Ministry of Municipal Affairs
PROPOSED CHANGE TO THE 2012 BUILDING CODE
O. REG. 332/12 AS AMENDED
CHANGE NUMBER:
B-03-01-04
SOURCE:
Ontario-NBC
CODE REFERENCE:
Division B / 3.1.4.2.
DESCRIPTION OF THE PROPOSED AMENDMENT
This proposed change introduces a new Sentence (2) for the protection of walk-in cooler or freezer consisting of
factory-assembled panels containing foamed plastic insulation; and, a new Sentence (3) as a pointer to Article
3.1.13.2. for the flame-spread rating requirement for doors.
EXISTING 2012 BUILDING CODE PROVISION(S)
3.1.4.2.
Protection of Foamed Plastics
(1) Foamed plastics that form part of a wall or ceiling assembly in combustible construction shall be protected from
adjacent spaces in the building, other than adjacent concealed spaces within attic or roof spaces, crawl spaces, and wall
assemblies,
(a) by one of the interior finishes described in Subsections 9.29.4. to 9.29.9.,
(b) by any thermal barrier that meets the requirements of Sentence 3.1.5.12.(2), or
(c) where the building does not contain a Group B or Group C major occupancy, by sheet metal,
(i) mechanically fastened to the supporting assembly independent of the insulation,
(ii) not less than 0.38 mm thick, and
(iii) with a melting point not below 650°C.
(See Appendix A.)
(2) The flame-spread rating on any exposed surface of combustible insulation, or any surface that would be exposed by
cutting through it in any direction, shall be not more than 500.
PROPOSED CODE CHANGE
3.1.4.2.
Protection of Foamed Plastics (See Appendix A.)
(1) Except as permitted in Sentence (3),Ffoamed plastics that form part of a wall or ceiling assembly in combustible
construction shall be protected from adjacent spaces in the building, other than adjacent concealed spaces within attic or
roof spaces, crawl spaces, and wall and ceiling assemblies,
(a) by one of the interior finishes described in Subsections 9.29.4. to 9.29.9.,
(b) by any thermal barrier that meets the requirements of Sentence 3.1.5.12.(2), or
(c) where the building does not contain a Group B or Group C major occupancy, by sheet metal,
(i) mechanically fastened to the supporting assembly independent of the insulation,
(ii) not less than 0.38 mm thick, and
(iii) with a melting point not below 650°C.
Building and Development Branch
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(b) provided the building does not contain a Group A, Group B or Group C major occupancy, by sheet metal,
(i) mechanically fastened to the supporting assembly independent of the insulation,
(ii) not less than 0.38 mm thick, and
(iii) with a melting point not below 650°C, or
(c) by any thermal barrier that meets the requirements of Sentence 3.1.5.12.(2)Sentence 3.1.5.13.(3) (See Appendix A.)
(See Appendix A.)
(2) The flame-spread rating on any exposed surface of combustible insulation, or any surface that would be exposed by
cutting through it in any direction, shall be not more than 500.
(3) A walk-in cooler or freezer consisting of factory-assembled wall, floor or ceiling panels containing foamed plastics
is permitted in a building permitted to be of combustible construction, provided the panels
(a) are protected on both sides by sheet metal not less than 0.38 mm thick having a melting point not less than 650°C,
(b) do not contain an air space, and
(c) when a sample panel with an assembled joint typical of field installation is subjected to the applicable test
described in Subsection 3.1.12., have a flame-spread rating not more than that permitted for the space in which
they are located, the space that they bound, or the walls of the building to which the cooler or freezer is attached,
as applicable.
(See Appendix A.)
(4)
The flame-spread rating of doors containing foamed plastics shall comply with Sentences 3.1.13.2.(1) to (3).
A-3.1.4.2.(3) and 3.1.5.7.(3) Walk-in Coolers and Freezers.
Sentences 3.1.4.2.(3) and 3.1.5.7.(3) are intended to apply to walk-in coolers and freezers that are constructed as
stand-alone structures as well as those that are constructed as additions to buildings or within buildings.
A-3.1.4.2. Protection of Penetrations.
Where foamed plastics are required to be protected from adjacent spaces within a building, the protection should be
continuous so as to cover the foamed plastics so they are not exposed to the interior of the building. However,
minor penetrations of the protective covering by small electrical and mechanical components, such as electrical outlets
and fixtures, sprinkler piping, and mechanical vents, are acceptable because the penetrant and associated fittings and
seals will prevent the small amount of foamed plastic surrounding the penetration from being exposed to the interior of
the building.
Foamed plastics that are penetrated by larger components or assemblies, such as windows and passageways, are
unlikely to be exposed to the interior of the building as they are protected by associated framing and finishes and/or the
installation of a closure.
Small amounts of foamed plastics, such as air sealants used between major components of exterior wall
construction, are not required to be protected (see Sentence 3.1.5.2.(1)).
Penetrations of a fire separation or of a membrane forming part of an assembly required to have a fireresistance rating are nevertheless required to be provided with a fire stop in accordance with Subsection
3.1.9.
A-3.1.4.2.(1) Concealed Space.
The term “concealed space” includes anyspace that is not visibly apparent and that is provided with an opening to
allow access for repair and periodic inspections.
A-3.1.4.2.(1)(b) Thermal Barrier in Combustible Construction.
Any thermal barrier that is accepted under the requirements of Sentence 3.1.5.12.(2) for noncombustible construction is
also acceptable for combustible construction.
Building and Development Branch
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RATIONALE FOR CHANGE
Problem/General Background
Sentence (1):
A new Appendix Note to Sentence (1) is required to ensure that architectural foamed plastic materials, as
described in the revised Sentence 3.1.13.1.(2), are not considered as part of a wall or ceiling assembly. It also
clarifies that the purpose of a concealed space is not to permit the space to be used for storage.
New Sentence (3):
There is no requirement in the current Subsection 3.1.4. that addresses the hazard of walk-in cooler or freezer
consisting of factory-assembled walls, floor and ceiling panels containing foamed plastic insulation. This could
lead to hazardous installation where foamed plastics insulation could be exposed on the basis that it should be
allowed in a combustible construction building.
New Sentence (4):
Not all Code users realize that other provisions could be applicable to combustible construction building with
some level of restriction on material properties such as the flame-spread rating of doors. This could lead to
hazardous conditions where a fire would spread more rapidly than expected limiting the time for the occupants to
safely evacuate a building in case of a fire emergency.
New Appendix Note A-3.1.4.2.
Penetrations in a wall assembly expose the insulation material. They are required for windows, doors, electrical
outlets, ventilation duct, etc. Foamed plastic insulation is a combustible material and is required to be protected
from adjacent spaces within a building. However, such protection measures for penetrations could be onerous and
difficult to apply when considering the limited amount of foamed plastic insulation exposed through penetrations.
New Appendix Note A-3.1.4.2.(1)
There is reported misinterpretation of the meaning of concealed space, which could lead to undue and costly
protection requirement in areas not intended to be protected based on the hazards present.
Justification/Explanation
This proposed change would harmonize requirements with the model National Building Code of Canada.
Sentence (1):
Editorial-Clarification. This change clarifies that foamed plastic interior finish materials are not part of a wall or
ceiling assembly and are not required to be protected.
It also clarifies that a concealed space is any space out of sight that may be provided with an opening for repair
and periodic inspections only, thus allowing temporary occupancy for specific purposes.
Building and Development Branch
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New Sentence (3):
There is no requirement in the current Subsection 3.1.4. that addresses the hazard of walk-in cooler or freezer
consisting of factory-assembled walls, floor and ceiling panels containing foamed plastic insulation. This new
requirement defines the minimum level of performance of such construction material when used in a combustible
construction.
New Sentence (4):
The requirements for doors found in Subsection 3.1.13., which apply to all buildings, was missed by Code users
because of the presumption that there is no limitation on the type of combustible materials permitted in a
combustible construction besides the ones for foamed plastics. This signpost clarifies that doors in combustible
construction are still bonded by the flame-spread rating requirements for doors.
New Appendix Note A-3.1.4.2.
The new Appendix Note to Article 3.1.4.2. clarifies that penetrations through wall assemblies containing foamed
plastic insulation are adequately protected from adjacent space by the penetrant. It is not expected that foamed
plastic insulation surrounding the inside of these openings would be exposed to a fire within a building due to the
framing and finishing around the openings and/or the provision of a closure.
New Appendix Note A-3.1.4.2.(1)
The new Appendix Note to Sentence 3.1.4.2.(1) clarifies the intent of the provision in regards to concealed space.
It clarifies that an opening could be provided to a concealed space for services, maintenance, etc.
Cost/Benefit Implications
Sentence (1):
None. It is already a current Code requirement.
New Sentence (3):
None. This new Sentence is a new permission defining under which conditions walk-in cooler or freezer
consisting of factory-assembled panels could be used in a combustible construction.
New Sentence (4):
None. It is already a current Code requirement.
New Appendices
None. Both Appendix Notes provides clarification of intent for Code users on current Code provisions.
Enforcement Implications
This will provide a better understanding of the required protection measures for combustible construction where
foamed plastic insulation is used.
Building and Development Branch
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Who is Affected
Building officials, architects, and building owners.
Objective Based Analysis
Provision
Objective/Functional Statement
Division B 3.1.4.2.
(1)
[F01-OS1.1][F02-OS1.2]
(1)
[F01-OP1.1][F02-OP1.2]
(3)
[F01-OS1.1][F02-OS1.2]
(3)
[F01-OP1.1][F02-OP1.2]
(4)
OTHER SUPPORTING MATERIALS
Building and Development Branch
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