Residential Fire Sprinklers & On-site Sewage Systems:

A Consultation on Proposed Changes to Ontario’s Building Code    

PART 4

Comment Submission

We look forward to receiving your comments on the proposed technical and administrative changes to the Building Code.  Your active involvement helps ensure that potential Code changes are fully informed, are technically and economically feasible, and are enforceable.

Steps to submission:

• Review this consultation paper, including the specific regulatory proposals;
• Complete Part A of the Comment Form included in this Consultation Paper; and
• Complete Parts B and/or C, depending on which proposed Building Code amendments you would like to comment on.

Your response to this consultation must be received by the Ministry by:

  May 1, 2008

In order to maximize the effectiveness of your comments and to fully understand your views, we ask that your comments relate to the specific proposed changes listed in this consultation.  A comment that refers to other requirements in the Code, for which no change is proposed, will not be considered as part of this consultation.  However, should you wish to comment on other Code requirements, you may do so by completing the “Code Change Request Form to 2006 Building Code” available on the Building Code website at:

www.ontario.ca/buildingcode

If you do not support the proposed changes, or would support the changes with modifications, please include an explanation of the rationale for your concerns to help the Ministry and the Technical Advisory Committees understand your views.
In reviewing the proposed changes, you are encouraged to keep in mind a number of considerations related to the benefits and impacts of the proposed changes.  Some possible considerations are set out below.

For tracking purposes please remember to include the following on each Comment Form:

• Your name;
• Your mailing address; and
• Whether you are responding on behalf of yourself or an organization.

Completed Comment Forms and supporting documents may be submitted to the Ministry by website, e-mail, fax, or mail:

To submit an online comment, follow this link:
www.ontario.ca/buildingcode


E-mail:
sabina.filipescu@ontario.ca
Subject Line: 2008 Building Code Consultation

Mail:
2008 Building Code Consultation
c/o Building and Development Branch
Ministry of Municipal Affairs and Housing
777 Bay Street – 2nd Floor
Toronto, ON
M5G 2E5

Fax:

(416) 585-7531

Subject Line: 2008 Building Code Consultation

Any questions on the consultation may be directed to:

David Brezer, Director and Chief Building Official
(416) 585-6656
Sabina Filipescu, Policy Advisor
(416) 585-6753

Considerations for Comment

Below is a list of things to keep in mind when preparing your submission to the consultation.
 
 Considerations regarding the proposed requirements for residential fire sprinklers

1. Are the proposed amendments consistent with the stated goal of improving public safety?  What life safety benefits would you expect to see as a result of these changes?
2. Are there any additional construction and ongoing maintenance costs or other issues related to residential sprinklers that should be considered?
3. What are the economic benefits resulting from the manufacture, installation and testing of sprinkler systems in multiple-unit residential buildings exceeding three storeys?
4. Is there sufficient capacity within the industry to design, manufacture, supply, install, maintain and test sprinkler systems in multiple-unit residential buildings exceeding three storeys?
5. Does the proposed transition period provide sufficient time for industry/stakeholders to prepare for these Code changes?
6. Are there alternatives that could achieve similar fire safety outcomes?
7. Are the proposed Code changes enforceable as written?  What is the impact on enforcement bodies?
8. Would any additional technical training be required for building officials, builders, designers, trades, etc?

 Considerations regarding the proposed requirements for on-site sewage systems

1. What are the economic benefits resulting from the manufacture, installation and repair of on-site sewage systems?
2. Is there sufficient capacity within the industry to design, manufacture, supply, install, maintain and test on-site sewage systems?
3. Do the proposed technical area bed standards provide an acceptable level of health and safety and environmental protection?
4. Do the proposed transition periods provide sufficient time for industry/stakeholders to prepare for these Code changes?
5. Are there implementation alternatives (e.g., qualification of inspectors, frequency of inspections) that could achieve similar outcomes?
6. Are the proposed Code changes readily enforceable? What are the impacts on local authorities to undertake maintenance inspections?
7. Is the proposed maintenance inspection methodology helpful?  If so, what form should it take (e.g., regulations within the Building Code, an Appendix Note)?
8. Would any additional technical training be required for building officials, builders, designers, installers, septage haulers, etc?

Part 3 - On-Site Sewage Systems                                              Part 5 - Proposed Regulations