Fire safety codes and bulletins

The needs for building security and the requirements for life safety in a building are sometimes in conflict. This bulletin helps clarify how to achieve compliance with the British Columbia Fire Code (BCFC) and the British Columbia Building Code (BCBC) when addressing requirements for locks, window bars, access and the installation of electromechanical and electromagnetic hardware on doors. A supplement to this bulletin titled "Electromagnetic locking devices and fire safety" is available.

In most cases, access doors may be locked to prevent entry but must allow egress for exiting. There are some exceptions allowed in the BCBC, which will be explained below. There is an understanding that the building may be occupied at any time. Although the term "occupied" is not defined in the codes, this assumption reflects a concern for the safety of anyone unintentionally trapped in a building. For this reason, all exit doors must permit egress to the outside at any time, unless alternative measures approved/permitted by the local building official are provided.

Permit application/installation requirements

A specific/separate building permit, and/or an electrical permit, may be required prior to any installation/replacement of exit door hardware. Consult your local building official for clarification.

The installation, replacement or alteration of hardware on new and existing exit doors must comply with the BCFC and the BCBC. Refer to Building Code Appeal Board (BCAB) decision #1498. The following is a summary of the requirements.

For access to the BCAB decisions, see Building Codes Appeal Board Decisions.

Fundamental requirements

There are three underlying requirements captured by the BCBC, all of which must be satisfied for the acceptance of locking devices.

1. Unrestricted exiting

Doors with double cylinder and/or captive key locks are not permitted.

If a door divides a floor area and egress is required in both directions through the door, "unrestricted exiting" is required in both directions.

Electromechanical devices which affect only the access side door handle (unrestricted egress) and maintain a positive latch even when unlocked (such as some electric mortise locks) are acceptable.

Electric operated strikes used to restrict access are considered to not restrict egress, provided a mechanical release for the door is installed on the egress side.

An electric operated bolt engaging a fixed receptacle (strike plate) is not permitted under any circumstance since it may fail locked in a position which prevents egress.

Magnetic locks (mag locks) may temporarily delay egress when installed in complete conformance with the BCBC. Mag locks that do not delay egress are presumed to comply with the BCBC (see BCAB decision #1483).

Mag locks are intended for use as auxiliary locking devices. The combined use of a fail-secure electromechanical device and a mag lock would be required where there is a need for automatic locking security, such as in the event of a power failure and single motion egress. The use of a push-button switch is considered "specialized knowledge" and is not permitted to be the primary release of a mag lock.

For installations that delay egress, a push-button can be used by security personnel for operating a mag lock. In installations that do not delay egress, and where acceptable to the authority having jurisdiction, the use of other devices such as motion sensors or pressure sensitive pads may be incorporated to facilitate unimpeded egress. However, they must be certified to a ULC standard or equivalent to ensure reliability because they are not controlled by a fire alarm system. In a fire separation, a latch and strike are required on a closure to facilitate automatic positive latching.

Electric mortise locks, and other electromechanical devices that only affect the access-side door handle and that use only mechanical means to control the latch bolt (there is no deadbolt) are permitted. The latch bolt and the egress side handle shall not be controlled by electromechanical means.

Electric bolts, and other devices that restrict egress when they fail are not permitted.

Labeling of all hardware and electronic components used in a fire separation is required in fire separations requiring a fire protection rating.

Exceptions to unrestricted exiting (BCBC)

The BCBC addresses remote or locally released locking devices in a contained use area or impeded egress zone. In these circumstances, specialized knowledge or devices may be permitted because the building will be occupied by security personnel with the training to operate these specialized devices.

The BCBC also addresses the requirements for mag lock installations.

The BCBC applies to unrestricted egress doors in buildings that are fully sprinklered throughout and identifies the criteria necessary in banks and mercantile occupancies for locked exit doors. Full compliance to all applicable sentences, as well as an active and approved Fire Safety Plan with exiting procedures and requirements specified for bank and mercantile occupancies with locked doors, is required.

2. Latching maintained

In fire separations, a positive latch is required to hold the door in the closed position after each use. Access control systems must not affect latching.

Labeled doors and frames equipped with closers help identify fire separations in existing situations.

3. Door, frame and hardware labeling

In fire separations which have a fire-resistance rating, all parts of a closure will be labeled. This includes door, door frame and hardware. Closures permitted to be modified must maintain their rating. Fire door hardware will normally have a fusible link incorporated in the design. See the hardware and fusible links bulletin for more information.

The door, frame and hardware must be listed for use with each other and be installed in conformance with their listing.

A manufacturer’s stamp on a door or frame does not confirm fire rating under the BCBC. A label from a recognized product testing and certification agency is required on the door and frame AFTER they are machined for the hardware (that is, "prepared" for the hardware).

Defective door assemblies shall be repaired/replaced in conformance with the BCFC. (For preparation of new fire rated assemblies, the labeling occurs prior to the door and frame arriving on site).

For preparation of existing fire rated doors and frames, the existing assembly shall be replaced with a new assembly (which is prepared and labeled before coming to the site); OR written confirmation shall be provided to the authority having jurisdiction from the fire door manufacturer, stating that the specifically named hardware installed per the manufacturer’s instructions will not void the door and/or frame label; OR the assembly may be re-labeled by a recognized product testing and certification agency.

When shipping the existing assembly offsite to a location that is under the label’s service for preparation (such as the manufacturer’s location or a machinists’ or pre-hanger’s shop which is licensed to apply labels), the existing fire separation must be maintained.

Electric strikes - there are restrictions for the use of electric strikes, and if used with hardware for a door located in a fire separation the electric strike will be labeled for use in a fire separation.

Exceptions

1. If the new hardware does not require any alteration (drilling, cutting) to the existing frame or door, the respective frame or door is not required to be re-labeled. Of course, the hardware must be listed for use in the door assembly: for example, listed for wood doors if used on wood doors and have the specific required fire rating
2. If the preparations are within those permitted as "job site preparation" in NFPA 80 and written confirmation from the fire door manufacturer is provided to the authority having jurisdiction stating that the specifically named hardware installed per the manufacturer’s instructions will not void the label, the assembly is not required to be re-labeled
3. Preparation that is permitted on-site for fire rated door assemblies is only for assemblies intended to receive this preparation (hence the requirement for confirmation from the door manufacturer for existing doors and frames) as permitted in NFPA 80

This means that, with written confirmation from the door manufacturer, surface-applied mag locks may be installed on-site without re-labeling, but recessed mag locks (or any other recessed hardware) shall have their preparation work done at a location which is under the label’s service.

NFPA 80 allows job site preparation for surface-applied hardware, function holes for mortise locks (for the door handles and key receptacle), holes for labeled viewers, undercutting of wood and composite doors and installation of protection plates (NFPA 80 specifies measurements). Preparation means round holes drilled through one or both faces of the door. The holes must not exceed a maximum of 2.5 centimetres.

Access to and through cross-over floors (and into areas of refuge)

Consult your local building official for modifications in cross-over floors.

Fire department access

Access panels or windows (as required by building and fire codes) provided to facilitate access for firefighting operations shall be maintained free of obstructions.

To provide fire department access into high-rise buildings without providing keys, one may install a wired glass panel within 300 mm of the door opening hardware. Note: if the glass panel is installed in a required fire rated door, the panel must be installed in accordance with NFPA 80 (that is, the panel may not be installed on-site).

Required access panels or windows are not permitted to be obstructed by window bars. An alternative is to allow window bars that are removable with the use of a key. A tagged copy of that key shall be kept in a lock box in a location approved by the authority having jurisdiction.

Window bars - Although there is no standard for window bars, the BCBC identifies certain windows to be used for egress in times of emergency. For example, a bedroom window required to provide egress must release from the inside without the use of tools (keys), or specialized knowledge. If window bars are put over these windows, the bars must open from the inside as easily as the window hardware.

Other hardware considerations

The BCBC addresses exit requirements. Other things to consider when designing the door hardware are:

1. Panic hardware requirements
   Note: Panic hardware in rated fire separations is required to be labelled as fire exit hardware and not just labelled as panic hardware
2. Head room clearance
3. Amount of force to open
4. Direction of the door swing
5. No automatic locking devices on doors between residential suites and public corridors
6. Accessibility of the door opening hardware for persons with disabilities. For example, door opening hardware must be operable without tight grasping, pinching or twisting of the wrist
7. Turn pieces which release a locking bolt on a building main entrance door or on exit doors should release the bolt with not more than a 90-degree turn
8. Although the BCBC allows another releasing device in addition to the main door release hardware of a dwelling unit, there are BCBC requirements for fire rated hardware to be used for suite doors in some multifamily dwellings. Therefore, a deadbolt lock, with a fire resistance rating, conforming to the ULC standard or equivalent, is the only recognized device allowed in addition to the main door release hardware

Terminology

The following terminology used in the door hardware industry is provided for clarification:

• Captive key locks are double cylinder locks that have a removable thumb turn
• Double cylinder locks are devices that require a key to unlock the device from either the egress side or the access side. This includes lockable thumb turns and locks which have no method of release from the egress side
• Electric bolt is an electromechanical dead bolt, latch bolt, pin or other similar device that retracts and/or extends electromagnetically to lock or unlock a door
• Electric mortise lock is a recessed lock that electromechanically disables or enables the levers/knobs capability to retract the latch bolt
• Electric strike is an electromechanical strike plate which can be released so that it does not retain the latch bolt in the door frame. There are two types of electric strikes, fail-secure and fail-safe
• Fail-secure - If the door is pushed/pulled in the direction of swing against an electric strike that is energized (released), the keeper (or lip) part of the strike plate folds back and releases the latch, allowing the door to open. This device always provides positive latching when it is de-energized
• Fail-safe - If the door is pushed/pulled in the direction of swing against an electric strike that is not energized, the keeper (or lip) part of the strike plate folds back and releases the latch, allowing the door to open. This device does not provide positive latching when it is de-energized
• Both types of electric strikes are permitted where the door assembly is not in a fire separation. When a labeled electric strike is installed in a door assembly in a fire separation, the electric strike must fail-secure
• Electromagnetic lock (mag lock) has an electromagnet body and an armature plate held together by an electromagnetic force. There are no moving parts. (The armature plate is usually mounted on the door. A mag lock is not an electromechanical device)
• Electromechanical devices incorporate latches or pins and use an electromagnetic field to move a mechanical component. Electric strikes and electrified hardware including knob sets, lever sets, shear locks, mortise and panic hardware are examples of electromechanical locking devices. These devices are usually available fail-secure (locked) or fail-safe (unlocked) in the event of a power failure
• Electromechanical releasing devices use a mechanical action to release an electrically activated component which is integrated into the mechanical portion of the device. Pressure sensitive pads, door paddles, touch bars, pushbuttons and micro-switch equipped panic hardware are examples of electromechanical releasing devices. These devices are available in normally-closed (circuit opens on activation) or normally-open (circuit closes on activation) configuration, or they may be configured as a combination of both (one circuit opens and one circuit closes on activation)
• Labeled means equipment or materials to which has been attached a label, symbol or other identifying mark of a recognized testing facility that is responsible for product evaluation/testing in Canada
• Mortise means fully recessed. A mortised device is flush mounted or concealed
• Strike plate is a plate on a door frame with a cut-out that receives the door latch when the door is closed
• Window bars are fixed and/or movable screens or partitions, such as grills, mesh, posts, lattice or sheeting, and may be fabricated out of materials such as metal, wood or plastic. Window bars create an obstruction of an opening when installed

Hardware Requirements for Access and Egress (HRAE) is a guideline developed by the Security and Life Safety Task Force, a group of public and private sector stakeholders working in cooperation with the Office of the Fire Commissioner.

The HRAE guideline defines and enumerates different ways of enhancing security while addressing life safety issues. This is a supplement to that guideline. As such it recognizes and does not conflict with the requirements of the British Columbia Fire Code (BCFC) and British Columbia Building Code (BCBC).

This supplement provides building and fire code users with information on the installation and use of Electromagnetic Locking Devices (EMLDs) that do not delay egress. Although this information was developed in response to security issues at 24-hour service stations, these principles are applicable to other occupancies where the owner/designer of a building may choose to use EMLDs to enhance security.

What is an EMLD?

An "electromagnetic locking device" or "mag lock" has an electromagnet body and an armature plate held together by an electromagnetic force. There are no moving parts. The armature plate usually is mounted on the door. A mag lock is not an electro-mechanical device.

EMLD use

The following situations are appropriate for EMLD use:

• Additional protection for staff
• Hold-up protection
• Intrusion protection

Fundamental requirements

As long as all BCBC and BCFC requirements are met EMLDs can be used to enhance building security.

The installation of EMLDs must in no way conflict with or compromise basic code requirements.

In the event of a component/system failure the EMLD must not impede egress (fail in an open or unlocked state).

EMLDs and their ancillary devices must be compatible and comply with appropriate recognized standards. Evidence of compatibility, on-site tests or verification by qualified individuals may be required by an authority having jurisdiction.

It is highly recommended that the installing contractor identify the system with a permanently marked weatherproof label. A label posted on the premises indicating the installer’s company name, phone number, design/testing company, date of installation and permit number(s) will assist in any verification and inspection.

Fire rated hardware plays a key role in helping to control and contain the effects of fire in a building.

During a fire falling debris and/or a hose stream can activate door release hardware, causing the latch to disengage the strike plate on the frame, which allows the door to open. Fire rated hardware is designed to be unaffected by falling debris and/or the hose stream.

Building code testing standards

Hardware must achieve compliance with ULC/- CAN4-S104 "Standard Method of Fire Tests of Door Assemblies" as required by the British Columbia Building Code (BCBC). Other similar tests include UL 10B, ASTM E152 and NFPA 252.

Testing requires that when hardware is being evaluated for use on fire doors it shall hold the door closed during the entire period for which the rating is required and, in addition, the latch bolt shall remain engaged in its intended strike and shall be intact after the test. The hardware need not be operable after the test.

Test methods are intended to evaluate the ability of a door assembly to remain in an opening (closed and latched position) during a predetermined fire exposure period and hose stream test.

This performance-based requirement gives the manufacturers flexibility when choosing a method to achieve compliance, whether it is fusible links and/or fusible components as part of the fire rated hardware design.

Flexibility allows components of fire-rated panic hardware and lever handles to be made from materials that are combustible or that have low melting points. Levers and vertical rods made from materials such as aluminum or zinc will disintegrate, leaving the latch mechanism remaining on or in the door with no ability for a hose stream or falling debris to activate it.

Fire rated mortise latch sets that have levers made of solid brass, bronze or stainless steel may incorporate a fusible link, such as a plastic or zinc component, in the releasing mechanism. During a fire the fusible link disintegrates. The lever handle may still be movable but a hose stream or falling debris impacting the lever handle will not operate the latch.

Vertical rod fire exit panic hardware certified without the lower vertical rod is provided with a spring-loaded bolt, activated by a "fusible link" for the bottom of the fire door. This product addresses the problem caused by the constant damage that the lower rods and latch receive in hospitals or schools. A bent lower rod or damaged lower latch can mean that the lower latch will not fully engage its strike plate. This condition can remain undetected as the upper latch may still hold the door closed.

Compliant panic hardware is also labelled as "fire exit hardware" and like all fire rated hardware must be certified for this use in Canada (ULC, cULus, cWHus, and so on) and acceptable to the authority having jurisdiction.

Uncertified or improperly installed latching hardware, door viewers, hinges, astragal plates and guarding devices may compromise the fire-resistance rating and certification of a fire door.

This bulletin provides guidance to assess whether a boarding/lodging/rooming house, or other additional accommodation, has become a multiple suite building. This bulletin does not address local government regulations regarding land use or other local government regulatory bylaws.

A dwelling unit (house), which is altered or occupied to provide accommodation for boarders, lodgers, or roomers, may not include the fire and life safety measures that are required in buildings that contain multiple residential suites/tenancies. These safety measures can include appropriate fire separations, means of egress (exits), emergency lighting, smoke alarms and fire extinguishers. The purpose of British Columbia Fire Code (BCFC) sentence 2.11.1.1.(1) is to extend the application of the current British Columbia Building Code (BCBC) to existing buildings used for this purpose, to ensure that proper safety measures are in place.

Accommodation definitions

A single dwelling unit (house) is a single suite operated as a housekeeping unit under a single tenancy. In part, the BCFC and the BCBC define "suite" as a room or series of rooms of complementary use, operated under a single tenancy, and includes dwelling units, individual guest rooms in motels, hotels, boarding houses, rooming houses and dormitories.

Single tenancy means all occupants of a living space live as one housekeeping unit with control over all the living space. Therefore, a building contains more than one dwelling unit or suite when the occupants are limited to controlling only designated areas of the building. The result is a building which has multiple suites/tenancies.

Examples of accommodation

Single suite

Single housekeeping unit – One or more people living in a house under a single tenancy, sharing the control and responsibility of the entire living space

Multiple suites

Rooming house – Several people are living in a house, each person having a separate tenancy agreement and having control over and responsibility for their own space. This arrangement can include transient accommodation

Secondary suite – An additional dwelling unit which is part of a house, such that the house becomes two dwelling units, each being a separate suite

Code requirements

Single dwelling units (houses) that are altered by creating an additional suite(s) that are under the control of the boarders, lodgers or roomers shall conform to the BCBC. This means that a site-specific evaluation of a building is essential to determine if the required safety features are present.

The fire commissioner and any delegated inspectors (fire service advisors of the Office of the Fire Commissioner (OFC)) and designated inspectors of the local authorities have the authority to accept alternatives to the BCBC and BCFC requirements if satisfied that an equivalent level of fire and life safety can be achieved.

The Fire Safety Act enables inspectors to inspect any premises anywhere in British Columbia to ascertain whether or not the premises are used or occupied in a way that fire would endanger life or property, which could include dwelling units providing accommodation for boarders, lodgers or roomers.

The authority for the fire commissioner and any delegated inspectors (fire service advisors of the OFC) and the designated inspectors of the local authority to enter and inspect private dwellings is described in Section 10 of the Fire Safety Act (FSA). Section 10 (2) of the FSA states that entry into a place occupied as a private dwelling requires the consent of the occupier.

A Consent to Enter Occupied Premises fillable form (DOCX, 44KB) (note this link downloads to the user’s system folders), should be presented to an occupier of a premises whenever the fire inspector requests entry of the occupier’s private dwelling for inspection purposes pursuant to Section 10 of the FSA.

Section 26 of the FSA provides authority for the fire commissioner and any delegated investigators (fire service advisors of the OFC) and designated investigators of the local authority to enter a private dwelling but only if a fire has occurred. Legally, written consent is not required but if an owner/occupier is available at the time of entry and the circumstance is such that it is reasonable to request consent, it would be good practice to ask the occupier to sign a consent form.

If a place is not occupied due to a fire incident, consent is not needed to be obtained.

Occupants and owners of private dwellings should also be aware that some local governments may have bylaws that provide authority for their fire department officials to enter private dwellings under certain conditions, such as 24 hour written notice or under the authority of a warrant. The fire department officials should be able to provide the occupant with the necessary documents that explain the authorization that allows them to enter the occupant’s private dwelling.

British Columbia Fire Code (BCFC) Article 2.3.1.3 requires that decorative materials on walls and ceilings shall have a flame spread rating not greater than that required for the interior finish of the space in which they are located. This is a change from previous fire code editions which allowed combustible material to be attached to the walls and ceilings in school corridors.

In response to concerns raised that all student artworks may have to be removed from school corridor walls in order to comply with the flame spread rating, the fire commissioner formed a task force of educators, parents, trustees and fire service representatives. The task force reviewed the intent of this code provision and suggested ways that the code requirements can be satisfied while allowing for the expression of creativity.

Flame spread rating

The British Columbia Building Code (BCBC) requires the interior wall finish of corridors serving classrooms to have a flame spread rating not more than 75. A flame spread rating of 150 is allowed if the building is protected by an automatic sprinkler system. For example, gypsum wall board has a flame spread rating of 25 while unfinished fir plywood has a rating of 150.

Apart from the interior furnishings, the interior finish is the component that most enhances the spread of fire, particularly if it has a high flame spread rating. Controlling the characteristics of the finish materials can reduce the rate at which fire could spread, particularly on walls and ceilings.

Alternatives to the codes

The BCFC applies to all existing buildings whether they are new or a 100-year-old heritage building. Although the fire code references the most recent building code, not all buildings were constructed to that standard. Therefore, provisions must be made in the fire code to accept existing features and arrangements while still maintaining an acceptable level of safety.

Alternative solutions to the requirements in the fire code are permitted if the alternative provides a level of fire and life safety that is equivalent to the level of performance required by the codes. Alternative solutions will require the approval of the authority having jurisdiction.

This requirement is intended as a means for the authority having jurisdiction to accept an arrangement, such as an existing building or fire protection system that is not identical to that required by the BCFC, but that is considered to provide an equivalent level of fire and life safety due to its specific qualities. It is the intent of the BCFC that an equivalent level of safety be achieved rather than necessarily achieving strict conformance to the referenced provisions in the BCBC.

The BCFC states that the owner or the owner’s authorized agent is responsible for carrying out the provisions of the code. However, the owner is expected to communicate with the authority having jurisdiction, which is in a position to assess alternatives to the code requirements.

Fire emergency planning

Section 2.8 of the BCFC requires that schools develop fire emergency procedures. The development of a fire safety plan should be prepared in cooperation with the local fire department. The control of fire hazards in the building should be included in the fire safety plan.

What is acceptable in school corridors?

A safe environment which also allows for creativity can be maintained if certain conditions are met to minimize the fire hazard and if the schools comply with the BCFC requirement for fire emergency planning which includes the preparation of a fire safety plan and the holding of fire drills.

The intent of the BCBC in restricting the flame spread in corridors is to prevent the unimpeded spread of fire along a corridor surface, to enable safe exiting from the building, and to restrict the ability of fire to progress from a classroom into a corridor, as well as from a corridor into the classroom. The purpose of the BCFC is to ensure that the building is used and maintained as was originally intended by the BCBC.

To maintain safe passage in corridors during a fire emergency, it is permissible to attach small quantities of combustible material such as teaching aids, notices and student artwork within designated display areas in school corridors under the following arrangements.

General provisions

Combustible material may only be displayed in areas designated for that purpose.

The location for the placement of combustible material in school corridors shall be established through cooperation between the school district or school and local fire officials.

Combustible material may not exceed 20 percent of the total wall area for each wall.

When possible, decorative material is to be attached at each corner of the paper to enable it to lie flat against the wall.

Combustible material may not be attached to the ceilings in corridors.

Stairwells and exits must be always kept clear of obstructions. Combustible material may not be displayed in stairwells and exits.

Areas designated for displaying combustible material

• The locations for the displaying of combustible material shall be:
  • Minimum 1 metre from classroom and exit doors
  • Minimum 0.5 metres below ceiling level and 0.5 metres above floor level, and
  • Minimum 0.5 metres from safety equipment such as fire alarm pull stations, fire extinguisher or fire hose cabinets, fire detectors, automatic sprinklers, emergency lighting and exit signs
• Display areas may not exceed 5 metres in length
• Display areas are to be separated from each other by a minimum of 1 metre clearance

Corridor width

Combustible material may not be displayed in corridors less than 1.8 metres in width.

Corridors 1.8 metres and 2.1 metres in width may have combustible material displayed on one wall only.

Corridors greater than 2.1 metres in width may have combustible material displayed on both walls.

Classroom doors

Combustible material may not to be attached to the corridor side of the classroom door.

For classrooms with one door, combustible material may not to be attached on the classroom side of the door.

For classrooms with two doors, combustible material may be attached to the classroom side of one door only.

Exemptions

Enclosed trophy and display cases and glass-faced framed pictures/posters/notice boards are exempt from these requirements.

There is no restriction on the amount and location of fire-retardant paper/material on corridor walls, other than the clearance from safety equipment.

Determining the wall area

To determine the maximum permitted combustible material for a wall the boundaries for each wall surface must be identified. However, because of unusual corridor configurations it is not always possible or practical to use corners as the demarcations for each wall surface. In such cases, natural or prominent breaks in the wall surfaces that could be used to define individual wall surfaces would be exit doors, stairs or function areas such as foyers or open areas in the corridor system.

For example, the area of the walls surrounding a function area could be considered when determining the amount of combustible material to be displayed in that area.

Each corridor wall surface must be considered individually; they are not cumulative. For example, the surface areas of opposing corridor walls cannot be combined to determine the permissible amount of combustible material for a single wall.

It is suggested that school authorities, in consultation with fire officials, include within their fire safety plan the locations of the display areas for combustible material.

The Ministry of Housing and Municipal Affairs Construction Standards and Digital Solutions Branch has issued an information bulletin (Before and After School Programs) (PDF, 355KB), which provides information on programs that are often offered in schools before and after instructional times, and how the British Columbia Building Code (BCBC) and British Columbia Fire Code (BCFC) apply when those programs are added and/or revised.

You will find the bulletin on the Building, Plumbing and Fire Code bulletins page.

Gas fired heaters are appliances that generate radiant, infrared and/or convection heat. Heating appliances must be certified by an accredited certification agency to a standard indicative of their intended use, such as indoors or outdoors. This bulletin provides guidance in assessing proper use of gas fired heaters when used indoors or under covered areas such as tents and awnings.

The British Columbia Fire Code (BCFC) does not permit the use of open flame devices in tents or air supported structures occupied by the public, unless approved by the local authority having jurisdiction.

When a partial enclosure is considered to be outdoors

The standard to which outdoor units are certified defines outdoor as a shelter such as:

• Walls on all sides but with no overhead cover
• A partial enclosure which includes an overhead cover and no more than two side walls which may be paralleled, as in a breezeway, or at right angles to each other
• A partial enclosure which includes overhead cover and three side walls, as long as 30 percent or more of the horizontal periphery of the enclosure is permanently open

Note: A screened wall (bug screen) does constitute a wall as air flow through screens is very poor.

Gas fired appliances and tents

Gas fired appliances generate products of combustion when in use, which must be vented to the outdoors. Manufacturers may require the heaters used indoors to be electrically interlocked to an exhaust fan with an air-proving switch. The exhaust fan must provide the exhaust flow rate required by the manufacturer or the British Columbia Building Code (BCBC). Some manufacturers require 300 cubic feet per minute for every 100,000 BTUs of input.

Propane cylinders are not permitted in a confined space, which includes enclosed tents.

A proper tent heater uses a forced air system to transfer heated air into the tent via ducting from an exterior combustion chamber, which exhausts combustion products to open air.

Installing gas fired appliances

The installation of gas fired appliances, including gas supply and electrical supply, must adhere to all applicable codes. Electrical equipment must be certified for the intended purpose. The manufacturer’s installation and usage instructions are a condition of that certification. Any limitations should accompany the product in the form of warnings on a nameplate or within the instructions provided. If in doubt, contact the manufacturer or the certification organization.

Only those individuals licensed by Technical Safety BC (TSBC) and qualified in the installation of gas fired heating appliances should be engaged to install such an appliance. All gas fired appliances require an installation permit from TSBC.

Heaters certified for indoor installations are permitted, and when the heater is installed near a combustible wall or under a combustible ceiling the minimum clearances to combustibles, as required by the manufacturer, must be adhered to. Combustible materials are considered to be wood, compressed paper, plant fibers or other materials capable of being ignited and burned. Such materials shall be considered combustible even if flame proofed, fire retardant treated or plastered.

Additional clearances may be required for glass, painted surfaces, plastics, vinyl and other materials which may be damaged or melted by radiant or convection heat. The manufacturer must be consulted.

The following information explains the provisions for occupant loads in the British Columbia Building Code (BCBC) and the British Columbia Fire Code (BCFC). There may be other external factors that affect occupant loads for a building or parts of a building, such as municipal bylaws and Liquor and Cannabis Regulation Branch regulations; these are not included within the scope of this document. These other factors may be more restrictive than the BCBC or the BCFC, but they cannot permit a higher occupant load than the fire code.

The BCBC occupant load is based on the intended use as determined by the designer. The occupant load determined under the BCFC is the maximum number of people permitted in a space under any condition.

Relationship between the building and fire codes

The BCBC establishes a satisfactory standard of fire, life and health safety for the design and construction and alteration of buildings. The BCFC establishes an acceptable standard for fire and life safety for buildings in use.

The two codes are intended to be complementary and coordinated documents which reduce the possibility of conflict in their respective contents. The BCFC should not conflict with or supersede the requirements in the BCBC. Occupant loads determined under the two codes will likely be different since they are determined for different reasons. They should not be seen as conflicting.

Definitions

For the purposes of understanding the terms used on this page, the following definitions are provided. These definitions are the same as those in both the building and fire codes.

Occupant load means the number of persons for which a building or part thereof is designed.

Means of egress means a continuous path of travel provided for the escape of persons from any point in a building or contained open space to a separate building, an open public thoroughfare or an exterior open space protected from fire exposure from the building and having access to an open public thoroughfare. Means of egress includes exits and access to exit.

Exit means that part of a means of egress, including doorways, which lead from the floor area it serves to a separate building, an open public thoroughfare or an exterior open space protected from fire exposure from the building and having access to an open thoroughfare.

Access to exit means that part of a means of egress within a floor area that provides access to an exit serving the floor area.

In summary, the means of egress is the path of travel from any point in the building to a safe space protected from fire, which is usually the street. The exit is the actual door leading out of the building and could also be the door leading into the fire protected stair shaft or corridor. The access to exit is the path of travel within the floor area to an exit.

British Columbia Building Code

One of the objectives of the British Columbia Building Code (BCBC) is to assure an adequate level of health and safety for the number of people the building is designed to accommodate. The occupant load determines the capacity of the means of egress and other building features.

Table 3.1.17.1 of the BCBC provides area per person criteria to assist in determining the occupant load for various buildings or spaces within buildings. These suggested densities are intended to assist in the design of the means of egress and other occupant load dependent facilities in the building.

Clause 3.1.17.1 (1)(c) indicates the occupant load is the number of persons the area is designed for. However, it should not be less than that determined from the table unless it can be shown that the area will in fact be occupied by fewer persons. In other words, the table is the default minimum occupant load for design purposes. However, due to potential variation in population densities in most of the categories listed, it is unrealistic to establish hard and fast rules for each category. Therefore, some reduction from the table’s values may be justified if it can be shown the area will be occupied for fewer persons. For instance, in a highly automated manufacturing operation the occupant load estimates might be relaxed from those calculated from the table, provided there is reasonable assurance that the occupant load will not be exceeded in the future.

On the other hand, if a building is designed for an occupant load which exceeds the values determined from the table, the higher values must be used. Table 3.1.17.1 is not intended to limit the number of occupants in an area, although it is sometimes used or applied this way. The values listed in Table 3.1.17.1 suggest a gross floor area for various uses, which includes the space occupied by fixtures, equipment, products and the like that are typical for the intended use of the space.

Where a building is designed with an occupant load which is different than determined using table 3.1.17.1, Sentence 3.1.17.2 (2) requires a permanent sign to be posted indicating this occupant load.

Article 3.1.2.6 of the BCBC permits an assembly occupancy with 30 persons or less to be classified as a business and personal services occupancy provided some conditions are met. Where this requirement is applied a sign indicating the occupant load is required. The requirements for the sign can be found in sentence 3.1.2.6 (3) of the BCBC.

There will be circumstances when it may not be appropriate to include all rooms in a building to determine the building's total design occupant load. This may be the case for an office building where washroom facilities are used only by occupants of the building. If the washroom was included in the count of the building's total occupant load, in effect you would be counting the same people twice.

British Columbia Fire Code

Under the British Columbia Fire Code (BCFC) article 2.7.1.3 there is a limit to the maximum number of persons permitted to enter a room. This limit is based on a density of not more than .4 square metres per person (4 square feet per person) provided the available egress capacity is adequate. The density is based on the net floor space of the room which excludes areas occupied by structural components and fixtures, furnishings or equipment but does not exclude furniture used for seating. Therefore, the maximum permissible occupant load is to be calculated on the basis of the lesser of either .4 square metres (4 square feet) of net floor space per occupant or the occupant load for which egress is provided.

Maximum permissible occupant load cannot exceed the maximum number of persons that can safely be accommodated by the means of egress provided from a room. Actual use of a room or space may result in more people than the number determined by applying the occupant load factors of the BCBC.

Determination of exit and egress capacities

The width of a means of egress should be not less than:

• 1,100 millimetres (43 inches) for corridors and passageways
• 900 millimetres (35.5 inches) for stairs and ramps
• 800 millimetres (31.5 inches) for suite door
• 800 millimetres (31.5 inches) for exit doorways [BCBC Sections 3.3 and 3.4]

Although these minimums may not be available in older buildings, the lesser dimensions will reduce the number of people that can be accommodated.

The capacity of the means of egress is calculated on the basis of:

• 6.1 millimetres (0.24 inches) per person for doorways, corridors and passageways and
• 8 millimetres (0.31 inches) for stairs. [BCBC Sentence 3.4.3.2 (1)]

The required capacity of access to exit is based on the occupant load of the portion of the floor area served. The most restrictive part of a means of egress is ultimately the occupant load’s controlling factor. For instance, the width of a corridor may not accommodate as many people as the egress doors or density of the room or rooms opening onto the corridor, so the width of the corridor becomes the controlling factor.

Door and hardware considerations

In addition to the width of the egress facilities the number of exit doors, direction of door swing and the type of hardware installed on a door can have an effect on its capacity. Examples are as follows:

1. A room or suite with only one egress door is limited to an occupant load not exceeding 60 persons. [BCBC 3.3.1.5 (1)(b)]
2. A door providing access to exit from a room with an occupant load of more than 60 persons must swing in the direction of travel to the exit. Therefore, a door that swings into the room limits the maximum permissible occupant load to 60 persons. [BCBC 3.3.1.11.(2)]
3. If a room used for an assembly occupancy has an occupant load of more than 100 persons then the doors must be equipped with door release hardware commonly known as "panic hardware". Doors without panic hardware limit the maximum permissible occupant load to 100 persons. [BCBC 3.3.2.7.(1) and 3.4.6.16.(2)]
4. A double leaf door that has one of the doors locked in place by manual flush bolts is considered to be a single leaf door for the purposes of exiting
5. Egress doorways that are obstructed by locking devices or the placement of fixtures can reduce the maximum permissible occupant load

Sign requirements

BCFC sentence 2.7.1.4 (1) requires a sign to be posted in an assembly occupancy where the occupant load exceeds 60 persons. This sign is intended to indicate the maximum permissible occupant load determined under article 2.7.1.3.

The BCFC requires the owner to carry out the provisions of the fire code which may include developing a fire safety plan in cooperation with the local fire authority. While it is the owner’s responsibility to post the required signs, it is recommended that the posting of the sign be done in consultation with the local fire authority.

In cases where the layout of an establishment periodically changes it is recommended that the different layouts are documented as part of the fire safety plan's ongoing review and development process. This will help to ensure that the periodic change in layout is compliant with the requirements of the BCFC.

Most fire deaths happen in homes as a result of people breathing smoke and toxic fumes while they are asleep. Smoke alarms are an effective early warning device that can awaken sleeping occupants and help provide time to safely exit the building.

Statistics

British Columbia’s fire statistics reveal a strong link between working smoke alarms and reduced fatalities from residential structure fires. Statistics show that smoke alarms help save lives, reduce fire related injuries, reduce the spread of fires and reduce the damage caused by fire. Numerous evaluations have been conducted by fire services using decades of data and the results are consistent. Studies show that your chances of dying in a home fire may be reduced by 50 percent if a working smoke alarm is present in your home.

Mandatory alarms

Smoke alarms are mandatory in all dwelling units under the British Columbia Fire Code (BCFC). All homes, sleeping rooms within boarding and lodging houses, hotels and recreational cabins are required to be protected by smoke alarms.

Dwelling units constructed after the 1979 building and fire code changes require smoke alarms to be permanently wired to the home’s electrical system and interconnected.

Dwellings constructed before 1979 still require a smoke alarm in dwelling units. However, these smoke alarms are permitted to be battery operated in older (pre-1979) dwelling units or in a building which is not supplied with electrical power.

While carbon monoxide alarms are not mandatory in B.C., it is recommended that alarms be installed if a home has a fuel-burning appliance, fireplace or attached garage. For more information visit the OFC’s carbon monoxide awareness page.

Alarm maintenance

All smoke alarms should be replaced after ten years to reduce the chances of failure due to product deterioration. When smoke alarms are being replaced the installation must not reduce the level of protection. In other words, existing electronically interconnected smoke alarms should be replaced with similar type smoke alarms that provide the same or higher level of protection. If additional smoke alarms are being added in the home, they may be battery operated. Always check local government bylaws for any further installation requirements.

Who is responsible?

See the below to help you understand what you are responsible for:

• Homeowners have a responsibility to install and maintain their smoke alarms. Homeowners should also consider installing smoke alarms that have carbon monoxide (CO) detection built in or adding a separate stand-alone CO detector. This will also help to provide early warning in the event that an unsafe CO level in the home is reached. For more information, check the Technical Safety BC Carbon Monoxide Safety page on the Technical Safety BC website
• Owners of recreational cabins must ensure their smoke alarm is working. Consider bringing a working battery-operated smoke alarm with you when you travel, especially if your cabin is remotely located and access to a replacement smoke alarm is not convenient
• Landlords/apartment managers have a responsibility to install smoke alarms as required based on the year of construction and test them to ensure they are in working order prior to tenant occupancy. The landlord is also required to maintain the smoke alarm in working condition Smoke alarms should be inspected whenever tenancy changes to ensure the smoke alarms are working properly
• Tenants should notify their landlord immediately if they do not have the required number of working smoke alarms. In the event there is an inadequate number of smoke alarms installed the tenant should consider installing their own battery-operated smoke alarm so that there is no delay from protection. In some situations, for example if there are bedrooms with no smoke alarm, a tenant should consult their landlord about installing extra battery-operated smoke alarms to provide additional protection
• Local fire departments that conduct inspections of hotels and public buildings should check the building maintenance records to help verify all smoke alarms are being maintained and are in working condition

The BC Games is an example of a planned mass gathering that occurs every second year in different locations throughout British Columbia and involves upwards of 3,600 athletes, coaches, officials and spectators from all over the province.

The purpose of this bulletin is to provide event organizers and volunteers with general guidelines and points to consider when planning a large sporting event such as the BC Games to ensure the safety of all participants.

Volunteers are strongly encouraged to connect with their local government to develop a working relationship prior to the event and to ensure that all fire safety regulations have been considered and planned for.

Fire safety at large community hosted events

Many communities throughout the province host events, such as sports tournaments, that involve large numbers of participants and spectators. Some communities lack the facilities to properly accommodate vast numbers of people. Facilities are sometimes used that were not originally designed to accommodate the number of persons attending these events.

A community must be advised of the potential number of people who will be in attendance for the event so that community officials can assess their ability to host the event. At this point, planning for fire and life safety needs during the event must begin in cooperation with the local building and fire authorities having jurisdiction (AHJ).

It is recommended that communities hosting large events establish a plan to address fire safety and the temporary changes in use of the buildings and/or facilities. This should be completed in the early planning stages and involve the AHJ.

From a fire safety perspective there are primarily two functions which require attention at the planning stage: assembly and sleeping uses.

Procedure for evaluation of assembly use

The concern with assembly areas is greater during a large event when many activities occur indoors. The times of greatest concern are during opening and closing ceremonies, due to the increased number of occupants and the possibility of pyrotechnical performances

Ensure the AHJ is aware of buildings and/or facilities that are to be utilized for assembly events. A preliminary review will verify that approval for assembly use has been given by the AHJ.

Ensure that safety systems are maintained in operational condition as per the requirements of the British Columbia Fire Code (BCFC).

Determine the activities and the number of people who will be in attendance. If the building has been approved for assembly use, regular fire safety maintenance is up-to-date and the proposed occupant load does not exceed the number established by the BCFC, the AHJ can consider the building acceptable for use.

Develop floor and seating plans in cooperation with the local fire department as part of the fire safety plan.

If the building has not been approved for assembly use upgrading may be required. If the safety systems, such as fire alarm systems, adequate exiting and exit and emergency lighting, are not installed or are not maintained in operational condition installation and/or maintenance must be considered prior to being accepted for use.

The AHJ decides whether or not the building may be used and under what circumstances. For example, the ice surface of an arena is approved for bleacher seating only. Life safety may be reduced when the increased number or placement of occupants exceeds the existing life safety design features.

Sleeping accommodation

The volume of participants at large community events has necessitated the use of schools, gymnasiums and other non-residential buildings to provide sleeping accommodation.

These non-residential facilities used for sleeping accommodation may meet the basic requirements for residential occupancies if the facility provides life safety systems such as fire alarm and smoke detection systems, emergency lighting, exit lighting, fire extinguishers and adequate exits.

• All sleeping rooms in B.C. are required to be provided with working smoke alarms
• Owner/occupier must ensure that the required systems are maintained in operational condition
• Layouts used for sleeping accommodation must not restrict access to exits
• If the fire safety systems are deficient the AHJ may require alternative solutions that are at least equivalent to the requirements, such as 24-hour fire/security watch, additional smoke alarms, and so on

Conflict with security measures

Problems arise when people leave sleeping areas through exit doors after lights out.

Exit doors may never be chained or otherwise locked, thereby impeding egress. Doors can be locked from the outside to prevent access. Security and fire safety organizers need to discuss these issues during planning in order to avert any potential problems.

Classroom equipment

Desks and classroom equipment should be stored in classrooms not in use to avoid conflicts with British Columbia Building Code (BCBC) and BCFC requirements such as no storage in the following locations: hallways, access to exits, exits and exit stair shafts.

Fire safety plans

Division B, Section 2.8 of the BCFC outlines requirements for assigning responsibility to ensure that buildings are used as designed, safety systems are operational and that emergency procedures are in place.

In the case of a school the school principal would normally be the "supervisor" for the fire safety plan. During the event the school principal may not be present; therefore, a separate fire safety plan is necessary. The fire safety plan must identify who is responsible.

The fire safety plan must be developed in cooperation with the local fire department and supervisory staff must understand the fire safety plan.

Those responsible for the building have a duty of care to ensure that every reasonable effort is made to comply with the life safety requirements.

Occupant loads must be enforced during events in the same manner as they are in other assembly occupancies. A regular system of inspection must be conducted by supervisory staff.

The Fire Safety Act (FSA) and the regulations establish the minimum requirements for life and fire safety in buildings. Bylaws, policy or other requirements should not be repugnant or establish a lesser level of safety than that provided for by the FSA and the regulations.

Summary

The preceding discussion has touched on the main areas of concern from a fire safety perspective and focuses on the need to adhere closely to regulations presently in place.

The BCBC and the BCFC regulations have a degree of flexibility built in. However, any alternate solutions to the prescriptive BCBC and BCFC requirements proposed by a building owner or owner’s authorized agent must be approved by the AHJ.

Inclusion of the AHJ in the planning stages of these events will help ensure the success of implementing fire and life safety regulations.

The purpose of this information bulletin is to provide industry with an easy-to-follow checklist to assist them in meeting the fire safety planning requirements of the British Columbia Fire Code (BCFC). The goal is to prevent fires and explosions in buildings containing a wood dust-producing operation, reducing the risk to life and property.

This bulletin only covers the following specific provincial fire code requirement:

• BCFC, Division B, Subsection 5.1.5 requires that a fire safety plan be prepared for operations that involve a risk from explosion, high flammability or related conditions that create a hazard to life safety.

Responsibilities and requirements

The owner or owner’s authorized agent is responsible for carrying out the provisions of the BCFC, which includes establishing a fire safety plan to ensure that:

• Fire hazards will be controlled
• Emergency responders will be notified of a fire emergency
• Emergency responders will not be delayed in carrying out their duties
• Firefighting operations will be managed effectively, without unnecessary delays
• Designated supervisory staff will be appointed and organized to respond to fire emergencies
• Instructions including schematic diagrams describing the type, location and operation of building fire emergency systems will be established
• Building facilities, systems, equipment and devices will be properly inspected and maintained

The fire safety plan not only reflects the unique characteristics of the building and the dust producing operation it contains but also considers the available firefighting infrastructure. For this reason, the fire safety plan must be prepared by the owner or owner’s authorized agent in cooperation with the local fire department and other applicable regulatory authorities.

It’s important for the owner or owner’s authorized agent to:

• Ensure they are also in compliance with laws and regulations applicable within British Columbia and the local jurisdiction
• Consult the local fire department and other regulatory authorities such as Technical Safety BC and WorkSafeBC

Fire safety planning and risk management assessments of the site are essential to prepare for and manage fire hazards. Planning and assessment will identify risks and lead to methods and processes that will minimize or contain potential fire hazards. All site safety activities should be coordinated through the planning and assessment process.

BCFC provisions must form part of the fire safety plan and are applied depending on the conditions at the site such as the size and type of building, the amount of dust produced, potential ignition sources, and so on

At a minimum, a fire safety plan should include the following information:

Emergency procedures and information needed

• Who is the designated and back-up person responsible for sounding the fire alarm (horn)?
• Who is the designated and back-up person responsible for notifying the fire department (9-1-1)?
• Is instruction given to site personnel on the procedure to follow when an alarm is sounded?
• Are exit routes clearly visible within the site and on all floors?
• Is the muster point (or meeting place) known by all site personnel?
• Is there a list of on-site personnel, and is it updated and current (can everybody on-site be accounted for)?
• Are there assigned personnel to meet the fire department upon arrival and give information such as the location of the fire, persons that are unable to evacuate or injured person(s)?
• Are there persons assigned as site fire wardens (ensuring various trades are represented)?
• Are there personnel directed and trained to confine or control the fire?

Training of site personnel on evacuation procedures

• Is site orientation provided?
• Are regular site fire safety discussions a part of regular safety meetings?
• Are simulated fire drills conducted when applicable and warranted?

Training of site personnel on identifying dust hazards

• Are personnel able to recognize potential fire and explosion hazards identified during fire safety planning and risk management assessments?
• Are personnel able to identify when the accumulation of wood dust becomes a hazard?

Training of site personnel to perform fire prevention duties

• Are the amounts of combustibles and accumulated wood dust on the site and around the buildings controlled to mitigate fire and explosion hazards?
• Is general site housekeeping being carried out?
• Are maintenance schedules for combustible dust operations and dust collections systems created and updated for sign off by site supervisor?
• Are excess pallets, garbage/waste material and other combustibles removed on a regular basis?
• Is the separation of combustibles from open flame devices being maintained?
• Is there a clear unobstructed access route(s) for fire department apparatus and to fire hydrants?
• Are designated exit routes from every floor maintained?
• Are access routes separated from stored combustible materials, equipment, and so on?
• Are vehicles or delivery trucks able to park so they do not obstruct fire department access routes to site or to adjacent buildings? If not, has off-site parking and storage been considered?

Firefighting services

Firefighting services – hydrant, fire department connections (FDCs), sprinkler, access route

• Are they installed, tested and maintained?
• Are firefighter access route(s) to the building provided?
• Are firefighting services (FDCs, standpipes, hydrants) maintained and accessible?
• Do drawings provided to the fire department show the location of firefighting systems as they become operational?
• Is the site address sign visible and legible to emergency crews from the street? (If they must be provided according to bylaw)
• Are fire suppression and explosion prevention systems incorporated within dust collection systems and duct work inspected and maintained?
• Are explosion venting gates on the dust collectors and buildings clearly identified and maintained?

Fire extinguishers

• Is there sufficient quantity and type on-site such as:
  • 2-A: 10-B:C on movable equipment?
  • 4-A: 40-B:C in all other locations?
• Is the servicing up to date (within the last year)?
• Are they provided at or near fuel operated equipment?
• Are they mounted with proper signage at exit locations within the required travel distance?
• Are they adjacent to any hot works operations (for example, cutting torch, welding, grinding, and so on)?

Hot works operations

• Is the area clear of flammable and combustible materials?
• Is a fire watch assigned during a hot works operation and for 60 minutes after its completion?
• Is there a final inspection of the hot works area four hours after completion?
• Are the hot works in the proximity of combustible or flammable materials?
• Have provisions been made for protection of such materials by non-combustible materials, thermal barrier or other means?
• Is the work being performed by trained or certified personnel?
• Is a fire extinguisher present at all times such as:
  • 2-A: 10-B:C on movable equipment?
  • 4-A: 40-B:C in all other locations?
• Is proper ventilation provided as required?
• Are hot tar pots on-site complete with fire extinguishers and trained personnel and located away from combustible materials?

Flammable and combustible storage

• Are flammable and combustible liquids properly stored, handled and used in and around the building?
• Are non-petroleum based compressed gases properly stored, handled and used in and around the building?
• Is the storage area separated from combustible material by three metres?
• Is the storage area locked and vented?
• Is the storage area protected from vehicular/industrial motorized traffic?
• Do containers and/or storage areas have proper signage/placards in place?
• Is there a current or updated list of dangerous goods on-site such as material safety data sheets (MSDS), as per the Workplace Hazardous Materials Information System (WHMIS)?
• Are portable extinguishers provided in close proximity to storage and work areas such as:
  • 2-A: 10-B:C on movable equipment?
  • 4-A: 40-B:C in all other locations?
• Is the storage area away from egress and access routes to the site?

Electrical installations and petroleum gases

Do the electrical installations, storage and use of petroleum gases comply with the requirements of the Safety Standards Act and pursuant regulations? (Contact Technical Safety BC for more information.)

Security

• What type of on-site security is provided: for example locked gate, monitored alarm and/or CCTV, 24 hour or nightly walk around?
• Do security personnel have knowledge of and understand their role in the site’s fire safety plan?
• Can the fire department effectively communicate with the security personnel during an emergency?
• Do security personnel have access (keys) to locked areas?

Contact personnel

• Is there a list of names and telephone numbers of persons to be contacted during and after normal operating hours or in the event of an emergency?
• Are the contact personnel able to respond in a timely fashion?
• What is their estimated response time?

Building diagrams

• Are diagrams available on-site? These diagrams should indicate:
  • Layout of each floor area
  • Muster point(s)
  • Location of nearest hydrant(s)
  • Location of fire protection equipment
  • Exit paths
  • Service rooms

The fire safety plan must be reviewed annually at minimum and updated whenever changes to the manufacturing process occur to provide the greatest value. The plan that is developed for a building where dust producing operations occur is used to maintain and protect the building and its occupants. It’s very important that all supervisory staff remain familiar with the plan, so they are aware of how it pertains to their responsibilities. The fire safety plan must be retained on site for review by the fire department, supervisory staff, personnel and other applicable regulatory authorities.

Although the BCFC does not regulate the format of a fire safety plan some local fire departments like the fire safety plans in their jurisdiction to be uniform. The Fire Prevention Officers’ Association of British Columbia (FPOABC) website provides an example of a format that may provide useful information that will help you when developing your fire safety plan in cooperation with the local fire department. Although the Office of the Fire Commissioner (OFC) is not responsible for the content on non-government websites, the link to the FPOABC fire safety plan documentation is provided.

It may also be beneficial to owners to obtain the services of a consultant who specializes in fire safety planning and risk management assessments. This consultant would oversee the fire safety plan’s development and implementation. This is especially useful to owners who have neither the time nor the expertise to develop their own plan or who do not have a fire department available to them.

British Columbia Codes are available online for general public access, and at local public libraries. [Also see National Fire Code 2020].

This information bulletin provides the construction and demolition industry with an easy-to-follow checklist to assist them in meeting the fire safety requirements of the British Columbia Fire Code (BCFC). The goal is to prevent fires in and around construction/demolition sites and reduce the fire risk to life and property.

This bulletin only covers provincial building and fire code requirements, specifically:

• British Columbia Building Code (BCBC), Division B, Section 8.1 references the BCFC, Division B, Section 5.6 which applies to buildings, parts of buildings and associated areas undergoing construction or demolition operations, including renovations.
• BCFC, Division B, Section 5.6.1.3 (1) states: "...prior to the commencement of construction, alteration or demolition operations, a fire safety plan shall be prepared for the site..."

Responsibilities and requirements

The owner or owner’s authorized agent is responsible for carrying out the provisions of the BCFC, which includes establishing a work site fire safety plan to ensure that:

• Fire hazards will be controlled
• Emergency responders will be notified of a fire emergency
• Emergency responders will not be delayed in carrying out their duties
• Firefighting operations will be managed effectively, without unnecessary delays
• Designated supervisory staff will be appointed and organized to respond to fire emergencies
• Instructions including schematic diagrams describing the type, location and operation of building fire emergency systems will be established
• Building facilities, systems, equipment and devices will be properly inspected and maintained

The fire safety plan not only reflects the unique characteristics of building, operation and construction techniques (including the construction/demolition trades) but also considers the available firefighting infrastructure. For this reason, the fire safety plan must be prepared by the owner or owner’s authorized agent in cooperation with the local fire department and other applicable regulatory authorities.

Prior to commencing any work at a site, it’s important for the owner or authorized agent of the owner to:

• Ensure they are also in compliance with the laws, regulations and requirements of the BCBC, the BCFC, local government and other regulatory authorities, and
• Consult the local fire department and other regulatory authorities such as Technical Safety BC and WorkSafeBC

Fire safety planning and risk management assessments of the site done prior to, during and after building construction/demolition is completed are essential to prepare for and manage fire hazards. Planning and assessment will identify and lead to methods and processes that will minimize or contain potential fire hazards. All site safety activities should be coordinated through the planning and assessment process.

BCFC provisions are included in the fire safety plan and are applied depending on the project’s scope and conditions of the site, for example, the size and type of the building and its proximity to adjacent buildings.

At a minimum, a fire safety plan should include the following information:

Emergency procedures and information needed

• Does the site have signage identifying the:
  • Civic address visible from the access route at the entrance to the site?
  • Floor level, stair location and civic address posted at each floor in the construction access stairway?
• Who is the designated and backup person responsible to sound the fire alarm (horn)?
• Who is the designated and backup person responsible to notify the fire department (9-1-1)?
• Is instruction given to site personnel on the procedure to follow when an alarm is sounded?
• Are exit routes clearly visible within the site and on all floors?
• Is the muster point (or meeting place) known by all site personnel?
• Is there a list of on-site personnel, and is it updated and current (can everybody on-site be accounted for)?
• Are there assigned personnel to meet the fire department upon arrival and give information, such as the location of the fire, persons that are unable to evacuate or injured person(s)?
• Are there persons assigned as site fire wardens (ensuring various trades are represented)?
• Are there personnel directed and trained to confine or control the fire?
• Are designated smoking areas clearly identified and located more than 3 meters from the building undergoing construction, demolition or alteration, and from other combustible materials?

Training of site personnel on evacuation procedures

• Is site orientation provided?
• Are regular site fire safety meetings a part of regular safety meetings?
• Are simulated fire drills conducted when applicable and warranted?

Site personnel duties

Assigned site personnel must be responsible to carry out fire safety duties such as:

• Controlling combustible waste:
  • Is there more than a 3-metre clearance between combustible refuse containers and the exits?
  • Are disposal chutes constructed of non-combustible material, or if combustible do they terminate more than 2 meters above the disposal bin?
• General site housekeeping
• Removing excess pallets, garbage/waste material and other combustibles on a regular basis.
• Maintaining separation of combustibles from open flame devices
• Maintaining clear unobstructed access route(s) for fire department apparatus and to fire hydrants
• Designating and maintaining at least one exit from every floor
• Separating access routes from materials stored on-site, combustibles, and so on
• Ensuring parking of vehicles or delivery trucks do not obstruct fire department access to the site or adjacent buildings (off-site parking and storage may be considered)

Firefighting services

Firefighting services – water supply, hydrant, hose connection, sprinkler, access route

• Is the required water supply for firefighting provided?
• Are the hydrants clearly identified by signage and accessible by more than 2 metres of unobstructed clearance?
• Are the hydrants and sprinklers installed, tested and activated at the start of construction?
• Are firefighter access route(s) to the building provided?
• Are standpipes and hose connections maintained and accessible?
• Do drawings provided to the fire department show the location of firefighting systems as they become operational?
• Is the site address sign (when required by local bylaw) visible and legible to emergency crews from the street?

Fire extinguishers

• Is there sufficient quantity and type on-site such as:
  • 2-A:10-B:C on movable equipment?
  • 4-A:40-B:C in all other locations?
• Is the servicing up–to-date (within the last year)?
• Are they provided at or near fuel operated equipment?
• Are they mounted with proper signage at exit locations within the required travel distance?
• Are they adjacent to any hot works operations (for example, cutting torch, welding, torching, and so on)?

Hot works operations

• Is the area clear of flammable and combustible materials?
• Is a fire watch assigned during a hot works operation and for 60 minutes after its completion?
• Is there a final inspection of the hot works area 4 hours after completion?
• Are the hot works in the proximity of combustible or flammable materials?
• Have provisions been made for protection of combustible or flammable materials by using a non-combustible/thermal barrier or other means?
• Is the work being performed by trained or certified personnel?
• Is a fire extinguisher present at all times such as:
  • 2-A:10-B:C on movable equipment?
  • 4-A:40-B:C in all other locations?
• Is proper ventilation provided as required?
• Are hot tar pots on-site complete with fire extinguishers and trained personnel and located away from combustible materials?

Flammable and combustible storage

• Are flammable and combustible liquids properly stored, handled and used in and around the building?
• Are non-petroleum based compressed gases properly stored, handled and used in and around the building?
• Is the storage area separated from combustible material by 3 metres?
• Is the storage area locked and vented?
• Is the storage area protected from vehicular/industrial motorized traffic?
• Do containers and/or storage areas have proper signage/placards in place?
• Is there a current or updated list of dangerous goods on-site such as material safety data sheets (MSDS), as per the Workplace Hazardous Materials Information System (WHMIS)?
• Are portable extinguishers provided in close proximity to storage and work areas such as:
  • 2-A:10-B:C on movable equipment?
  • 4-A:40-B:C in all other locations?
• Is the storage area away from egress and access routes to the site?

Electrical installations and petroleum gases

Do the electrical installations, storage and use of petroleum gases comply with the requirements of the Safety Standards Act and pursuant regulation? (Contact Technical Safety BC for more information.)

Security

• What type of on-site security is provided, for example, locked gate, monitored alarm and/or CCTV, 24 hour or nightly walk around?
• Do security personnel have knowledge of and understand their role in the site’s fire safety plan?
• Can the fire department effectively communicate with the security personnel during an emergency?
• Do security personnel have access (keys) to locked areas?
• Is the required security fence, boarding or barricade:
  • Strongly constructed,
  • Erected around the perimeter of the construction or demolition site, and
  • Not less than 1.8 m high?
• Do the provided barricades have:
  • A reasonably smooth surface facing the outside, and
  • No openings other than those required for access?
• Are the access openings through barricades equipped with gates that are:
  • Kept closed and locked when the site is unattended, and
  • Kept in place until completion of the construction or demolition activity?
• Are the fencing, boarding and barricades constructed and maintained so that they do not restrict access to the construction or demolition site for firefighting purposes or to the fire protection equipment?

Contact personnel

• Is there a list of names and telephone numbers of persons to be contacted during and after normal operating hours or in the event of an emergency?
• Are the contact personnel able to respond in a timely fashion?
• What is their estimated response time?

Building diagrams

Are diagrams available on-site? These diagrams should indicate:

• Plans of each floor area
• Muster point(s)
• Location of nearest hydrant(s)
• Location of fire protection equipment
• Exit paths
• Service rooms

The fire safety plan must be reviewed and updated as construction/demolition progresses and then periodically afterwards to provide the greatest value. The plan that is developed for a building construction site should evolve into the plan that will be used to maintain and protect the building and its occupants after completion. It’s very important that all supervisory staff remain familiar with the plan throughout the process, so they are aware of how it pertains to their responsibilities. The fire safety plan must be retained on site for review by the fire department, supervisory staff, personnel and other applicable regulatory authorities.

Although the BCFC does not regulate the format of a fire safety plan some local fire departments like the fire safety plans in their jurisdiction to be uniform. The Fire Prevention Officers’ Association of British Columbia (FPOABC) website provides an example of a format that may provide useful information that will help you when developing your fire safety plan in cooperation with the local fire department. Although the Office of the Fire Commissioner is not responsible for the content on non-government websites, the link to the FPOABC fire safety plan documentation is provided.

It may also be beneficial to owners to obtain the services of a consultant who specializes in fire safety planning and risk management assessments. This consultant would oversee the fire safety plan’s development and implementation. This is especially useful to owners who have neither the time nor the expertise to develop their own plan or who do not have a fire department available to them.

The BCFC is available online for general public access, and available at local public libraries. (Also see National Fire Code 2020).

For schools attended by children, the fire commissioner has approved a fire drill system that consists of total evacuation fire drills held at least three times in each of the fall and spring school terms.

The Office of the Fire Commissioner (OFC) has a School Fire Drill Checklist (PDF, 309KB) available for schools that wish to use it.

Requirements

Subsection 2.8.2 of the British Columbia Fire Code (BCFC) requires that a fire safety plan be prepared in cooperation with the fire department and any other applicable regulatory authorities. A fire safety plan must include the requirement for a regular system of fire drills.

It is recommended that the local fire chief be contacted for any assistance necessary in organizing fire drills or designing a system to meet any special needs.

Responsibilities

Principal or person in charge

The principal or person in charge of the school must instruct all staff members and students in the fire drill procedure. The person in charge will also ensure that all staff members have a copy of the fire drill procedure.

All corridors and stairs should be checked daily to ensure that doors are free to open and that no obstructions exist.

They must also ensure that the fire department is notified immediately when a fire alarm occurs. The emergency telephone number for the fire department should be prominently displayed near all telephones in the school.

Teachers

Teachers will instruct students in accordance with the approved drill procedure and make provision for the special care of any students who may be physically or mentally incapable of proceeding to the exits.

If a teacher leaves a class unattended, they must notify the person in charge of the nearest classroom. That teacher becomes responsible for the unattended class and will be required to take charge of both classes in the event of a fire alarm.

A teacher may appoint one or more students from the class to act as monitors in the event of a fire alarm. These monitors will check to ensure that no children remain in the classroom or any other room installed in the classroom in the event of an alarm or fire. After the check, the monitors will report to the teacher and then take their places with the rest of the class.

Fire drill procedure

The following procedure has been approved by the fire commissioner:

1. When the fire drill commences, all teaching activities must stop, machinery should be shut down, gas-and-oil-burning apparatus and appliances other than those used for heating the building should be shut off and the students should remain still and quiet to await further orders.
2. The teacher is to give the command STAND
   • Students should stand and remain silent
   • The teacher then takes the class register or attendance list and keep possession of it until the end of the drill
3. The teacher will open the classroom door, determine the route to be taken and give the command MARCH
   • The teacher will then supervise the class out of the building in an orderly manner to a predetermined point of safety
   • Students will remain in formation until dismissed by the principal or person in charge
4. Students outside the classroom and still in the building must go to the nearest corridor and join with any class or, if close to an exit, shall leave the building and report to their own class group outside the building
5. Once assembled at the predetermined point of safety the teacher shall check the names and the number of students
   • If there are any missing or additional students the teacher shall report this to either the principal or person in charge, giving the names, the classroom numbers and the location
6. The principal or person in charge must make every effort to ensure that no student remains in the school.

This information bulletin provides care facility owners/operators with an easy-to-follow checklist to assist them in meeting the fire safety planning requirements of the British Columbia Fire Code (BCFC). The goal is to prevent fires in buildings that provide care to seniors, reducing the risk to life and property.

This bulletin only covers the specific following provincial fire code requirement:

• BCFC, Division B, Section 2.8 requires that a fire safety plan be prepared for care occupancies.

Responsibilities and requirements

The owner or the owner’s authorized agent is responsible for carrying out the provisions of the BCFC which includes establishing a fire safety plan to ensure that:

• Fire hazards will be controlled
• Emergency responders will be notified of a fire emergency
• Emergency responders will not be delayed in carrying out their duties
• Firefighting operations will be managed effectively, without unnecessary delays
• Designated supervisory staff will be appointed and organized to respond to fire emergencies
• Instructions including schematic diagrams describing the type, location and operation of building fire emergency systems will be established
• Building facilities, systems, equipment and devices will be properly inspected and maintained

The fire safety plan not only reflects the unique characteristics of the building but also considers the available firefighting infrastructure. For this reason, the fire safety plan must be prepared by the owner or owner’s authorized agent in cooperation with the local fire department and other applicable regulatory authorities.

It is important that the owner or owners authorized agent know they are responsible to:

• Ensure they are also in compliance with laws and regulations applicable within British Columbia and the local jurisdiction and
• Consult the local fire department and other regulatory authorities such as the local health authority, Technical Safety BC and WorkSafeBC.

Fire safety planning and risk management assessments of the site are essential to prepare for and manage fire hazards. Planning and assessment will identify and lead to methods and processes that will minimize or contain potential fire hazards. All site safety activities should be coordinated through the planning and assessment process.

BCFC provisions form part of the fire safety plan and are applied depending on the circumstances at the site, such as the size and use of the building, and so on

At a minimum, a fire safety plan should include the following information:

Procedures and information needed

• Who is the designated and backup person responsible to sound the fire alarm (horn)?
• Who is the designated and backup person responsible to notify the fire department (9-1-1)?
• Is instruction given to site personnel on the procedure to follow when an alarm is sounded?
• Are exit routes clearly visible within the site and on all floors?
• Is the muster point (or meeting place) known by all site personnel?
• Is there a list of on-site personnel, and is it updated and current (can everybody on site be accounted for)?
• Are there assigned personnel to meet the fire department upon arrival and give information such as the location of the fire, persons that are unable to evacuate or injured person(s)?
• Are there persons assigned as site fire wardens?
• Are there personnel directed and trained to confine or control the fire?

Training of site personnel on evacuation procedures

• Is site orientation provided?
• Are regular site fire safety discussions a part of regular safety meetings?
• Are simulated fire drills conducted when applicable and warranted?
• Are there adequate personnel available to carry out evacuation procedures?
• Are there special provisions or persons assigned for evacuating persons that require assistance?

Assigned site personnel

Assigned site personnel must be responsible to carry out fire safety duties such as:

• Controlling combustibles on the site and around the building(s)
• General site housekeeping
• Removing garbage/waste material and other combustibles on a regular basis
• Maintaining separation of combustibles from open flame devices
• Maintaining clear unobstructed access route(s) for fire department apparatus and to fire hydrants
• Maintaining exits from every floor
• Separating access routes from materials stored on-site, combustibles, and so on
• Ensuring parking of vehicles or delivery trucks does not obstruct fire department access to the site and any adjacent buildings (off-site parking should be considered)

Firefighting services

Firefighting services – hydrant, fire department connections (FDCs), sprinkler, access route

• Are firefighter access routes to the building provided?
• Are firefighting services (FDCs, standpipes, hydrants) maintained and accessible?
• Do drawings provided to the fire department upon arrival show the location of firefighting systems?
• Is the site address sign (when required by local bylaw) visible and legible to emergency crews from the street?

Fire extinguishers

• Is there sufficient quantity and type on-site such as:
  • 2-A:10-B:C on movable equipment?
  • 4-A:40-B:C in all other locations?
• Have they been serviced within the last year?
• Are they provided at or near fuel-fired equipment?
• Are they mounted with proper signage at exit locations within the required travel distance?
• Are they adjacent to any hot works operations (for example, cutting torch, welding, torching, and so on)?

Hot works operations

• Is the area clear of flammable and combustible materials?
• Is a fire watch assigned during a hot works operation and for 60 minutes after its completion?
• Is there a final inspection of the hot works area 4 hours after completion?
• Are the hot works in the proximity of combustible or flammable materials?
• Have provisions been made for protection of combustible or flammable materials by using a non-combustible/thermal barrier or other means?
• Is the work being performed by trained or certified personnel?
• Is a fire extinguisher present at all times such as:
  • 2-A:10-B:C on movable equipment?
  • 4-A:40-B:C in all other locations?
• Is proper ventilation provided as required?
• Are hot tar pots for any on-site roofing replacement operations provided with fire extinguishers, supervised by trained personnel and located away from combustible materials?

Flammable and combustible storage

• Are flammable and combustible liquids properly stored, handled and used in and around the building?
• Are non-petroleum based compressed gases properly stored, handled and used in and around the building?
• Is the storage area separated from combustible material by 3 metres?
• Is the storage area locked and vented?
• Is the storage area protected from vehicular/industrial motorized traffic?
• Do containers and/or storage areas have proper signage/placards in place?
• Is there a current/updated list of dangerous goods on-site such as the material safety data sheets (MSDS), as per the Workplace Hazardous Materials Information System (WHMIS)?
• Are portable extinguishers provided in close proximity to storage and work areas such as:
  • 2-A:10-B:C on movable equipment?
  • 4-A:40-B:C in all other locations?
• Is the storage area away from egress and access routes?

Electrical installations and petroleum gases

Do the electrical installations, storage and use of petroleum gases comply with the requirements of the Safety Standards Act and pursuant regulations? (Contact Technical Safety BC for more information.)

Security

• What type of on-site security is provided: for example, locked gate, monitored alarm and/or CCTV, 24 hour or nightly walk around?
• Do security personnel have knowledge of, and understand, their expected role described in the site’s fire safety plan?
• Can the fire department effectively communicate with the security personnel during an emergency?
• Do security personnel have access (keys) to locked areas?

Contact personnel

• Is there a list of names and telephone numbers of persons to be contacted during and after normal operating hours or in the event of an emergency?
• Are the contact personnel able to respond in a timely fashion?
• What is their estimated response time?

Building diagrams

• Are diagrams available on-site? These diagrams should indicate:
  • Layout of each floor area
  • Muster point(s)
  • Location of nearest hydrant(s)
  • Location of fire protection equipment
  • Exit paths
  • Service rooms

The fire safety plan must be reviewed annually at minimum and updated whenever changes occur, such as new staff or new floor layout. The plan that is developed for a building is used to maintain and protect the building and its occupants. It’s very important that all supervisory staff remain familiar with the plan, so they are aware of how it pertains to their responsibilities. The fire safety plan must be retained on site for review by the fire department, supervisory staff, personnel and other applicable regulatory authorities.

Although the BCFC does not regulate the format of a fire safety plan some local fire departments like the fire safety plans in their jurisdiction to be uniform. The Fire Prevention Officers’ Association of British Columbia (FPOABC) website provides an example of a format that may provide useful information that will help you when developing your fire safety plan in cooperation with the local fire department. Although the Office of the Fire Commissioner is not responsible for the content on non-government websites, the link to the FPOABC fire safety plan documentation is provided.

It may also be beneficial to owners to obtain the services of a consultant who specializes in fire safety planning and risk management assessments. This consultant would oversee the fire safety plan’s development and implementation. This is especially useful to owners who have neither the time nor the expertise to develop their own plan or who do not have a fire department available to them.

The purpose of this bulletin is to provide:

• Owners with the British Columbia Fire Code (BCFC) requirements for confined spaces such as shipping containers being used for the storage of fuel fired equipment, containers of flammable liquids or explosives
• Emergency response personnel with information regarding their safe conduct when working around metal shipping containers and similar confined spaces where flammable liquids, or explosives are stored

Background

In December 2011, a fire officer was fatally injured as the result of an explosion in a metal storage container (sea can). The storage container was being used for general storage purposes, which included gasoline-fuel fired tools and approximately one litre of methyl hydrate.

The locked container was exposed to direct fire impingement and radiant heat on three sides caused by a burning wood frame building. As a result of that heat, some of the combustible material inside ignited. At the same time, the fuel tank(s) on gasoline-fuel fired tools allowed gasoline vapor to escape into the confined space. The requisite fuel-to-air mixture was eventually achieved and was ignited. The explosion caused both doors to disengage, sending them approximately 40 meters from the storage container. One of the doors hit a fire officer, causing fatal injuries. The explosion occurred an estimated two hours after the arrival of fire department resources.

Discussion

The fire investigators concluded that the amount of flammable liquids stored in this storage unit was well within the amount permitted by the BCFC. In this incident extenuating factors led to the catastrophic failure of the container. Two of those factors were:

• Extreme external heating of a non-combustible closed storage container
• Structural characteristics that initially contained the explosion until the weakest part of the unit failed

These structures can pose a unique and previously unidentified risk to fire service personnel when responding to fires where metal storage containers (sea cans) are present. It is recognized that these containers are used extensively throughout the province and under most circumstances do not represent significant issues. However, in some circumstances special precautions should be considered by responding fire personnel when the potential for an explosion exists or may exist.

British Columbia Fire Code requirements

Storage of flammable and combustible liquids for incidental use in ancillary outdoor enclosures:

• A fire safety plan developed in cooperation with local fire department is required in all buildings and open areas where flammable/combustible liquids are stored, handled or used [BCFC, Div. B, 4.1.5.5.]
• Ventilation of an enclosed space is required to conform to BCFC, Div. B, 4.1.7.2. if open containers are stored
• Ventilation of an enclosed space is not required if class 1 flammable liquids are stored in closed containers. [BCFC, Div. B, 4.1.7.2.(2)]
  Note: Closed container means a container sealed by means of a lid or other device such that neither liquid nor vapour will escape from it at ordinary temperatures. [BCFC, Div. A, 1.4.1.2.(1)]

Where the storage of flammable/combustible liquids are secondary to the principal activity the limit of flammable/combustible liquids in closed containers that can be outside of storage cabinets is 600 litres, of which only 100 litres can be Class 1A liquid(s). [BCFC, Div. B, 4.2.8.]

Individual storage areas are required to be separated by a minimum width of 2.4 metres [BCFC, Div. A, 1.4.1.2.(1)]

Suggested safety advice

These storage units should be listed in the site owner’s fire safety plan, and any stored flammable liquids or hazardous materials should be identified by dangerous goods placards affixed to the exposed sides of the container to provide responders with information regarding hazardous contents.

Fire departments should include in the pre-fire plan the content of such containers, their locations on the lot and proximity to combustible structures that may contribute to excessive heating of the storage unit should adjacent materials be ignited.

The hazard must be recognized in the initial assessment of an incident and measures taken to isolate the hazard or modify firefighter suppression tactics. If there is flame impingement/exposure to any structure, container or vessel it should be investigated, assessed and monitored throughout the incident.

To reduce the chance of injury to a firefighter from explosion, the use of unattended hose streams and the firefighters’ distance from the storage unit should be considered if there is, or has been, significant direct or indirect heat applied to the container by the fire. These storage units or containers should be given the same consideration as pressure vessels when flammable or combustible liquids are suspected to be stored inside. Many of these containers are unable to vent when sealed and therefore greater exclusion zones should be maintained at weaker points of the containers such as doors, where the container would be most likely to fail.

Whenever possible the site owner or coordinator should be encouraged to provide some physical separation between these containers and combustible structures to prevent excessive heating during fire situations.