But We’re Up to Code…. Aren’t We?
Among the clients I work with, the issue of codes is a common dilemma. Codes get thrown around constantly and can be an alphabet soup of mystery. NFPA, FM, ASHRAE, API, OSHA, WSBC, NBC, NFC, BCBC, BCFC, VFC, UBC, ASME, ASTM, ISO, GMP, HACCP, CAN/ULC… the list can be endless. But what exactly do they mean and when do they apply? What codes are enforceable and which ones are best practices? Why does an insurance company apply one or the other to a risk?
Codes are essentially collections of guidelines that are designed to provide the minimum level of life/health safety, structural uniformity, product safety or fire safety. They are prescriptive in nature in that they say “you should” and contain guidelines for implementation. For instance, NFPA 13 provides prescriptive rules on the installation of sprinklers and could be applicable to two different warehouses storing the same materials, at two different locations in the world. Application of the code will give you the same level of protection regardless of the physical location.
Now here’s where things get complicated. Codes have to be legally adopted and enacted as enforceable legislation within a region to have any actual power. Codes can then be superseded by other codes. One great example are the Canadian building codes. The National Building Code of Canada applies everywhere in the country as the minimum acceptable standard in construction. In British Columbia, that code is superseded by the BC Building Code which is, in turn, superseded by the City of Vancouver codes.
Wood frame construction is a great illustration of this principle. The NBC permits three storeys of wood frame construction. The BCBC ups the allowable height to six storeys! The VFC adds on layers of requirements for fire protection systems and fire rating of components. You then have to build to the highest code applicable to get approval. Needless to say that code application starts to get muddy and granular depending on the location.
Codes can also change periodically. This can be driven by new information, failures in the existing code, large losses and new technology. When codes change, the new standards can be applied to new construction only, apply to all situations retroactively, or even apply selectively for any number of reasons.
Further complicating matters is that code compliant buildings or operations are not always adequately protected in the eyes of all stakeholders. Many fire codes in force have no protection requirements for certain types of operations or storage. Other protection systems prescribed by codes are now being shown to be inadequate overall, while the codes are lagging behind in changing. This opens the door to proprietary codes such as the FM Data Sheets and other third party codes. Insurance companies are free to select from any of these in their assessment of risks and creation of loss control recommendations, often to the chagrin of our clients.
The challenge for the client is to know when the codes in force provide suitable protection or design, or when improvement might be in their best interest in order to protect their assets and operations. Insurance carrier recommendations can often appear self-serving, and it’s always in the client’s best interest to get engineering feedback on codes. Don’t just say you’re up to code, find out where you actually stand and what you could do to improve.
Author: Rick Adam, P.Eng., PE, CRP