BCAB 1960 - Integrity of an exit at service equipment penetrations into an exit fire separation

Integrity of an exit at service equipment penetrations into an exit fire separation

Project Description

The project is the construction of a Part 3 building containing an exit stair shaft.  Vertical fire separations, constructed of wood studs with layers of gypsum wallboard on each side, enclose the exit stair shaft.

Drain, waste, and vent piping, water piping, gas piping, and electrical wiring penetrate the gypsum wallboard layers on the floor area side of the fire separation and are firestopped at the penetrations.  The building services described do not penetrate the gypsum wallboard layers on the exit side of the fire separation.

Applicable Code requirements (BCBC 2018)

Sentence 3.1.9.2.(1), Division B, Service Equipment Penetrations

(1) Ducts, electrical outlet boxes, pipes, totally enclosed raceways, optical fibre cables, electrical wires and cables, and other similar service equipment are permitted to penetrate a fire separation or a membrane forming part of an assembly required to have a fire-resistance rating, provided they are protected at the penetration with a firestop conforming to Sentence 3.1.9.1.(1). (See Note A-3.1.9.2.(1).)

Sentence 3.4.4.4.(1), Division B, Integrity of Exits

(1) A fire separation that separates an exit from the remainder of the building shall have no openings except for

(a) standpipe and sprinkler piping,

(b) electrical wires and cables, totally enclosed noncombustible raceways and noncombustible piping that serve only the exit,

(c) openings required by the provisions of Subsection 3.2.6.,

(d) exit doorways, and

(e) wired glass and glass block permitted by Article 3.1.8.16.

Decision being appealed (Local Authority’s position)

The Code ascribes a high degree of importance to exit facilities such that fire separations around exits require a higher level of fire protection and cannot be treated the same as other fire separations.  Sentence 3.4.4.4.(1), Division B, establishes this higher level of protection by stating that no openings, other than a short list of exceptions, are permitted.

The Code uses the words “penetration” and “opening” somewhat interchangeably.  Therefore, it is interpreted that penetrations into the exit fire separation, other than those in the list of permitted openings, are not permitted as they might degrade the intended performance of the exit fire separation.

Appellant's position

All of the building services described will be fully enclosed within the wood stud cavity of the exit fire separation.  The penetration points on the floor area side of the fire separation will be firestopped using assemblies in conformance with CAN/ULC-S115.

The service equipment penetrations into the fire separation enclosing the exit stair shaft are not openings in the fire separation and the installation will comply with the Code.

Appeal Board Decision #1960

The Board reverses the decision of the local authority.

It is the determination of the Board that the partial penetrations of the exit fire separation, located on the floor area side of the fire separation, are not openings in the exit fire separation.

Reason for decision

Through penetrations of an exit fire separation are considered to be openings in the exit fire separation and, for building services, are limited to standpipe and sprinkler piping as well as some services that serve only the exit.  Partial penetrations, located on the floor area side of an exit fire separation, are not openings in the exit fire separation.  Penetrations need to comply with Subsection 3.1.9., Division B.

Don Pedde
Chair, Building Code Appeal Board

Dated:  April 17, 2025