Fire Protection Systems in Primary Grain Elevators - 922-1-IPG-026

Effective Date: May 26, 1989

1. Subject

Application of Sections 2.1 and 17.3 of the Canada Occupational Safety and Health Regulations (COSHR) Regulations to the installation of fire protection systems in primary grain elevators.

2. Scope

This directive is applicable to "typical" primary elevators. Such elevators have the following characteristics:

  1. vertical bins;
  2. total capacity usually ranging from 2000 to 6000 metric tonnes;
  3. either traditional wood-crib construction, or of non-combustible construction but of similar size and arrangement as the wood-crib design; and
  4. approximately 3 employees per shift.

Elevators of radically different design or capacity such as the Buffalo sloped-bin elevator are not within the scope of this directive, although they may be defined as primary elevators by the Canada Grain Act .

3. Issue

Human Resources Development Canada (HRDC) - Labour "Safety Officers" require an interpretation of the COSH regulations with respect to applicable requirements for the following fire protection systems in primary elevators:

  1. portable fire extinguishers;
  2. fire alarm systems;
  3. fire hose and standpipe systems;
  4. automatic sprinkler systems; and
  5. water supply systems for fire fighting.

Sections 2.1 and 17.3 of the COSH Regulations prescribe requirements for such systems by means of references to the National Building Code of Canada (NBC) and National Fire Code of Canada (NFC). The NFC reference deals mainly with inspection, testing, and maintenance. The only installation requirements in Part 6 of the NFC are those for portable fire extinguishers.

The NBC states that its requirements must be applied with discretion in buildings of unusual configurations. Primary elevators are such structures. Although a typical elevator is 25 m in height, it does not contain "storeys" in the normal sense, and has a very low occupant load. Therefore, the extent to which certain provisions of the NBC should be applied to primary elevators is subject to interpretation by the authority having jurisdiction.

4. Interpretation

In order to provide for consistent application of the Code, HRDC - Labour Safety Officers shall apply the following interpretations of the NBC - 1985 as amended to January, 1989.

  1. Portable fire extinguishers are required in all primary elevators, as prescribed by Section 17.3 of the COSH Regulations and Part 6 of the NFC.
  2. A fire alarm system is not required in a primary elevator unless the occupant load is in excess of 25. The building height need not be considered a determining factor.
  3. Standpipe and fire hose systems are not required in primary elevators.
  4. Automatic sprinkler systems are not required in primary elevators.
  5. Water supply systems for fire fighting are not required in primary elevators.

The above interpretations do not prohibit the installation of any fire protection systems in primary elevators.

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