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Interpretation of Firestopping Requirements according to the 1997 Ontario Fire Code

AND the 1997 Ontario Building Code

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Firestop Slide Show 1 of 10 Basics

Firestop Slide Show 2 of 10 Code

Firestop Slide Show 3 of 10 No Seal

Firestop Slide Show 4 of 10 Deemed-to-comply

Firestop Slide Show 5 of 10 Misinstalled

Firestop Slide Show 6 of 10 Re-entered

Firestop Slide Show 7 of 10 Faulty Spec.

Firestop Slide Show 8 of 10 Proper Firestops

Firestop Slide Show 9 of 10 Test

Firestop Slide Show 10 of 10 Smoke and Trays

Sample Firestop Listing

Kitchen Exhaust Cleaning; Boiling-Hot Pressure Washing

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Summary / Conclusion:

Firestops (for building joints, mechanical or electrical services or structural steel) in existing as well as new construction has to be bounded by certification listings of UL, ULC or WH. Additionally, firestops in firewalls and occupancy separations must bear an FT rating equivalent to the rating of the separation. US listings are acceptable, except that plastic pipe penetration firestops must have been tested with a 50 Pa positive furnace pressure. F ratings can be downgraded from the fire separation identically to closures. Re-entered firestops must be immediately repaired in such a manner that the repaired seal is bounded by a certification listing by UL, ULC or WH. The authority having jurisdiction (AHJ) (= municipal fire prevention officer and/or building inspector, or Labour Canada inspector for federal buildings) is entitled to see back-up for compliance with Fire Code and/or Building Code. The owner is obligated to demonstrate compliance. The only proof of compliance for firestops is a certification listing, which bounds the installed firestop in all aspects of the listing. Alternatives my be approved by the AHJ but the onus is upon the owner to prove that the alternative is at least as safe as that which the Code requires. Changes to firestops or the fire-resistance rated wall or floor assemblies that contain them require a building permit. Owners who do not follow these principles can (a) be proven negligent in a court of law and (b) assume the liabilities associated therewith.

The following Code excerpts back up the above summary. The Author's notes are written in ordinary font, whereas Code excerpts are written in Italics.

1 General

1.1 The following is a set of excerpts from the 1997 Ontario Fire Code (OFC), which outlines the regulatory basis to use and maintain proper firestops, as certified by ULC, ULI or WH. The excerpts are merely re-typed from the code, for ease of use, to provide a document specific to firestopping. No representation of accuracy or completeness is made. The user is cautioned to refer to the actual code documents to ascertain his or her own requirements and the regulatory basis applying to his or her own building. Corrections were made in consideration of British English spelling.

1.2 New buildings must conform to the OBC, which is valid at the time of the application for a building permit. At the time of commissioning, or after the issuance of an occupancy permit by the building department to the owner of the building, the building is presumed to be in compliance with the OBC, which does not mean that the building department has necessarily caught all the sins that may have been committed in a building. After that point, the owner is obligated to run the building in compliance with the OFC. OFC and OBC refer back and forth to one another numerous times in order to avoid duplication. This also applies to firestopping requirements.

2 Definitions as per 1997 OFC and OBC relating to firestopping

2.1 Approved means approved by the Chief Fire Official.

2.2 Building means any structure used or intended for sheltering any use or occupancy.

2.3 Building Code means the Ontario Building Code made under the Building Code Act or a predecessor to that Act.

2.4 Chief Fire Official means the assistant to the Fire Marshal who is the Municipal Fire Chief or a member or members of the fire department appointed by the Municipal Fire Chief under Subsection 1.1.8.

2.5 Closure means a device or assembly for closing an opening through a fire separation such as a door, shutter, a wired glass or glass block and includes all components, such as hardware, closing devices, frames and anchors.

2.6 Combustible means that a material fails to meet the acceptance criteria of CAN4-S114, "Standard Method of Test for Determination of Non-Combustibility in Building Materials".

2.7 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.

2.8 Fire department means a group of fire fighters authorised to provide fire protection services by a municipality, group of municipalities or by an agreement made under section 3 of the Fire Protection and Fire Prevention Act.

2.9 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.

2.10 Fire-resistance means the property of a material or assembly in a building to withstand fire or give protection from it and is characterised by the ability of the material or assembly to confine a fire or to continue to perform a given structural function or both.

2.11 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.

2.12 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.

2.13 Firewall means a fire separation of non-combustible 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.

2.14 Listed means equipment or materials included in a list published by a certification organisation accredited by the Standards Council of Canada.

2.15 Major Occupancy means the principal occupancy for which a building or part thereof is used or intended to be used, and includes subsidiary occupancies that are an integral part of the principal occupancy.

2.16 Non-combustible construction means that type of construction in which a degree of fire safety is attained by the use of non-combustible materials for structural members and other building assemblies.

2.17 Non-combustible means that a material meets the acceptance criteria of CAN4-S114, "Standard Method of Test for Determination of Non-Combustibility in Building Materials".

2.18 Occupancy means the use or intended use of a building or part thereof for the shelter or support of persons, animals or property.

2.19 Sprinklered (as applying to a building or part thereof) means that the building or part thereof is equipped with a system of automatic sprinklers.

2.20 Test means the operation of a device or system to ensure that it will perform in accordance with its intended operation or function.

3 OFC Excerpts relating to Firestopping


SECTION 2.2 FIRE SEPARATIONS

Subsection 2.2.1. Major Occupancies

Damaged fire separations

2.2.1.1 Where fire separations between major occupancies are damaged in a manner so as to affect the integrity of their fire-resistance ratings, such as damaged fire separations shall be repaired so that the integrity of the fire separations is maintained.

Subsection 2.2.2. Rooms and Spaces

Damaged fire separations

2.2.2.1. Where fire separations between rooms, corridors, shafts and other spaces are damaged so as to affect the integrity of their fire-resistance ratings, the damaged fire separations shall be repaired so that the integrity of the fire separations is maintained.


4   1997 OFC Firestop Baseline Abstract:

4.1 Firestops obviously are contained inside of fire separations. The definition of the term fire separation, as well as the term fire-resistance rating refers back to the Ontario Building Code. The oldest version of this baseline, which is actually printed in the appendix of the OFC, is the 1986 Ontario Building Code. The excerpts from the 1986 code, however, match earlier building regulations. The following excerpt from the 1986 OBC essentially outlines, how a fire-resistance rating has been achieved for all rated walls and floors. This is nearly identical, the world over, including The United States of America, The People's Republic of China, Hong Kong, Scandinavia and all of Western Europe. The only difference is that the standard-numbers vary from one country to another. But the time/temperature curve does not vary much. Local differences in the required temperatures are offset by the differences in thermocouples. Whether the test burn is run in Mainland China, Chicago, Finland or Scarborough, the fire exposure is quite similar. Wall and floor assemblies have to be exposed to this fire endurance test and, in some cases, hose-stream testing or other impact testing - the assembly must remain intact and the fire must not protrude through to the unexposed side. Also, no heat-rise above ambient at the start of the test of 180°C on any single point, or 140°C on average must be recorded, either through protrusion of flames, or flue gases hot enough to ignite combustibles on the unexposed side. As soon as either of those temperature rise criteria are exceeded, the test is over. The requirement is based upon the National Standard of Canada CAN4 S101. S101 is rooted in the American standard ASTM E119, and its predecessor ASTM C19, which was first published in 1918. Fire-resistance rated assemblies have been constructed in conformance with assemblies that have passed testing to this method, since that time. Here is how the 1986 OBC phrases this requirement:


3.1.5.1.(1) Except as provided in Sentences (2) and (3), where a material, assembly of materials or a structural member is required to have a fire-resistance rating, the rating shall be determined on the basis of results of tests conducted in conformance with CAN4-S101, "Standard Method of Fire Endurance Tests of Building Construction and Materials".

(2) A material, assembly of materials or a structural member may be assigned a fire-resistance rating on the basis of Chapter 2 "Fire Performance Ratings" of the Supplement to the NBC 1985.


Note: Many countries, including Canada and the Federal Republic of Germany, have published such lists or code supplements, containing simple structures, using common building materials, which have proven time after time, when tested to the basic building elements curve (inherent in S101 and its international cousins) to provide certain fire-resistance ratings. As a result, for instance, portland cement based concrete floor and wall assemblies have become standardised, for anyone to copy right out of the book. Such copies instantly meet code.

4.2 Right, so now we know that the wall or floor, which contain the firestop is only rated because it has been tested to S101 and built the way that the test assembly was built. That is, in theory. A deviation from this are head of wall joints, and other moving joints, which have been neglected in testing and simply covered over with insulation or omitted altogether. A note in the code about intent for such gaps to withstand fire and gases etc. had been around for a long time. It is quite vague, due to the absence of proper test protocols and willingness to apply funds to remedy the situation. Recent advances in this regard by the firestop industry have produced a UL standard, which actually cycles the joint through motion prior to the fire test. The resulting listings quantify not only the fire-resistance in hours, or fractions thereof, but also the percentage of motion. But the general requirement to test assemblies to the building elements curve inherent in S101 and E119 goes back all the way to 1918. Now, let's see what the OBC has to say specifically about mechanical and electrical through penetrations in fire-resistance rated wall and floor assemblies:


3.1.7.1.(1) Piping, tubing, ducts, chimneys, wiring, conduit, electrical outlet boxes and other similar service equipment that penetrate a fire separation or a membrane forming part of an assembly required to have a fire-resistance rating shall be

(a) tightly fitted, or

(b) sealed at the penetration with firestop materials conforming to sentence (2).

(2) Fire stop materials in Sentence (1) shall consist of material that will remain in place and prevent the passage of flame when subjected to the standard fire exposure in CAN4-S101, "Standard Methods of Fire Endurance Tests of Building Construction and Materials", for a period of time equal to the fire-protection rating required for the grade of fire separation in Table 3.1.6.A.

Table 3.1.6.A.:

Table 3.1.6.A of the 1986 Ontario Building Code


Note: This particular table predates the 1986 OBC and has remained in the Code to this day, although the table-number has changed along the way.


3.1.7.2.(1) Except as provided in Sentences (2) to (6) and articles 3.1.4.5 and 3.1.7.3, pipes, ducts, electrical outlet boxes, electrical conduits or other similar service equipment that partly or wholly penetrate an assembly required to have a fire-resistance rating shall be non-combustible unless the assembly has been tested incorporating such equipment.

(2) Electrical or similar wiring enclosed in non-combustible conduit may partly or wholly penetrate an assembly required to have a fire-resistance rating without being incorporated in the assembly at the time of testing as required in sentence (1).


Note: This does not remove the requirement of tightly fitting all the way through the wall or floor assembly (meaning no through openings that you can see through or blow smoke through) and the owner's obligation to demonstrate that the material used for this purpose is capable of withstanding an S101 test, remaining intact, not raising temperatures on the unexposed side and holding back a hose-stream test. This also does not address multiple penetrants and the treatment for this. Using materials that are the same as that which the wall or floor is made of, does not sanction the use of drywall mud in openings that are any wider than the butt joint between two sheets of Type X drywall. If a block or two are missing out of a brick or concrete block wall, the use of common bricklaying mortar, which is used in small 'beds' between bricks or blocks, cannot suddenly be used to take the place of an entire brick or block or more, to accommodate multiple penetrants without demonstrating the ability of the combined assembly to withstand testing and meeting the performance criteria of S101 for the required fire-resistance rating. This Sentence (2) sanctions single conduit penetrations, neatly passed through tight clearances, grouted all the way through an assembly with zero annulus. Anything else is certainly bordering on poetic license.


(3) Wiring, including single wires or groups of wires, with combustible insulation or jacketing that is not enclosed in non-combustible conduit may partly or wholly penetrate a vertical assembly required to have a fire-resistance rating without being incorporated at the time of testing as required in Sentence (1) provided the wiring does not exceed 25mm in overall diameter.

(4) Combustible conduit which is embedded in a concrete floor slab is permitted in an assembly required to have a fire-resistance rating without being incorporated at the time of testing as required in Sentence (1) where the concrete provides at least 50 mm of cover between the conduit and the bottom of the slab.

(5) Combustible outlet boxes are permitted in an assembly required to have a fire-resistance rating without being incorporated in the assembly at the time of testing as required in Sentence (1) provided the opening through the membrane into the box does not exceed 160cm².

(6) Outlet boxes that penetrate opposite sides of a wall assembly shall be offset where necessary to maintain the integrity of the fire separation.

3.1.7.3.(1) Except as permitted in Sentences (2) to (5) and Article 3.1.4.5, combustible piping shall not be used where any part of the piping system partly or wholly penetrates a fire separation required to have a fire-resistance rating or penetrates a membrane that forms part of an assembly required to have a fire-resistance rating.

(2) Combustible piping is permitted to penetrate a fire separation required to have a fire-resistance rating or a membrane that forms part of an assembly required to have a fire-resistance rating provided

(a) the rated assembly incorporating the penetration will resist the passage of flames when subjected to the standard heat exposure criteria in CAN4-S101, "Standard Methods of fire Endurance Tests of Building Construction and Materials", at a pressure on the exposed side at least 50 Pa (gauge) greater than on the unexposed side, and

(b) the piping is not located in a vertical shaft

(3) Combustible drain piping is permitted to penetrate a horizontal fire separation provided it leads directly from a non-combustible floor-mounted water closet through a concrete floor slab.

(4) Combustible piping need not conform to Sentence (1) where the combustible piping penetrates a vertical or horizontal fire separation and the fire compartments on each side of the fire separation are sprinklered.

(5) Combustible piping need not conform to Sentence (1) where the combustible piping penetrates a vertical or horizontal fire separation and the fire compartments on each side of the fire separation are sprinklered.


4.3 In more than one location, the 1986 OBC tells us, as its predecessors did, that service penetrations in fire separations required to have a fire-resistance rating must be included in the fire test of the wall or floor assembly - according to S101 - the fire test that was and is used for walls and floors and structural steel. Even back then, before S115 (The test used for firestops) was issued or was ever considered by anyone apart from the code writers, the requirement was already there that plastic piping (combustible piping) penetration firestops had to be tested to S101 - with 50 Pascal positive furnace pressure. This is where we find the cause of code violations relative to firestopping from that period of time. Long before the issuance of S115 and its US cousin UL1479 or ASTM E814, firestops were in fact tested both to S101 (in Canada) and E119 (in the US). The results were published in lists issued by ULI and ULC. The resulting systems were available for use and can safely be considered public knowledge, thwarting any and all plausible deniability for justifying missing or improper firestops. The logic behind this is so simple as to be infantile. If you tested a floor assembly or a wall assembly to E119 or C19 or S101 and you had a hole in it - it would burn through and the rating would be ZERO. Whether the hole is penetrated or not - it would fail. And without incorporating the penetration seal at the time of test, as the code demands and has demanded for a long time, there is no proof of what would happen. This simple logic is also evident to all those involved in fire testing and product design. To this day, many firestop assemblies built and submitted by assorted vendors, actually fail the test, sending the manufacturer back to the drawing board. If a firestop manufacturer can fail a test, which costs serious money (around $15,000.00 per test minimum!), and he or she has experience in firestop design, why would a code writer or building official purport to accept willy-nilly designs on a site by anyone other than someone experienced in the field (meaning an experienced firestop expert), with a listing backing up the installed configuration? Who would gladly accept this sort of liability? Firestops had been in use on board ships, particularly combat ships since before World War 2. These devices were called "stuffing tubes" and had been accepted for use by the US Navy and other navies around the world. The first firestops tested to ASTM E119, which is identical in this regard to CAN4-S101, were MCTs or Multi Cable Transits, made by Lyckeaborg Bruks AB of Karlskrona, Sweden. The US licensee is now called Nelson Firestop Products and operates out of Tulsa, OK. The individual responsible for marketing these firestops out of New York City, at the time, was one Mr. Joe O'Brien (a.k.a. 'Mr. MCT'). First sales of MCTs were to US naval shipyards in 1966. Joe btw. still sells these to shipyards both in Canada and the US. His handiwork can be found on our most recent Royal Canadian Navy frigates as well as the oilrigs off the shores of the Maritimes. The use of MCTs spread to land-based construction in 1970 at the Fort St. Vrain nuclear generating station in Colorado. This is where plausible deniability disappears for justifying missing or untested firestops. Certification listings by Underwriters Laboratories are and always were a matter of public record. The incorrect interpretation of our code, which would not stand up to any legal review, even by the most junior attorneys, to justify untested firestops (including home-made creations involving fibreglass, ordinary mortar, drywall mud and so forth), was this: "The code said to use materials tested to S101." Therefore, people often used materials for 'firestopping', which were used in the construction of the wall or floor itself. In the case of drywall, this convenient and false interpretation (money and ignorance being the key factors here) could go so far as to justify the liberal use of drywall mud and tape in annuli around single penetrants, as well as larger holes with multiple penetrants, that far exceeded the use of these materials in the original S101 or E119 test. Neither the laboratory engineers, nor the drywall or blockwall makers sponsoring the tests would ever have considered risking their costly test assemblies by inserting unproven firestops around mechanical or electrical services or structural steel penetrations or joints. They would not do this, because failure would be the certain result. As in site jury-rigs concerning penetration seals in drywall assemblies the same concept applied to wrongdoers in blockwall and concrete wall or concrete slab penetrations. Here is where we first see the popular emergence of pencil-whipping. In the S101 or E119 test, the mortar bed surrounding each block was perhaps ½" wide. But suddenly, liberal code interpretations regarding through penetrations went so far as to use common bricklaying mortar for large cable tray penetrations, piping penetrations and so forth. This was never permissible or intended by the code. The code said (with only minor exceptions, such as single max. 1" wide cables, which still had to be tightly fitted - all the way through the wall or floor) that penetration seals had to be incorporated at the time of test. That means, just like today, that the installed configuration of the firestop has to be bounded by a certification listing. Those were available and public knowledge prior to the seventies. In other words, the proof of function has to be supplied and can be demanded by the authority having jurisdiction from the owner. As of the late nineteen sixties, such systems were available from Nelson Firestop Products. In the mid seventies, Nelson was joined in this effort by 3M and in the early eighties there were already a dozen or so firestop vendors actively testing, marketing and selling their wares all over North America. The listings were and remain a matter of public record. Here is a legal parallel from the construction industry: There was proof in the nineteen twenties that exposure to asbestos fibres could cause or contribute to cancer. This proof became evident in the 1970's and resulted in enormous legal ramifications, still felt by the construction industry and owners to this day, as well as the establishment of a thriving asbestos removal trade. There was simply no excuse that would stand up to even cursory legal review beyond the 1920's that asbestos could be used in any conditions other than those which are used today by the removal trade - full body condoms, tenting off affected areas, negative air units, fibre concentration measurements etc. The same thing applies to firestopping. As of the late sixties, early seventies, firestops have been tested to S101 and E119, which is precisely what the code demands. Then and now, you could and can penetrate assemblies required to have a fire-resistance rating, but the penetrations have to be included at the time of test. The only thing that is different now, is that we have more specific test standards, with multiple ratings available. Back to the above mentioned legal parallel, you can still mine and use asbestos to this day, but you have to follow regulations in its handling, storage and identification.

5 Now

5.1 The 1997 OBC's firestop requirements do not vary much from the 1986 version, except that we now use S115 as the basis for firestop tests, with 5 available ratings, two of which are mentioned in the Code. Firestops in occupancy separations and fire walls have to be FT rated, equivalent to the fire-resistance rating of the surrounding wall or floor assembly. That, in essence, is what is new. Plastic pipe still must be tested with 50Pa positive furnace pressure.

5.2 What is still somewhat vague is joints and structural steel penetrations. Then and now, there is no specific reference to a standard test, apart from S101 or E119 to be found in the Code. But the firestop industry has essentially closed this gap, so to speak, ahead of the code writers. Joints, in Canada, are tested to S115, same as the penetrations. UL has a separate test for this, which is identical to E119, except that the joint is cycled through motion prior to the burn. The results are quantified at the top of the listing, in percentage of joint width motion, as well as the hourly rating. In Canada, we still wrestle with this, although the UL test is certainly more stringent than what we do and is, therefore, permissible. Actually, as a matter of public record, since ULI listings are public record in Canada since its accreditation via the Standards Council of Canada, UL's joint listings can be argued to be mandatory in Canada. The fire exposure is identical and meets the performance requirements of S115 as well as S101. And all architects and engineers know that joints do experience motion - that is why we have joints after all. If not by the use of assemblies qualified to this test (whose fire exposure is identical to that mandated in S101 as well as S115), how can an architect justify the use of a system in a moving joint? That leaves motion tests for service penetrations. With publicly available tables, which quantify metal expansion and contraction as a result of thermal exposures (such as hot and cold water running through a pipe, water hammer being mentioned right in the Plumbing Code of Canada and the OBC), insulators making a handsome living off repairing pipe covering, which gets wrecked as a result of plants shut-downs and start-ups, no one can deny the fact that motion testing should be part and parcel of firestop testing. However, as this costs money, the concept is still hard to sell and is basically covered only in marketing literature, where some firestop vendors either ignore motion or tout the virtues of the unquantified flexibility of their firestop systems (as a whole in regular operation as well as immediately prior to the fire test - not the doggie bone stretch tests run on caulking at a bench in a laboratory). That leaves structural steel penetrations. These are a common deficiency in construction. Filling in around them with grout or simply with spray fireproofing is similar to the code violations, which resulted from misinterpretations of the 1986 OBC and its predecessors. However, again there are firestop systems available, which cover steel beam penetrations, tested to ASTM E814. There is really no way to talk oneself out of the use of listed firestops, where the installed configuration is bounded by certification listings, which would stand up to any judicial review of all the factors, involving publicly available information.

FIRESTOP SLIDE SHOW PAGE 2 OF 10

Next

(bad examples - no firestop)

Back

(Basics)

Firestop Page

Main Page

Glossary

Comments

Main Site

Firestop Site

Code Evaluations AVAILABLE!

Glossary of Fire Protection Terms

3M Fire Barriers

Vectorising Drawings and Maps; Paper to CAD

Circuit Integrity Fireproofing

Bounding

Code Req's for Firestops

Essay on Performance Based Codes

Master Spec. Section 07840 Firestopping

Related Sections to 07840

Penetration Seal Drawings

Building Joint Drawings 1

Building Joint Drawings 2

Building Joint Drawings 3

History of Firestops in North America

Warnock Hersey Experience

Firestop Trade Jurisdiction

Achim Hering Bio

Man Made Mineral Fibres

Fire Protection Industry Links

Firestop Products and Equipment

Firestop Mortar

Firestop Silicone Foam

Intumescent Products

Endothermic Products

Insulation Products

Caulking & Paint Firestops

Firestop Pillows

Firestop Devices

Firestop Slide Show 1 of 10 Basics

Firestop Slide Show 2 of 10 Code

Firestop Slide Show 3 of 10 No Seal

Firestop Slide Show 4 of 10 Deemed-to-comply

Firestop Slide Show 5 of 10 Misinstalled

Firestop Slide Show 6 of 10 Re-entered

Firestop Slide Show 7 of 10 Faulty Spec.

Firestop Slide Show 8 of 10 Proper Firestops

Firestop Slide Show 9 of 10 Test

Firestop Slide Show 10 of 10 Smoke and Trays

Sample Firestop Listing

Kitchen Exhaust Cleaning; Boiling-Hot Pressure Washing

ULC           UL

T O S

(Theory of Survival)

DIBt

TU Braunschweig iBMB

CONTACT

1