OFM - TG-04-2002: Assessing Existing Fire Separations and Closures
Office of the Fire Marshal
ASSESSING EXISTING FIRE SEPARATIONS AND CLOSURES
The reproduction of this guideline for non-commercial purposes is permitted and encouraged. Permission to reproduce the guideline for commercial purposes must be obtained from the Office of the Fire Marshal, Ontario.
TABLE OF CONTENTS
APPENDIX A – Sample Retrofit Fire Separation Checklist for Walls, Floor Ceiling
Assemblies and Closures
APPENDIX B – Sample Retrofit Fire Separation and Closure Assessment Summary Sheet
OFM Section: Fire Safety Standards at (416) 325-3100
The reproduction of this guideline for non-commercial purposes is permitted and encouraged. Permission to reproduce the guideline for commercial purposes must be obtained from the Office of the Fire Marshal, Ontario.
This instructional guideline is intended to assist fire officials and building owners, including their agents, to assess existing fire separations and closures in fire separations in order to determine compliance with the Fire Code. The guideline also provides assistance for documenting compliance or non-compliance with Part 9 Retrofit of the Fire Code based upon observations made during an inspection. This guideline is intended for guidance only and is not to be considered a statement of law in this area.
This guideline is intended to help people understand how to interpret and apply the requirements of the Ontario Fire Code (OFC) respecting fire separations and closures regulated under Section 2.2 and Part 9 Retrofit.
The guideline provides example illustrations, photographs and practices that will assist a person in:
- • correctly interpreting the regulation requirements,
- • assessing fire separations and closures in existing buildings, and
- • documenting observations and conclusions.
The person conducting the assessment and interpreting the OFC requirements must know and understand the definitions assigned to various words and terms used in the OFC. The following words and terms have the following meaning in the OFC and this guideline:
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.
Building means any structure used or intended for supporting or sheltering any use or occupancy.
Building area means the greatest horizontal area of a building above grade within the outside surface of exterior walls or within the outside surface of exterior walls and the centre line of firewalls.
Closure means a device or assembly for closing an opening through a fire separation such as a door, a shutter, wired glass or glass block and includes all components, such as hardware, closing devices, frames and anchors.
Combustible construction means that type of construction that does not meet the requirements for noncombustible construction.
Dwelling unit means a suite operated as a housekeeping unit, used or intended to be used as a domicile by one or more persons and usually containing cooking, eating, living, sleeping and sanitary facilities.
Exit means that part of a means of egress, including doorways, that leads 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 public thoroughfare.
Fire compartment means an enclosed space in a building that is separated from all other parts of the building by enclosing construction that provides a fire separation having a required fire-resistance rating.
Fire damper means a closure that consists of a damper installed in an air distribution system or in a wall or floor assembly that is normally held in the open position and that is designed to close automatically in the event of a fire in order to maintain the integrity of the fire separation.
Fire-protection rating means the time in hours or fraction thereof that a closure, window assembly or glass block assembly will withstand the passage of flame when exposed to fire under specified conditions of test and performance criteria, or as otherwise prescribed in the Building Code.
Fire resistance means the property of a material or assembly in a building to withstand fire or give protection from it and is characterized by the ability of the material or assembly to confine a fire or to continue to perform a given structural function or both.
Fire-resistance rating means the time in hours or fraction thereof that a material or assembly of materials will withstand the passage of flame and the transmission of heat when exposed to fire under specified conditions of test and performance criteria, or as determined by extension or interpretation of information derived therefrom as prescribed in the Building Code.
Fire separation means a construction assembly that acts as a barrier against the spread of fire and may or may not have a fire-resistance rating or a fire-protection rating.
Fire stop means a draft-tight barrier within or between construction assemblies that acts to retard the passage of smoke and flame.
Firewall means a fire separation of noncombustible construction that subdivides a building or separates adjoining buildings to resist the spread of fire that has a fire-resistance rating as prescribed in the Building Code and that has structural stability to remain intact under fire conditions for the required fire-rated time.
Floor area means the space on any storey of a building between exterior walls and required firewalls and includes the space occupied by interior walls and partitions, but does not include exits and vertical service spaces that pierce the storey.
Heavy timber construction means that type of combustible construction in which a degree of fire safety is attained by placing limitations on the sizes of wood structural members and on thickness and composition of wood floors and roofs, by avoidance of concealed spaces under floors and roofs and by use of approved fastenings, construction details and adhesives for structural members.
Major occupancy means the principal occupancy for which a building or part thereof is used or intended to be used, and includes the subsidiary occupancies that are an integral part of the principal occupancy.
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 both exits and access to exits.
Noncombustible construction means that type of construction in which a degree of fire safety is attained by the use of noncombustible materials for structural members and other building assemblies.
Occupancy means the use or intended use of a building or part thereof for the shelter or support of persons, animals or property.
Public corridor means a corridor that provides access to exit from more than 1 suite.
Retrofit means the minimum performance requirements for life safety for existing buildings.
Service room means a room in a building used to contain equipment associated with building services.
Service space means space in a building used to facilitate or conceal the installation of building service facilities such as chutes, ducts, pipes, shafts or wires.
Smoke alarm means a combined smoke detector and audible alarm device that is designed to sound an alarm within the room or suite in which it is located when there is smoke within the room or suite.
Storey means that portion of a building that is situated between the top of any floor and the top of the floor next above it, and where there is no floor above it, that portion between the top of the floor and the ceiling above it.
Suite means a single 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 as well as individual stores and individual or complementary rooms for business and personal services occupancies.
Vertical service space means a shaft oriented essentially vertically that is provided in a building to facilitate the installation of building services including mechanical, electrical and plumbing installations and facilities such as elevators, refuse chutes and linen chutes.
Fire separations are provided within buildings to limit the spread of fire and the premature collapse of the building or portion of the building. Certain rooms, areas, suites and major occupancies in buildings are generally fire separated into fire compartments. These fire compartments limit fire spread for a specified period of time intended to allow persons to escape and to limit fire growth until the fire department extinguishes the fire.
Consider a fire compartment to be a box (Refer to Figure 1). Most multi-tenant buildings have many fire compartments (boxes), which are situated side by side and on top of each other. Generally, each fire compartment has walls, a floor and a ceiling. The walls are fire separations that limit the spread of fire horizontally from one fire compartment to an adjoining fire compartment. The walls may also support the load of the building above. The top and bottom of each fire compartment are often referred to as floor assemblies when they separate one storey from another. The floor assemblies are fire separations that limit the spread of fire vertically from one fire compartment to another.
2.1 How Fire Separations Limit The Spread Of Fire
Fire separations can be constructed of combustible or non-combustible elements or a combination of materials. For example, masonry walls and reinforced concrete floor slab assemblies are considered to be non-combustible. Due to the physical characteristics of the materials, they have substantial strength and will effectively limit the spread of fire provided the assembly has been properly constructed and maintained.
The design and types of material used in the construction of a fire separation will determine its fire-resistance rating. The fire-resistance rating of a fire separation means the time in hours or fractions thereof that a material or assembly of materials will withstand the passage of flame and transmission of heat when exposed to fire under specified conditions of test and performance criteria, or as determined by extension or interpretation of information prescribed in the Ontario Building Code (OBC).
For example, walls consisting of wood studs with lath and plaster, or gypsum board membranes are common fire-separation assemblies found in existing buildings. The strength of the assembly comes from the wooden structural elements. The fire-resistance qualities of the assembly come from the plaster or gypsum board membranes. The design of the fire separation, the thickness and qualities of materials used and the manner of construction will determine the fire-resistance rating for the entire assembly.
In some buildings combustible materials are not desired for use in the construction of the building. In these instances the fire separations (partition walls) are commonly constructed of steel studs with gypsum board membranes. These fire separations generally do not act as structural supporting walls, but provide a vertical fire separation between different fire compartments on the same storey.
Floor assemblies and roof assemblies that have a specified required fire-resistance rating are structurally supported by walls, columns or arches that have been designed and constructed with the same fire-resistance rating as the assembly they support. This practice prevents premature collapse of the structure under fire conditions resulting from the supporting elements located below having a lower fire-resistance rating.
It is important to note that the fire-resistance rating of an assembly is based upon all of the components of the assembly. The individual elements in themselves do not have a fire-resistance rating (Refer to Figure 2).
Fire separations must be constructed as a continuous element to act as a barrier against the spread of fire. A fire separation is required to be continuous and extend from one fire separation to another or to an exterior wall or roof. Appropriate fire stopping is also essential to retard the passage of smoke and flame, particularly at locations where a vertical fire separation meets a floor or roof assembly.
For example, where a vertical fire separation that requires a fire-resistance rating abuts a horizontal fire separation involving a T-Bar ceiling assembly, the wall must extend through the concealed ceiling space and terminate so that a smoke-tight joint is provided. This is necessary where the vertical fire separation buts against or intersects the floor, roof slab or deck (Refer to Figures 3 and 4).
2.2 Building Services and Service Spaces
Buildings have a variety of building services including but not limited to electrical, plumbing, telephone, cable TV, data cables, elevator, garbage chutes, linen chutes and heating, ventilation and air conditioning (HVAC).
Plumbing, wiring and mechanical services commonly pass through required fire separations. The penetrations in the fire separations should be examined to determine if fire stopping has been provided at the penetrations. These penetrations are often poorly sealed or neglected when they are situated within concealed spaces.
Certain HVAC ducts that pass through a required fire separation are required by the OBC to have a fire damper installed at these penetrations. The fire damper is intended to maintain the integrity of the fire separation. Generally, Retrofit Part 9 of the OFC does not require a fire damper to be installed in existing noncombustible ducts that breach an existing fire separation.
Service spaces are provided in buildings to facilitate or conceal the installation of building service facilities such as chutes, ducts, pipes, shafts or wiring. These service spaces may be oriented horizontally or vertically.
Vertical service spaces are shafts that are provided in a building to facilitate the installation of building services such as mechanical, electrical and plumbing installations and facilities including elevators, refuse chutes and linen chutes. For example, special attention should be taken to examine the fire separations where plumbing and other services enter a fire compartment, such as under kitchen sinks and inside bathroom vanities, etc.
2.3 Protection Against Structural Collapse Due To Fire Exposure
Structural elements that support a building under normal conditions can be located within fire separations, or independent from them. To maintain the structural integrity of a building during a fire, these independent elements often have to be protected from fire exposure. For example, when wood is exposed to fire, it can be consumed, resulting in the collapse of the structure. Similarly, structural steel elements of a building will weaken and distort when exposed to extreme temperatures from fire and result in collapse of the structure.
In order for these elements to withstand exposure to fire they are thermally protected from fire using accepted methods. Thermal protection can be obtained through the use of a variety of materials such as:
- lath and plaster
- gypsum board
- sprayed-on thermal coating
- brick or block
- listed suspended ceiling assemblies
Unprotected steel support columns or beams, floor assemblies consisting of open web steel joists, floor assemblies consisting of exposed wood joists and deck, exposed wooden posts or lintels could be of concern. When exposed to a fire, these elements could prematurely fail and contribute to the spread of fire or collapse of the structure.
2.4 Heavy Timber Construction
There are buildings constructed of combustible construction in which the degree of fire resistance is attained by placing minimum size restrictions on the sizes of wood structural members and on the thickness and composition of wood floors and roofs, and by the avoidance of concealed spaces. In these types of buildings, the wooden structural elements are not protected from fire exposure using insulating membranes. For information relating to buildings of "heavy timber construction", refer to the OBC.
3.0 ASSESSING EXISTING FIRE SEPARATIONS FOR COMPLIANCE WITH SECTION 2.2 (MAINTENANCE O FIRE SEPARATIONS)
The OBC has regulated the construction of fire separations since1976. Prior to that (pre-1976), municipal building by-laws may have been in place stipulating requirements for the construction of fire separations including specifications for required fire-resistance ratings. The OFC is a companion document to the OBC. The OFC indicates that the owner is responsible for repairing damaged fire separations between major occupancies and between rooms and spaces.
As noted earlier, fire separations are to be constructed as a continuous element to act as a barrier against the spread of fire. Once constructed, however, the fire separations can become damaged from a variety of causes. For example, openings could be made in the fire separations to facilitate installation of plumbing, wiring, heating and ventilating equipment. Generally the OBC regulates these types of alterations and the fire separations in these areas must be properly fire stopped. Where fire separations have been damaged for whatever reason, the OFC requires that repairs be made to maintain the fire-resistance qualities of the fire separation.
In other examples, fire separations can be damaged from:
- deterioration resulting from water exposure,
- deterioration from fire exposure,
- physical abuse by people or equipment damaging the structure or protective membranes,
- failure to replace ceiling tiles in a listed floor ceiling or roof assembly and maintain hold down clips,
- the creation of passageway openings between fire compartments and failing to protect the opening by installing a suitable closure,
- building settlement resulting in cracks,
- corrosion of steel structural elements,
- rotting or decaying wooden structural elements,
Examples of improper or damaged fire separations;
Fire separation damaged by physical abuse
Closure not provided in passageway between two fire compartments
Fire separation damaged by water
Hole cut in fire separation
3.1 Penalties and Enforcement
When fire separations are damaged, the owner is responsible for promptly repairing the damage.
The building owner or property manager should always contract trades people working in the building to repair damaged fire separations promptly when their work involves breaching any fire separation.
Failure to repair damaged fire separations may lead to prosecution. Upon conviction in accordance with the FPPA, an individual can receive a fine of not more than $25,000 or imprisonment for not more than one year, or both (for each offence). A corporation convicted of an offence is liable to a fine of not more than $50,000 for each offence.
When fire officials observe damaged fire separations between major occupancies they should inform the owner of the deficiency by making reference to Article 188.8.131.52. and provide a list of examples where the damage was observed. Article 184.108.40.206. states:
Where fire separations between major occupancies are damaged in a manner so as to affect the integrity of their fire-resistance rating, such damaged fire separations shall be repaired so that the integrity of the fire separations is maintained.
When fire officials observe damaged fire separations elsewhere in a building, they should inform the owner of the deficiency by making reference to Article 220.127.116.11. and provide a list of examples where the damage was observed. Article 18.104.22.168. states:
Where fire separations between rooms, corridors, shafts and other spaces are damaged so as to affect the integrity of their fire-resistance rating, the damaged fire separations shall be repaired so that the integrity of the fire separations is maintained.
Retrofit requirements in Part 9 of the OFC are applied to a building or portion of a building in order that a minimum level of life safety can be achieved by satisfying minimum performance levels specified by the regulation. In many instances, existing fire separations may be deemed by Retrofit to satisfy the performance requirements that are outlined by the regulation. However, in other instances the lack of fire separations or the inadequacy of existing fire separations will require the owner to undertake construction in order to comply. Construction may involve upgrading an existing assembly or constructing a new assembly. When construction is going to take place a building permit is generally required. The OBC requirements apply to the construction or renovation of the fire separation with the exception that, the required fire-resistance rating is determined by the Retrofit requirement in the OFC.
The containment requirements imposed by Retrofit are intended to control the size of the fire and smoke spread, and are important for two reasons. The first is to allow the occupants sufficient time to evacuate the building and the second is to aid firefighters in their suppression efforts.
Slowing the spread of fire and smoke is of particular importance where the occupants of a building are asleep or require assistance to evacuate. Under these circumstances more time is required to become aware of a fire emergency and begin evacuation. The potential for the means of egress, access to exit or exit being blocked by fire or smoke is compounded by the fact that multiple fire compartments often share the access to exits and exits, some of which may contain storage or hazardous service areas.
The requirements for fire separations in Retrofit generally address the following:
- the construction and fire-resistance rating of floor assemblies, wall assemblies and structural supports,
- fire separations between occupancies,
- fire separations between suites, rooms, dwelling units and corridors,
- fire separations for areas of hazardous occupancies, and
- fire separations for vertical service spaces.
4.1 Understanding The Regulation Requirements
Persons assessing the building and determining Retrofit compliance must understand how the regulation is to be applied.
Where the OFC requirement refers to an article of the OBC, it is necessary to read the OBC article and consider its content in the context of the Retrofit requirement.
For example, Sentence 22.214.171.124.(2) of the OFC states:
Fire separations required by this Section to have a fire-resistance rating shall be in accordance with Subsection 3.1.7. and Articles 126.96.36.199., 188.8.131.52., 184.108.40.206. and 220.127.116.11. of the 1990 Building Code.
To assist the user of the OFC to quickly refer to the referenced requirements, the applicable OBC references have been consolidated in the Appendix to the Office Consolidation Version of the OFC. This version is available at the Office of the Fire Marshal Website at http://www.ofm.gov.on.ca.
- For occupancies regulated under Sections 9.2, 9.3 or 9.4, refer to Appendix A
- For occupancies regulated under Sections 9.5 or 9.6, refer to Appendix B
- or Two Unit Residential Occupancies regulated under Section 9.8, refer to Appendix C
4.2 Existing Fire Separations Deemed To Be Acceptable
Each Section of Retrofit recognizes that some existing materials in wall or floor assemblies have inherent fire resistance characteristics. For example, in Section 9.5 [refer to Sentences 18.104.22.168.(3) and (4)], existing assemblies using lath and plaster, gypsum wallboard or heavy timber construction in conformance with Article 22.214.171.124. of the OBC, are acceptable in lieu of a 45-min fire-resistance rating.
In another example, under Section 9.6 [refer to Sentence 126.96.36.199.(3)], where a 1-hr or less fire-resistance rating is required, existing wall assemblies, floor assemblies and their supporting assemblies consisting of
(a) reinforced concrete,
(b) masonry, or
(c) clay tile with plaster or gypsum board finish on both sides
shall be deemed to be equivalent to a fire separation having a 1-hr fire-resistance rating.
4.3 Construction and Floor Assembly Requirements
Determination of Retrofit requirements for fire separations is often dependant upon the size of the building and the nature of the building construction and its use. Examples of this include;
- Section 9.3 - Articles 188.8.131.52. to 184.108.40.206.
- Section 9.4 - Articles 220.127.116.11. to 18.104.22.168.
- Section 9.5 - Articles 22.214.171.124. to 126.96.36.199.
- Section 9.6 - Articles 188.8.131.52. to 184.108.40.206.
The applicable construction requirements outlined in the Retrofit articles listed above are intended to ensure a minimum level of structural integrity during fire conditions. They specify the minimum fire-resistance rating for floor assemblies and structural elements such as walls, columns and arches that support the floors. The required fire-resistance rating varies according to the building height and/or the building area. Generally, larger buildings require more time for evacuation and suppression and therefore must maintain a higher level of structural integrity under fire conditions.
Along with building size, building combustibility is a major factor in determining the containment measures that must be provided. The rate at which a fire grows during the early stages of development is relatively unaffected by the combustibility of the structural elements of the building as it usually only involves building contents. As well, combustible or noncombustible structural elements are usually protected with a thermally insulated covering consisting of noncombustible materials. However, once this protection fails, the structural elements are exposed and, if combustible, contribute fuel to the fire. At this point the rate of fire growth is substantially higher in combustible buildings resulting in a greater threat to life. Since larger buildings require longer evacuation times, additional protection provided by early warning smoke detectors in corridors or sprinklers are required for large combustible buildings.
4.4 Alternative Features Deemed To Be Acceptable
In some circumstances Retrofit also permits alternative features to be accepted in lieu of providing the desired fire-resistance rating for the floor assemblies and supporting elements.
For example, refer to Section 9.5, Articles 220.127.116.11. and 18.104.22.168. As you will see, Sentences 22.214.171.124.(1) and (2) establish the building size criteria with which the floor assemblies and supporting elements are to have a 30-min fire-resistance rating. Sentences 126.96.36.199.(3) and (4) and Article 188.8.131.52. provide a waiver of the required 30-min fire-resistance rating of floor assemblies between the basement and first floor based upon the provision of other design features.
Examples where this provision is applied in Retrofit include:
- Section 9.3 - Article 184.108.40.206.
- Section 9.4 – Sentences 220.127.116.11.(3) and 18.104.22.168.(3) and (4) and Article 22.214.171.124.
- Section 9.5 - Sentences 126.96.36.199.(3) & (4), Article 188.8.131.52., Sentences 184.108.40.206.(4), and 220.127.116.11.(2) and (3)
4.5 Fire Separations Between Major Occupancies
Occupancies regulated under Retrofit often must be separated from other major occupancies by a fire separation having a specified fire-resistance rating. Some Retrofit Sections permit alternative features to be accepted in lieu of providing the desired fire-resistance rating.
Examples of this include;
- Section 9.2 - Article 18.104.22.168.
- Section 9.4 - Article 22.214.171.124.
- Section 9.5 - Article 126.96.36.199.
- Section 9.6 - Article 188.8.131.52.
4.6 Fire Separations Between Bedrooms Not Within Dwelling Units, Dwelling Units and Public Corridors
Dwelling units and sleeping rooms not within dwelling units are required to be fire separated from adjacent rooms and areas by fire separations having a specified fire-resistance rating. Additionally, some sections of Retrofit require public corridors to be separated from adjacent rooms and areas by fire separations having a specified fire-resistance rating. The purpose of these requirements is to protect the occupants from fire in adjacent rooms not under their control and to confine fire to the fire compartment of origin. It also provides a protected escape route for occupants to reach available exits (Refer to Figure 6).
In some instances alternative features such as providing sprinkler protection is accepted in lieu of the fire separation having the specified fire-resistance rating.
These provisions are found in:
- Section 9.3 - Article 184.108.40.206.
- Section 9.4 - Article 220.127.116.11.
- Section 9.5 - Article 18.104.22.168.
- Section 9.6 - Article 22.214.171.124.
- Section 9.8 - Article 126.96.36.199.
4.7 Fire Separations For Required Exit Stairways
Requirements for the protection of required exit stairways are found in the following Retrofit articles including: 188.8.131.52. to 184.108.40.206, 220.127.116.11., 18.104.22.168., 22.214.171.124., 126.96.36.199. and 188.8.131.52.
In order to protect people using exit stairways from fire on any floor area, the required exit stairway(s) must be separated from the remainder of the building by a fire separation having a specified fire-resistance rating.
4.8 Fire Separations For Areas Requiring Special Consideration
Retrofit identifies various rooms or spaces that require special consideration. In many instances, these spaces are required to be enclosed by fire separations having a specified fire-resistance rating. The enclosure confines the fire to the area of fire origin. Areas requiring special attention may include:
- rooms containing fuel-fired appliances,
- storage garages,
- storage rooms,
- garbage rooms,
- garbage chute and laundry chute discharge rooms,
- incinerator rooms, and
- vertical service spaces
Examples of these requirements include but are not limited to:
Fuel-Fired Appliance Service Rooms
Refer to Figure 8 and Article 184.108.40.206. as an example of Retrofit requirements for fuel-fired appliance service rooms. Fuel-fired appliances are required to be enclosed in a service room separated from the remainder of the building by a fire separation having a 45-min fire-resistance rating with some exceptions. Sentences 220.127.116.11.(1) and (2) state that fuel-fired appliances are not required to be fire separated from the remainder of the building where the building height is not greater than 2 storeys or the building area is less than 400m², or the fuel-fired appliance serves only one suite or room.
Where the vertical fire separation is provided and the service room is sprinklered in the manner specified in Sentence 18.104.22.168.(3), the fire separation above the service room does not require a fire-resistance rating.
Special consideration would have to be made for providing make-up air for the operation of the fuel-fired appliances.
Vertical Service Spaces, Refuse and Linen Chutes
*Where an existing closure is provided, it must be maintained.
Refer to Figure 9 and Articles 22.214.171.124 and 126.96.36.199. as examples of Retrofit requirements for vertical service spaces and for linen or refuse chutes.
Vertical service spaces are extremely vulnerable to fire and smoke spread if not adequately sealed. The requirement in Sentence 188.8.131.52.(1) requires the shaft to be separated by a fire separation having a fire-resistance rating equivalent to that required for the floor assembly through which it passes.
There is also provision in sentence 184.108.40.206.(2) to accept existing shaft construction where all openings are adequately sealed to limit smoke movement.
Linen and refuse chutes are required to be fire separated in accordance with the requirements for vertical service spaces. In addition, the room into which the chute discharges is required to be separated from the remainder of the building by a fire separation having a 1-hr fire-resistance rating. Sprinklers are required in both the chute and discharge room.
Openings in fire separations are generally required to be protected with suitable closures to limit the spread of fire through the opening from one fire compartment to another. The OFC defines a “closure”. Refer to the definitions for “closure” and “fire-protection rating” in Section 1.2 of this guideline.
Closures can consist of a variety of materials. The closures can be permanently mounted in the fire separation and be fixed shut (i.e. wired glass window, glass blocks, etc.) or they may be capable of being opened or closed when necessary (i.e., door, shutter, damper, etc.). Refer to Figure 10.
When closed, closures limit the spread of fire by virtue of their physical construction. Under the OBC and OFC Retrofit requirements, closures in required fire separations are required to have a specified "fire-protection rating". Closures and frames usually have a permanent label attached to them identifying their listed fire-protection rating.
OFC Article 220.127.116.11. states:
Where closures are damaged so as to affect the integrity of their fire-protection rating, the damaged closures shall be repaired so that the integrity of the closures is maintained.
Alternatively, damaged closures may be replaced.
Examples of damaged closures can include but are not limited to:
Damaged wired glass screen.
Bent door that does not properly close off the opening in a fire separation.
Door modified improperly by the installation of a vent.
Article 18.104.22.168. states:
Closures in fire separations shall be maintained to ensure that they are operable at all times by:
(a) Keeping fusible links and heat or smoke actuated devices undamaged and free of paint and dirt
(b) Keeping guides, bearings and stay rolls clean and lubricated
(c) Making necessary adjustments and repairs to door hardware and accessories to ensure proper closing and latching.
Article 22.214.171.124. specifies that doors in fire separations shall not be blocked or wedged open.
Article 126.96.36.199. specifies that doors in fire separations shall be inspected monthly. “Inspect” is a defined word meaning, conducting a physical examination to determine that the device or system will apparently perform in accordance with its intended function.
Further, Article 188.8.131.52. states:
Any appliance, device or component of a device that does not operate or appear to operate as intended when checked, inspected, or tested as required by this Code shall be repaired or replaced if the failure or malfunctioning of the appliance, device or component would adversely affect fire or life safety.
“Check” means conducting a visual observation to ensure the device or system is in place and is not obviously damaged or obstructed.
Article 184.108.40.206. requires that doors in fire separations in occupied buildings shall be checked as frequently as necessary to ensure that they remain closed unless the door is designed to close automatically in the event of fire, or doors for which an approved fire safety plan contains provisions for closing in the event of fire.
Article 220.127.116.11. specifies that fire dampers and fire-stop flaps shall be inspected annually, or on an approved time schedule.
Cable prevents fire damper from closing properly.
Article 18.104.22.168. specifies that door openings and the surrounding areas shall be kept clear of anything that would be likely to obstruct or interfere with the free operation of the door.
6.1 Penalties and Enforcement
The owner is responsible for conducting inspections and checks and for initiating repairs and service.
Failure to conduct the required maintenance may lead to prosecution. Upon conviction, an individual can receive a fine of not more than $25,000 or imprisonment for not more than one year, or both (for each offence). A corporation convicted of an offence is liable to a fine of not more than $50,000 for each offence.
When fire officials observe damaged closures, they should inform the owner of the violation by making reference to the applicable Article(s) under Subsection 2.3, and provide a list of examples where the defective conditions are observed.
To help understand how to apply and interpret Retrofit requirements for closures, an example is provided. For this purpose, the applicable requirements under Section 9.5. will be examined and analysed.
7.1 Understanding The Regulation Requirements
The person assessing the closures and determining Retrofit compliance must understand how to apply the regulation.
Similar to requirements for fire separations addressed previously in this guideline (Section 4.2), where the OFC requirement refers to an Article of the OBC, it is necessary to read the OBC Article(s) and consider the content in the context of the Retrofit requirement.
Sentences 22.214.171.124.(1) of the OFC states:
Closures in fire separations shall be in accordance with Sentences 126.96.36.199.(2), 188.8.131.52.(1) and 184.108.40.206.(1) and Article 220.127.116.11. of the 1990 Building Code.
Sentence 18.104.22.168.(2) of the OFC states:
Openings in a fire separation having a 30-min fire-resistance rating shall be protected with closures having a 20-min fire-protection rating.
The OBC references below state:
22.214.171.124.(2) Except as provided in Sentence 126.96.36.199.(1), the fire-protection rating of closures shall conform to Table 3.1.8.A. for the required grade of fire separation.
188.8.131.52.(1) A door assembly having a fire-protection rating of not less than 20 min is permitted to be used as a closure in
(a) a fire separation not required to have a fire-resistance rating more than 1 h and located between
(i) a public corridor and a suite,
(ii) a corridor and adjacent sleeping rooms, or
(iii) a corridor and adjacent classrooms, offices and libraries in Group A, Division 2 major occupancies, and
(b) a fire separation not required to have a fire-resistance rating more than 45 min, located in a building not more than 3 storeys in building height.
184.108.40.206.(1) Except as provided in Sentence (2), every door in a fire separation other than doors to freight elevators and dumbwaiters shall be equipped with a self-closing device designed to return the door to the closed position after each use.
220.127.116.11. Except as permitted in Subsection 3.3.3. (not relevant to Fire Code reference), every swing-type door in a fire separation shall be equipped with a positive latching mechanism designed to hold the door in the closed position after each use.
Fire-Resistance Rating of Fire Separation, h
Required Fire-Protection Rating of Closure, h
After considering the above, Sentences 18.104.22.168.(1) and (2) of the OFC can be interpreted in the following manner;
- first, it is necessary to identify the required fire-resistance rating for the fire separation under consideration,
- determining the required fire-protection rating for the closure is based upon the information derived from Table 3.1.8.A or
- based upon information contained in Sentence 22.214.171.124.(1) as applicable, or
- based upon information contained in OFC Sentence 126.96.36.199.(2), and
- closures are required to be equipped with a self-closing device, and
- closures are required to be equipped with a positive latching mechanism.
7.2 Existing Closures Deemed To Be Acceptable
Each Section of Retrofit recognizes that some existing closures have inherent fire resistance characteristics. For example Sentences188.8.131.52.(3) and (4) state;
(3) Where a 45-min fire-protection rating is required, existing closures consisting of
(a) hollow metal or kalamein doors in hollow metal frames, with openings, if any, protected by wired glass, and equipped with self-closing devices, or
(b) wired glass screens set in fixed steel frames
shall be deemed to be in compliance with Sentence (1).
(4) Where a 20-min fire-protection rating is required, existing closures consisting of 45 mm (1 3/4-in) solid core wood doors installed in solid wood or hollow metal frames and equipped with self-closing devices shall be deemed to be in compliance with Sentences (1) and (2).
7.3 Alternative Features Deemed To Be Acceptable
In some circumstances Retrofit also permits existing closures to be acceptable, provided alternative compensating features are implemented. For example, Sentence 184.108.40.206.(5) states:
(5) Existing closures in fire separations to which Article 220.127.116.11. applies shall be deemed to be in compliance with Sentences (1) and (2) where
(a) the floor area is sprinklered, or
(b) interconnected smoke alarms are installed in accordance with Article 18.104.22.168., the building has not more than four dwelling units and the building provides sleeping accommodation for not more than ten persons.
7.4 Other Considerations
Sentences 22.214.171.124.(6), (7) and (8) contain additional requirements or provisions that would apply to closures depending upon the circumstances under consideration.
These Sentences state:
(6) Despite Sentence (1), closures in fire separations to which Article 126.96.36.199. applies do not require self-closing devices, except as required in Sentences 188.8.131.52.(2) and 184.108.40.206.(3).
Sentence (6) can be interpreted to mean that under this section of Retrofit self-closing devices are only required to be installed on existing closures in dead end corridors [220.127.116.11.(2)] and in exit stairways 18.104.22.168.(3)].
(7) Existing operable transoms and glass lights shall be fixed shut and shall meet the fire-protection rating requirements of Sentences (1) and (2).
(8) Despite Sentences (1) and (2), fire dampers or fire-stop flaps are not required in existing noncombustible ducts at penetrations of fire separations.
Sentences (7) and (8) are self-explanatory.
The person who will be assessing the fire separations and closures for OFC compliance should prepare in advance of conducting the actual inspection:
- review this guideline and understand the concepts contained therein,
- review the applicable Section of Retrofit in its entirety and corresponding references to the OBC to determine the requirements for fire separations and closures as they would apply to the building in question, and
- have suitable equipment to facilitate the examination including
- - flashlight or portable lamp (for the examination of concealed spaces, shafts, etc.),
- suitable step ladder (for access to concealed ceiling spaces etc.),
- protective eyewear and clothing (for personal protection and safety),
- screw drivers of various types (for opening access panels and removal of electrical cover-plates to facilitate observations in concealed spaces and to identify the nature of the existing construction materials used),
- a clipboard, pen, paper and sufficient checklists, camera (to aid in documenting observations).
8.2 Conducting The Inspection
The building should be inspected in its entirety (if possible and practical) in a progressive manner from top to bottom, room by room, etc. The vertical and horizontal fire separations and closures for each fire compartment should be inspected.
When conducting the inspection of each fire compartment, the person must determine what occupancies are contained in the adjoining fire compartments (above, below and beside). This is necessary to determine what the requirements are and analyse the suitability of the fire separations and closures based upon the applicable OFC requirements.
Vertical service space locations must be identified. The interior and exterior of the service shafts should be examined in detail whenever possible. When it is not possible to inspect both sides of the vertical service space, special care should be taken to examine the exterior of each service space to identify unprotected penetrations in the fire separation.
When a person conducts an inspection of an existing building to determine compliance with Part 9 Retrofit of the OFC it is not always possible to determine compliance entirely and unconditionally. In a number of instances, a determination of compliance may have to be qualified, and some subjective conclusions must be made by the person conducting the inspection, or by the fire official reviewing an inspection report or other document.
For example, due to concerns for liability, many people conducting an inspection under Retrofit will often qualify their observations. The person may indicate that their conclusions are based on the examination of specific areas inspected within the building or list areas of the building not inspected. Further, the report may state that the examination of the building materials or components was non-destructive in nature and the conclusions are based on observations only. These types of conclusions are by circumstance subjective in nature and may not be precise.
9.1 Sample Forms
The person conducting the inspection may wish to use the following checklists and summary sheet to help document observations and conclusions. A sample form for documenting your observations for each fire compartment is found in Appendix A.
It is important to list the spaces in the building that were not accessible for inspection. This information can be recorded on the sample Summary Inspection Sheet found in Appendix B.
Persons wishing to use these forms are expected to make photocopies of the blank form in quantities desired for future use.
Alternatively, a Microsoft Word version of the forms may be obtained through e-mail by telephoning the Fire Safety Standards Section at (416) 325-3227.
Sample Retrofit Fire Separation Checklist for Walls, Floor/Ceiling Assemblies and Closures
Complete pages 1 and 2 for each fire compartment or for typical fire compartments where appropriate.
Identify the fire compartment(s) being examined, location(s) and its use or occupancy.
(A) Examination of Vertical Fire Separations (Walls)
Describe/identify the occupancy(s) of the adjoining fire compartment(s) situated beside the fire compartment being reviewed.
Identify the required fire-resistance rating(s) required for the walls and the applicable OFC reference.
North Wall - Required fire-resistance rating:
OFC Reference Number:
South Wall - Required fire-resistance rating:
OFC Reference Number:
East Wall - Required fire-resistance rating:
OFC Reference Number:
West Wall - Required fire-resistance rating:
OFC Reference Number:
The existing interior fire separations (walls) situated between fire compartments consist of:
concrete not applicable
concrete block, brick, or stone not applicable
The existing fire separations (walls) situated between fire compartments have surface membranes consisting of:
gypsum board not applicable
lath and plaster not applicable
The existing fire separations (walls) are constructed of other materials Yes No
The fire separations (walls) provide a continuous barrier. There are no gaps, cracks, breaches, or other types of defects noted. Yes No
If “No” describe the defective conditions and locations:
There is a suspended ceiling tile assembly(s). Yes No Not Applicable
The fire separations (walls) situated above the suspended ceiling and located between fire compartments were examined and it was determined that there is a smoke tight barrier provided. Yes No
If “No” describe:
(B) Examination of Horizontal Fire Separations (Floor/Ceiling Assemblies)
Describe the occupancy(s) of the adjoining fire compartments situated above the fire compartment:
Identify the fire-resistance rating required for the floor/ceiling assemblies above the fire compartment and identify the applicable OFC reference for the fire separation:
Required fire-resistance rating:
OFC Reference Number:
Describe the occupancy(s) of the adjoining fire compartments situated below the fire compartment:
Identify the fire-resistance rating required for the floor/ceiling assemblies below the fire compartment and identify the applicable OFC reference for the fire separation:
Required fire-resistance rating:
OFC Reference Number:
The existing fire separation (floor/ceiling assembly) above the fire compartment consists of
concrete unprotected open web steel joist and metal pan unprotected wood
an assembly with a gypsum board membrane an assembly with a lath and plaster membrane
The existing fire separations identified above provide a continuous barrier. There are no gaps, cracks, breaches, evident or other types of defects noted. Yes No
Describe defective conditions and locations:
There is a suspended ceiling tile assembly(s) in the fire compartment. Yes No Not Applicable
If "Yes" complete the following:
The suspended ceiling is part of a listed fire separation. Yes No Undetermined
The portion of the floor/ceiling assembly above the T-Bar suspended ceiling consists of
structural steel and concrete: Yes No
wood joist and sub floor: Yes No
Describe other assembly:
The floor/ceiling assembly of materials above the ceiling tiles was examined and determined that there is a smoke tight barrier provided by the assembly. Yes No
(C) Structural Supporting Elements
The structural supporting elements (walls, column, arches, etc.) of the floor/ceiling assembly have the required fire-resistance rating or suitable protective membranes. Yes No
If “No” describe:
The openings in the fire separations are protected with appropriate closures.Yes No
The closures consist of:
labelled door and frame
fire-protection rating on labels
hollow metal/kalamein door and frame
45mm solid core wood & wood or metal frame
other - describe
equipped with self-closing device
equipped with positive latching mechanism
Print Name of Person Conducting Inspection
Address of building:
Address of Owner:
Number of storeys above grade:
Number of storeys below grade:
Building area (as determined using the OFC definition):
List major occupancies and locations:
Retrofit Section(s) applied:
The required fire separations and closures of each fire compartment in the building were inspected with the exception of the following spaces:
List the fire compartments not inspected, their locations, and the reason for not inspecting.
The fire separations and closures of each fire compartment listed in the attached checklists were inspected by adhering to the practices outlined in the Office of the Fire Marshal guideline "Assessing Existing Fire Separations and Closures for Fire Code Compliance". The attached pages of checklists accurately reflect the observations made at the time of inspection. The fire compartments that were not inspected are listed above and the reasons for not inspecting are stated.
Print Name of Person Conducting Inspection