How tall is too tall?

An investigation by Public Eye has uncovered serious concerns about the government's controversial decision to allow for the construction of five and six storey wood-frame buildings. Premier Gordon Campbell first announced his intention to allow for such buildings in May. This, after the ailing forest industry lobbied the government to promote provincial wood products by making the BC Building Code "wood-centric" and requiring all new private buildings to use such products in their construction.

At the time, Public Eye was the first to tell you senior engineers were worried about how such buildings would respond to earthquakes. And, in the United Kingdom, there have been calls to halt their construction because of fire safety issues. Despite those worries, though, the government enacted an amendment to the code earlier this month that will allow for the construction of five and six storey wood-frame buildings effective April 6, 2009.

But Public Eye has uncovered numerous concerns related to that amendment and the process by which it was introduced. Among them:

* In an exclusive interview, Stephen Gamble, the chair of British Columbia's fire services liaison group stated, "We have some real big concerns" about five and six storey wood-frame buildings. "I wish (the government) would step back a bit and address these first" before allowing their construction.

Specifically, in a letter sent to the government on September 3, 2008, Mr. Gamble warned, "Many fire departments do not have the training or resources to respond" to fires in building of that height.

"The current 3 and 4 storey wooden structures provide for demanding challenges when fighting fires from an external upper floor access perspective as it is," the letter continued, adding most fire departments would be "challenged if they need to reach any higher."

Moreover, "the more floors a building has, the longer it takes to escape and with our aging population more time will be needed in the future for occupants to safely exit a structure during a fire."

The government is requiring five and six storey wood-frame buildings to have sprinklers and fire-resistant exterior cladding, which Mr. Gamble - the president of the Fire Chiefs' Association of BC - acknowledged will give firefighters "at least some chance to deal with the issue."

But the government hasn't acted on other recommendations made by the fire services liaison group, including suggestions those buildings should have non-combustible exit stair shafts, smoke control measures and emergency generators - among other features.

"In B.C., we're already allowed to go to four storeys - which is above the National Building Code. And why not solve some of these problems first before you even consider five and six? But they seem to be pushing ahead with this idea."

* In response to questions as to whether six storey wood-frame construction is safe, the government has claimed "six storey wood frame construction is already practiced in other places, such as Seattle, Washington and Portland, Oregon. Buildings recently constructed there have performed well." But, after speaking with officials in Seattle and Portland, Public Eye has confirmed those cities only allow for the construction of five storey wood-frame buildings.

Asked about that conflicting information, a provincial housing and social development ministry spokesperson maintained such buildings do exist - citing the example of a "six storey all-wood condo development that is visible from Interstate 5."

* When contacted by Public Eye, American local government officials in cities that presently allow five-storey wood-frame buildings questioned British Columbia's decision to allow six storey wood-frame buildings.

"I have talked to a lot of building officials. I've worked for a lot of building departments in four states in the past 20 years. And nobody even wants to talk about six wood" because of its "inherent dangers," said Des Moines, Washington plans examiner Greg Fox.

"Wood burns, obviously. And I know that sounds like a ridiculous statement. But it's a very basic statement. And the premise is you're not going to have enough time to get people out of six on wood," he continued, questioning whether such structures would be vulnerable to earthquakes or even economical to build.

For his part, SeaTac assistant building official Robert Kingsley said, "That's really, really stretching what you can do with wood. I would never recommend it. I don't think it can be as steady or safe a construction as you could get from some either kind of construction."

As for Portland chief engineer Jed Sampson, he told Public Eye, "At some point it doesn't become economically reasonable to stack up that much wood. And it doesn't perform very well for you. If you have shrinkage, if you don't design properly, it will cause you problems with your construction - cracking, settlement, whatever."

And, even at five storeys, Portland plan review section manager Terry Whitehill said he's seen some buildings where "they end up putting so many nails in those wooden panels that the plywood and board behind it just splitter." It's a "big" structural concern, he explained, and one that would be heightened at six storeys. "You can only get so much strength out of those panels."

"I'm not willing to go there. I think you guys are brave. We'll watch you guys," said Seattle principle engineer and building official Jon Sui. "Myself, I'd be a little nervous about it - probably more than a little. I think we are getting toward the edges of what we can do (with wood). Sure things calculate out nicely. But, at some point, there are too many variables in there."

"Yes, you apply safety factors to make up for those uncertainties. But, at some point, you just don't know" how a wood building, as it gets higher, will react during an earthquake.

Moreover, "even though the building is sprinkelered, you've got this big pile of wood. And am I comfortable, if someone's up on the sixth floor, that they're going to have enough time to get out of the building in a fire?"

Although, "if you assume everything the sprinkelers work, then everything is peachy," Mr. Sui added.

Asked about those concerns, the government spokesperson stated, "We are not aware of any instances where mid-rise wood frame buildings in neighbouring jurisdictions have not performed well."

* A government analysis of the issues surrounding multi-storey wood-frame construction heavily relied on the work of Kevin Cheung, who is described as "an expert in the field of multi-storey wood-framed construction and an advocate for increasing this type of construction." But what the analysis doesn't mention is Cheung is the technical services director for the Western Wood Products Association, an industry association representing softwood lumber manufacturers in the United States.

In response, the government spokesperson denied the Campbell administration relied "on any single opinion expressed in the scoping review" in making its decision to allow five and six storey wood-frame buildings. Instead, that decision "relied instead on the extensive advice of our BC/Canadian experts to develop Code changes that meet BC's needs."

* The analysis, while discussing the vulnerability of multi-storey wood-frame buildings to earthquakes, paraphrased Mr. Cheung as stating "wood is timeless building material known for its structural capabilities"¦During recent earthquakes, damage to most wood-frame structures occurred to homes built prior to modern seismic code requirements."

But the analysis provided just one example of such a building being subject to seismic testing. On October 23, 2007, a seven-storey wooden house survived when exposed to a simulation of the earthquake that destroyed Kobe, Japan in 1995.

That building, however, was built using special materials and techniques, including "massive cross-laminated wood panels that range from 5 to 30 centimetres in thickness." So the results of the test aren't, according to the analysis, "directly transferable to the typical North American wood-framed building."

* The government won't allow five and six storey-wood frame structures constructed in the province's earthquake zones to have irregular shear walls. In other words, according to Structural Engineers Association of British Columbia interim president David Davey, those walls - which are meant to protect against seismic and wind forces - must "line up" and the building "must be of a regular shape."

The government has described this as a "conservative approach" to ensuring such buildings are earthquake resistant. But University of British Columbia earthquake engineer facility director Carlos Ventura told Public Eye, "I doubt it."

"We don't have evidence to state these are conservative provisions," continued Dr. Ventura. "Is that sufficient? Maybe it is? Maybe it is not? But we just don't have the hard data to show that works."

* The Structural Engineers Association of British Columbia is developing guidelines for the construction of five and six-storey wood-frame buildings. But it's a mostly volunteer effort.

The reason: according to a December 2008 interim report from the association's six storey wood frame committee, the government initially turned down a request to fund that process. And then, when the Campbell administration did agree to fund those guidelines, it was less then requested.

The government - which gave the engineers a $107,500 grant - has denied declining to provide that funding.

* In an interview with Public Eye, the association's six storey committee chair Jim Mutrie said he's of the opinion those buildings are "probably a good idea" because they might be cheaper to construct. But he said, "I don't like the process - the way they did it" because it wasn't "transparent."

"And the rush (to allow those buildings) makes it difficult to make sure you've dotted all the i's and crossed all the t's," Mr. Mutrie continued. "The provincial government makes a big deal about getting all the stakeholders involved. But I went to a lot of those meetings. And there were a lot of very nice people there. But the depth of the government's technical knowledge is very, very low."

"I'm not sure who even made the decision," to allow for five and six storey wood frame buildings. "As far as I know, there's only one structural engineer who works for the building policy safety branch over there - so that's only one guy, no matter how good he is."

* There is presently no legal requirement for builders to follow the Structural Engineers Association of British Columbia's guidelines when they are released. And that was a disappointment for the association's interim president Mr. Davey, telling Public Eye that he "would have liked them to be made mandatory by referencing them in the Building Code. But the time was not sufficient for that to be done. So they will come out more as recommendations and assistance to designers."

The following is a complete copy of the fire services liaison group's letter, which was sent to Premier Campbell, Forests and Range Minister Pat Bell, Housing and Social Development Minister Rich Coleman and building and safety policy branch manager Trudy Rotgans.


Unit 9 - 715 Barrera Road
Kelowna, BC V1W 3C9
Office 250-862-2388

Fire Service Liaison Group comments re: Amending BC Building Code to allow for 6 storey wood-frame construction

This report has been prepared by the Fire Services Liaison Group, which is comprised of the five associations whose members are directly involved in fire service delivery in the Province of BC - Fire Chiefs' Association of BC; Volunteer Firefighters Association of BC; BC Fire Training Officers; Fire Prevention Officers of BC; Professional Fire Fighters Association of BC and a representative of the Union of BC Municipalities.

At a recent conference of Mayors in May of 2008, Premier Gordon Campbell stated that he wants to support the province's forest industry by allowing the construction of wood-framed condominiums above the current four-storey limit.

Housing Minister Rich Coleman advised the Canadian Home Builder's Association that he wants to see wood-framed buildings up to six storeys high. He also indicated that the necessary building code changes could be accomplished through regulatory change and could be in place by September 2008. Forests Minister Pat Bell supported the Premier's and Minister Coleman's position to change the building code to allow more height which will help revitalize the forestry industry.

Canadian Wood Council VP Etienne Lalonde has stated they have been lobbying for a change in the BC Building Code the past year and in a struggling forest industry, mid rise construction is a new and viable market.
Under the National Building Code wood framed construction has been limited to three storeys, whereas in BC, builders are allowed to go to four storeys. Architects have said that BC is already pushing the limit under the National Building Code by going as high as four storey's in wood specifically because any shrinkage in the thickness of floor joists tends to compound with each additional storey.

Recently in the, interim president David Davey of the Structural Engineers Association of BC, recommended that the government
conduct a "proper study on the effects of increasing the construction height of wood buildings" in BC.

The article goes on to say that "coincidentally, the government quietly announced it was looking for a consultant to review its planned code amendments". The RFP states

"In May, 2008, the Minister announced plans to change the Building Code to allow for wood-framed residential occupancy buildings of up to and including six storeys. By late September, 2008, the Minister will announce details of the proposed changes."

The RFP goes on to state, "the project is divided into three phrases, all of which are included in this RFP." The first phase (to be completed by September 5, 2008) is a research phase, reviewing and identifying technical literature and risks associated with increasing the maximum number of storeys. The second phase (to be completed by October 31, 2008) will focus on developing a technical proposal for changing the Building Code to meet the government's objective. The third phase (to be completed by November 30, 2008) is to prepare a presentation to multi-stakeholder workshops in conjunction with Building Safety and Policy Branch.

All of the above is not making the BC fire service comfortable.
A major concern for the fire service is the response capabilities many fire departments in BC. Most fire departments do not have the training or resources to respond to a high rise fire incident. Additionally, outside of municipal boundaries, there is no mandatory requirement for building inspections, so many small or rural fire departments end up responding to an incident where they have not conducted a pre-fire plan nor have they been consulted with as to the whether they have the capability to mitigate the incident.

UBCM has stated in a staff report that six storey structures require hi-rise firefighting tactics which are much different than those used for low-rise structures (1-4 storeys). The current 3 and 4 storey wooden structures provide for demanding challenges when fighting fires from an external upper floor access perspective as it is. Most fire departments are able to access 3rd floor balconies with ground ladders, but are challenged if they need to reach any higher. The more floors a building has, the longer it takes to escape and with our aging population more time will be needed in the future for occupants to safely exit a structure during a fire.

UBCM's Executive indicated cautious support for the proposed six storey wood framed construction based on the following measures:

- Phased implementation - from four storey, to five storeys on top of one story non-combustible construction;
- Informed evidence based decision making - need to consider construction techniques, fire protection issues, enforcement/regulation issues, and potential liability concerns;
- Education/training and best practice guidelines for building industry, building officials and firefighters;
- Public review of proposed Building Code changes.

The Martin Lofts project in Kelowna is technically a four storey wood frame building but looks like a six storey structure. The under building concrete parking is mostly above ground, forming the first floor. There are four storeys of condominiums with a fifth storey of lofts, accessible only by stairs from the fourth storey units. Without corridor access, lofts are allowed and are not counted as an extra storey under the building code. Conceivably, if the building code starts to allow six storey wood buildings, they could stretch to eight storeys if exposed under building concrete parking and lofts are added. Assistant Fire Chief Bryan Collier, Kelowna stated that it is an issue of more property loss and greater risk for occupants and firefighters in the event of fire, as wood is more combustible than concrete and steel.

A recent paper by Sean Tracey, Canadian Regional Manager, NFPA, (Comments regarding BC Proposal to Increase Lightweight Frame Construction to 6 Storeys) raised the concern that expected building performance criteria must be established. Currently in the codes, the expectations for continuous structures above three storeys, is to require 2 hour fire resistive construction. This is intended to prevent the structure from collapse; to provide adequate time for occupants to safely evacuate; and to allow time for the fire service to conduct an interior search and rescue as well as fire attack. Tracey maintains if a combustible structure is to be permitted it should not go below the requirements of:

- Provide structural sufficiency for occupant evacuation and firefighter operations
- Minimize damage to the structure
- Limit or prevent damage to adjacent structures.

Tracey goes on to indicate that BC has a wide variety of fire department response capabilities and approvals of such structures must consider the fire department response capabilities. The Codes in BC make certain assumptions already on the adequacy of the fire department response, in regards to limiting distances, but does not define these.

Tracey references the TF2000 project in England where a concern about fire entering into wall cavities and thus spreading beyond the room of origin to other floors was raised. How many BC fire departments have infrared cameras to detect hotspots in wall cavities? He goes on to warn that if an Authority Having Jurisdiction permits such construction in their area, they will need to consider what resources their fire departments will need and at what level of service their firefighters are capable of providing, to properly address such fires. The National Building Code does not define what an adequate fire department response capability is, so if the fire department does not perform interior fire attack, are they exposing their communities to increased civil litigation? Should a community such as Sechelt allow high rise construction without their fire department having the training, equipment, or sufficient number of firefighters to respond to a fire in that structure?

Tracey feels there is a serious potential disconnect in BC between the minimums in the building code and community expectations. He feels that a worst case scenario in analyzing the fire scenarios must be used. The building proposal must assume that the building will be constructed in a community with a volunteer response with limited resources and training.
NFPA 13R Sprinkler Systems are intended to cover residential occupancies up to 4 storeys. These new proposed structures would no longer be acceptable under NFPA 13R and therefore would be required to be designed to NFPA 13 throughout the structure. This means that all rooms and spaces would need to be sprinklered including attic spaces, all rooms, all closets, exterior balconies, etc. These would be areas that would have been excluded in residential construction up to and including four storeys. NFPA 13 R systems are considered life safety systems and are not installed for property protection.

Timber framed buildings are not resistant to fire until completed. The risky period is during the construction phase, because the timber frame goes up first and the fire protective cladding, plaster board and fire stops are added later. Two recent examples of timber frame fire destruction in New Westminster and Penticton, where fire not only destroyed the condo buildings under construction, but also impacted neighbouring structures and residences. Penticton Fire Chief Wayne Williams stated that, "the drywall wasn't in yet, so it was a fast moving fire, which also required evacuation of neighbouring structures and residences."

FCABC Building Codes & Life Safety Committee Chair, Deputy Chief Mike Helmer recommends that in additional to the current requirements for a 4 storey wood frame buildings the following items should be considered in a five or six storey wood frame building:

1. Fully sprinklered, including eaves and/or soffit area and attic space
2. Minimum 2 hour rated non-combustible exit stair shafts, minimum of two shafts (one for exiting and one for operations)
3. Non-combustible exterior cladding to prevent vertical fire travel
4. Fully addressable high rise type fire alarm system including firefighter telephones and voice communication systems
5. Smoke control measures to pressurize exit corridors and shafts
6. Emergency generators to supply emergency power for a 2 hour minimum
7. Ceilings rated for minimum 1 hour
8. Hose connections (minimum 1 ¾") in corridors adjacent to exit doors and additional locations if travel distance exceeds 30m.

Captain Doug Bell, President of the Fire Prevention Officers Association of BC has also raised the following concerns that need to be addressed:

1. Building to be sprinklered to NFPA 13 - no equivalencies - all balconies to be sprinklered
2. Stand pipes to be NFPA 14
3. Buildings to be classed as Ordinary Hazard Class 1
4. Hallway pressurization - NFPA has recently reviewed the requirements for hallway makeup air and fusible links - further research should be considered
5. Control room for fire department operations
6. Roof access on all stairways
7. Addressable alarm systems
8. Emergency lighting on standby generators
9. Firefighter elevators with elevators large enough for stretchers to fit, without using chair cots.

Smaller or rural fire departments will be challenged to provide higher building protection. The more protections built-in and/or installed, will allow the fire service to better protect BC residents.

Items that the FSLG feel need further consideration include:

1. Fire Department access to site
2. Are there any occupancy classification limitations/restrictions? (e.g. 6 storey assisted living facilities)
3. Does BCBC 3.2.6. high building requirements apply?
4. What are the increased occupant load impacts on evacuations?
5. Will there be a limited use of vinyl siding and other combustible materials used on the exterior of buildings?
6. Will the passive and active fire protection system be increased?
7. How will emergency power be addressed?
8. Will consideration be given to increase fire resistance of corridors and stairwells?
9. Will the jurisdiction where the building is built have adequate water supplies? Will fire pumps be required?
10. What effect will pre-engineered wood assemblies have on structural integrity in a fire? Will they be fire and load tested? Will the fire service have to change their current practices for this type of structure?
11. What are the impacts to existing neighbouring structures in the case of a fire in a wood frame structure still under construction?
12. Will there be a standard grade for height measurement? What are the impacts to height measurement standards if wood frame storeys are built over concrete storeys?
13. Will alternative solutions or performance design be allowed under "objective-based codes"?
14. Who will be responsible for the costs of firefighter training; materials; and resources?
15. If changes are made to allow higher wood frame buildings, will the insurance industry raise rates to property owners for increased risk?
16. Will there be consideration made in the Code to the capability of the local/responding fire department.
17. What methods/assurances will be made to ensure protection for openings and penetration of fire-rated membranes during the initial construction and later when the building is occupied?
18. How will the Building Code address the issue of 5 to 6 storey buildings becoming 7 & 8 storey buildings (over above ground non-combustible parking garages and the addition of lofts?
19. Will the Building code changes be restricted to Group C, D, and E occupancies or are others groups being considered?

Two key items that the Fire Services Liaison Group would like to have considered before any changes are made to the BC Building Code are the mandatory inspection of buildings in Regional Districts and the ability for local governments to implement sprinkler bylaws in their local jurisdictions.

The FSLG would also like to see research on impacts done and then consultations with fire service providers and their Authorities Having Jurisdictions before any changes are made to the BC Building Codes and BC Fire Codes to accommodate any amendments.

The FSLG would like to leave the reader with one final thought - most fire deaths and injuries occur in residential wood frame construction - we need to ensure that the safe guards are in place before these residences are occupied.

Stephen Gamble, CFO, MIFireE
Chair, Fire Services Liaison Group
President, Fire Chiefs' Association of BC

1 Comment

This is very worrying.

The over-arching concern in establishing and updating building design standards should be advancing human health and safety, not economic benefit or employment. When you see changes ("innovation") instead being driven primarily by an economic interest group, no matter how deserving of our support, it is cause for concern. When you see it being done so hurriedly, and without transparency, you have to wonder why??

If your primary concern was the children (as opposed to who's funding your re-election campaign), would you really be pushing this in this manner?

Sean, is there a consumer protection agency or group that will be alerting home-buyers and/or renters to the potential risks before they buy or move into such buildings? Have consumer groups, renters' associations, seniors' groups, children's advocates, etc. been given equal time and voice in the discussion to date. If not, why?

And why aren't the mainstream media alerting the public about this? Or about the new "leaky condo" issues associated with the new generation of concrete condos?

As Canadians, I think we're far too passive in trusting that our governments and news media can provide consumer protection advocacy, despite repeated evidence that the interests of the consumer are often way down on their priority lists. Where's our Ralph Nader?

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