BCAB #1818

December 20, 2018

Re: Water Supply for Firefighting

Project Description

The project is a mushroom processing facility, consisting of multiple buildings, that includes growing, composting and processing mushrooms on properties devoted to farm use. The facility has combined total building area of 17 000 m². The existing buildings are predominantly noncombustible and the proposed 3 500 m² expansion and new composting bunker are also noncombustible. The facility includes office area, loading area, composting, processing and production areas, lunch room and washroom areas, and storage.

Applicable Code Requirements

Sentence 1.1.1.1.(4) of Division A of the 2012 British Columbia Building Code (BCBC).

1.1.1.1.(4)   Farm buildings shall conform to the requirements in the National Farm Building Code of Canada 1995.

Sentence 3.1.1.1.(1) of the National Farm Building Code of Canada 1995 (NFBCC).

3.1.1.1.(1)   Unless specifically required, farm buildings of low human occupancy need not conform to the requirements of Parts 3 and 9 of the National Building Code of Canada 1995 with regards to fire safety or egress, but shall conform to the requirements of this Part. (See Appendix A.)

Decision being Appealed (Local Authority’s Position)

The local authority has determined that the operation is a large scale industrial operation and that the buildings are not farm buildings as defined in the BCBC. The local authority has the following requirement for water for firefighting:

  • Development Bylaw Schedule F, Section 3, 4(a), 4(b), 8(a), 8(b)
  • Corporate Policy No 900-0-01 and Procedure 900-4-02

The local authority considers buildings and structures designed and constructed to the NFBCC to be exempted from requiring a water supply for firefighting, but that the subject industrial buildings are not farm buildings and therefore need to meet NFPA 1142 water supply requirements identified in Development Bylaw Schedule F.

Appellant's Position

The appellant maintains that the existing buildings, proposed addition and new composting bunker are farm buildings as defined in the BCBC. Therefore, the NFBCC is applicable. It is a reasonable assumption that farm buildings do not require a water supply for firefighting, as often a municipal supply is not available and storing water per NFPA 1142 would be prohibitively expensive. The provision of a water supply for firefighting is not required by the BCBC or the NFBCC for farm buildings.

Appeal Board Decision # 1818

It is the determination of the Board that existing buildings, proposed addition and new composting bunker are farm buildings as defined in the BCBC.

The Board acknowledges that pursuant to Section 5 of the Building Act, local authorities are permitted to enact a local building requirement when prescribed as an unrestricted matter.

The Building Act General Regulation identifies water supply for firefighting as an unrestricted matter for buildings not described in Sentence 3.2.5.7.(2) of Division B of the BCBC.

Reason for Decision

The subject mushroom processing facility meets the definition of farm building and the definition places no limits on the size of farm buildings.

It is outside of the Board’s authority to comment on the content of the local building requirement.

Lyle Kuhnert

Chair, Building Code Appeal Board