July 16, 2020
Re: Protection of Electrical Conductors for Emergency Equipment
The project is a multi-occupancy building where Subsection 3.2.6. Additional Requirements for High Buildings is applicable.
It is proposed to locate emergency conductors in electrical closets that are separated from the remainder of the floor area by a fire separation with a 1 hour fire-resistance rating. The electrical closets are located on the same location on each storey (stacked). The electrical closets contain other non-emergency electrical wiring and electrical panel(s).
Applicable Code Requirements
Sentence 18.104.22.168.(1) and Article 22.214.171.124. of Division B of the British Columbia Building Code 2018, specifically Sentences (2) and (4).
126.96.36.199.(1) Except as required by Sentence (2) and Article 188.8.131.52., optical fibre cables and electrical wires and cables with combustible insulation, jackets or sheathes are permitted in a building required to be of noncombustible construction, provided
a) the wires and cables exhibit a vertical char of not more than 1.5 m when tested in conformance with the Vertical Flame Test – Cables in Cable Trays (FT4 rating) in CSA C22.2 No. 0.3, “Test Methods for Electrical Wires and Cables,”
b) the wires and cables are located in
i) totally enclosed noncombustible raceways (see Note A-184.108.40.206.(1)(b)(i)), ii) masonry walls,
iii) concrete slabs,
iv) a service room separated from the remainder of the building by a fire separation having a fire-resistance rating not less than 1 h, or
v) totally enclosed non-metallic raceways conforming to Clause 220.127.116.11.(1)(b), or
c) the wires and cables are communication cables used at the service entry to a building and are not more than 3 m long.
(See Note A-18.104.22.168.(1).)
22.214.171.124.(2) Except as otherwise required by Sentence (3) and permitted by this Article, electrical conductors that are used in conjunction with systems identified in Sentence (1) shall
a) conform to CAN/ULC-S139, “Fire Test for Evaluation of Integrity of Electrical Power, Data and Optical Fibre Cables,” including the hose stream application, to provide a circuit integrity rating of not less than 1 h (see Note A-126.96.36.199.(2)(a) and (3)(a)), or
b) be located in a service space that is separated from the remainder of the building by a fire separation that has a fire-resistance rating not less than 1 h.
188.8.131.52.(4) The service spaces referred to in Clauses (2)(b) and (3)(b) shall not contain any combustible materials other than the conductors being protected.
Decision being Appealed (Local Authority’s Position)
The local authority has determined that an electrical closet where emergency conductors are proposed to be located within, and which is separated from the remainder of the floor area by a fire separation with a 1 hour fire-resistance rating, does not comply with the Building Code’s requirement that emergency conductors be located in a fire-rated service space. The local authority considers the electrical closets to be service rooms not service spaces, in that they have floors, which increase the possibility of other combustibles being stored in the room.
The local authority considers non-emergency electrical conductors with combustible sheathing, which are also located in the electrical closet, non-compliant with the requirements of Sentence 184.108.40.206.(4).
It is the position of the appellant that the electrical closets, that line up vertically and which are separated from the remainder of the floors by a fire separation with a 1 hour fire-resistance rating, constitute a separated service space as required by Clause 220.127.116.11.(2)(b).
It is the appellant’s position that other non-emergency wires in the electrical closet, installed in noncombustible raceways, do not represent combustibles referred to in Sentence 18.104.22.168.(4); and as such are permitted per Sentence 22.214.171.124.(1)(b), which is also consistent with the Canadian Electrical Code, “General Requirements”.
Appeal Board Decision #1847
It is the determination of the Board that the subject electrical closets, which have floors, are considered to be service spaces. The non-emergency wires with combustible jacketing installed in noncombustible raceways do not comply with the restriction of Sentence 126.96.36.199.(4) which states “The service spaces referred to in Clauses (2)(b) and (3)(b) shall not contain any combustible materials other than the conductors being protected”.
Reason for Decision
The Board acknowledges the protection provided by noncombustible raceways which may provide a level of protection similar to being noncombustible- however this would have to be demonstrated through an alternative solution.
Chair, Building Code Appeal Board