Code Infraction Notification Ontario Generic Docket 2, November 21st, 2000

This document concerns a photographic and written notification to the government of Ontario regarding the fact that the majority of Ontario buildings, including hospitals, homes for the aged, schools, apartment buildings, hotels and more, which are designed to have fire resistance rated walls and floors, are perforated such that smoke and fire can spread quickly, which contributes to casualties resulting from smoke inhalation and/or fire exposure.

This violates the 1997 Ontario Fire Code, as well as the 1997 Ontario Building Code, as well as each of the aforementioned codes' predecessors back to the 1960's.

This CIN (Code Infraction Notification) outlines the applicable regulations, commercial reasons for avoiding compliance on the part of the owners and the design community, the state of enforcement by the Ontario government, as well as suggestions for a course of action to ensure compliance with Ontario law.

Confidentiality of the Source of this Information is understood to be maintained by the Office of the Ontario Fire Marshal. Our members feel threatened for their very lives in regards to some of these disclosures.

Ontario Generic Docket 2 (ONGENDOC2)

The next 16 pages document what Ontario law says about firestopping, and exactly what it means, as well as the historical context, all of which impact on the operability of firestops in occupancies all over the Province of Ontario. Ontario's situation, and suggested remedies follow the code and history texts.

1997 Ontario Fire Code Reference:

Interpretation of Firestopping Requirements according to the 1997 Ontario Fire Code AND the 1997 Ontario Building Code

Firestops (for building joints, mechanical or electrical services or structural steel) in existing as well as new construction have 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 conforms with a certification listing by UL, ULC or WH. The authority having jurisdiction (AHJ) (= municipal fire prevention officer and/or building inspector, or Labor 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 may 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. Our notes are written in ordinary font, whereas Code excerpts are written in Italics.

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.

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&ldots;. 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

2.2 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 authorized 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 characterized 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 organization 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 1997 OFC Excerpts relating to Firestopping

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 damaged fire separations shall be repaired so that the integrity of the fire separations is maintained.

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 (DIN4102), 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 standardized, for anyone to copy right out of the book. Such copies instantly meet code.

4.2 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

(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.

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 (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 or 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. 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

(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 fiberglass, 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. 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 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 fibers 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 protective suits, 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.

BOUNDING OF FIRESTOPS

The necessity of bounding applies to much more than just firestops. It encompasses all fire resistive and many more products.

Because that, in combination with the observance of mandatory ratings criteria stipulated by the code for certain types of fire separations and fire walls and occupancy separations is the only way to meet code.

Here is an analogy: Look at your toaster. Unplug it and empty the crumbs over your sink first. Then look for the certification label. You may find labels there from cUL through CSA. These certification labels indicate typically what the item is, who the maker is and a listing number. The laboratory that did the testing, has to be accredited in Canada by the SCC, both for testing and certification purposes. Otherwise it's actually illegal for you to operate this toaster in this country. Because that is how the Government of Canada protects its residents and visitors from injury or accidental death. This is a basic human rights issue, anchored firmly in Canadian law. The SCC accredited testing and certification organization (such as UL, ULC or WH) has a certification agreement (a.k.a. follow-up agreement) with the maker of that toaster. The toaster (in Canada) was tested to a nationally approved (approved by SCC that is) standard. The standard is a written test procedure, which was developed by volunteers at a committee chaired by CSA. CSA also tests and certifies. But apart from that, anyone who does testing and certification of electrical equipment must follow CSA standards because that is who is designated by the SCC as the standards writing organization on record for electrical equipment. The standard developed by the group of volunteers, which is monitored for 'balanced representation' as per SCC guidelines, is first approved by a council at the standards writing organization and can then be forwarded for approval by the SCC. Thus, in Canada, we have several levels of checks and balances to attempt to check special agendas by any one group or company or individuals. Having said that, one cannot interdict on behalf of groups who may never bother to show up for a meeting. The squeaky wheel gets the oil. But on the whole, the Canadian system is reasonably sound. Back to your crumb-relieved toaster: The number given by the certification organization can be traced six ways to breakfast. It is traceable to a follow-up procedure, which is intended to make sure that when the manufacturer tested a $5.00 toaster, he hasn't suddenly substituted parts to make it any different, such as a $2.50 toaster - for economic gain, obviously, or even unintended error. The follow-up agreement between the certification organization and the manufacturer enables regular unannounced access to the factory, to make sure that this toaster is identical to the one, which was tested - so you won't get zapped through ordinary operation of the device, such as for toasting bread. The instructions, which accompany the toaster, must be approved by the certification organization. Thus, when you opened the box, you were asked to read these instructions before operating the toaster, so that the retailer and the wholesaler and the manufacturer don't get sued by the attorney representing your estate, when you and the (plugged in) toaster go for a bath in the tub. The listing number on the label also is traceable to the annual publications of the certification organization. Thus, an electrical inspector can look up whether or not a listed device is still in the certifier's 'good books'. That also protects the user. How? Well, sometimes, devices and entire companies get de-listed. Why? Because of a variety of potential reasons. The company may have violated the follow-up agreement in some manner. Or, new information may have come to light, which has convinced the certifier or the maker that the product may not be safe after all. Or, it may simply be a case of the maker may not have paid his bills to the certifier or the maker may have chosen to test and certify with a competitor to the original certifier. All of this is the red tape and protective barrier behind a certification listing. Without the label, you cannot prove whether or not the widget is in compliance with the law. It thus becomes illegal in this country and in such a case, the sellers and users become negligent and liable in a court of law. As the user, you are responsible to operate the toaster within the confines of the certification listing, which is what you do when you follow the operating instructions. Bathe with a live toaster, and you are reasonably out of compliance and your attorney won't have a chance to defend your case. Replace the plug and upgrade the size so that you can plug it into the 240V outlet you use for your welding machine, hoping you can toast bread FASTER than ever before, you are now no longer bounded by the certification listing. Only the label on the product is proof of proper certification. If the follow-up program has been invalidated or violated, the manufacturer has obligated himself to pay for the certifier to remove the labels from all products, including those located in stores, warehouses, distributors' premises, or wherever they may be reached. But if you, as the user, violate the certification listing terms (meaning that you are no longer BOUNDED by the listing), you also become negligent and liable for the consequences.

How does this apply to firestops?

Everything in the paragraph above applies to firestops verbatim. Toaster or firestop, the laws are the same. What makes bounding firestops more tricky, which is why users need expert help, is the complexity of the certification listings. The toaster is a single purpose device. You toast with it. That's it. You can under-toast or burn your bread beyond recognition, but you are still just toasting bread. You might think: "But with firestops you JUST firestop and therefore one size fits all." WRONG. Firestops are but interdependent SYSTEM COMPONENTS. A firestop product by itself has the fire-resistance rating of a whopping ZERO hours. A firestop product may be a component in hundreds of listings, for a multitude of uses, but by itself it does not provide a rating. It only provides a rating when used in a bounded assembly, together with all the other components. As a further example: a firedoor is a listed device. So is a snow blower. The two, or constituent parts thereof, are not, however, interchangeable. Firestops can vary as much as the two items in the example.

Please review the above link before reading further. It is but one of many examples. The vendor of the materials used in this example has no knowledge of our reference to it. It is merely shown as an easily accessible example of a firestop listing. As you can clearly see, each item is described in mandatory terms, with maximum and/or minimum tolerances. When firestops are bounded by certification listings, what that means is that an installed field configuration, such as you can see here, falls within all applicable parameters and tolerances of the certification listing. And for many products, there are literally hundreds of listings. When a firestop system is chosen for installation, each component, not just the firestop product(s), must fall within the minimum and/or maximum tolerances of the listing. Check http://www.3m.com/us/arch_construct/firestop/system/CAJ8073.html for another example. You will see that UL chose to divide this one big firestopped hole into SIX different configurations. Each of the configurations describes precisely the hole, the penetrant(s) and the firestop procedure, as well as the LISTED repair procedures. There are location and sizing tolerances for each item. When your installed firestop configuration falls within the required listing tolerances, your firestop is BOUNDED. And that is your necessary first step towards code compliance.

Additional Code Requirements

There are also some code requirements, which must become part of system selection - regardless of whether the firestop is in an existing facility and must comply with the Fire Code, or in a new building, which must comply with the Building Code. The determination of the hourly ratings (of which there are 5 at present - F, FT, FH, FTH and L) must be determined, which depends upon the type of fire separation the firestop is to be located in. Firestops in common fire separations can be downgraded, as per the closure table. Thus a 2 hour wall only needs 90 minute F ratings for firestops and 90 minute rated fire dampers and fire doors - unless the penetrant is combustible (i.e. plastic) piping, in which case the firestop must have an FT rating equivalent to the fire resistance rating of the fire separation. Also, firestops in fire walls and occupancy separations must have an FT rating equivalent to the fire-resistance rating of the fire wall and/or occupancy separation that contains it. FT ratings are hard to come by on metallic penetrants. Metal piping for instance, try as you might, is difficult to convince not to conduct heath through to the unexposed side. Fully insulated certification listings, thus, must be employed, which means that each penetrant on both sides of the fire wall and/or occupancy separation must be fully insulated for the entire penetrant run within each fire compartment (which may be more than one room!) on both side of that fire wall and/or occupancy separation. Fulfilling these code requirements PLUS complete bounding of each seal meets code. Nothing else does. Everything else is false and a code violation.

History of Firestops in North America, incl. Ontario

Firestopping in North America started on board combat ships. The first quasi product on the marketplace was the stuffing tube, which at best is a jury-rig, though moderately functional. Walls and floors aboard ships are referred to as bulkheads and decks and they consist of insulated plate steel. Essentially, stuffing tubes were pieces of pipe, which are fed through a torch cut hole in the plate steel, and then welded at the interface. Penetrants are then fed through this sleeve and the ends are 'stuffed' and sealed or grommeted to effect a firestop. The method is quite tedious, particularly when multiple penetrants are involved which fatigues the plate steel, as one stuffing tube is used per penetrant, which leads to a bit of a rat's nest, when many penetrants must be fed through a small area.

Enter the MCT - Multi Cable Transit, invented by Lycab, Sweden. In 1966, Lycab's US licensee from New York employed the North American Pope of Firestopping, Mr. Joe O'Brien ('Mr. MCT'). Joe, still at it (as of Y2K), began quite successfully to market MCT firestops to shipyards and in fact, his systems are still the US Navy's preferred method of firestopping and probably still a major source of income for his employer, Nelson Firestop Products, now based in Tulsa, OK. The use of MCTs spread to land-based construction in 1970, at the Fort St. Vrain nuclear power station in Colorado. Fort St. Vrain was the first of 30 such plants to install MCT firestops - and then came foam. Through the first public UL testing of a proper firestop and the resulting listings, which are deemed public knowledge, Joe single-handedly removed all excuses for using anything other than a certified firestop as of that time, as you can see in the code baseline site.

Picking such worthy targets of opportunity as the US Navy and US Coast Guard, was likely Joe's best move, as selling firestops on land anyplace else was pretty much a martyr's game for a long time. Like many safety items, it is usually strict enforcement of very clear and unambiguous legislation that is the only thing that will persuade most building owners to part with money for items like firestops, which really only pay for themselves in the face of an order to comply by the authority having jurisdiction or in a fire.

And thus Joe trekked across the country in a Chevy pick-up, loaded with a pilot scale furnace, bunches of cables and boxes of MCT firestop components. He would stop at the shipyards, set up shop in the parking lot, unload his furnace, hook up the gas, build his mock-up firestops, order sandwiches and coffee, and run a test right in front of the customers, who ordered, bigtime. Nothing but the best for US Sailors and Marines. Joe and his MCTs against stuffing tubes was like Tyson against Peewee Herman. Throughout this time, much of land-based construction completely ignored the issue of 'plugging holes'. Apart from the marine market, the US nuclear industry spear-headed the standardization of firestop testing. That does not mean that all US nuclear stations are problem free, when it comes to firestopping. Many 'reportable events' to this day in nuclear generating stations have to do with non-compliant firestops. In fact, nuclear stations in North America need not comply with local codes and are not subject to enforcement by the local building or fire departments. This does not make for more safety by any means.

In the mid-seventies, Joe was joined by a number of other companies, typically large electrical manufacturers, as well as silicone manufacturers, who sought to expand into this promising new field, which makes sense, since there were and are millions of holes to be filled out there. Initial firestop systems focused almost exclusively on electrical through penetrations in concrete block wall as well as cast concrete walls and floors.

The individuals involved in these early groups were very few in number, their start-up costs were high, due to R & D, Testing, certification and other such costs and had to prove themselves early on, when measured against core businesses, which were turning much larger sales volumes.

Gradually, piping penetrations were added to the bag of tricks, though still quite far from matching with actual applications with the multitude of floor and wall assemblies and ratings and pipe insulation and jacketing materials. Thus, pipes tested were typically perfectly centered in the openings and had no insulation or jacketing of any kind. Firestop manufacturers frankly had no clue about piping and pipe covering back then. Many still don't. A firestop manufacturer who is not at least conversant on the important aspects of cable types and pipe covering cannot safely be expected to be an expert in firestopping. Questions such as "What is the approximate diameter of a 1C1000MCM?" or "Why would anyone (and who might this be) choose perlite block pipe covering over calcium silicate?" or "What effect does jacketing emissivity have on thermal performance of pipe covering?" can quickly discern the expert from the amateur. There is a frighteningly large gradient of experience and expertise out there among vendors of firestops, whether they be contractors or manufacturers. Some can't tell a fire-resistance rated wall assembly from a fire wall. Some have no clue what an occupancy separation is and what difference that might make to firestop rating requirements. Others are well versed.

Apart from the MCTs, firestop systems were quite clumsy, compared to today's methods. Early German importers in fact saw much humor in this. Still, in the nuclear industry, MCTs were displaced by silicone foam, as a perceived cost benefit - which is probably the largest folly of all, considering all the reported events and continuous fire watches involved with silicone foam seals, the majority of which were designed by contractors and thus deviated substantially from manufacturers' instructions and certification listings. Most of the testing was run to 3 hours fire-resistance because the majority of fire separations in nuclear generating stations in the US were rated for 3 hours.

In the early eighties, domestic makers of firestops got serious competition (lighters ahead technically, though not necessarily ethically) from German vendors, who imported their products and later either manufactured locally or entered into other collaborative agreements in North America. By now, one would be hard-pressed to find firestop products in North America, that are actually imported from anywhere, in any significant volume. Margins and freight costs simply prohibit such practices. So much copying has gone on, that many, if not most product lines bear striking resemblance to one another.

Just like any in other business, ethics among manufacturers can vary to a large degree.

Widespread use of firestops in land-based construction came very gradually, and for the most part is still far from where it should be, when compared against that which the law requires now, or even that which was required in the early eighties.

Gradually, the most dedicated individuals within the firestop manufacturing companies began to have more and more of an effect upon code writing bodies, which resulted in a reduction of loopholes within the codes, which permitted the more usual methods of hole-plugging, such as nothing at all, or things like tar, paper waste, fibrous insulations, veneers of common cementitious grouts, discarded apparel or footwear, flammable organic foams etc.

When firestops are nowhere near code compliant, particularly in new construction, this is the scenario that cost cutting experts insist on engaging in by making sure that the firestopping is not done by one specialty firestop contractor, but instead by everyone who builds wall and floors, as well as those who poke holes in said walls and floors to permit passage of wiring, plumbing and other such mechanical and electrical services:

How to make sure that firestopping stays cheap and non-compliant with the law:

The architect may or may not provide a Section 07840 specification, which outlines firestopping requirements. Let's say the architect has provided this section. For best effect (making sure that non-compliances result beyond the shadow of a doubt), this section will not be co-ordinated even within the 14 Divisions of work under the control of the architect (There must be a law requiring this butchery.). Cutting and patching requirements in the general provisions, concrete block wall specs, drywall specs, as well as mechanical and electrical specs each have something to say about firestopping. If locally accepted practice has been to permit garbage firestops, then it stands to reason, that in order to survive, all contractors were forced to base their pricing and their estimate sheets on these ultra cheap methods, or else they would lose the job and go broke and hungry before too long. Since the low tender system is the best we as yet have to offer for contract awards, and since few to no owners are excessively interested in spending any more money than they are absolutely forced to do (and let's not judge here, since most of us go for the best pricing in a lot of the items we purchase on a regular basis), contractors react allergically to anything that can be considered to be an added cost, regardless of the reason. Added costs bring the project over budget and result in lost jobs, which means someone is not feeding his or her children, or paying the mortgage. So 'cheap', is the operative word. Firestopping is labor intensive and the materials are always more expensive than doing nothing at all or stuffing in some useless junk, using low skill or no skill labor at minimum wage or on a 'contract-basis'. No one who has spent any amount of time installing firestops particularly enjoys this work. It is a pain. To do it right and make it look good, you have to get into the most awkward positions, scurry into tiny, congested and dirty little places and work with sticky, gooey, fibrous, itchy, goos and slops and devices and widgets, that may look great on a website, be described in shining color by assorted sales reps, or in glossy literature, but it's basically all an industrial sized pain in the neck when it comes to doing the actual work. Firestopping for an electrician or a master plumber or sprinkler pipe fitter, is like traffic duty for a narcotics cop - instant decaf to the Starbucks customer, Diet Pepsi for the Coke Classic fan. To add insult to injury, when you really know what you are doing and actually apply it in each case, you're up to your neck in listings and tags and paperwork, in addition to the actual work of installations. And thus, human nature dictates that quality suffers. Ask yourself: How much do you enjoy doing something that you know is a pain in the neck? Thus, when the workscope is all busted up among a half a dozen or more trades on one single construction site, the new guys or the 'flunkies' get the work. And they don't like it any better. OK, so now instead of carrying say $50,000.00 to do the firestopping, trades carry perhaps $5,000.00. Then the general may bully and beat them down further (After all, GC's have to make a living in this tough business also.). "You want this mechanical job? OK, you've got it, but you're including the firestops for me, aren't you?" "Yes Sir!" Along comes our favorite martyr, the firestop salesman. He asks: "Who is responsible for firestopping here?" Plumber and electrician point to the masonry and drywall contractors. WHY? "Guess what: We're there first. We run our services and then whatever they do afterwards is not out deal." So, our martyr asks the mason and the drywaller the same question: "Can I show you my firestops - and would you like a price?? Pretty please?" "No way. Electricians and Plumbers do their own." How can this be? No one can afford proper firestops on the estimate sheets they based their contracts on. And thus no-one wants to admit anything and sends people all over the place. Some of the firestops may get done and some won't. The only way to combat this is if the architect sets the ground rules by using this specification, and then makes sure that proper installations actually take place, and that proper documentation is made available and then turned over to the owner post commissioning. And for the most part, he must be forced nearly at gunpoint to do this. Everything else is nonsense. It is quite cruel to do anything else and then let the subtrades run into a big knife, when suddenly firestopping may have to be done correctly, such as if the authority having jurisdiction begins to be vigilant in this area and starts randomly pointing to firestops on site and asking for copies of the certification listings which bound that hole. The whole cost-cutting charade of the above mentioned scenario falls apart like a house of cards and people start losing very serious money indeed. Some firestop manufacturers have expressed Schadenfreude at this, as they have been told lines of BS for years and years and all the endless excuses (insults to any quantum of intelligence) for why no one firestopped correctly, meaning their investments in testing and R & D, literature and promotions, travel costs etc. etc etc. would take that much longer to pay off, which should not have occurred if everyone had simply followed the building code and/or the fire code. It is tough to compete with rated materials, against - nothing - or against stuffed fibreglass or rags, etc. Probably, all the lies and excuses are simply part of human nature, particularly where one's own career or means to earn a living and support one's children is at stake. Still, what is perfectly amazing, is the level of deviousness in such cover-ups, even among professionals, who should be concerned about their liability insurance or just plain worry about waking up to a news story about burn victims, knowing they had a substantial part in this - even in hospitals, residential buildings (sleeping children!!!) or old folks homes. There is no reason we should have as many smoke inhalation victims as we can read about each year in statistics. Inoperable or missing firestops play a significant role in those statistics. At the same time, cover-ups concerning fire safety must be weighed by the perpetrators against negative financial effects upon their own families if unexpectedly added costs may sink their companies, departments or jobs. And thus we all struggle with the proverbial scales of justice in our own minds and actions.

This complex and sorry set of traps has been responsible for the majority of code infractions, insofar as firestops are concerned. The results can be grizzly indeed.

For instance, despite endless claptrap about assorted fires that come and go, it was specifically the Browns Ferry Nuclear Plant Fire of 22. March 1975, see SFPE Technology Report # 77-2, which kick-started land-based firestopping. To make a long story short, a multiple cable tray penetration in a pressurized service room of the plant was deemed in need of fixing. This 'firestop' was made of flammable polyurethane foam, with two coats of a fire retardant cable coating (Flame Mastic, made in California) on both sides. There is significant claptrap about the technical justification for this seal, despite the fact that proper MCT firestops were available in the US since the mid sixties and should have been used here. But suffice it to say that foaming holes shut with polyurethane foam is cheap. Put on some flame mastic and bingo, you have a listed product (though not listed or recommended by the manufacturer for this purpose), which will not burn when subjected to a cigarette lighter (the coating that is) and then add the customary QA/QC smoke screen, which makes everything look good in the nuclear field, as the more irrelevant physical properties are described and documented in voluminous agony, ad nauseam, as their regulations dictate. One day, there was a pressure leak. Someone sent an individual, armed with a candle, to this penetration seal. The idea was that he hold the candle to said penetration seal and wherever the candle flickered, he had to do some more sealing. An extinguisher was on hand as well. This leak finding procedure started a fire that lasted 6 hours and 40 minutes and resulted in a direct loss of 10 million US Dollars, as well as 30 million US Dollars because of business interruption related costs. In an operating nuclear plant, it is a good idea to have a solid fire safety plan to combat fire such that one can shut a reactor down to prevent the BIG 'M' word - meltdown.

This accident caused a flurry of paperwork, regulations and remedial work all over the US, which eventually funneled down to commercial/industrial/residential occupancies as well.

Fires occur on a regular basis. One can look up the statistics on a number of governmental websites, as well as NFPA's site. Insurance companies are also a great source of information on this particular topic, as each loss costs money. A large amount of damage, as well as casualties, are entirely preventable through solid fire prevention and fire safety practices, of which properly maintained and documented firestops are a large part. But often, even the fire investigation reports pay only minor attention to the role of absent or unlawful firestops as contributing factors to damages, lost lives and insurance claims.

The firestop business has grown since its fledgling beginnings to the point where we now count about 50 manufacturers, or at least companies that appear as though they are manufacturers, as they hold listings or co-listings. Often, private label arrangements and other collaborative arrangements are struck between trading partners, across the continent and around the world.

Firestop contracting, as a stand-alone business or trade is another uncharitable venture, for the most part. A large number of architects have un-coordinated specifications and workscopes are so fragmented, that in order to chase a small amount of work, such as all the firestopping on one construction site, an enterprising firestop contractor has the privilege of contacting upwards of 100 different companies, who are segmented into their respective trades, such as drywallers, curtainwall builders, mechanical and electrical contractors and so forth. In many locations, such sub and sub-sub tenders are never turned down at the time of tender, but often wind up as but a lowly occupier of space in the waste paper basket of these trades, who would jeopardize their jobs by carrying the right amount for firestopping. The low bidder will have the slimmest estimate sheet and must hedge his or her bets in terms of what may happen enforcement-wise, when it is time to execute the job. This is such a complex, though predictable mess, that very specific action is required by the architect to take control and prevent it by making it absolutely nonsensical and economically unviable to do anything other than to let a specialty firestop contractor do this work in one contract for the general contractor. At the outset, this provides great relief for all those subtrades, who can actually price their own work on a more level playing field, unburdened by the economical need to make shortcuts in fire safety in order to survive. Nothing other than this works. We have been at this for far too long than to be fooled by any of the misconceptions, lies, nonsense and claptrap that typically accompanies the decisions to bust up the firestop workscope. They are all, and always were and never will be anything other than nonsense and a sure path to jeopardizing fire safety on the job through pre-determined code violations. We would challenge anyone to come up with a new excuse for this. If, at the time of commissioning, the architect does not know how many holes there are and cannot tell you when walking up to a firestop, which certification listing bounds that installed configuration, the building is unsafe. And that is the case with the overwhelming majority of buildings in this Ontario.

There have certainly been improvements since 1966, when it all started. But what does that really mean to the 3 year old girl asleep on the 20th floor of the high-rise apartment or hotel building? No sprinklers, but her parents' apartment is supposed to protect her for two hours from smoke and fire. Of the 20 odd holes in this apartment, how many can we tolerate to be wrong? And how do we know that they were firestopped correctly? The architect MUST KNOW this, not guess and point in 20 different directions, weasel clauses, subtrades, M & E engineers - one must know at a glance. And for the most part they don't. They have no idea and more excuses than a convict going to jail. Perhaps that too is why additional provisions to the Architects Act are being implemented in Ontario to increase the quality of documents expected to be accepted by building departments across the Province of Ontario. Only by using and enforcing the a properly co-ordinated, single workscope firestop specification Section 07840 is there even a fighting chance of having properly documented and operable firestops. This way, the owner will actually have workable due diligence back-up to prove that what he has bought will work. He will then also know what to do and who to talk to make sure that it stays this way, when hordes of tenants, maintenance people and contractors storm the building with change orders, tenant work, new wiring and plumbing lines, data transmission cable bundles and so forth. If you have no clue as to what a firestop is all about, who made it, when it was installed and which certification listing bounds it, how can you possibly effect 1997 OFC compliant repairs?

The necessary steps towards a remedy to the intolerable status quo in this Province on this topic, strongly involve standardization, at every available opportunity. This is followed by legislation and then enforcement, all of which provides a level playing field so that the right thing is actually done and allowed for on construction sites. At least that is the ideal. There will always be inexperienced operators and also mistakes cannot be entirely avoided and neither can predatory pricing.

And human nature is still the biggest factor in it all. Cheap cheap cheap cheap. Please! Do it all for free and preferably yesterday with certificates and engineers' stamps, all for next to nothing and FAST! Then kiss up to the buyer for allowing you the privilege to do all this for next to nothing and so fast and with so much bullet-proof documentation. That is our species at its best I suppose. Who is to judge or cast the first stone?

So, standardization history of firestops. First there were the US military standards. The exact history of this within the United States Navy escapes us. But it is those good folks, who started it all in the sixties.

And from this community were spawned the civilian nuclear power folks. And that brings us to the American Nuclear Insurers. We now get to the realm of the revered Firestop Pope #2: Bill Bornhoeft. Bill was a man who became known for the fact that his first answer to a firestop vendor was typically "No." Bill also witnessed a number of Canadian tests at ULC. He was a joy (though tough yet fair) to have around. Unlike Firestop Pope #1 (Joe O'Brien), Bill retired from ANI, while Joe is still responsible for significant firestop sales each year.

One of the earliest firestop standards in land-based use on record in North America began when NEL-PIA (Nuclear Energy Liability Property Insurance Organization) outlined basic parameters for an acceptable fire exposure test for mechanical and electrical penetration firestops in a June 1975 bulletin to agents, brokers and architectural/engineering firms involved in the growing US nuclear power generating market. In February 1976, undoubtedly after consideration of Browns Ferry data, this was refined and issued as an 'NEL-PIA/MAERP Standard Method of Fire Tests of Cable and Pipe Penetration Firestops'. This standard was subsequently superceded by an ANI/MAERP RA GUIDELINES FOR FIRESTOP AND WRAP SYSTEMS OF NUCLEAR FACILITIES. On 05. January 1983, ULI issued UL1479, which was the basis of ASTM E814, which was the basis for ULC-S115 in Canada, which became a National Standard of Canada, through approval by the SCC, in July 1985, which missed the issue date of the next National Building Code of Canada by a hair and thus caused countless more infractions by means of provisions for more excuses by the aforementioned scenario. In 1978, IEEE (The Institute of Electrical and Electronics Engineers, Inc. issued IEEE Std 634-1978 IEEE Standard Cable Penetration Fire Stop Qualification Test. This was approved by ANSI on 21st June 1979. Among others, Firestop Pope #1 (Joe O'Brien) was on the committee. IEEE634 only covered electrical penetrations and most importantly provided a nice, cool shower for the test sample, immediately following the fire exposure. This makes it easier to pass the hose-stream test, particularly when compared to the typical 30PSI solid stream testing used everywhere else. Some US nuclear plants still utilize this test as a the original design basis for product evaluation. Other than that, it is a dead issue. However IEEE also issued Std. 848-1996 IEEE Standard Procedure for the Determination of the Ampacity Derating of Fire-Protected Cables, which applies not only to circuit protective fireproofing but also to firestops. Omega Point Laboratories has a routine set-up for running this test. Apparently, it took 17 drafts to get to the final stage. This is the state of the art for testing ampacity derating right now. The other significant development in standards of recent history is UL2079 Tests for Fire Resistance of Building Joint Systems dated 29. November 1994. UL2079 is the first test to cycle a firestopped joint through motion prior to the fire test. As far as Canadian standards history concerning firestops, significant work has gone into Canada's firestop test methods by members of Task Group 21 at ULC. There has been a lot of activity concerning updating this standard. An L rating has been issued in the last edition, dated 1995, as well as clarification concerning where pipes should be capped during a fire test, top or bottom, which makes a significant difference in terms of the results. Fortunately, TG21 took the high road and dispensed with the idea of permitting top capping, as the field controls on this issue would have led to nightmares.

The work of TG21 is probably the most progressive and positive development in North American firestopping to date. It continues at a steady rate.

The Situation in Ontario concerning Firestops

Everything stated above in the History of Firestops is applicable to Ontario. Regardless of what the OFC or OBC, NBC or NFC say or used to say about firestopping, the economic situation, coupled with a lack of understanding, lack of clout (particularly in rural communities, or 'one-horse-towns') of the enforcement community, both fire prevention officers and building inspectors, with few exceptions, such as The City of Mississauga, as of the late eighties, has ensured that inoperable or missing firestops are the norm in the Province of Ontario.

Moreover, the situation is continuing today. As you read this right now, there are architects and general contractors splitting up the firestop workscope on new buildings, such as hospitals, apartment buildings, homes for the aged, manufacturing plants etc., and thus making absolutely certain that what your fire prevention officers inherits with each building is an untraceable, irreparable and undocumented mess, in terms of the firestopping.

Since the stability, integrity and insulation functions of assemblies required to have a fire-resistance rating is voided with each missing and/or inoperable firestop, you have a very big problem on your hands.

Firestop non-compliances can be broadly grouped into the following categories:

This particular example can be found at the "Sudbury Supermall", 1485 Lasalle Blvd., Sudbury, ON P3A 5H7

You are looking at a large (each missing concrete block = 1ft²) multiple penetrant through penetration. If you lift some ceiling tiles in the stores, near fire separations, as well as check service rooms, you will find this condition to be typical in this building, which is consistent with the above outlined history. This is a generic docket. These are specific examples from our travels through your Province. But rest assured that they apply across the board. Directly across Barrydowne Rd., from the above mentioned mall, you will find more of the same, this time as seen from a store, which does not have a dropped ceiling. The view shows the rated fire separation between the service corridor and the store:

Upon closer examination, you will see that the fire separation is not only penetrated, with the through penetrations unsealed, but in fact the wall itself is inoperable in other respects. In the bottom picture, the blocks have been partially dislodged as a result of savage re-entry with assorted services. Unfortunately the resolution is not as clear as one might wish, due to the lighting in the place, which interferes with better photography above the store lights. But when you have a closer look on site, you will discover that the block wall actually stops short of the Q deck above. The space was then filled with rockwool batts, in place of concrete block.

The rockwool stuffing is actually representative of the next category of non-compliant firestops:

This picture shows a cable tray penetration with serious power cables, above a firedoor, at Domtar's pulp and paper mill in Espanola, ON. The apparent (and partial) "seal" consists once again, of plain rockwool. Not unlike many other occupancies in the Province of Ontario, pulp and paper mills such as Domtar require constant penetrant changes. Additions and renovations are a matter of constant occurrence. Even when new additions are firestopped, the firestops, which may be operable for up to a week post commissioning, they are soon re-entered and either not re-sealed at all, or unlawfully sealed by means of stuffed fibers of some sort. No records indicate what existing seals are about and thus no approved repair procedures are in place. In fact, plant personnel often don't even know which assemblies are required to have a fire-resistance rating and what the duration of said rating might be, and whether the separation is perhaps a fire wall or an occupancy separation. No idea and no concern one way or the other. What is typical (generic), and indicative of Domtar, compared with other such occupancies across the Province of Ontario is that the local plant has a lot of what we refer to as "JUICE". In smaller towns, as is the case in this particular example, building inspectors and fire prevention officers can be volunteer staff with next to no backing from the municipality. They dare not venture into the facility unless asked, let alone point out deficiencies or to hand out orders to comply to deal with any such deficiencies.

Similar conditions are known to exist at the following industrial occupancies (among others, again the problem is generic, but you may have a look in these places to confirm the generic nature of the problem for yourself - particularly in the older plants)

3.) Proper firestops defeated by busted up workscopes, improper specs, absence of sufficient inspections

Here is a typical scenario of the "I-was-there-first" syndrome. This particular example was found at the Nortown Casitas style condominiums east off Yonge Street in Toronto, (formerly North York, ON, north of the 401). Consistent with the history section shown above, we have a plumber saddled with doing his own firestops, for which he was unable to allow enough money if he really wanted the job from this particular developer. In fact, this particular project is typical of the developer. A probe into all written statements provided by architectural staff concerning fire protection on the job (including site minutes and all correspondence) may be enlightening to your investigator. You may find a pattern from one project to the next. Bear in mind that site inspection reports on behalf of the condominium corporation included site visits, after finishes were up. Only a portion of problems traceable through the entirety of the architects' written statements (correspondence and site meeting minutes) are routinely found in such final inspection reports. In this case, the generic problems multiply beyond firestopping.

But back to the firestop application shown here: The plumber did not allow sufficient funding for the firestops through the slabs. Apart from that, there was a question about provision of firestops within concrete slabs inside of the suites due to code compromises combining a part 3 and part 9 approach. The floor penetrations you see are actually done correctly. But drywall penetrations were excluded from the firestop workscope. Why? The plumber was there first and considered the through penetrations resulting from drywall based fire separations to be the drywaller's business. Do you think the drywaller agreed? Have a look at the holes behind the finishes. By law, you CAN lift ceiling tiles at the very least. Then have a look at the surgically small annular spaces permitted around through penetrants in drywall penetrations in the listings provided by UL, ULC and WH. Try to find a listed firestop that covers such large penetration sizing - particularly with plastic piping! Drywall mud does not make up for gypsum wall board in a listing. This sort of thing is every-day reality in the Province of Ontario. Also, at Nortown, have a look in the parking garage. Once inside, when you look up, you will see an occupancy separation. This means that all the firestops must have a 2 hour FT rating. See if this exists on the gas piping, conduit, wiring and other metallic penetrants. When you investigate this building, bear in mind that there are sleeping children, who depend on those firestops. The situation is aggravated because of the fact that the building is a combination between Part 3 (non-combustible) and Part 9 (combustible) construction. All the plastic piping provides an enormous amount of fuel, to go with the questionable firestops.

All of this is repeating itself RIGHT NOW at each hospital currently under construction in Ontario.

What you are looking at is a typical electrical through-penetration in a service room at the CBC building in Toronto, ON, Front Street. Please note that the generic conditions are prevalent not only in the private sector, but also in government, both Provincial and Federal. Of immediate concern, for the Province, should be buildings owned and operated by the Ontario Realty Corporation, as well as the hospitals, due to the nature of occupants. The matter is of critical importance here. One must be aware of the contributing factor inoperable or missing firestops have towards increasing the number of smoke inhalation casualties in the Province of Ontario. How much smoke, do you seriously think this through-penetration seal is capable of impeding? This generic condition exists all over the Province and we all know about it. The reasons for it are clearly outlined and demonstrated in this document. In this specific case (CBC Toronto), we have a combination of factors. First of all, re-entries have occurred all over the building. Re-sealing, has not. Next, the majority of firestops in the building are inoperable to begin with. The firestop mortar utilized in this penetration seal is listed for use in a minimum thickness of 3". The actual thickness here hovers around the 1" mark and varies all over the building but never actually reaches the required 3".

Because of the way that firestops are installed and documented in the Province of Ontario, the owner was not provided with anything useful that enabled him to tie the installed configuration in the field to a certification listing. What documentation they do have, was provided after the fact by an outside report, which did not, to the best of our knowledge, result comprehensive remedial action all over that building. Just have a look in the service rooms. Lift a few ceiling tiles next to fire separations. If you see intact firestops, ask what certification listing bounds the installed configuration.

Telltale Signs for Fire Prevention Officers indicating Firestop Non-Compliances

1. Owner has no answer for the question: "How many firestops are in your building?" If he or she does not have an answer to this question, there is no comprehensive maintenance going on. All the conditions described in here are sure to exist in this building.

2. Owner has no idea who made the firestops used in his or her building. Everyone re-enters openings and/or makes new openings all the time for new wiring, plumbing lines etc. If the owner does not know what he or she has (out of the 50 odd manufacturers out there), then how could he or she possibly know what the approved repair procedures are?

3. No tags on any of the firestops. If the holes are not tagged, no inventory of them exists, mayhem rules.

Quick Firestop Inspection Guidelines for Fire Prevention Officers

1. Ask the owner how many firestops are in his or her building. If the answer is anything less than a certain number, rest assured the building is far out of compliance. They have no idea what they are doing; look further.

2. Go to the main electrical room first, then other service rooms. Check for firestops. If they are breached, you now have proof of this generic condition all over the building. If there are intact seals in place, then point to one and ask the owner which certification listing bounds the installed configuration. If the answer is anything less than a copy of the certification listing by UL, ULC or WH, which actually bounds the installed configuration in each respect (CHECK!), you now have the basis for an order to comply.

3. Continue by lifting a few ceiling tiles in corridors, particularly at cross barriers and repeat the same steps as in #2 above. Indicate that you will be back to perform random checks. You are entitled by law to receive a copy of the certification listing for each installed firestop. This is the only proof of compliance in existence.

Remedial Action recommended by FPDL

1. Confirm, as recommended herein, the nature of the generic conditions/fire code infractions through your own investigation in the occupancies shown here as typical examples.

2. Communicate your findings by means of bulletin to each of your fire chiefs, mandating inspections in all occupancies, which contain assemblies required to have a fire resistance rating and issuance of orders to comply where non-compliances are found.

3. Engage in dialogue with the Ontario Ministry of Municipal Affairs and Housing, publishers of the Ontario Building Code. We recommend that provisions be added to both codes that include the requirement that all firestops be clearly marked to indicate bounding, as described herein. The tagging requirement already exists for fire extinguishers and sprinkler systems. Those systems and items are simple, compared to firestops. In order to determine bounding, each listing components must be identifiable and quantifiable in terms of location and sizing tolerances.

4. A further code requirement we recommend is that all mechanical and electrical drawings show all fire separations, indicating hourly fire resistance ratings, type and construction and clearly identify all fire walls and occupancy separations. Mechanical and Electrical drawings should also clearly show all penetrants. Currently, they do not. If you cannot see the penetrants, how can you plan for the firestops?

5. Another recommended addition to your fire code is mandatory inspection of all accessible firestops on a minimum semi-annual basis everywhere, every 3 months for all hospitals and nursing homes as well as industrial occupancies with major power distribution centers. Similar requirements, again, are mandatory for suppression and detection systems. But bear in mind that those are not subject to anywhere near the abuse that firestops are routinely subjected to.

6. Furthermore, we recommend that all particulars of the firestop maintenance program be submitted to the fire department prior to commissioning. Ongoing certificates must be regularly filed with the fire prevention officer. All firestops must thus be clearly identified (tagged) by means of a durable tag, on both sides of each hole, showing the name of the installer and bounding references, as defines herein.

In short, bounded firestops are the law of the Province of Ontario. This law has been and is continuing to be broken all over the Province, which is resulting in a serious threat to safety for Ontario residents. It takes specific and vigilant enforcement action to remedy this. This action is warranted for compliance with existing legislation. The added code provisions we recommend herein should help to clarify and simplify the enforcement task.

As always, we would appreciate your acknowledgment of this docket and welcome any questions. Please refer to this file number. Our members will be monitoring your progress in the field in 4 different municipalities.