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When to Submit a Fire Plan? (Part 1 of 2)

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This blog is written based on experience with the New Brunswick Office of the Fire Marshal.  Other jurisdictions may have some different requirements, such as the Nova Scotia Fire Safety Act which requires certain high hazard industrial occupancies to submit building plans for review. Generally, however, this blog is applicable throughout Canada. Your local authority having jurisdiction should be consulted to confirm Fire Plan requirements.

 

A Fire Plan is a set of documents and drawings which show the civil, architectural, electrical, and mechanical design elements of a building confirming compliance with the National Building Code of Canada (NBCC), and other applicable standards. A Fire Plan is required by the Fire Prevention Act (FPA) to be submitted to the NB Office of the Fire Marshal (OFM) for any building where there is potential for a large loss of life resulting from fire (50 or more occupants), or when a building contains particularly vulnerable persons such as hospitals, daycares, nursing homes and special care homes. Fire Plans are not required for office buildings or industrial occupancies unless the industrial occupancy contains large quantities of flammable and combustibles liquids.

 

A fire plan is required to be submitted if:

  1. any building is constructed as a place of assembly or sleeping accommodation, or
  2. any building (or part thereof) is converted into a place of assembly or sleeping accommodation, or
  3. structural alterations are made to any building that includes a place of assembly or sleeping accommodation. (Reference: FPA, Part 1, 18(1))
  4. any person constructs, establishes, modifies or enlarges a petroleum products facility, or
  5. any existing building or premises is converted into a petroleum products facility if the amounts of flammable liquids to be stored in the facility exceed 3,000 L or the amounts of combustible liquids to be stored in the facility exceed 10,000 L. (FPA Part 1, 19(1))

Although not a defined term in the FPA, structural alterations are considered to be any modification to the load bearing supports of a building. However, any modification which could impact the means of egress from a building or other life safety system is encouraged to be submitted for review. Modifications to a room in a building, or adding a small room or washroom, are generally not considered significant to warrant a plan review.

The FPA indicates that a Place of Assembly is a building or structure, or portion thereof, or a tent or awning with walls of side curtains, designed, used or intended to be used to accommodate fifty (50) or more persons at the same time for the purpose of meeting, entertainment, instruction, worship, recreation, drill or the viewing or purchasing of goods.

The FPA’s definition of “place of assembly” differs from that of the NBCC definition as it also includes occupancies for the view and purchasing of goods, which is considered as “Mercantile Occupancy” in the NBCC.

 

The FPA indicates that Sleeping Accommodations include:

  • A hotel or any other building in which lodgings are provided for rent or hire,
  • Any building in which lodgings are offered to members of the public on a gratuitous basis,
  • Any building in which an educational institution lodges its students,
  • Any building, other than a single-family residence, in which a religious organization lodges its members,
  • A hospital facility, sanatorium, infirmary, nursing home or home for the aged,
  • An orphanage or children’s home,
  • A jail, reformatory or other penal institution, or
  • An apartment house (building) with three or more self-contained units above the ground floor

The FPA does not require a Fire Plan submission for apartment buildings with 10 or fewer occupants. (Reference: NB Fire Prevention Act, Part 1, 18(4))

PLC Fire Safety Solutions has the knowledge and expertise to help plan submitters (Owners, Facility Operators, Architects, etc.) with their fire and life safety needs. PLC staff is knowledgeable in the requirements of the National Building and Fire codes and can help identify the potential building and life safety issues.

Click here to read Part 2 of this blog.  

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