturer has provided evidence that the coil is certified for use in the model of space heater owned by the appellant and therefore, conforms with the installation standard CAN3-B365.
Building Official's Position
The building official maintains that the space heater standard ULC S627/CSA B366.2 does not address the water heating coil and therefore, Article 184.108.40.206. applies. The official considers the coil to be effectively part of the service water heater and Article 220.127.116.11. prohibits it from being in the flue or combustion chamber of a furnace. The official is also concerned with the lack of backflow prevention and the fact that there is no provision to protect the coil from overheating.
Appeal Board Decision #1274
It is the determination of the Board that the water pre-heating coil installed in a certified solid fuel burning space heater does not contravene the requirements of the Building Code. The space heater and coil have been certified as complying with CSA B366.2, "Standard for Space Heaters for use with Solid Fuels" and should, therefore, be considered an acceptable space heating appliance.
Article 18.104.22.168. prohibits the installation of a service water heater coil in the combustion chamber of a furnace, not in other space heating appliances such as a solid fuel burning space heater. The Board considers the solid fuel burning appliance in question to be a space heater, not a furnace, so Article 22.214.171.124. does not apply. The Board does not consider Article 126.96.36.199. to apply because the heating coil is not an add-on heating system as defined by CAN3-B365, "Installation Code for Solid-Fuel Burning Appliances and Equipment."
The connection of the water pre-heating coil to the potable water system must meet the applicable requirements of the Building and Plumbing Codes. It should also be noted that the coil is certified for use with an uninsulated water tank as described in the manufacturer's installation instructions.
George R. Humphrey, Chair