NBC Public Review, Fall 2013 Comments on Part 9 and Other Related Proposed Changes

Transcription

1 NBC Public Review, Fall 2013 Comments on Part 9 and Other Related Proposed Changes Prepared by G. Adaire Chown for CHBA and CMHI 19 November 2013 Contents Overview... 3 Introduction... 3 Comment Count... 3 Significant Proposed Changes... 4 Accessibility... 5 Air Leakage... 5 Airborne Sound Transmission (7 PCFs)... 5 Div. A, Defined Terms Sound Transmission Sound Transmission Control and Cross-References... 7 EIFS (1 Part 9 PCF) Cladding Exit Signs (1 Part 9 PCF) Exit Signs... 8 Fire Alarm and Detection Systems (2 Part 9 PCFs) Commissioning of Life Safety and Fire Protection Systems Smoke Alarms... 9 Masonry Terminology (12 Part 9 PCFs)... 9 A Defined Terms Fire-Resistance and Fire-Protection Ratings Support of Floor Joists Masonry Veneer (1) Cavity Walls Supporting Framing Members (3) Cavity Walls Supporting Framing Members Distance to Edge of Supporting Members A Distance to Edge of Supporting Members Corbelling Wall Thickness Pilasters Parapet Walls Masonry Unit Standards Distance to Edge of Supporting Members Other (4 Part 9 PCFs) A Application Soft Conversion Limitations Soft Conversion Table Guards for Floors and Ramps in Garages Penetrations (1 Part 9 PCF) Required Fire Blocks in Concealed Spaces Protection near Cooktops and Ovens (2 Part 9 PCFs) Fire Protection for Gas, Propane and Electric Cooktops and Ovens Vertical Clearances above Cooktops CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 1 of 36

2 Reference Documents Wood-Based Fire Blocks (1 Part 3 PCF) Fire Block Materials Residential Sprinklers (2 Part 3 PCFs) Roofing Dampproofing, Waterproofing - (9 Part 9 PCFs) Scope and Application Dampproofing Waterproofing Roofing General Roofing Materials Material Standards Secondary Suites - (2 Part 9 PCFs) Design and Attachment of Handrails Loads on Guards Security Systems that Affect Egress - (2 Part 9 PCFs) A Location of Exits Visibility of Exits Smoke Tightness of Closures in Fire Separations - (1 Part 9 PCF) Fire Dampers Stairs, Ramps, Handrails & Guards Div.A Defined Terms Stair Configurations (2015) Step Dimensions Ramps Landings Handrails Guards Structural Design Glass (1 Part 9 PCF) Structural Sufficiency of Glass Use and Protection of Foamed Plastics Glass (2 Part 9 PCFs) Protection of Foamed Plastics Coverings, Linings, Adhesives and Insulation Ventilation Dryer Venting (1 Part 9 PCF) General CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 2 of 36

3 Overview Introduction The comments provided in this document have been prepared for consideration by CHBA and CMHI for submission during the Fall 2013 public review of proposed changes to the national model codes. For each proposed change to the National Building Code (NBC) Part 9 Housing and Small Buildings and related changes in other Parts of the NBC, this document provides: a summary of the proposed change a suggested comment, which is drawn from the options permitted in public reviews a) b) Support with comments c) I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below d) I do not support this proposed change for the reason(s)* stated below. for the suggested comment where the comment is c) or d), a Recommendation to resolve the concern. Where issues related only to code wording or structure have been identified, the suggested comment is and comments will be submitted by the author as a private comment. These cases are identified under. The proposed change forms (PCFs) are provided on the national codes website in code order and also by subject. This document presents the PCFs by subject. To assist reviewers, a few headings are provided to to indicate subjects where there are no proposed changes to Part 9. Comment Count The options for comments on proposed changes are: PCFs identified a) 40 b) Support with comments 6 c) I support this proposed change with the modification(s) to 11 the Code material and associated reason(s)* stated below. d) I do not support this proposed change for the reason(s)* 1 stated below. Total Part 9 and related Division A 58 Division A 5 Division B, Part 9 (duplicates in web count) 53 (+11 duplicates) Referenced Division B, Part Sound Transmission - accept Fire Block Materials - comment Landings - modify (parallel to Part 9 requirement) Handrails - modify (referenced by Part 9) CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 3 of 36

4 Significant Proposed Changes Supported PCFs PCF Code Ref. Subject Comments done 8 of 19 Stairs, Ramps, Handrails and Guards Handrails (2) A (2) Graspability accept Guards Climbability Support with comments Fire Protection for Gas, Propane and Electric Cooktops and Ovens Vertical Clearance above Cooktops - Support with comments Microwave Ovens PCFs Recommended for Modification or Withdrawal PCF Code Ref. Subject Comments done 8 of 19 EIFs Cladding - EIFS modify question re. capillary break for high moisture load Soft Conversion 747 A Soft conversion of spacing modify address more cases Stairs, Ramps, Handrails and Guards Stair Configurations 702 [ ] Flights with Mixed Treads within Dwelling Units consistency of tread depth Step Dimensions 701 [ ] Dimensions of Tapered Treads in Dwelling Units modify measurement of tread depth from handrail modify measurement of tread depth from handrail; A Landings A Spiral Stairs Dimensions of Landings, simplification modify tread measurement modify CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 4 of 36

5 PCF Code Ref. Subject Comments done 8 of Handrails (2) A Handrail Reachability modify intermediate handrails, direct path; Appendix Note (5) Side of Stair do not support Invalid justification; incorrect costing Continuity modify Sound Transmission Flanking Sound Transmission modify topping and flooring Accessibility No PCFs apply to Part 9 provisions Air Leakage No PCFs apply to Part 9 provisions Airborne Sound Transmission (7 PCFs) Div. A, Defined Terms PCF 707 DivA Adds defined terms for ASTC and STC and an Appendix note OK as published. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 5 of 36

6 Sound Transmission PCF 742 -DivB Clearer reference to Part 9. Essentially editorial Sound Transmission Control PCF 772 -DivB Sound provides limits to address flanking sound - for the general case, requires min. apparent sound transmission class (ASTC) of 47 db, or min. STC 50 db plus compliance with prescriptive construction criteria - for dwellings in houses with secondary suites, requires min. apparent sound transmission class (ASTC) of 40 db, or min. STC 43 db, or compliance with prescriptive construction criteria references only the laboratory test for STC, deleting the reference to site tests for determination of ASTC, provides the options of - testing/measurement (reference to standards) or - calculation (reference to Part 5) for compliance with ASTC rating, provides the options of - testing/measurement - calculation, or - construction of assemblies according to new ASTC tables that describe treatment of flanking assemblies for separating wall or floor/ceiling assemblies described in the existing STC tables. updates Appendix notes I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. 1. Editorial /Technical Application of Without a limit on the application of Article , this Article may be interpreted as applying in all instances. Recommendation Insert a new Sentence (1) to state the application of Article : 1) This Article applies where required protection is provided according to Clauses (b) and (2)(b). 2. Editorial /Technical (2)(b) and application of Table Without considering the contents of Table , it is not clear whether the clause conforming to Table applies to both topping and finished flooring or one and/or both. A dry-run f the requirements indicated that the Clause may be interpreted as requiring concrete topping plus the materials described in the Table. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 6 of 36

7 The words and/or between topping and floors would be clearer. If this construct is not permitted, it would be better to refer to the Table without referring to topping and flooring. Recommendation Revise Clause (2)(b) to read as follows: b) be supported on joists/trusses that are i) not continuous across the junction, and ii) covered as described in Table for the applicable wall construction. 2. Editorial /Technical Table The entry for walls W13, W14 and W15 states that it applies Where a continuous subfloor or other rigid materials at the floor/wall junction provide structural connection between the two rows of studs of the separating wall. Because there is no entry in the Table describing assemblies where there is NO continuous subfloor or other rigid materials at the floor/wall junction to provide structural connection between the two rows of studs of the separating wall, this could be mistakenly interpreted to mean that such assemblies are not permitted when in fact they are permitted and there is no requirement for topping or flooring. Recommendation Insert at the beginning of the Table entry for walls W13, W14 and W15: Where there is no continuous subfloor or other rigid materials at the floor/wall junction that provides structural connection between the two rows of studs of the separating wall, topping need not be installed and any finished flooring is acceptable and Cross-References PCF (01) / (04) / (05) Editorial changes for sentences that currently refer to the A A and B tables PCF to moves Tables A into the body of the Code is provided as a supporting document OK; essentially editorial. EIFS (1 Part 9 PCF) Cladding - PCF 645 -DivB EIFS Adds provisions to address use of EIFS. I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. Technical Minimum Protection Referencing the EIFS standard is supported as a positive step in recognizing this cladding system in the Code. Concerns remain, however, with respect to its use in climates with a higher moisture index, where the cladding assembly is required to incorporate a capillary break, and where the substrate is moisture susceptible. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 7 of 36

8 Existing Sentence (1) describes acceptable capillary breaks as: a) drained & vented airspace min 10 mm over full area b) drainage material... min 10 mm and min 80% open c) horizontal strip siding. min 10 mm at bottom; min 71% 6 mm d) masonry veneer or cavity wall... min 25.4 mm and min 50 mm For EIFS, proposed Clause (1)(b) specifies a min. depth of 6 mm over a minimum 13% of the panel area. This is considerably less stringent than the existing requirements and does not allow for construction tolerances. While it is recognized that drainage tests have been conducted, reliance on the results of these tests is questioned in light of the MEWS report which indicated poor drying capability in warmer and wetter climates. The installation as described in the proposed change is acceptable over masonry or concrete, and appears to provide acceptable performance in drier climates. CHBA requests confirmation that the proposed change will provide acceptable performance in warmer and wetter climates where the substrate is moisture susceptible. See attached excerpt from Final Report from Task 8 of MEWS Project (T8-03) Hygrothermal Response of Exterior Wall Systems to Climate Loading: Methodology and Interpretation of Results for Stucco, EIFS, Masonry and Siding Clad Wood-Frame Walls (IRC-RR-118, National Research Council of Canada, Ottawa, November 2002) noting that the climate in Seattle is very similar to that in the south coastal B.C. Exit Signs (1 Part 9 PCF) Exit Signs PCF 556 -DivB Exit Signs OK; editorial Fire Alarm and Detection Systems (2 Part 9 PCFs) Commissioning of Life Safety and Fire Protection Systems PCF 382 -DivB References CAN/ULC-S1001 for integrated systems testing OK; the standard is accepted for the purpose. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 8 of 36

9 Smoke Alarms PCF DivB Accepts fire alarm systems in lieu of smoke alarms OK as an option. Masonry Terminology (12 Part 9 PCFs) A Defined Terms PCF Div. A - Solid Masonry Definitions Provides definitions for solid masonry OK; consistent with usage in CSA standard Fire-Resistance and Fire-Protection Ratings PCF A Solid masonry units - fire and sound resistance Change to wording consistent with definitions for solid masonry OK CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 9 of 36

10 Support of Floor Joists Masonry Veneer (1) Cavity Walls Supporting Framing Members (3) Cavity Walls Supporting Framing Members Distance to Edge of Supporting Members A Distance to Edge of Supporting Members Corbelling Wall Thickness PCF Masonry Terminology Change to wording consistent with definitions for solid masonry OK [Comment to be submitted by GAC on wording.] Pilasters Parapet Walls PCF Masonry Terminology - Solid Masonry Change to wording consistent with definitions for solid masonry OK [Editorial comment to be submitted by GAC.] Masonry Unit Standards PCF Masonry Unit Standards Replaces individual references to various standards in CSA A-82 with a single reference OK; appropriate updates to standards. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 10 of 36

11 Distance to Edge of Supporting Members PCF (1) - Distance to Edge of Supporting Members Deletes projection provisions for hollow units OK [Editorial comment to be submitted by GAC.] Other (4 Part 9 PCFs) A Application Soft Conversion Limitations Soft Conversion Table PCF Soft conversion Provides explanatory Appendix Note. I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. 1. Editorial The title of the Appendix note does not describe the issue discussed. The issue of conversion applies to numerous provisions in Part 9, not just those identified in this PCF. It can t be assumed that framing remains at imperial spacing to align with sheathing material sizes; the opposite could be true. The two are undoubtedly tied together. 2. Technical..a) Because the information is provided only in an Appendix note, it is not enforceable so specified metric dimensions could be imposed...b) There are other issues that arise in addition to those identified. Recommendation Reference the Appendix note from a new provision in Subsection 9.1. as follows: Dimensions General 1) Unless otherwise provided in this Part, compliance with specified dimensions shall not include tolerances Sizes and Spacing 1) Variation from specified dimensions shall be permitted for minimum sizes and maximum spacings where the construction used has been demonstrated to provide effective performance. (See Appendix A.) CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 11 of 36

12 A Variation in Dimensions for Sizes and Spacings Article is intended to effectively identify an alternative acceptable solution, recognizing that traditional construction relying on imperial dimensions remains in use and that this is deemed to comply with the dimensions specified in Part 9. The conversion table at the end of the Code provides factors for the conversion of millimeters to inches. Many dimensions specified in the Code are exact (hard) conversions; e.g., step dimensions, lumber sizes, panel thicknesses, fastener length, spans. However, this is not always the case. The metric dimensions specified for some sizes and spacings are soft conversions Sizes and spacings consistent with the imperial values and their corresponding hard conversions as provided in Table A are deemed to comply for elements such as, but not limited to: - framing including furring and strapping - spacing of elements that depend on spacing of framing such as ties for masonry veneer - footing sizes - dimensions that depend on traditional component dimensions such as concrete blocks and resultant foundation wall thickness and spacing of reinforcement in block foundation walls... Table A Acceptable Hard Conversions...Traditional...Acceptable...Soft Conversion Imperial Value... Hard Conversion... Provided in the Code 12 inches..305 mm mm 16 inches..406 mm mm 24 inches mm mm 32 inches mm mm 40 inches.1016 mm mm 48 inches mm mm 64 inches.1625 mm mm 72 inches.1828 mm mm Guards for Floors and Ramps in Garages PCF Vehicle Guardrails References Part 4 for loads OK; appropriate cross-reference. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 12 of 36

13 Penetrations (1 Part 9 PCF) Required Fire Blocks in Concealed Spaces PCF Required Fire Blocks in Concealed Spaces of Part 9 Building Applies requirement for blocking in ceiling/attic/roof spaces to unsprinklered spaces rather than unsprinklered buildings Consistent with Part 3 and provides protection where the fire originates in unsprinklered spaces or outside the building where the soffit is not protected. Protection near Cooktops and Ovens (2 Part 9 PCFs) Fire Protection for Gas, Propane and Electric Cooktops and Ovens PCF Protection of Above Ranges Adds text to Appendix note on installation of microwave ovens over cooktops and revises figure to illustrate Support with comments Change responds to interpretation problems. The proposed wording for the Appendix note should help to avoid misinterpretation Vertical Clearances above Cooktops PCF Asbestos millboard above cooktops Deletes option of providing protection with asbestos millboard OK; asbestos mill board is no longer used. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 13 of 36

14 Reference Documents Wood-Based Fire Blocks (1 Part 3 PCF) Fire Block Materials PCF New Wood-Based Fire Block Materials Accepts manufactured wood-based materials for use as fire blocks Support with comments SC-FP or the TG responsible for the change should have proposed the same for Part 9, Sentence (2) Residential Sprinklers (2 Part 3 PCFs) No Part 9 PCFs Roofing Dampproofing, Waterproofing - (9 Part 9 PCFs) Scope and Application PCF General (waterproofing and dampproofing) States the Scope of the Section and application of each of the Subsections OK; largely editorial Dampproofing PCF Dampproofing Materials provides performance requirements including maximum vapor permeance deletes references to old standards and adds references to new ones identifies other acceptable materials Application Standards deletes references to old standards Preparation of Surface requires substrate preparation according to manufacturer s instructions references Section 9.20 for parging material identifies additional materials that can be used for sealing holes in concrete walls expands application of requirement for surface to be clean, dry, etc. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 14 of 36

15 Application requires application according to manufacturer s instructions requires continuity Protection of Interior Finishes accepts polystyrene for dampproofing floors and deletes bitumen OK; the update is needed Waterproofing Waterproofing Required Waterproofing provides more generic description of where waterproofing is reuqired Materials provides performance requirements including maximum vapor permeance deletes references to old standards and adds references to new ones identifies other acceptable materials Application Standards deletes references to old standards Preparation of Surface requires substrate preparation according to manufacturer s instructions references Section 9.20 for parging material expands application of requirement for surface to be clean, dry, etc. Application requires application according to manufacturer s instructions requires continuity, protection, etc. Protection of Interior Finishes accepts polystyrene for dampproofing floors and deletes bitumen OK; the update is needed Roofing General Roofing - General Definitions Provides definitions for roof and roofing Purpose of Roofing Expands performance provision References Part 5 an alternative A (2) Expands performance provision References Part 5 an alternative CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 15 of 36

16 OK. Largely editorial. Reference to Part 5 is needed for approaches not described in Part 9. [Editorial comment to be submitted by GAC.] Roofing Materials PCF Application of Materials Deletes references to material standards Requires substrate prep and roofing materials listed in new Tables A and B to be installed in accordance with manufacturer s instructions OK; the update is needed Material Standards PCF Add/delete Roofing Material Standards Deletes references to material standards Requires substrate prep materials listed in Table A to comply with listed standards Provides new Table A of substrate prep materials and standards Requires roofing materials identified in Table B to comply with listed standards Provides new Table B of roofing materials and standards Limits application of ASTM D 3019 for lap cement to non-asbestos roll roofing. OK; the update is needed. Secondary Suites - (2 Part 9 PCFs) Design and Attachment of Handrails PCF Design and Attachment of handrails for houses with secondary suites Expands application of handrail attachment requirement for single dwelling units to include houses with secondary suites Support with comments The change makes the application of this requirement consistent with the application of other requirements and exceptions for stairs, ramps, guards and handrail to single dwelling units and houses with secondary suites. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 16 of 36

17 Loads on Guards PCF Loads on Guards for houses with secondary suites Expands application of loading provisions for guards within single dwelling units to include those within houses with secondary suites Support with comments The change makes the application of these provisions consistent with the application of other requirements and exceptions for stairs, ramps, guards and handrail to single dwelling units and houses with secondary suites. Security Systems that Affect Egress - (2 Part 9 PCFs) A Location of Exits PCF Remoteness of exit discharges Change to Appendix Note to recognize that provision of second exit also addresses the case where one exit may be blocked by an exterior incident. OK; explanatory only Visibility of Exits PCF Signs on exterior exit doors prohibiting parking and storage Adds requirement for a sign or physical barrier prohibiting obstruction of exit by parking or storage OK; acceptable requirement. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 17 of 36

18 Smoke Tightness of Closures in Fire Separations - (1 Part 9 PCF) Fire Dampers PCF Introduction of Smoke Dampers in Air-Transfer Openings in Small Buildings Fire dampers references Part 3 for fire dampers and exceptions expands application to air transfer openings. Smoke dampers Adds requirement for smoke dampers in air transfer openings (not ducts) Appendix note makes clear that the requirements for smoke dampers only applies to air transfer openings (not ducts) Support with comments reference to Part 3 is reasonable for these elements and helps to avoid inconsistencies limited application of the smoke damper requirement to air transfer openings is acceptable and reasonable for Part 9 buildings a definition of air transfer opening would assist in proper interpretation and application Note to Reviewers: With more frequent use of dwelling unit ventilation systems complying with Section 9.32 in multi-unit residential buildings and consequently the installation of a separate system for spaces outside the dwelling units, are air transfer openings through fire separations an issue? Stairs, Ramps, Handrails & Guards Summary of PCFs and Comments PCF Code Ref. Subject Comments Div.A Defined Terms Run. Definition accept Tapered Tread, Definition accept Flight modify nosing dimensions Stair Configurations Stair Configurations General accept A Winders move Sentence accept 702 [ ] Flights with Mixed Treads within modify Dwelling Units consistency of tread measurement of tread depth depth from handrail CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 18 of 36

19 PCF Code Ref. Subject Comments Step Dimensions 699 A Appendix Note for Tread Configurations Dimensions of Tapered Treads in Public Stairs 701 [ ] Dimensions of Tapered Treads in Dwelling Units Uniformity and Tolerances for Risers and Treads Spiral Stairs A Ramps accept accept modify measurement of tread depth from handrail accept modify tread measurement, provision/a-note location Ramp Width accept Ramp Slope accept Landings Dimensions of Landings, dimensions A Handrails Dimensions of Landings, simplification Support with comments modify (2) Handrail Reachability modify A Handrail Reachability intermediate handrails, direct path modify intermediate handrails, direct path; Appendix Note (05) Side of Stair do not support Invalid justification; incorrect costing Continuity modify Handrail Height accept (1) Clearance to Rough Surface accept (2) A (2) Guards (1) and (3) Graspability Exception for maintenance, Required at stair/ramp wells accept accept Loads on Guards accept Openings in Guards Industrial Occupancy accept Climbability Support with comments CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 19 of 36

20 Div.A Defined Terms PCF Code Ref. Subject Comments done 8 of 19 Div.A Defined Terms Run. Definition accept Tapered Tread, Definition accept Flight modify nosing dimensions PCF Run. Definition Provides definition for run. OK PCF Tapered Tread, Definition Provides definition for tapered tread OK PCF Flight (stair) - Definition Provides; definition for flight Appendix note figure to illustrate. I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. - technical The top and bottom dimension lines should clearly indicate that the flight includes the top and bottom riser and any nosing on the landing. Recommendation Revise Appendix figure to show nosings, and to include these and the top and bottom risers within the flight. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 20 of 36

21 Stair Configurations (2015) PCF Code Ref. Subject Comments done 8 of Stair Configurations Stair Configurations General accept A Winders move Sentence accept 702 [ ] Flights with Mixed Treads within modify Dwelling Units consistency of tread measurement of tread depth depth from handrail PCF Stair Configurations - General Requires tapered treads in a flight to turn in one direction References Part 3 for exception to permission to use curved flights Moves limit on number of sets of winders in a flight Provides Appendix table describing acceptable configurations. OK [Comment to be submitted by GAC on code structure and wording] PCF Winders move Sentence Moves limit on number of winders to Article on Winders OK; editorial only. [Comment to be submitted by GAC on code structure.] PCF 702 [ ] Flights with Mixed Treads within Dwelling Units Measurement of tapered tread depth to be from centre of handrail at narrow end of tread I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. Technical/Editorial The proposed change assumes that there is a handrail on the inside of stairs with tapered treads. The proposed change cannot be supported because: a) it assumes support of the proposed change to add a new Sentence (5) to require handrails on the inside of stairs with tapered treads, a change that is not supported, b) there is no requirement for handrails to be installed in the inside of winders so there may be no handrail from which to measure. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 21 of 36

22 Recommendation Revise Sentences (1) and (2) [2015] to read as follows: 1) Except as permitted in Sentence (2) and as permitted in Article , tapered treads and rectangular treads within flight shall have a consistent run at the narrow end and of the tread measured 300 mm from a) the center line of the handrail where a handrail is installed at the narrow end of the tread, or b) the end of the tread where there is no handrail at the narrow end. 2) Where tapered treads are located at the bottom of the flight, the run of the tapered tread measured as described in Sentence (1) may exceed the run of the rectangular tread. [Comment to be submitted by GAC on code structure.] Step Dimensions PCF Code Ref. Subject Comments done 8 of Step Dimensions 699 A Appendix Note for Tread Configurations Dimensions of Tapered Treads in Public Stairs 701 [ ] Dimensions of Tapered Treads in Dwelling Units Uniformity and Tolerances for Risers and Treads Spiral Stairs A accept accept modify measurement of tread depth from handrail accept modify tread measurement, provision/a-note location PCF 699 A Appendix Note for Tread Configurations Revises Appendix note on Step Dimensions to describe the four acceptable tread configurations, elements of steps and their measurement. OK [Comments to be submitted by GAC on code wording and structure, with editorial comments on the appendix note illustrations.] CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 22 of 36

23 PCF Dimensions of Tapered Treads in Public Stairs Specifies minimum run measured from centre of handrail at narrow end of tread consistent angle measurement of tolerances See also: Dimensions of Tapered Treads in a Curved Flight Div.B (01)_(04) Curved Flights in Exit Stairs Div.B (03)(04) OK. Measurement from handrail is acceptable because curved public stairs are required to have handrails on both sides [Comment to be submitted by GAC on code structure and wording.] PCF 701 [ ] Dimensions of Tapered Dwelling Units Specifies minimum run measured from centre of handrail at narrow end of tread consistent angle measurement of tolerances Treads in I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. Technical The proposed change assumes that there is a handrail on the inside of stairs with tapered treads. The proposed change cannot be supported because: a) it assumes support of the proposed change to add a new Sentence (5) to require handrails on the inside of stairs with tapered treads, a change that is not supported, b) there is no requirement for handrails to be installed in the inside of winders so there may be no handrail from which to measure. Recommendation Revise Sentence (1) [2015] as follows: [2015]. 1) Except as provided in Articles and , tapered treads in dwelling units shall have a run that a) is not less than 150 mm at the narrow end of the tread, and b) complies with the dimensions stated in Table when measured at a point 300 mm from. i) the center line of the handrail where a handrail is installed at the narrow end of the tread, or ii) the end of the tread where there is no handrail at the narrow end [Comment to be submitted by GAC on code structure.] CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 23 of 36

24 PCF Uniformity and Tolerances for Risers and Treads Deletes sentence specifying single direction in turn of tangled treads. (The requirement is proposed to be included in Article ) OK [Comment to be submitted by GAC on code structure.] PCF Spiral Stairs I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. 1. Requirement Technical - Measurement of Tread Depth For all other stairs, tread depth is proposed to be measured 300 mm from the centre of the handrail, consistent with the path of travel. For this PCF, the proposal is to measure form the narrow end of the tread, which could be some distance from the handrail and not correspond to the path of travel. Recommendation Revise Clause (1)(d)(i) to read: d) treads that i) are a minimum of 190 mm deep at a point 300 mm from the centre line of the inner handrail narrower edge, If the 190 mm (7.5 ) limit is based on an assumed distance from the end of the tread to the handrail, this should be reduced to reflect the equivalent depth measured from the handrail. 3. Appendix Note - Technical The description of a spiral stair in the proposed Appendix note describes typical construction for these stairs; i.e., the structure of these stairs rather than properties that affect safety in use. Stairs could be constructed with the same circular plan, reduced width and tread depth and greater riser height but not be supported on a central column. There is no reason why such stairs should not be acceptable. Conversely, curved stairs, as described in the Code, could also be constructed with a central supporting column and radiating treads. The inner edge of the tread or path of travel determined by handrail position could such that the minimum tread depth complies with that for curved stairs. The critical difference in the context of the Code is that, compared to curved flights, the minimum width and tread depth are less, and the maximum riser height is greater. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 24 of 36

25 Recommendation Revise Appendix information to read as follows:. Spiral Stairs A spiral stair is typically described as a stair with a circular plan having uniform treads that radiate from and wind around a common central post or supporting column. In the context of the Code, the term spiral stair is used to describe any stair where the plan of the treads form part or all of a circle, the minimum width and tread depth are less than required for curved stairs, and the maximum riser height is greater than permitted for curved stairs. [Comment to be submitted by GAC on code structure and wording.] Ramps PCF Code Ref. Subject Comments done 8 of Ramps Ramp Width accept Ramp Slope accept PCF Ramp Width Deletes clause relating width to occupant load for non-residential buildings Accept OK; simplifies requirement. Occupant load limit would rarely if ever come into play for Part 9 buildings. PCF Ramp Slope Decreases max. slope for mercantile ramps from 1:6 to 1:8 Accept OK. Consistent with Part 3 and not an issue for residential buildings Landings PCF Code Ref. Subject Comments done 8 of Landings Dimensions of Landings, dimensions A Dimensions of Landings, simplification Support with comments modify CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 25 of 36

26 PCF Dimensions of Landings for dwelling units, change min. length from 900 to 860 delete references to clear width of ramps Less stringent - Reduces minimum length of exterior landings serving a single dwelling unit the same as interior landings in dwelling units. More stringent - Reference to width of the ramp makes the minimum length longer by the distance from the inside of the handrail(s) to the edge of the ramp. This is consistent with the long-standing minimum landing length for Part 9 stairs and Part 3 stairs and ramps. PCF , A Landing Dimensions Dimensions of Landings Simplification of requirements I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. 1 Editorial/Technical (2) The application of Sentence (2) refers to a straight run. It is not clear whether this applies to the flights or the stair. The and could be interpreted to mean that the requirement applies only to stairs that have straight flights and have landings that turn less than 90. Stairs with tapered treads are not excluded from the existing requirements and no reason has been provided to exclude them in the proposed requirements. Recommendation Revise Sentence ( 2) to read as follows: 2) Where the landing on a stairway or ramp does not turn or turns less than 90, the length of the landing need not be more than the lesser of a) the required width of the stair or ramp, or b) mm. [Comment to be submitted by GAC on wording.] CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 26 of 36

27 Handrails PCF Code Ref. Subject Comments done 8 of Handrails (2) Handrail Reachability modify A Handrail Reachability intermediate handrails, direct path modify intermediate handrails, direct path; Appendix Note (05) Side of Stair do not support Invalid justification; incorrect costing Continuity modify Handrail Height accept (1) Clearance to Rough Surface accept (2) A (2) Graspability accept PCF (2) - Handrail Reachability Requires a handrail within 750 mm of direct path of travel Does not apply to stairs serving 1 or 2 dwelling units References Part 3 Appendix note A (4) See also I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. Technical/Editorial 1. Support This change is supported because: a. it recognizes that Part 9 stairs and ramps are not required to be 2200 mm or more as a consequence of occupant load b. while the dimension is more stringent it applies only to the path of travel rather than any point on the stair. 1. Exceptions a. Sentence (1), which specifies whether a handrail is required on one or both sides of a stair or ramp, identifies Sentence (2) as an exception. As such, it would permit the installation of handrail(s) not more than 750 mm from the path of travel in lieu of handrails at the side(s) of the stair or ramp. For interior stairs, presumably the handrail along the path of travel might need to be installed in addition to the handrail(s) at the side(s). b. The exception within Sentence (2) would not allow this option for stairs serving one or two dwelling units. No reason is provided for this. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 27 of 36

28 2. Path of Travel While not intended by the SC, if the most direct path is diagonally up a stair, a handrail would have to be installed diagonally if the stair is more than 1500 mm wide. The referenced Appendix note uses the term natural path of travel. 3. Justification The Justification for the change states that it is meant not to require additional handrails but rather to ensure their proper location. It is not clear what additional is compared to. Intermediate handrails will invariably be in addition to handrails at the side(s) of the stair. If the handrails along the path of travel are meant to be an option to handrails and the sides, this is not actually stated by the proposed wording and does not seem reasonable for interior stairs. Recommendation Revise Sentences (1) and (2) to clarify application of the requirements and to refer to a natural path of travel consistent with the wording in the referenced Appendix note. 1) One or more handrails shall be provided along natural paths of travel on stairs and ramps so that a) a handrail is within 750 mm of all portions of the required exit width, b) at least one portion of the stair or ramp between two handrails is the minimum width required for stairways or ramps (See Appendix A (x).) 2) Except as provided in Sentences (3)[4] and (4)[5], handrails shall be installed on the sides of interior stairs and all ramps in accordance with Table PCF Handrails Requires 2 handrails for stairs 1100 mm wide or more a handrail within 750 mm of required exit width a handrail at the most direct path of travel where the stair or ramp is wider than required I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. with respect to the Code provisions are the same as for the corresponding Part 9 requirement PCF (2) - Handrail Reachability. Additional comments are provided on the Appendix note which is referenced from Part Technical - Location of handrails Sentence (2) requires handrails to be installed on each side of the stairs/ramps identified. Sentence (4) requires handrails to be installed along the most direct path of travel. The Appendix Note suggests that location of handrails only along the path of travel applies only to exterior stairs. This needs to be clarified. Sentence (3) requires intermediate handrails in addition to those at the side of the stair or ramp. The Appendix Note states that the handrails are to be installed in relation to exit width and along the path of travel, which may not be at the side of the stair or ramp. this also needs to be clarified. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 28 of 36

29 2. Editorial - Sentence (2) - Wording The handrails described in Sentence (3) are not in addition to Sentence (2); they are in addition to the handrails required in Sentence (2). 3. Technical - Sentence (4) Path of Travel While not intended by the SC, if the most direct path is diagonally up a stair, the Sentence would require a handrail be installed diagonally. The referenced Appendix note uses the term natural path of travel. 3. Technical - Appendix note Path of Travel 3a. Assumes that any stair wider than the required exit width is monumental. This is not the standard use of the term. It should also be recognized that the installation of handrails can define paths of travel. 3b. As noted above, the Appendix note uses wording suggesting that only exterior stairs are monumental stairs. If this is the case, it should be stated explicitly in the body of the Code; if not, the Appendix note should be revised. Recommendation Replace Sentences (1) to (4) and revise the Appendix note to read as follows: 1) One or more handrails shall be provided along natural paths of travel on stairs and ramps so that a) a handrail is within 750 mm of all portions of the required exit width, b) at least one portion of the stair or ramp between two handrails is the minimum width required for stairways or ramps (see Sentences (8) and (4)), and c) all other portions of the stair or ramp between two handrails have a clear width of 510 mm or more. (See Appendix A.) (cont d next page) 2) For interior stairs and ramps a) at least one handrail shall be installed at the side of stairs, and b) handrails shall be installed on both sides of i) stairs that are mm or more in width, ii) curved flights of any width, and ii) ramps. (See Appendix A (1).) A (1) Stair Width and Handrail Location. Handrails are meant to be installed in relation to the required exit width, regardless of the actual width of the stair or ramp. In most cases, especially for interior stairs, the natural path of travel will be along one or both sides of the stair and required exit width can be measured from the side of the stair. There are exterior stairs, however, where single or multiple handrails located within the width of the stair or ramp will serve. It should be noted that handrails can define natural paths of travel. PCF (05) - Handrail on the Narrow End of Treads in Flight with Mixed Treads For dwelling units, requires handrail on inside of curved flights and mixed-run flights except on stairs with winders. I do not support this proposed change for the reason(s)* stated below. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 29 of 36

30 - Technical CHBA supports the exception for stairs with winders which allows the handrail to be installed on the side of the stair where winder treads are deep. The proposed change, however, lacks a valid justification. 1. Justification The Justification refers to uniformity on the walking line. Because curved flights will have uniform tread run at the outside of the curve, the justification does not support requiring the handrail to be installed at the narrow end of the tapered treads. 2. Cost Implications It is current practice to install handrails at the narrow end of tapered treads only where the inside of the curve is open to the space below. Where the outside of the stair is open to the space below, a guard must be installed at the wide end of the tapered treads and a second handrail will be required at the narrow end. No costing is provided for these cases. Recommendation Withdraw PCF Continuity of Handrails requires continuity for the length of ramps and flights except in single dwelling units and houses with secondary suites, requires continuity for the full length of the stair. for single dwelling units and houses with secondary suites allows handrail to start back form end of stair to allow for volute I support this proposed change with the modification(s) to the Code material and associated reason(s)* stated below. - Technical 1. For stairs serving OTHER THAN a single dwelling unit or house with a secondary suite 1.a Application Sentence (2) [2013] states that the handrail must be continuous at the landings where the stair or ramp changes direction. If the intent is to provide continuity, the handrail should also be continuous at landings where the stair or ramp does not change direction. 1.b Justification - Explanation The Rationale states that the current requirement is not consistent with the wording of the Appendix note and consequently the current exception for discontinuity at newel posts at changes in direction is not acceptable. The current requirement is consistent, however, with its Intent which is To limit the probability of UNEXPECTED discontinuity of handrails in stairs and ramps... As newel posts are not unexpected at changes in direction, the intent would have to be revised before this change proceeds. 1c. Costing An additional handrail would be required in the case where there is a wall on inside of the stair as it turns, and there is no wall on the outside so a handrail would be included in the guard. This is not recognized in the Costing. 1d. Objective-Based Analysis The objective-based analysis adds an attribution to [F73-OA1] to Sentence (2) [2015]. OA1 is Barrier-Free Path of Travel and F73 is To facilitate access to and circulation in the building and its facilities by persons with physical or sensory limitations (see Sentence (3) for application limitation). CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 30 of 36

31 Sentence (3) states that: 3) Functional Statements F73 and F74 do not apply to a) detached houses, semi-detached houses, houses with a secondary suite, duplexes, triplexes, townhouses, row houses and boarding houses (see A (1), Secondary Suite, in Appendix A), b) buildings of Group F, Division 1 major occupancy, and c) buildings that are not intended to be occupied on a daily or full-time basis, including automatic telephone exchanges, pumphouses and substations. The application of the attribution must be limited to exclude stairs that serve semi-detached houses, duplexes, triplexes, townhouses, row houses, boarding houses and the buildings described in Clauses (b) and (c). 2. For stairs serving a single dwelling unit or house with a secondary suite 2.a Location of Newel Allowing the handrail to start at a newel post, or volute on the first tread reflects accepted practice. It is not clear what is meant by newel post on the bottom riser. If a volute is acceptable on the first tread, a newel post should also be acceptable. 2.b Justification - Explanation The Rationale states that the current requirement is not consistent with the wording of the Appendix note and consequently the current exception for discontinuity at newel posts at changes in direction is not acceptable. The current requirement is consistent, however, with its Intent which is To limit the probability of UNEXPECTED discontinuity of handrails in stairs and ramps... As newel posts are not unexpected at changes in direction, the intent would have to be revised before this change proceeds. 2c. Costing Construction of a continuous handrail at the narrow end of winder treads is more complicated and therefore more expensive than installing a newel post. The option of installing the handrail at the wide end of the tread would at least result in a longer handrail and may require an additional handrail in the case where the stair is open on the inside of the turn. This is not recognized in the Costing. Recommendation Limit the application of the objectives attribution and revise Sentences (2) and (3) to read as follows: 2) Except for stairs or ramps serving a single dwelling unit or a house with a secondary suite including their common spaces, where a stairway or ramp includes a change of direction, at least one required handrail shall be continuous throughout the length of the stair or ramp, including at landings except where interrupted by a newel post. (See Appendix A.) 3) For stairs or ramps serving a single dwelling unit or a house with a secondary suite including their common spaces, a handrail is permitted to start from a newel post or volute installed on the bottom tread. Notes to Reviewers 1. Continuity of Handrails Serving a Single Dwelling Unit or House with a Secondary Suite Where a stair includes winders and the handrail is installed on the inside of the turn, the proposed change means that a newel post would not be permitted to be installed at the winder. PCF (05) on location of handrails requires installation on the inside of the turn for curved stairs and stairs with mixed treads except for stairs with winders. If the proposed change on continuity is approved unchanged, an option is to install the handrail on the outside of stairs with winders. CMHI, CHBA, GAC Comments on Proposed Changes 19 Nov Page 31 of 36