September 20, 2018
Re: Occupancy Classification of Farm Building
The project is a single-storey, noncombustible building of 3800 m² in area, primarily used as a hatchery for chickens and located on land that is dedicated to agriculture. Near the building’s main entrance there is an office area (95 m²), lunch room, and decontamination change room, with a cumulative area of about 175 m². The intended occupant load of the building is 20 persons or less. Further, there are other complementary rooms such as first aid room that are not occupied during normal use.
Applicable Code Requirement
2012 British Columbia Building Code: Sentence 188.8.131.52.(4) and the definition of ‘farm building’ in Division A
184.108.40.206.(4) Farm buildings shall conform to the requirements in the National Farm Building Code of Canada 1995.
Farm building means a building or part thereof that does not contain a residential occupancy and that is associated with and located on land devoted to the practice of farming, and used essentially for the housing of equipment or livestock, or the production, storage or processing of agricultural and horticultural produce or feeds. (See Appendix A.)
1995 National Building Code of Canada: Sentence 220.127.116.11.(1) of Division B
18.104.22.168.(1) In determining the fire safety requirements of a building in relation to each of the major occupancies contained therein, the building height and building area of the entire building shall be used.
1995 National Farm Building Code of Canada: definition of ‘low human occupancy’, Sentence 22.214.171.124.(2) and part of Appendix Note A-126.96.36.199.(1)
Low human occupancy (as applying to farm buildings) means an occupancy having an occupant load of not more than one person per 40 m² of floor area during normal use.
188.8.131.52.(2) A farm building of low human occupancy or part thereof shall be separated from an occupancy conforming to Part 3 or Part 9 of the National Building Code of Canada 1995, including a farm building of other than low human occupancy, by a fire separation having a fire-resistance rating of at least 1 h.
A-184.108.40.206.(1) …It is possible to have areas of both high and low human occupancy in the same building provided that the structural safety and fire separation requirements for high human occupancy are met in the part thus designated.
Decision being Appealed (Local Authority’s Position)
The local authority has determined that the building can be considered a farm building with low human occupancy, except for the office, lunch room, and decontamination change room which, in this circumstance, should be considered as other than low human occupancy. The local authority considers the requirements for Group D occupancies in Part 3 of the 2012 BC Building Code apply to these spaces. Further, the local authority is requiring the application of Sentence 220.127.116.11.(1) of Division B of the 2012 British Columbia Building Code, which states that the fire safety requirements of a building shall be based on the entire building area.
The appellant maintains that the entire building is a farm building with low human occupancy, and that the office, lunch room, and decontamination change room are subsidiary.
Appeal Board Decision # 1815
It is the determination of the Board that the building is a farm building that contains both low human occupancy and high human occupancy. In this circumstance the board considers all of the building to be low human occupancy except the office area of 95 m². The office area is not a major occupancy and therefore Sentence 18.104.22.168.(1), which would require the fire safety requirements to be based on the entire building area, is not applicable.
Reason for Decision
The Board acknowledges the complexity of the interface between the National Farm Building Code of Canada and the 2012 BC Building Code/1995 National Building Code of Canada. As the National Farm Building Code of Canada is from 1995, and its genesis is much earlier than that, it may not reflect modern agricultural buildings that contain mixed uses. The Board’s decision has taken into account the National Farm Building Code’s requirement that the appropriate provisions of the 1995 National Building Code (not the 2012 BC Building Code) are applicable unless specifically exempted or amended.
Chair, Building Code Appeal Board