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BRANCH OPINION

Building Permit

A building permit is required before EMLD's can be installed because such devices impact on the life safety of a building.

Fire Alarm System

In buildings built after 1975, EMLD's are allowed only if they are equipped with a fire alarm system meeting the requirements of the Ontario Building Code (OBC). However, in buildings built in or before 1975 and equipped with fire alarm systems which do not fully meet the OBC requirements, EMLD's may be installed provided that:

1. they are compatible with the existing fire alarm systems, or
2. the existing fire alarm systems are upgraded or modified to accommodate these devices.

Mandatory upgrading of existing fire alarm systems is not required except as otherwise required by Part 9, Retrofit, of the Ontario Fire Code.

Inspection by Ontario Hydro

EMLD's are considered to be ancillary devices of a fire alarm system. Their installation, therefore, must be in conformance with the Electrical Safety Code and be subjected to inspection by Ontario Hydro. For purposes of Section 32 of the Electrical Safety Code, an ancillary device is a device actuated by but is not part of the fire alarm system.

Listed Devices

Presently, the OBC does not mandate that EMLD's be listed. However, they must be installed in accordance with good engineering practices since they impact on life safety.

The OBC requires every door required to have a fire-protection rating be provided with a latching device (doors to patients' sleeping rooms excepted). Since EMLD's are not allowed to incorporate latches, separate latching devices must be installed in conjunction with EMLD's in order that this requirement can be satisfied.

2 Stage Fire Alarm Systems

In buildings equipped with a 2 stage fire alarm system, EMLD's must release upon the activation of the first stage alert alarm. It should be noted that, in the 1993 amendments to the OBC (O. Reg. 158/93), the term "alarm signal" in Subclause 3.4.6.15.(4)(b)(i) is no longer italicized (i.e. not a defined term).

Alternative arrangements in unusual cases will have to be ruled upon by the Building Code Commission.

Power Failure

Power failure referred to in Subclause 3.4.6.15.(4)(b)(ii) is meant to be the interruption of electrical supply to the:

1. building,
2. fire alarm system, or
3. EMLD's.

Where standby power is provided, failure refers to the interruption of both the primary and standby powers.

Ground Fault

Ground fault referred to in Subclause 3.4.6.15.(4)(b)(ii) is meant to be a fault occurring in the primary 110 volt supply to the EMLD's.

Emergency Generator

It could take up to 15 seconds for an emergency generator to restore power to a building. During this brief interval, it is not mandatory that EMLD's be released. Should the emergency generator fail to restore power within 15 seconds, the EMLD's must release.

By-Pass During Testing

During testing of the fire alarm system, the normal operation of EMLD's as required by the OBC must not be affected, and vice versa. In other words, when one system is being tested, the other system must be able to function as intended, i.e. no by-pass.

Emergency Release of EMLD's

EMLD's must release immediately when the fire alarm signal is activated either by detection devices, sprinklers or the operation of manual pull stations.

A manual pull station for emergency release must be installed within 600 mm of every door equipped with an EMLD. In addition, an EMLD may also be released by a card reader or microprocessor under non-emergency situations. A time delay of up to 15 seconds is allowed for non-emergency releases only. However, a sign must be posted to properly inform the building occupants.

Manual Reset and Release of EMLD's

Following release of EMLD's by the fire alarm system or as a result of power failure, EMLD's must be reset manually by a single switch. This reset switch must be separate from that for the fire alarm system, capable of also being used to manually release all EMLD's simultaneously, and accessible only to designated personnel.

Automatic reset of EMLD's following release as a result of power failure, although desirable from a building security viewpoint, is not allowed by the OBC because of life safety concerns for building occupants. The installation of other hardware, such as panic bars, in conjunction with EMLD's could prevent unauthorized entry during power failures, particularly in buildings without supervisory staff on the premises.

Emergency Access to Floor Areas (Cross-Over Floors)

Where EMLD's are used on doors required for emergency access to floor areas (commonly referred to as cross-over floors) under Article 3.4.6.16., manual pull stations are required both outside and inside the stairwells for emergency release. The manual pull stations inside the stairwells should be zoned with the stairwells rather than with the access floors. This would be a help to fire fighting personnel responding to an emergency.

Buildings Within the Scope of Part 9

Although not addressed in Part 9 of the OBC, EMLD's may be allowed in buildings within the scope of Part 9 on the same basis as buildings within the scope of Part 3.

Panic Hardware

Where an exit door is required by Sentence 3.4.6.15.(1) to be equipped with panic hardware, an EMLD meeting the requirements of Sentence 3.4.6.15.(4) is allowed to be installed on this exit door only if it does not interfere in any way with the normal operation of the panic hardware. In other words, the operation of the panic hardware must immediately disengage the EMLD.

September, 1993

Revised, April, 1995