| 2024 |
24-0001 |
Power Door Operators for Entry Doors |
16/04/2024 |
File No: 24-0001 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-14
Interpretation Date:
April 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Power door operators for entry doors
Keywords:
Accessibility, power door operators, entrance
Building Code Reference(s):
Div B: 3.8.2.2.(1); 3.8.2.2.(2); 3.8.2.7.(1)(a)
Question:
1.
Clause 3.8.2.7.(1)(a) requires an accessible entrance referred to in Article 3.8.2.2.(1) be equipped with power door operators. Do all required accessible entrances of a building require power door operators?
2.
If the accessible entrance(s) in question 1 meets the accessible door clearances in Sentence 3.8.3.6.(11), is a power door operator still required?
3.
Do exterior doors leading to/from an exterior space that is part of the building such as a restaurant patio or an outdoor play space for a daycare require a power door operator?
Interpretation:
1.
Yes (with exceptions).
Sentence 3.8.2.2.(1) requires all pedestrian entrances to an accessible storey to be accessible except service entrances and entrances to residential suites described in Clause 3.8.2.3.(2)(l). If there are multiple entrances to an accessible storey of a building this requirement applies to all entrances.
Sentence 3.8.2.2.(2) requires an accessible entrance required by Sentence (1) shall be designed in accordance with Subsection 3.8.3. Even though Sentence (2) indicates a singular entrance by using the word “an” but it means to cover each of those accessible entrances required by Sentence (1).
Clause 3.8.2.7.(1)(a) requires doors located in an entrance referred to in Article 3.8.2.2. be equipped with power door operators. Such requirement shall apply to every accessible entrance even though “an entrance” is being referred to.
Similarly, Clause 3.8.2.7.(1)(b) refers to an accessible path of travel. That applies to every accessible path of travel.
Sentence 3.8.2.2.(3) only requires one of the doorways at an accessible entrance that includes more than one doorway, to be designed in accordance with Subsection 3.8.3. Sentence 3.8.2.7.(3) only requires one doorway to be equipped with a power door operator where more than one doorway is provided at an accessible entrance.
Notes to Sentence 3.8.2.7.(3) provides clarification: “In selecting which doorway to equip with a power door operator as required by Sentence 3.8.2.7.(3), consideration should be given to the location of accessible paths of travel, to ease of access, and to minimizing congestion.”
2.
Yes.
Clause 3.8.2.7.(1)(a) requires entrance doors to be equipped with a power door operator regardless if they meet the door clearances in Sentence 3.8.3.6.(11). Sentence 3.8.3.6.(6) provides specific clearances for doors equipped with a power door operator and references Sentence 3.8.2.7.(1) for entrances.
3.
No (with conditions).
Doors to exterior areas of a facility such as a restaurant patio and outdoor play spaces are likely within an accessible path of travel and therefore are required to have door clearances specified in Sentence 3.8.3.6.(11). If the doors are equipped with a power door operator, then the door clearance may conform to Sentence 3.8.3.6.(6).
Note A-3.8.2.2. clarifies that “doors that open onto exterior facilities that are only accessible from inside the building (e.g., hotel pools) are not considered entrances in the context of Article 3.8.2.2.”
Power door operators are not required for self-contained exterior areas where the required door clearances are provided.
However, if such door is also served as a normal entrance to the suite, such as a restaurant in a shopping mall, even though there may be another entrance to the suite from inside the mall, such entrance would be considered as a pedestrian entrance to the suite and a power door operator is required. It is also because the restaurant may still be open while the mall entrance is closed. |
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| 2024 |
24-0003 |
Dead End Corridors |
16/04/2024 |
File No: 24-0003 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-05-03
Interpretation Date:
April 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Dead End Corridors
Keywords:
Dead end, corridor
Building Code Reference(s):
3.3.1.3.(11) &(12), 3.3.1.9.(5)
Question:
Does Sentence 3.3.1.9.(5) supersede Sentence 3.3.1.3.(12) for dead end corridors that are less than 6 m in length?
Interpretation:
Yes.
Sentence 3.3.1.3.(11) requires each suite in a floor area that contains more than 1 suite to have an exterior exit doorway, a doorway to a public corridor, or a doorway to an exterior passageway.
Sentence 3.3.1.3.(12) requires the doorway described in Clause 3.3.1.3.(11)(b) to discharge to a public corridor or exterior passageway where it is possible to travel in opposite directions to reach 2 separate exits.
Sentence 3.3.1.3.(12) states “Except as permitted by this Section”.
Since Sentence 3.3.1.9.(5) is part of Section 3.3, dead end corridors that are less than 6 m in length need not comply with Sentence 3.3.1.3.(12). |
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| 2024 |
24-0004 |
Spatial Separation Between Dwelling Units with Storage Garage |
21/05/2024 |
File No: 24-0004 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-15
Interpretation Date:
May 21, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Spatial Separation between dwelling units with storage
garage
Keywords:
Dwelling unit, occupancy, spatial separation
Building Code Reference(s):
9.10.14, 9.10.15
Question:
A property has two separate buildings. Both buildings fall within the scope of Part 9.
The first building contains a dwelling unit on the second floor with a storage garage on the first floor, providing parking for both dwelling units.
The second building is a dwelling unit but does not have an attached garage.
1. Do spatial separation requirements of Subsection 9.10.15. apply to the first building?
2. Do spatial separation requirements of Subsection 9.10.15. apply to the second building?
Interpretation:
1. No.
If the storage garage only serves the attached dwelling unit, it can be considered subsidiary to the residential use and can be considered as part of the dwelling. The parking located in the first building is intended to serve also the second building; therefore, the use is no longer subsidiary to the residential occupancy in the same building but rather an industrial occupancy. Since Subsection 9.10.15. cannot not apply to industrial occupancy, Subsection 9.10.14. would apply to the first building.
2. Yes.
Since the second building only contains a dwelling unit; therefore, Subsection 9.10.15. would apply. |
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| 2024 |
24-0005 |
Encroachment of Clear Transfer Space for the Change Room Accessible Bench |
18/06/2024 |
File No: 24-0005 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-14
Interpretation Date:
June 18, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Encroachment of clear transfer space for the change room accessible bench
Keywords:
Accessible Shower, Accessible Washroom, Clear Transfer Space
Building Code Reference(s):
3.8.3.6.(11), Figure A-3.8.3.6.(11), 3.8.3.6.(14), 3.8.3.6.(15), 3.8.3.6.(16), Figure A-3.8.3.6.(14) to (16), 3.8.3.17.(2)
Question:
1.
In universal dressing and shower room is it acceptable for the lavatory to impinge on the clear transfer space at one end of the required long bench?
2.
In universal dressing and shower room or washroom is it acceptable to impinge the clear space required for the door opening on the clear transfer spaces required for other uses?
Interpretation:
1.
No.
Clause 3.8.3.17.(2)(e) requires a bench to be 1 830mm long and 760mm wide and 480 – 520mm high in a universal dressing and shower room. This bench must have a clear 900mm wide transfer space adjacent to the long side of the bench as required by Clause 3.8.3.17.(2)(f). This clear space must not be impeded by the lavatory as it is allowed at the entrance of the shower in Clause 3.8.3.17.(1)(b) because the lavatory may restrict the persons who need to make a lateral transfer from the wheelchair onto the bench.
2.
Yes, with limitations.
The spaces required for the door operation are used by the wheelchair person to open or close the door, therefore as per Figure A-3.8.3.6.(11) the wheelchair must be positioned facing the door latch. The spaces required in Articles 3.8.3.6.(11), 3.8.3.6.(14), 3.8.3.6.(15) & 3.8.3.6.(16) may overlap the open transfer spaces required for the bench, shower or access to the bathtub, but in the space for lavatory use, only the portion of this space outside of the rim of the lavatory or counter may be considered acceptable for the overlapping with the door opening area.
Figure A-3.8.3.6.(14) to (16) provides the graphic representation of the areas required for the door operation depending on the used type of door and its swing, and as noted in Article 3.8.3.6.(11) the space must be free of obstacles for the full door height.
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| 2024 |
24-0006 |
Application of Tables in 9.36.2.6, 9.36.2.7 and 9.36.2.8. |
16/07/2024 |
File No: 24-0006 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-29
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Application of Tables in 9.36.2.6, 9.36.2.7 and 9.36.2.8.
Keywords:
Energy Efficiency, Prescriptive Approach, Step Code
Building Code Reference(s):
9.36.1.3.(1), 9.36.1.3.(3), Notes A-9.26.1.3.(3), 9.36.1.3.(6), Tables 9.36.2.6.-C, 9.36.2.7.-D, 9.36.2.8.-C.
Question:
Are the Tables 9.36.2.6.-C, 9.36.2.7.-D, and 9.36.2.8.-C intended to be applied to additions and renovations to existing houses while the step code applies to new houses?
Interpretation:
No.
In general, Sentence 9.36.1.3.(3) requires that all houses except log homes, have to comply with Section 9.36.6., Energy Step Code.
Energy Step Code applies to all new houses; and addition and renovation to existing houses. Similar to applying other parts of the code to existing buildings, discretion and judgement must be exercised when applying the Energy Step Code to addition and alteration to an existing building as described in Division A. It is up to the AHJ to determine what is appropriate and practical on a case-by-case basis.
In order to use the prescriptive approach in Section 9.36. with specific requirements for insulation, windows and other equipment, the Building Act General Regulation would allow local authorities with a bylaw to permit the use of the prescriptive approach. If that is the case, Tables 9.36.2.6.-C, 9.36.2.7.-D and 9.36.2.8.-C can be applied to new construction including additions and renovations for houses as per Sentence 9.36.1.3.(6).
More explanation can be found in Information Bulletins B23-01 and B23-02 published by the Building and Safety Standards Branch and Note A-9.36.1.3.(3) of the Code. |
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| 2024 |
24-0007 |
Cooling System in a Dwelling Unit |
19/03/2024 |
File No: 24-0007 INTERPRETATION Page 1 of 2
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-04-03
Interpretation Date:
March 19, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Cooling System in a Dwelling Unit
Keywords:
Dwelling Unit, Cooling
Building Code Reference(s):
9.33.2.1.(2), 9.33.3.1.(2)
Question:
Can required cooling facilities for a dwelling unit be roughed-in for future installation, instead of being installed as a completed system when the unit is constructed?
Interpretation:
No.
The BCBC 2024 contains new requirements for cooling of dwelling units. Sentence 9.33.2.1.(2) states:
Article 9.33.5.1, referenced above, states the method of determining the design capacity of heating and cooling appliances, except that the design temperatures shall conform to Subsection 9.33.3. In that Subsection, Sentence 9.33.3.1.(2) states:
The term “shall be capable” is not intended to mean that cooling equipment can be roughed-in for future installation. Before the dwelling unit is completed and occupied, the required cooling facilities must be installed and functional.
Note that in some circumstances it may be possible to use solutions in addition to air conditioning as part of a system to achieve the required indoor air temperature. The BCBC Notes include the following:
In areas of B.C. where the outdoor summer design temperature is sufficiently below 26°C, it may be possible to use outdoor air as part of the required cooling. Appendix C of Division B provides climatic data for numerous locations in B.C. |
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| 2024 |
24-0008 |
Unsupported Height of Foundation Wall |
16/07/2024 |
File No: 24-0008 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-05
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Unsupported height of foundation wall
Keywords:
Unsupported, height, foundation wall
Building Code Reference(s):
9.15.4.2.(1), Table 9.15.4.2.-A, 9.15.4.3.
Question:
Does Table 9.15.4.2.-A limit the height of foundation walls to 3m for Part 9 buildings when the foundation walls are constructed of solid concrete, concrete core in flat insulating concrete form, or unreinforced concrete block walls?
Interpretation:
Yes.
The columns entitled “Height of Foundation Wall Laterally Supported 4 to 6 of Table 9.15.4.2.-A indicates the maximum height of a foundation wall when it is laterally supported at the top in accordance with Article 9.15.4.3.
Rows 4 to 15 of columns 4 to 6 of Table 9.15.4.2.-A indicate the maximum height of finished ground level above the basement floor or crawl space ground cover (i.e. the maximum allowable height of soil which is retained by the foundation wall).
The scope of Part 9 limits the height of a foundation wall to 3m when it is supported at the top in accordance with Article 9.15.4.3.
For example, a 300 mm thick solid concrete wall with a maximum height of 3m can retain up to 2.85 m of soil. Refer to Table 9.15.4.2.-A on the following page.
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| 2024 |
24-0009 |
Landing at Top of Mezzanine Stair |
18/06/2024 |
File No: 24-0009 INTERPRETATION Page 1 of 1
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-07-14
Interpretation Date:
June 18, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Landing at Top of Mezzanine Stair
Keywords:
Mezzanine, Stair
Building Code Reference(s):
3.2.1.1, 3.4.2.2
Question:
Where a mezzanine is served by a stair that is not enclosed at the mezzanine level, is the landing at the top of the stair included in the mezzanine area?
Interpretation:
Yes.
Article 3.2.1.1 limits the area of a mezzanine in relation to the open area of the plane it which it is located, or the area of the suite in which it is located, depending the degree of openness of the mezzanine. The mezzanine area and the travel distance to the mezzanine stair also determine the type of egress required for the mezzanine as stated in Article 3.4.2.2.
Where there is no enclosure around a mezzanine stair, the landing at the top of the stair will be at the same level as the mezzanine floor. There is an opening in the mezzanine floor where the stair flight is located so that the stair is not part of the mezzanine area, but the top landing of the stair is part of the mezzanine floor. As such, it is considered to be part of the mezzanine area. |
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| 2024 |
24-0010 |
Climbable Objects and Steps Near Guards |
16/07/2024 |
File No: 24-0010 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-30
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Climbable Objects and Steps near Guards
Keywords:
climbable, objects, steps, guards
Building Code Reference(s):
3.3.1.18.(4), 9.8.8.6.(1)
Question:
Are permanently fixed objects permitted near guards if they form a climbable element that is between 140 mm to 900 mm above the level protected by the guard?
Interpretation:
No (unless the fall is less than 4.2m).
For Part 3 buildings, Sentence 3.3.1.18.(4) prohibits climbable elements on guards between 140 mm and 900 mm above the level protected by the guard when the fall is greater than 4.2m.
For Part 9 buildings, Sentence 9.8.8.6.(1) has a similar requirement.
The intent of 3.1.18.(4) is:
“To limit the probability that preschool aged children will climb a guard and fall, which could lead to harm to persons”
Although these two Sentences only address climbable elements which form part of the guard itself and do not regulate other permanent fixtures that are near the guard, to meet the intent of the code and for safety reason it is recommended to apply this requirement to permanently fixed objects that are near a guard (such as planters, shelving, windowsills, door thresholds).
This recommendation is supported by EGBC’s professional practice guidelines “Designing Guards For Building Projects” PP Guidelines - Designing Guards for Building Projects V.2.0 (egbc.ca)
The Guide stated that :
“Guards should be designed to meet the requirements for non-climbable guards, as defined in the governing building code and this standard. Additionally, steps and curbs must be considered, and must not reduce the required height of the Guard. In general, the height of the Guard must not be less than the radial distance from the highest and nearest point on the step.”
It is recommended that the climbable objects should be setback from the guard, or the guard height be increased so that the diagonal dimension from the top of the object to the top of the guard is a minimum 1070 mm as illustrated below. |
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| 2024 |
24-0012 |
Future Visible Signal Devices in Ensuite Bathrooms |
18/06/2024 |
File No: 24-0012 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-07-15
Interpretation Date:
June 18, 2024
Building Code Edition:
BC Building Code 2024, Book I: General
Subject:
Future Visible Signal Devices in Ensuite Bathrooms
Keywords:
Special Outlet Box, Visual Signal Device; Bathroom; Accessibility; Adaptability
Building Code Reference(s):
3.2.4.19.(1)(h)(i), 3.2.4.19.(4).(e), 3.2.4.19.(7)(c)
Question(s):
1.
Is an ensuite bathroom serving a bedroom in an adaptable dwelling unit required to be roughed in with a special outlet box for a future visible warning system?
2.
Is a small storage room in an adaptable dwelling unit required to be roughed in with the special outlet box for a future visible warning system?
1.
Yes.
Subclause 3.2.4.19.(1)(h)(i) waives the requirement for visible signal devices in washrooms in suites of residential occupancy, but this is superseded by Clause 3.2.4.19.(7)(c) in adaptable dwelling units which requires special outlet boxes and cover plates for future visible signal devices in locations described in Clause 3.2.4.19.(4)(e).
Sentence 3.2.4.19.(4) provides requirements for visible signal devices to be installed in the rooms and spaces required by 3.2.4.20. and Section 3.8., for the purpose of notifying persons who may be experiencing auditory sensory impairment, such as reduced hearing or deafness, which could lead to delay in evacuation due to being incapable of hearing or distinguishing an alarm from being promptly notified of fire conditions.
Clause 3.2.4.19.(4)(e) provides further clarification that it is required to be installed in each sleeping room or bed space, in addition to living area and hallways serving it, and various other rooms closed off from living areas, including bathrooms.
The general intent of this is to provide visual information of an alarm condition, in areas likely to regularly contain occupants throughout the day.
Refer to Interpretation18-0288 for an option to use the electrical outlet boxes of fire alarm audible devices as the “special outlet box”.
2.
No.
Subclause 3.2.4.19.(4)(e)(ii) requires all “rooms” that are closed off from the living area to be equipped with special outlet boxes for futures strobes, but this does not apply to “storage closets”.
Small storage rooms could be considered to be a “closet” if they are not large enough to accommodate prolonged usage.
Designers should confirm with the AHJ if the storage room is small enough to be treated as a closet. |
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| 2024 |
24-0013 |
Accessible Ramp, Landing and Walkway Curb Protection |
18/06/2024 |
File No: 24-0013 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-15
7Interpretation Date:
June 18, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Accessible ramp, landing and walkway curb protection
Keywords:
Ramps, curb, edge protection
Building Code Reference(s):
3.8.3.1., Table 3.8.3.1., 3.8.3.2.(3)(a) and (b), 3.8.3.5.(5)
Question:
1.
Is the edge protection required by 3.8.3.5.(5) for a ramp and landings permitted to be horizontally offset from the edge of the ramp outwards, so there is a gap between the edge of ramp/ landing and the edge protection?
2.
For an elevated walkway that has side mounted guardrails, is there any requirement for edge protection and if so, does the edge protection need to align with the edge of the walkway as Question 1?
Interpretation:
1.
No.
Sentence 3.8.3.5.(5) has a requirement of edge protection. Table 3.8.3.1. also permits the use of CSA B651-2018 section 5.3. and 5.5. as an alternative.
The above sentence (5) mentions either a raised curb or barrier above the ramp or landing surface, neither of these two options permit a horizontal gap between the edge of ramp and the edge protection.
B651-2018 figure 34 has useful diagrams which are useful illustrative guidance of the CSA standard.
2.
Yes.
While Section 3.3. and 3.4 guardrail requirements are trying to address a fall hazard, BCBC Clauses 3.8.3.2.(3)(a) and (b) address requirements for interior and exterior accessible walking surfaces.
3.8.3.2.(3)(a) notes no openings in the walking surface are to permit the passage of a sphere more than 13mm in diameter and Clause 3.8.3.2.(3)(b). The elongated opening is not intended to apply to the gap between the walking surface and the inside face of the guard because the gap is not a part of the walking surface.
Both Clauses 3.8.3.2.(3)(a) and (b) share the same functional statements and objectives of that of Sentence 3.8.3.5.(5) being F30-OS3.1 which intend to limit the probability a person in or adjacent the building will be exposed to an unacceptable risk of injury caused by tripping, slipping, falling, contact, drowning or collision.
The designer must exercise professional judgment to limit the above probability of such an unacceptable risk of injury from occurring. The provisions of 3.8.3.5.(5) do provide guidance of a suitable method of protection, and are further reinforced by Figure 34 of the B651-2018 standard. |
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| 2024 |
24-0015 |
Measurement of Clear Floor Space Width at a Door |
16/07/2024 |
File No: 24-0015 INTERPRETATION Page 1 of 2
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-08-10
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Measurement of Clear Floor Space Width at a Door
Keywords:
Clear floor space, Swinging door
Building Code Reference(s):
3.8.3.6.(14), (15) and (16)
Question:
Where a clear space is required at a door for accessibility per Sentence 3.8.3.6.(14), is the width measured from the door jamb on the hinged side?
Interpretation:
Yes.
Sentence 3.8.3.6.(14) states that the pull side of a swinging door in an accessible path of travel requires a clear and level floor space “of not less than 1700 mm by 1500 mm measured from the hinged side of the door”, with a reference to Note A-3.8.3.6.(14) to (16). Sentences 3.8.3.6.(15) and (16) also contain requirements for clear spaces at doors.
The question relates to whether the width of the required clear area is measured from the hinged side of the door when the door is in the closed position, or the face of the door on the hinged side when the door is in the open position. These two measurements will be different by the thickness of the door and by the distance that the hinges hold the door off the frame.
The excerpt on the next page is one of the sketches in Note A-3.8.3.6.(14) to (16). This interpretation is not intended to reproduce all of those sketches. Please refer to Note A-3.8.3.6.(14) to (16) for a graphic representation of various clear space conditions at doors.
In this sketch and in the other sketches in Note A-3.8.3.6.(14) to (16), the width of the clear floor space is measured from the door jamb, not from the inside face of the open door. The clear space is intended to allow a disabled person to approach the door and to open the door, without their position impeding the opening of the door. The position of the door in the open position is not relevant for this intent because the greatest restriction will be when the door is initially being opened, not when it is fully open. The width of the clear space should be measured from the door jamb as shown in the sketches in Note A-3.8.3.6.(14) to (16).
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| 2024 |
24-0016 |
Accessory Building |
16/07/2024 |
File No: 24-0016 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-08-29
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024, Book I: General
Subject:
Accessory Building
Keywords:
Accessory building, storage shed; ancillary
Building Code Reference(s):
Division A, 1.4.1.1.(1); Division B, 9.12.2.2.
Question(s):
Is storage shed the only form of accessory building under the BCBC?
No.
The term “Accessory Building”, is undefined in the BC Building Code, but is commonly associated with provisions in the Code to exempt certain types of structures, which would otherwise be classified as buildings, from complying with requirements which might prove to be overly onerous relative to the size, purpose or use of that building. The most common usage of the term “accessory building” is that of Division A, Clause 1.1.1.1.(2)(e) which waives the application of the Building Code to small ancillary buildings under 10 m2 that do not create a hazard.
As an undefined term, common practice has been to consider the common usage of the term “ancillary building”, which is further clarified in Sentence 1.4.1.1.(1), which identifies that non-defined terms should be attributed the meanings commonly assigned to the words in the context used, with special attention to its usage in building construction or design. From this guidance, it can generally be established that this is typically viewed as a subordinate structure to a principal building, providing support1 to the usage of the principal building.
1 Ancillary: 1. Ancillary (to something) providing necessary support to the main work or activities of an organization 2. in addition to something else but not as important (Oxford English Dictionary (2024May)
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-08-29
However, in many cases this may not provide sufficient context for interpretation and so it may be useful to consider local developmental regulations with respect to this term, as this often outlines broad developmental goals of a municipality that can help guide code users in determining what should be considered to be “ancillary” with respect to those regulatory objectives.
By inspection, it can readily be seen that there is broad variation between local municipalities with respect to what should be regulated, and so it may likewise be inferred that it is not solely storage sheds which might be considered as “ancillary buildings” – provided that this fits within the regulatory goals of that municipality. Structures such as greenhouses, detached storage garages, or other subordinate structures may potentially be seen as an “ancillary building” within a given municipality along with the consequential allowances within the BC Building Code.
If the interpretation of whether a given building is unclear within a particular jurisdiction, the code user is encouraged to contact the local Authority Having Jurisdiction so they can provide additional guidance. |
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| NEW 2024 |
24-0018 |
Open Mezzanine |
15/10/2024 |
File No: 24-0018 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-10-21
Interpretation Date:
October 15, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Open mezzanine
Keywords:
Mezznine, partition, open
Building Code Reference(s):
Div. A 1.4.1.2.(1); Div. B 3.2.1.1.(3)(b), 3.2.1.1.(7)
Question:
If a mezzanine is not considered as a storey, is it permitted to have a full height glass partition installed on the open edge of the mezzanine?
Interpretation:
No.
Clause 3.2.1.1.(3)(b) states that when a mezzanine is not considered as a storey, there cannot be any walls or partitions higher than 1070mm above the mezzanine floor, except for walls surrounding an enclosure that is less than 10% of the open area of the room in which the mezzanine is located per Sentence 3.2.1.1.(7).
Partition is defined in Division A Sentence 1.4.1.2.(1) as a non-loadbearing 1 storey or part-storey high wall. |
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| 2024 |
24-0020 |
Double Header Joist around Floor Opening |
16/07/2024 |
File No: 24-0020 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-11
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Double Header Joist around Floor Opening
Keywords:
Header joist, floor opening
Building Code Reference(s):
9.23.9.5.(1)
Question:
If the header joist at the side of an opening in a floor sits directly above a wood stud bearing wall, must the header joist be doubled if the opening is wider than 1.2 m?
IInterpretation:
No.
The load on a single header joist that sits directly on a bearing wall is supported by the bearing wall itself, so there is no need to double the header joist when the width of the opening is greater than 1.2 m as described in Sentence 9.23.9.5.(1).
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| 2024 |
24-0021 |
Adaptable Bedrooms |
21/05/2024 |
File No: 24-0021 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-15
Interpretation Date:
May 21, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Adaptable Bedrooms
Keywords:
Adaptable, bedroom, bed size, clearances
Building Code Reference(s):
A-3.8.5.6.(1), 3.8.5.6.(1)(b), 3.8.5.9.
Question:
1.
Is it mandatory to design adaptable bedrooms to accommodate 2 people?
2.
Is it mandatory to provided 850 mm clearance on both sides of the bed and on the foot of the bed.
3.
Can the size of an adaptable suite be based on a single bed that is tight to the wall on one side?
Interpretation:
1.
No.
Refer to the Building and Safety Standards Branch Bulletin B24-09-R.
https://www2.gov.bc.ca/gov/content/industry/construction-industry/building-codes-standards/bc-codes/technical-bulletins
2.
No (with conditions).
Clause 3.8.5.6.(1)(b) requires a pathway clearance in an adaptable bedroom of 850 mm wide. This 850 mm wide pathway applies from the bedroom entry door to the transfer space on one side of the bed as required in Clause 3.8.5.6.(1)(a).
This 850 mm wide pathway also applies from the adaptable bedroom entry door to any operable window, door and dwelling unit controls, switches and outlets that are intended for frequent operation as described in Article 3.8.5.9.
Refer to the Building and Safety Standards Branch Bulletin B24-09-R.
3.
Yes (with conditions).
For demonstration of compliance to Clause 3.8.5.6.(1)(b), a single bed can be tight to the wall on one side provided it does not interfere with access to any operable window, door and dwelling unit controls, switches and outlets that are intended for frequent operation as described in Article 3.8.5.9.
Refer to Building and Safety Standards Branch Bulletin 24-09-R.
Note that adaptable requirements are temporary unrestricted matters with time limitations in the Building Act.
Local governments can adopt bylaws to require additional adaptable design features that are more than the building code requirements. Their bylaws cannot include less restrictive requirements than are required by the building code.
Check with the AHJ to determine if they have additional adaptable requirements within their community. |
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| 2024 |
24-0022 |
Adaptable Bathrooms |
21/05/2024 |
File No: 24-0022 INTERPRETATION Page 1 of 3
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-14
Interpretation Date:
May 21, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Adaptable Bathrooms
Keywords:
Adaptable, bathroom, water closets, clearances
Building Code Reference(s):
3.8.5.7.(1)(c) & (d), A-3.8.5.7.(1)(c) &(d)
Question:
1.
Is it mandatory that the water closet in an adaptable bathroom be adjacent to a wall?
2.
Is it mandatory that the water closet in an adaptable bathroom be provided with 900 mm side clearance at the initial installation of the water closet?
3.
If the initial installation of an adaptable bathroom includes a bathtub, is it mandatory to provide 1700 mm diameter floor area clearances in the bathroom?
Interpretation:
1.
Yes.
Clause 3.8.5.7.(1)(a) to locate the water closet within 460 mm to 480 mm is a mandatory requirement for the initial installation.
It would be difficult for a homeowner to relocate a water closet to make it accessible in the future. The building code mandates that the water closet be in a fixed location in the bathroom with a wall on one side to accommodate future grab bars.
Refer to the Building and Safety Standards Branch Bulletin 24-09R.
https://www2.gov.bc.ca/gov/content/industry/construction-industry/building-codes-standards/bc-codes/technical-bulletins.
2.
Yes.
Clause 3.8.5.7.(1)(b) to provide 900 mm side clearance at the water closet is a mandatory requirement for the initial installation.
Although Clause 3.8.5.7.(1)(c) requires that the “plumbing system” be designed to accommodate the future installation of a lavatory with adequate clear spaces, this only applies to the future clearances in front of the lavatory. It does not permit the initial installation of a lavatory to encroach into the 900 mm side clearance for the water closet.
As stated in the Bulletin 24-09R, “the functional clear space adjacent the water closet described in Article 3.8.5.7. of Division B is required at the time of initial construction. This helps ensure the dwelling unit is visitable by people with diverse abilities by providing reasonable access to a water closet as part of a visit.” It also stated that the 900 mm side clearance for the water closet can be provided within a zero-threshold shower if it is provided in the initial installation.
3.
No.
3.8.5.7.(1)(d) requires that the “plumbing system” be designed to accommodate a future shower per 3.8.3.17.(1) or a future bathtub per 3.8.3.18.(1).
The Note to Part 3 – A-3.8.5.7.(1)(c) & (d) clarifies that the “plumbing system” means the water supply as well as drainage and venting system only. It does not include all plumbing components as defined in Section 1.4 of Division A for “plumbing systems”.
3.8.3.17.(1)(b) requires future showers to have a 900 mm deep x 1500 mm wide floor area clearance in front of the shower.
3.8.3.18.(1)(a) requires future bathtubs to be located in a room with a clear floor space of not less than 1700 mm diameter.
Since 3.8.5.7.(1)(d) provides the option to design for a future shower or bathtub, the initial installation can include a bathtub without the 1700 mm diameter clearance on the basis that the homeowner will convert the existing bathtub to an accessible shower in the future.
Note that adaptable requirements are temporary unrestricted matters with time limitations in the Building Act.
Local governments can adopt bylaws to require additional adaptable design features that are more than the building code requirements. Their bylaws cannot include less restrictive requirements than are required by the building code.
Check with the AHJ to determine if they have additional adaptable requirements within their community. |
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| 2024 |
24-0023 |
Future Conversion of Adaptable Suites |
21/05/2024 |
File No: 24-0023 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-14
Interpretation Date:
May 21, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Future Conversion of Adaptable Suites
Keywords:
Adaptable, future, conversion
Building Code Reference(s):
3.8.3.1.(1), 3.8.5.7.(1)(c) & (d), A-3.8.5.7.(1)(c) &(d)
Question:
1.
When a homeowner decides to convert an adaptable suite to include some accessible features to suit their needs, does the future installation have to comply with the requirements for public washrooms as described in Subsection 3.8.3.? This would include future grab bars, future push buttons for power door operators, toilet paper dispensers, etc.?
2.
If the answer to (1) is NO, are there any design requirements of Subsection 3.8.3. for future installations?
Interpretation:
1.
No (with some exceptions).
Sentence 3.8.3.1.(1) states that Subsection 3.8.3. apply to buildings or parts thereof and facilities that are required to be accessible.
Clause 3.8.2.3.(2)(l) states that access is not required within a suite of residential occupancy provided that is “has not been designated by this Code or an authority having jurisdiction to be accessible or designed and constructed as an adaptable dwelling unit”.
This means that an adaptable dwelling unit is not required to comply with the accessible requirements of Section 3.8. except those provided in Subsection 3.8.5.
It is not the intent of the code that interior spaces within an adaptable dwelling unit for future accessible conversions be designed in a similar manner to public spaces as required by Subsection 3.8.3.
The homeowner can design accessible features within their dwelling unit to suit their individual needs.
For example, they may utilize a remote-control device to activate power door operators rather than using upper and lower push paddles that are setback from the latch side of the door by 600 mm as required by 3.8.3.6.(6).
The exception to this is backing for future grab bars:
3.8.3.7.(1)(e) mandates that backing for grab bars for water closets, showers and bathtubs be installed in accordance with 3.8.3.12.(f) & (g) for water closets, 3.8.3.17.(1)(f) for showers and 3.8.3.18.(1)(f) for bathtubs.
2.
No.
As stated in the answer to question 1, Clause 3.8.2.3.(2)(l) states that access is not required within a suite of residential occupancy, and adaptable dwelling units need only to comply with Subsection 3.8.5.
Note that adaptable requirements are temporary unrestricted matters with time limitations in the Building Act.
Local governments can adopt bylaws to require additional adaptable design features that are more than the building code requirements. Their bylaws cannot include less restrictive requirements than are required by the building code.
Check with the AHJ to determine if they have additional adaptable requirements within their community. |
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| 2024 |
24-0024 |
Plumbing Systems for Showers in Adaptable Suites |
16/07/2024 |
File No: 24-0024 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-11
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Plumbing Systems for Showers in Adaptable Suites
Keywords:
Adaptable suites, plumbing systems, showers
Building Code Reference(s):
3.8.5.7.(1)(d)(i), A-3.8.5.7.(1)(c) &(d)
Question:
1.
For the purposes of Article 3.8.5.7., does the term “plumbing systems” include all aspects of the plumbing system as defined in Article 1.4.1.2. of Division A?
2.
Must the initial installation of a shower in an adaptable dwelling unit include pressure equalizing mixing valve mounted on the opposite wall as per Clause 3.8.3.17.(1)(h) and handheld shower as per Clause 3.8.3.17.(1)(i)?
Interpretation:
1.
No.
Sentence 3.8.5.7.(1)(d) requires that the “plumbing system” be designed to accommodate a future shower as per Sentence 3.8.3.17.(1) or a future bathtub per Sentence 3.8.3.18.(1).
“Plumbing system” is defined in Article 1.4.1.2. of Division A as a drainage system, venting system and a water system or parts thereof.
“Parts thereof” includes all other aspects of the plumbing system such as faucets, mixing valves, plumbing fixtures, etc.
The Notes to Part 3 – A-3.8.5.7.(1)(c) & (d) clarifies that, for the purposes of Article 3.8.5.7., “plumbing system” means the water supply as well as drainage and venting system only. It does not include all plumbing components as defined in Article 1.4.1.2. of Division A for “plumbing systems”.
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-11
2.
No.
As stated in the answer to question 1, “plumbing systems” with respect to Article 3.8.5.7. only includes water supply piping, drainage and venting system, and does not include mixing valves or handheld showers.
A rough in for the water supply piping for the future mixing valve and future hand-held shower must be provided as part of the initial installation in the location described in Clauses 3.8.3.17.(1)(h) and 1(i), but the installation of the mixing valve and hand-held shower can be provided when the adaptable suite is converted to include some accessible features as required by the homeowner.
The initial installation of a bathtub or shower must be installed in accordance with the Plumbing Code with a mixing valve and temperature control, but the location of this initial installation need not be in accordance with Clauses 3.8.3.17.(1)(h) or 3.8.3.18.(1)(e).
Note that adaptable requirements are temporary unrestricted matters with time limitations in the Building Act.
Local governments can adopt bylaws to require additional adaptable design features that are more than the building code requirements. Their bylaws cannot include less restrictive requirements than are required by the building code.
Check with the AHJ to determine if they have additional adaptable requirements within their community. |
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| 2024 |
24-0025 |
Lever Handles for Faucets in Adaptable Suites |
21/05/2024 |
File No: 24-0025 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-14
Interpretation Date:
May 21, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Lever Handles for Faucets in Adaptable Suites
Keywords:
Adaptable, faucets, lever handle
Building Code Reference(s):
3.8.5.7.(1)(c) & (d), A-3.8.5.7.(1)(c) &(d)
Question:
Are lever handles required on lavatory, bathtub, shower and kitchen sink faucets in adaptable suites?
Interpretation:
No.
Refer to Interpretation 24-0023.
Adaptable dwelling units are not required to comply with the accessible requirements of Section 3.8. except those provided in Subsection 3.8.5.
Subsection 3.8.5. does not include any requirement for lever handles on faucets.
Note that adaptable requirements are temporary unrestricted matters with time limitations tin the Building Act.
Local governments can adopt bylaws to require additional adaptable design features that are more than the building code requirements. Their bylaws cannot include less restrictive requirements than are required by the building code.
Check with the AHJ to determine if they have additional adaptable requirements within their community.
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| 2024 |
24-0028 |
Egress from Multi-Level Dwelling Units |
16/07/2024 |
File No: 24-0028 INTERPRETATION Page 1 of 1
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-08-11
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Egress from Multi-Level Dwelling Units
Keywords:
Exit, Egress, Dwelling Unit
Building Code Reference(s):
9.9.9.1
Question:
If a multi-storey dwelling unit in a Part 9 building complies with Sentence 9.9.9.1.(2) or (3), and it does not have a door to a public corridor, enclosed exit stair or exterior passageway, does it require an exterior exit door not more than 1.5 m above adjacent ground level?
Interpretation:
Yes.
Sentence 9.9.9.1.(1) states:
Sentence 9.9.9.1.(2) allows the travel limit to exceed 1 storey in a non-stacked dwelling unit for a floor level with an openable exterior window meeting the criteria stated in that Sentence. Sentence 9.9.9.1.(3) allows the travel limit to exceed 1 storey where the floor level has direct access to a balcony.
Sentences 9.9.9.1.(2) and (3) allow different approaches for the vertical travel limit to the exterior exit or egress door to exceed 1 storey. They do not supersede or alter the other requirements of Sentence 9.9.9.1.(1). The exit door is still required to be a maximum height of 1.5 m above adjacent ground level. |
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| 2024 |
24-0030 |
Illumination of Exterior Path of Travel |
16/07/2024 |
File No: 24-0030 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-08-29
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024, Book I: General
Subject:
Illumination of Exterior Path of Travel
Keywords:
Lighting; Accessibility; Accessible Path of Travel
Building Code Reference(s):
3.2.7.1.(1); 3.8.2.2.(1); 3.8.2.5.(1); 3.8.3.2.(3) & (7)
Question(s):
Do the minimum lighting levels required by Sentence 3.2.7.1.(1) apply to exterior accessible paths of travel?
Yes.
The minimum lighting requirements under normal power for a building is regulated by Sentence 3.2.7.1.(1) and specifically identifies several locations requiring illumination. Accessible paths of travel required by Section 3.8. are specifically identified by this requirement, which is a notable change from previous code edition.
Article 3.8.2.5., Sentences 3.8.2.2.(1), 3.8.3.2.(3), 3.8.3.3.(1) and 3.8.3.4.(1) include both interior and exterior accessible paths of travel.
Sentence 3.8.3.2.(7) requires illumination of interior and exterior paths of travel in accordance with Sentences 3.2.7.1.(1) and (2).
Explanatory material provided in Note A-3.8.2.5.(1) and (2) state that it is the intent of Sentences 3.8.2.5.(1) and (2) to provide means of access so that “persons of all abilities can move to and from a building with minimal effort”. Providing illumination supports this intent, by providing additional illumination to assist those with reduced visual acuity, who might otherwise have difficulty navigating during periods of reduced visibility.
The requirements of Article 3.2.7.1. identify various minimum and average lighting levels for the purposes of an accessible path. The Code does not address the potential interactions between the lighting needs for accessibility and the potential impact on adjacent properties and exterior spaces, including adjacent vehicular roadways or the potential for nuisance lighting. To minimize potential adverse impacts on the surrounding spaces, designers may consider various strategies to reduce glare, uplighting, and backlighting. |
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| 2024 |
24-0032 |
Tactile Walking Surface Indicators |
16/07/2024 |
File No: 24-0032 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-29
Interpretation Date:
July 16, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Tactile Walking Surface Indicators
Keywords:
Tactile, warning, indicators
Building Code Reference(s):
3.3.1.19.(1)(a), CSA B651 - 4.3.5.3.2., 5.4.3.1.
Question:
1.
Are tactile walking surface indicators required at intermediate landings in an open stair?
2.
Are tactile walking surface indicators required to be setback 1 stair tread from the top stair riser?
IInterpretation:
1.
Yes.
Clause 3.3.1.19.(1)(a) requires that tactile walking surface indicators be located at the top of flights of stairs that are unenclosed.
Flight is defined in Division A - Article 1.4.1.2. as follows:
Flight means a series of steps between landings.
When a stair contains more than one flight, the top of each flight requires a tactile walking surface indicator.
The term “top of flights of stairs” means the top of each flight of stairs.
When a visually challenged person is descending several flights of stairs, they are not aware when they have reached the bottom of the stairs. Therefore, it is important to identify the top of each flight of stairs to warn the user of the start on a subsequent flight of stairs.
2.
Yes.
BCBC Sentence 3.3.1.19.(1) requires that tactile walking surface indicators be designed to Clauses 4.3.5.3.1.(Configuration), 4.3.5.3.3. (Installation) and 4.3.5.3.4. (Luminance) of CSA B651.
Note that Clause 4.3.5.3.2. (Location) of CSA B651, is not referenced in BCBC Sentence 3.3.1.19.(1) because the location of the indicators is described in BCBC Article 3.3.1.19.
CSA B651 Sub-clause 4.3.5.3.3.(b) (Installation) states that one side of the indicator be against the edge of the hazard, unless otherwise indicated in this Standard.
CSA B651 Article 5.4.3. specifically deals with Tactile attention indicator surfaces at stairs which is referenced by Sub-clause 4.3.5.3.3.(b).
CSA B651 Sub-clause 5.4.3.1.(d) requires the indicator to commence one tread depth back from the edge of the stair as shown in Figure 27 below.
Although there is no direct reference in BCBC to CSA B651 Sub-clause 5.4.3.1.(d), the indirect reference through CSA B651 Sub-clause 4.3.5.3.3.(b) does make it applicable in BC. |
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| 2024 |
24-0033 |
Spatial Interpolation with LD < 1.2m |
13/08/2024 |
File No: 24-0033 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-08-29
Interpretation Date:
August 13, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Spatial Interpolation with LD < 1.2m
Keywords:
Spatial, limting distance, exposing building face
Building Code Reference(s):
Table 3.2.3.1.-D, Table 3.2.3.7., 3.2.3.5.(1)
Question:
For a Part 3 building where the limiting distance of an exposing building face (EBF) is more than 0m but less than 1.2m, is it acceptable to interpolate the allowable area of unprotected openings (UPO) with respect to the construction requirements of the exposing building face (i.e. combustible or noncombustible construction)?
Interpretation:
No.
For sprinklered buildings with major occupancies of Groups A, B, C, D and F3, Table 3.2.3.1.-D permits the area of unprotected openings to be 14% to 16% when the limiting distance is 1.2m and 0% when the limiting distance is 0m.
For major occupancies of Groups A, B, C, D and F3, Table 3.2.3.7. permits the exposing building face to be combustible construction when the allowable UPO is more than 10%.
Sentence 3.2.3.5.(1) clearly states that when the limiting distance is less than 1.2m, no unprotected openings are permitted. This sentence is silent with respect to the type of construction of the exposing building face when the limiting distance is less than 1.2m.
It should be noted that for Part 9 building, the wording of Table 9.10.14.4.-A is different than Table 3.2.3.1.-D.
The Part 9 Table clearly states that where the limiting distance is “less than 1.2m”, the allowable area of unprotected openings is 0%, which would require the construction of the exposing building face to be noncombustible construction.
Although the wording of Table 3.2.3.1.-D does not specifically say “less than 1.2m”, the same intent is provided by Sentence 3.2.3.5.(1) which mandates 0% area of unprotected openings when the limiting distance is less than 1.2m.
Hence the type of construction of the exposing building face must be noncombustible when the limiting distance is less than 1.2m. |
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| 2024 |
24-0034 |
Balcony Access in Adaptable Suites |
21/05/2024 |
File No: 24-0034 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-07-14
Interpretation Date:
May 21, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Balcony Access in Adaptable Suites
Keywords:
Balcony, access, adaptable
Building Code Reference(s):
3.8.5., 3.3.1.7.(1)(c)
Question:
Is access for persons with disabilities required to balconies in adaptable suites?
Interpretation:
No (with some exceptions).
Subsection 3.8.5. does not require access for persons with disabilities to balconies serving an adaptable suite.
Note that if the adaptable suite is unsprinklered, Clause 3.3.1.7.(1)(c) does require an accessible path of travel to balconies in accordance with Sentence 3.3.1.7.(4).
This means that for adaptable suites within buildings that are sprinklered throughout, there are no restrictions in Subsection 3.8.5. on balcony size, balcony door threshold height or balcony door width. There may be restrictions in other parts of the code that do apply.
Note that adaptable requirements are temporary unrestricted matters with time limitations in the Building Act.
Local governments can adopt bylaws to require additional adaptable design features that are more than the building code requirements. Their bylaws cannot include less restrictive requirements than are required by the building code.
Check with the AHJ to determine if they have additional adaptable requirements within their community. |
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| 2024 |
24-0035 |
Exhaust Air Inlet as a Return Air Inlet in Dwelling Unit |
13/08/2024 |
File No: 24-0035 INTERPRETATION Page 1 of 1
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-09-24
Interpretation Date:
August 13, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Exhaust Air Inlet as a Return Air Inlet in Dwelling Unit
Keywords:
HRV, Exhaust Air, Return Air
Building Code Reference(s):
9.33.6.12.(2), 9.32.3.4.(4)
Question:
In a dwelling unit with a heat recovery ventilator (HRV), can an inlet to an exhaust air duct satisfy the requirement for a return air inlet on each floor?
Interpretation:
Yes.
Sentence 9.33.6.12.(2) states:
“Except for unfinished areas and floor levels which are less than 900 mm above or below an adjacent floor level which is provided with a return-air inlet, at least one return-air inlet shall be provided in each floor level in a dwelling unit.”
The BCBC does not directly address whether an inlet to an exhaust air duct, instead of an inlet to a return air duct, can satisfy this requirement. However, the intent statement for Sentence 9.33.6.12.(2) refers to considerations including maintaining adequate air temperatures and avoiding inadequate ventilation. This requires air movement through the floor level, which can be accomplished with either an exhaust air duct or a return air duct.
Sentence 9.32.3.4.(4) requires that, where an HRV is the principal ventilation system, the HRV exhaust duct shall draw exhaust air from one or more indoor inlets of which at least one is located at least 2 m above the floor of the uppermost floor level. This is also intended to promote air movement through the unit. Therefore, it is interpreted that an inlet to an exhaust air duct can satisfy the requirement of Sentence 9.33.6.12.(2) for an inlet to a return air duct.
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| NEW 2024 |
24-0037 |
Fire Dampers in Houses with Secondary Suites |
24/09/2024 |
File No: 24-0037 INTERPRETATION Page 1 of 1
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-09-27
Interpretation Date:
September 24, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Fire Dampers in Houses with Secondary Suites
Keywords:
Fire damper,secondary suite, ducts
Building Code Reference(s):
9.10.9.9.(6); 9.32.3.2.(5)
Question:
Can fire dampers be omitted in ducts penetrating the fire separations in a house with a secondary suite?
Interpretation:
Yes (with conditions).
Sentence 9.32.3.2.(5) requires that ducts penetrating fire separations shall be equipped with fire dampers in conformance with Article 3.1.8.10. except as provided in Sentence 9.10.9.6.(14),
9.10.9.6.(14) was in the 2018 BCBC but was relocated to 9.10.9.9.(6) in the 2024 BCBC. Sentence 9.32.3.2.(5) should have referenced 9.10.9.9.(6) as the exception rather than Sentence 9.10.9.6.(14).
As per Sentence 9.10.9.9.(6), “in a house with a secondary suite including their common spaces, ducts penetrating fire separations need not be equipped with fire dampers in conformance with Article 3.1.8.10. provided they are noncombustible with all openings in the duct system serving only one fire compartment”.
Building and Safety Standards Branch has been informed of this error and the revision is forthcoming. |
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| 2024 |
24-0038 |
Separation of Suites in a House having a Suite without a Kitchen |
13/08/2024 |
File No: 24-0038 INTERPRETATION Page 1 of 2
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-09-23
Interpretation Date:
August 13, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Separation of Suites in a House having a Suite without a Kitchen
Keywords:
Secondary Suite, house, suite separation
Building Code Reference(s):
9.10.9.16.(1), (2) and (4)
Question:
The basement of a house is finished with sleeping accommodation but no kitchen and is used by the building owner for occasional sleeping accommodation. The floor above is finished and occupied by another tenant. There is no interior connection between the two levels. Is a fire separation required between the two floor levels?
Interpretation:
Yes.
Sentence 9.10.9.16.(1) requires a 45 min fire separation between suites in residential occupancies, with exceptions.
One of the exceptions is Sentence 9.10.9.16.(2) for sleeping rooms in boarding or lodging houses where the sleeping rooms form part of the proprietor’s residence and do not contain kitchens. Since the owner does not live in the floor above it cannot be considered as the proprietor’s residence. Also, a typical boarding or lodging house has common areas and a common kitchen. In this case, the two floor areas are entirely separate with no common areas, so they do not constitute a boarding or lodging house where the sleeping rooms in the basement do not form part of the proprietor’s residence.
The other exception is Sentence 9.10.9.16.(4), separation of secondary suite. Secondary suite is defined as “self-contained dwelling unit…” and dwelling unit is defined as “a suite operated as a housekeeping unit … and usually containing cooking, eating, living, sleeping, and sanitary facilities”. Although the basement is not finished as a typical secondary suite with a kitchen, it should be considered as such because it is used for sleeping accommodation by the owner that is different from the tenant on the upper floor.
Therefore, the floor assembly between the two units is subject to the fire separation requirements of Sentence 9.10.9.16.(4) for a house with a secondary suite. The required fire-resistance rating is 0 h, 15 min, 30 min, or 45 min depending on the applicable conditions, as stated in that Sentence.
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| NEW 2024 |
24-0042 |
Camera as a Door Viewer |
24/09/2024 |
File No: 24-0042 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-09-27
Interpretation Date:
September 24, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Camera as a door viewer
Keywords:
Door viewer, camera
Building Code Reference(s):
9.7.2.1.(1), 9.7.2.1.(2)
Question:
Does an electronic camera at an entry to a dwelling unit meet the requirements for a door viewer?
Interpretation:
No.
Sentence 9.7.2.1.(2) requires the main entrance doors to dwelling units shall be provided with a door viewer or transparent glazing in the door or a sidelight.
One of the intents from the 2015 National Building Code of Canada (NBCC) is to limit the probability of person unknowingly opening a door to an intruder, which could lead to unwanted entry, which could lead to harm to persons. In other words, occupants must be able to see who is at the door prior to opening it.
Products are available that can allow persons to view the exterior of their dwelling on their smart devices via a small camera near the door. While these products are convenient, the reliability and functionality of such products should be considered when satisfying Code requirements.
The use of such technology can be problematic as there could be conditions where the devices are not effective due to connectivity issues, power supply, or persons that are not technologically savvy. Although the wording “door viewer” is not specific to a peephole, this wording has been in the code for upwards of 20 years which predates the modern devices that are available today.
The assumption of the Code authors is to provide a means for the vast majority of people to view the exterior with minimal maintenance and without the need for special knowledge or devices. |
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| 2024 |
24-0043 |
Venting Requirements for Floor Drains NPS 3 and Larger |
13/08/2024 |
File No: 24-0043 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-09-23
Interpretation Date:
August 13, 2024
Building Code Edition:
BC Building Code 2024, Book II: Plumbing Systems (BCPC) and BC Building Code Book I: General
Subject:
Venting Requirements for Floor Drains NPS 3 and Larger
Keywords:
Floor Drain, Venting
Building Code Reference(s):
2.5.1.1.(3), Table 2.4.9.3. of the BCPC
Question:
Does the trap for a non-emergency floor drain, which is NPS 3 or larger, require a vent?
Interpretation:
No.
Sentence 2.5.1.1.(3) waives the requirement for a vent on a trap for a floor drain where;
a)
the nominal pipe size of the trap is not less than NPS 3,
b)
the length of the fixture drain is not less than 450 mm, and
c)
the fall of the fixture drain does not exceed its nominal pipe size.
Whether the floor drain is an emergency or non-emergency floor drain has no effect on whether the trap requires a vent or not, but rather, is based solely on the above criteria. If the floor drain is installed for a specific purpose, (i.e. non-emergency), then the hydraulic load from Table 2.4.9.3. would apply to the drainage system based on the trap size.
Attached to this Interpretation is a comprehensive summary of drainage and venting requirements for floor drains taken from the 1992 BC Plumbing Code. Since the wording regarding floor drain requirements has not substantially changed since that time, it is reasonable to use the included methods for drainage and venting hydraulic load calculations and other considerations. |
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| 2024 |
24-0045 |
Industrial Mineral Stockpile Cover |
13/08/2024 |
File No: 24-0045 INTERPRETATION Page 1 of 3
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-09-02
Interpretation Date:
August 13, 2024
Building Code Edition:
BC Building Code 2024, Book I: General
Subject:
Industrial Mineral Stockpile Cover
Keywords:
Low Hazard Industrial, Storage Building, Low Fire Load
Building Code Reference(s):
Division A, 1.4.1.2.(1); Division B, 3.2.2.91.
Question(s):
1.
Can an industrial mineral stockpile cover (triodetic dome) with no human occupancy be used for permanent storage of mineral stockpile materials without having to meet any requirements of the BC Building Code?
2.
If such a mineral storage structure is considered a building, would Article 3.2.2.91. “Group F, Division 3, One Storey, Low Fire Load Occupancy” be an appropriate major occupancy classification?
Interpretation:
1.
No (with exceptions).
In various industries it is common to utilize large cover structures for the storage of raw materials, products, or equipment. Such structures typically do not have a continuous human occupancy, are unconditioned, and may be open to the exterior. Common construction includes truss or framed structures covered by lightweight materials, in configurations such as domes, industrial sheds, or tents.
Such structures fall within the definition of building in the BC Building Code (BCBC) and are therefore subject to the applicable requirements of this regulation. Broadly speaking, a building is any kind of structure supporting or sheltering a use, including not only persons, but also animals or property.
This interpretation is consistent with past BCIC interpretations and BC Building Code Appeals Board rulings for non-traditional structures such as the following:
•
BCIC Interpretation 18-0265 Use of Containers as a Building for Storage
•
BCAB Ruling #1335 - Definition of Building, Water Storage Reservoir, Article 1.1.3.2
•
BCAB Ruling #1418 - Definition of "Building", Covered Storage Bins, Article 1.1.3.2.
•
BCAB Ruling #1455 - Definition of Building, Article 1.1.3.2.
•
BCAB Ruling #1640 - Article 1.1.3.2. Definition of Building (“umbrella” structure) Sentence 4.1.1.3.(1), Structural Design Requirements (application to fabric “umbrella” structure)
Regardless of its classification as a building, it may be that not all the requirements of the building code ought to apply. The NRC’s Users Guide to Part 3 (“what is a building?”, Page 5) acknowledged this despite many structures being considered buildings, it may be impractical for all the requirements of the building code to apply. The Users Guide identified that the designer and the authority must agree on the most appropriate fit and that “Good judgment must be exercised in determining whether to apply a requirement under extenuating circumstances, provided always that the safety of the occupants is not threatened.”
If the interpretation of whether a given building is unclear within a particular jurisdiction, the code user is encouraged to contact the local Authority Having Jurisdiction so they can provide additional guidance.
2.
Yes.
In many cases, to be suitable for storage in an exterior unconditioned space, the stored resource or product is non-reactive and non-hazardous. If the material is also effectively non-combustible and it can be demonstrated that the total combustible fuel load is not more than 50 kg/m2 or 1 200 MJ/m2 of floor area, then a Group F, Division 3 major occupancy may be appropriate.
Article 3.2.2.91. identifies the further constraint that the use should be a Low Fire Load Occupancy, meaning that the total fuel load should be consistent with the fuel load that might be expected of a power generating plant or facility used for the manufacture or storage of noncombustible materials. Conceptually means little to no combustible fuel loads and may require some interpretation by the designer and AHJ in circumstances where this is not inherently clear. |
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| NEW 2024 |
24-0046 |
Opening Restrictor on Bedroom Window |
15/10/2024 |
File No: 24-0046 INTERPRETATION Page 1 of 2
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-10-29
Interpretation Date:
October 15, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Opening Restrictor on Bedroom Window
Keywords:
Window, Restrictor, Egress, Bedroom
Building Code Reference(s):
9.8.8.1.(4) and (5), 9.9.10.1.(1) and (2)
Question:
In an unsprinklered Part 9 building, can an openable window required for emergency egress from a bedroom have a restrictor to limit the extent of its opening?
No.
The openable portion of the bedroom window must be at a height where it does not require a restrictor or guard.
Sentences 9.8.8.1.(4) and (5) require openable windows in buildings of residential occupancy to be protected by a guard or by a mechanism that will limit the clear openable part of the window to not more than 100 mm measured either vertically or horizontally, except where the bottom edge of the openable portion of the window is more than 900 mm above the floor or less than 1800 mm above the floor or ground on the other side of the window.
Article 9.9.10.1 regulates “Egress Windows or Doors for Bedrooms”. Except where a suite is sprinklered, Sentence 9.9.10.1.(1) requires a bedroom or combination bedroom to have at least one outside window or exterior door openable from the inside without the use of keys, tools or special knowledge and without the removal of sashes or hardware. Sentence 9.9.10.1.(2) requires the openable window to have an unobstructed opening area of at least 0.35 m2 with no dimension less than 380 mm.
A window required by Article 9.9.10.1 for egress from a bedroom cannot have a restrictor as required by Article 9.8.8.1 because the openable area limitation is too small for egress purposes. If the bottom of the openable portion of the window is more than 1800 mm above the floor or ground on the other side of the window, the bottom of the openable portion of the window must be at least 900 mm above the floor, so that a restrictor or guard is not required.
A bedroom window could have a restrictor or guard if the suite is sprinklered, or if the bedroom has a door or another window that complies with Article 9.9.10.1.
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| NEW 2024 |
24-0048 |
Sprinklers on top Floor Residential Balconies |
24/09/2024 |
File No: 24-0048 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-10-02
Interpretation Date:
September 24, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Sprinklers on top floor residential balconies
Keywords:
Sprinklers, balconies, open air
Building Code Reference(s):
3.2.5.12.(7), A-3.2.5.12.(7)
Question:
Are sprinklers required on balconies that are open to the sky in buildings regulated by Articles 3.2.2.48., 3.2.2.51., 3.2.2.57. or 3.2.2.60 (i.e. up to 6 storey combustible buildings or up to 18 storey EMTC or noncombustible buildings)?
Interpretation:
Yes (with exception).
Sentence 3.2.5.12.(7) states that all balconies that are deeper than 610 mm must be sprinklered when they are serving buildings regulated by Articles 3.2.2.48., 3.2.2.51., 3.2.2.57. or 3.2.2.60.
This applies to all balconies, even when they have no balcony or roof overhang above them.
As stated on the Notes to Part 3 – A-3.2.5.12.(7), the purpose of this requirement in combustible buildings up to 6 storeys or up to 18 storey EMTC or noncombustible buildings is to limit fire spread from exterior balconies to the roof assembly or to other parts of the building.
The only exception to this requirement is when the balcony is less than 610 mm deep. |
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| NEW 2024 |
24-0049 |
Adaptable Water Closet Encroachments |
24/09/2024 |
File No: 24-0049 INTERPRETATION Page 1 of 2
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-10-02
Interpretation Date:
September 24, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Adaptable water closet encroachments
Keywords:
Water closet, wall hung sink, clearances
Building Code Reference(s):
3.8.5.7.(1)(a), 3.8.5.7.(1)(c), 3.8.3.12.(1)(b)
Question:
Can a future wall hung sink in an adaptable dwelling unit bathroom encroach into the 900 mm x 1500 mm clear transfer space beside the water closet?
Interpretation:
Yes.
Clause 3.8.5.7.(1)(a) states that a clear transfer space adjacent to a water closet be designed in accordance with Clause 3.8.3.12.(1)(b).
Clause 3.8.3.12.(1)(b) requires a clear transfer space of 900 mm x 1500 mm beside the water closet.
Clause 3.8.5.7.(1)(c) states that a plumbing system be designed to accommodate the future installation of a sink with knee clearance beneath it in accordance with Clauses 3.8.3.16.(1)(a) to (f) that does not impede the space for or use of other fixtures described in this Article.
Subclause 3.8.3.16.(1)(c)(ii) permits the clear space in front of an accessible wall hung sink to encroach 430 mm beneath the sink.
The Notes to Part 3 – A-3.8.3.7.(1)(b) indicates that a wall hung sink is permitted to encroach into the 900 mm x 1500 mm clearance in front of an accessible shower when
the sink is located on the opposite side of the fold down bench in the shower. Refer to illustration below:
It is interpreted that a similar encroachment of a future wall hung sink is permitted in the 900 mm x 1500 mm side clearance of the water closet when the sink is located on the opposite side from the water closet.
This is because the future wall hung sink does not impede the space for or use of the water closet. The occupant using the water closet will have the back of their wheelchair facing the back of the wall behind the water closet, so their knees and feet can extend beneath the sink for distance of 430 mm per Clause 3.8.3.16.(1)(e).
So, the wall hung sink can encroach up to 430 mm into the required 900 mm x 1500 mm transfer space beside the water closet.
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| NEW 2024 |
24-0050 |
Group A Division 2 Occupancy in an Article 3.2.2.60 Building Without Group D Occupancy |
15/10/2024 |
File No: 24-0050 INTERPRETATION Page 1 of 2
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-11-03
Interpretation Date:
October 15, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Group A Division 2 Occupancy in an Article 3.2.2.60 Building Without Group D Occupancy
Keywords:
Group A Division 2, Combustible Construction, Group D
Building Code Reference(s):
3.2.2.60., 3.2.2.26.
Question:
Can Article 3.2.2.60. be applied to a 2 storey building of Group A Division 2 major occupancy, where the building has no Group D major occupancy?
Interpretation:
No.
Article 3.2.2.60. allows a 6-storey building of Group D major occupancy to be of combustible construction, with a maximum allowable building area of 9000 m2 for a 2 storey building. A Group A Division 2 major occupancy is permitted below the third storey.
This is inconsistent with Article 3.2.2.26. for a building of Group A Division 2 major occupancy, which permits a maximum building area of only 2400 m2 for a sprinklered 2 storey building of combustible construction. It does not allow combustible construction of an A2 major occupancy in a building of more than 2 storeys.
For example, Article 3.2.2.60. permits a maximum building area of 4500 m2 for a 4 storey building. If a 2 storey building of A2 major occupancy has a building area of 4500 m2, noncombustible construction is required by Article 3.2.2.26. However, if 2 storeys of Group D major occupancy of the same area are added on top, the A2 occupancy in the larger building would now be permitted by Article 3.2.2.60. to be of combustible construction.
There are similar inconsistencies in the BCBC requirements that have been introduced in recent years to allow 6 storey buildings of Group C major occupancy, and encapsulated mass timber buildings of Group C and Group D major occupancy. While it may seem logical to apply Article 3.2.2.60. for larger 2 storey combustible buildings of A2 occupancy, this is not specifically permitted by the BCBC. Application of Article 3.2.2.60. requires that the building have a Group D major occupancy on at least 1 storey.
Applying Article 3.2.2.60. to a building of Group A Division 2 major occupancy, with no Group D major occupancy, would require an alternative solution and acceptance by the authority having jurisdiction. |
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| NEW 2024 |
24-0051 |
Small Residential Care Home |
15/10/2024 |
File No: 24-0051 INTERPRETATION Page 1 of 2
___________________________________
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the committee’s
proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province wide
interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based on the
BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint committee
should not be construed as legal advice.
2024-10-29
Interpretation Date:
October 15, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Small Residential Care Home
Keywords:
Care Facility
Building Code Reference(s):
9.10.2.2.(6)
Question:
If a residential care facility in a Part 9 building is small enough that it does not require provincial licencing, is it required to comply with the BCBC requirements of Sentence 9.10.2.2.(6) for residential care facilities?
Interpretation:
No.
Sentence 9.10.2.2.(6) states “A care facility accepted for residential use pursuant to provincial legislation is permitted to be classified as a residential occupancy…”. Such a facility is limited to sleeping accommodation for no more than 10 persons who must live in a single housekeeping unit in a dwelling unit. The unit must have smoke alarms and emergency lighting, and the building must be sprinklered throughout.
The Province of BC website includes the following statement, for residential care facilities:
Residential care facilities provide accommodation, meals and care and supervision based on the person’s needs. Facilities that provide care and supervision to three or more persons must have a licence, whether they receive funding (subsidized) from a health authority or another agency, or whether a person pays privately.
Based on this information, if a residential care facility provides care and supervision to only one or two persons, it does not require a licence. In that case, Sentence 9.10.2.2.(6) is not applicable. It is interpreted that if the facility provides care and supervision to fewer than 3 persons, it can be classified as a residential occupancy.
Note that the Provincial licencing requirements for residential care facilities may be revised from time to time, with no coordination with the BCBC requirements. Any persons referencing this Interpretation should check the current Provincial requirements at the time of application to their project. |
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| NEW 2024 |
24-0055 |
Curtains for Accessible Showers |
15/10/2024 |
File No: 24-0055 INTERPRETATION Page 1 of 1
Patrick Shek, P.Eng., CP, FEC, Committee Chair
The views expressed are the consensus of the joint committee with members representing AIBC, EGBC and BOABC, which form the BC Building
Code Interpretation Committee. The Building and Safety Standards Branch, Province of BC and the City of Vancouver participate in the
committee’s proceedings with respect to interpretations of the BC Building Code. The purpose of the committee is to encourage uniform province
wide interpretation of the BC Building Code. These views should not be considered as the official interpretation of legislated requirements based
on the BC Building Code, as final responsibility for an interpretation rests with the local Authority Having Jurisdiction. The views of the joint
committee should not be construed as legal advice.
2024-10-29
Interpretation Date:
October 15, 2024
Building Code Edition:
BC Building Code 2024
Subject:
Curtains for Accessible Showers
Keywords:
Accessibility, Showers, Curtains,
Building Code Reference(s):
3.8.3.17.(1)(c).
Question:
Are curtains allowed for accessible showers?
Interpretation:
Yes, with conditions.
Clause 3.8.3.17.(1)(c) permits curtains for accessible showers provided they do not obstruct the shower entrance or the shower controls.
Curtains are permitted, but they must be installed in such a way that a person with disabilities can use the facilities. |
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