BCAB #1752 - Application of Subsection 3.1.15. “Roof Covering”

September 18, 2014

BCAB #1752

Re: Application of Subsection 3.1.15. “Roof Covering”

Project Description

The project is 4 storey residential Part 3 building with decks/balconies located on the 2nd, 3rd and 4th storeys of the building.  The decks are located directly above one another.  The 4th storey deck is not covered by a roof and none of the balconies are enclosed by walls or glass.

Reason for Appeal

Subsection 3.1.15. requires a roof covering to be classified as Class A, B or C in conformance with CAN/ULC-S107, “Fire Tests of Roof Coverings.”

Appellant's Position

The appellant contends that the requirements of Subsection 3.1.15. do not apply as the Subsection and the referenced standard apply only to roof coverings.  The code does not define “roof” and so the conventional definition of the word applies.  The conventional definition of “roof” does not include decks.

Building Official's Position

The building official maintains that the requirements of Subsection 3.1.15. apply.  Though the code does not define what is a “roof”, it is clear in Sentences and that platforms or horizontal assemblies effectively serve as roofs and accordingly are subject to the same requirements as roofs for both coverings and hydraulic loads, respectively.

Appeal Board Decision #1752

The Board considers that unenclosed balconies are horizontal platforms primarily intended as walking surfaces.  Other areas of the code, such as Subsection 3.2.2., have requirements for the fire protection of balconies.  Therefore it is the determination of the Board that these balconies are not roofs for the purposes of the application of Subsection 3.1.15.

Lyle Kuhnert, Chair