Extent of application of the legally adopted Codes during addition, renovation, upgrade or equipment replacement projects

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This article is the result of numerous questions raised by the electrical designers, electrical contractors and even electrical inspectors on the subject at hand. When a design and installation apply to a new construction, it is quite clear that all relevant provisions of the legally adopted codes (i.e., of the National Building Code of Canada – NBCC, and the Canadian Electrical Code, Part I – CE Code) must apply. But what about the projects that cover only replacement of a piece of an existing electrical equipment, upgrade of such piece of equipment, or addition of certain electrical equipment to the existing electrical infrastructure of a building?

Here is where fun really begins, as the scope of necessary (i.e., required) work for such projects is understood differently by the designers, electrical contractors and regulators.

Let’s illustrate the essence of this issue by 8 different examples as follows:

 

  1. Replacement of a faulty service entrance panelboard by the new service panelboard with identical electrical characteristics (i.e., with the identical ampere and voltage ratings, with identical size and a number of branch circuit positions).

In this particular case, a scope of electrical work will be limited to disconnection of the existing faulty panelboard, to replacement of this panelboard by the new one and by reconnection of the newly installed service entrance panelboard in the location, where the faulty service entrance panelboard was originally installed. This scope of work appears to be simple, but in some cases, [if the original location is no longer in compliance with Rule 6-206(1)(c) of the currently adopted CE Code], the new panelboard is being moved to the location mandated by the current Code, and new wiring is also being run to and from the newly installed service entrance panelboard, although the scope of work should be limited to a simple replacement of the faulty panelboard.

Such relocation of the panelboard and additional wiring – to comply with the requirements of Rule 6-206(1)(c) of the currently adopted CE Code, is unwarranted, as Codes change all the time, and the newly adopted Codes are not retroactive for the existing installations which were made under provisions of the previous editions of the Code and which were inspected and accepted by the local AHJ’s.

Relocation of the existing service entrance panelboard – to comply with the current Code, would be only necessary, if the scope of the intended work would not have been limited to a simple replacement of the existing faulty panelboard, but would include upgrade of the service panelboard (i.e., would include change of the panelboard rating, change in a number of branch circuit positions, etc.).

 

  1. Replacement of the existing fire pump. In this case, approach described in the example 1 above, would have to take place – if the replacement of a fire pump is limited to a simple removal of the existing non-operational fire pump and to installation of the fire pump with identical characteristics.

However, if a newly installed fire pump has different characteristics than the replaced fire pump, then all applicable provisions of Subsection 32-300 series rules of the CE Code would have to be met (based on the CE Code 2018). It means that a new fire pump controller would have to be installed in accordance with NFPA 20, new automatic transfer switch would have to be installed in conformance with Rule 32-308 of the CE Code, overcurrent protection in the normal and emergency power supply feeders (upstream of a fire pump controller and upstream of a fire pump automatic transfer switch), would have to comply with Rule 32-306 of the CE Code, and protection of the fire pump emergency feeder conductors against exposure to fire would have to meet provisions of Rule 32-300(b) and Article 3.2.7.10. of the NBCC.  Of course, the existing emergency generator should be also evaluated whether it could accommodate the newly upgraded fire pump.

 

  1. Voluntary upgrade of the existing fire alarm system. In this case, everything depends on the extent of the voluntary upgrade. If a few field devices have to be replaced in the existing locations (i.e., manual stations, smoke detectors, end of line resistors), then no new wiring would be required under this scope of work, but upon completion of the devices replacement, all fire initiating zones where such devices have been replaced, would have to be re-verified, as required by the ULC S537. Building and electrical permits would have to be obtained for such work from the applicable local AHJ’s, as this work would cover provisions of the NBCC and the CE Code.

If additional field devices are intended to be installed by such voluntary upgrade, then under the scope of work, all newly installed field devices would have to meet provisions of the currently adopted editions of the NBCC and ULC S524, wiring to these newly installed devices would have to comply with Section 32 of the CE Code, and verification of the fire alarm system would have to comply with ULC S537.

If the entire fire alarm system is planned to be upgraded by the building owners, the extent of such upgrade must be discussed between the owners, designers and the AHJ, as the owners may not elect a full compliance with the currently adopted edition of the NBCC by this upgrade. It means that if, for instance, there was an agreement that the existing fire alarm system in the old high building (fire alarm system that did not have voice communication) is subjected to a voluntary upgrade, and the owners do not have funds to bring the voice communication system to the current requirements of the NBCC, the owners (or designers on behalf of the owners) may be able to substantiate to the AHJ, that the safety improvements of the existing fire alarm system would be limited not to a full blown 2 way voice communication system, but only to a “all call” voice communication system that would consist of one way voice communication (i.e., of speakers only), but without emergency phones. However, after such decision is made in consultation with the AHJ, all aspects of the upgrade must meet requirements of the currently enforced editions of the NBCC and ULC S524, wiring of this upgraded fire alarm system must meet Section 32 of the currently adopted edition of the CE Code, protection of riser conductors of this upgraded fire alarm system against exposure to fire in a high building must be provided in conformance with Article 3.2.7.10. of the NBCC and a complete verification of the upgraded fire alarm system must meet ULC S537.

 

  1. Field modification of existing luminaires by incorporating approved LED kits inside each existing, already installed luminaire (i.e. retrofit of luminaires).

This particular work represents an extension of the equipment manufacturing process. This work would not have to be done under electrical permit, as this particular work would not be performed in accordance with Rules of the CE Code (i.e., rules of the installation Code do not apply to modification of electrical equipment, and all CE Code users are well aware  that only “approved” equipment must be installed under rules of the CE Code.). Thus, such modification work must be done by qualified persons authorized by the manufacturer of luminaires to perform this type of the field modification/retrofit) to the existing luminaires, and after completion of this retrofit in the field, the modified luminaire must be made “approved” by means of its re-certification to the CSA safety standard for luminaires or by means of a field evaluation/special inspection in accordance with the CSA Model Code for the field evaluation of electrical equipment SPE 1000.

 

  1. Voluntary upgrade of the existing elevator.

These types of projects are also subjected to various scenarios as follows:

(a)  If it is intended to simply to remove the existing non-operational elevator and to replace it by the new elevator, which is absolutely identical to the originally installed elevator in all technical aspects, then the scope of electrical work would be limited only to disconnection of the existing, non-operational elevator and connection of the new elevator, which replaces the original elevator.

(b)  If the new elevator is intended to replace the existing elevator in the existing building, and the elevator being replaced does not have automatic emergency recall feature, but the new elevator is provided with such feature, as described in the CSA standard B44 “Safety Code for Elevators and Escalators”, then new smoke detectors must be provided in the elevator machine room and in the elevator lobby on each storey of the building in accordance with requirements of that edition of B44, which is referenced in the legally adopted edition of the NBCC, and installation of these smoke detectors must comply with relevant provisions of ULC S524. These smoke detectors would have to be interlocked with the elevator controls so, that actuation of any such smoke detector would automatically return the upgraded elevator to the recall level. Newly installed smoke detectors required by B44, would have to be connected to the building existing fire alarm system. Of course, all applicable provisions of Section 38 of the CE Code would have to be added to the scope of the upgrade work. And if this upgraded elevator is installed in a high building and is intended to function as the “elevator for Use by Firefighters” in conformance with Article 3.2.6.5. of the NBCC, feeder conductors supplying such new elevator from the exiting emergency generator would have to be also protected against exposure to fire, as required by Article 3.2.7.10. of the NBCC. Of, course, the rating of the existing emergency generator in such high building should be also evaluated – to validate that the existing generator could accommodate the newly upgraded fire fighters’ elevator. If the exiting building is not provided with the emergency generator, then the scope of work would have to also include installation of the emergency generator and associated equipment in a dedicated 2 h rated generator room that conforms to Article 3.6.2.8. of the NBCC, as the emergency generator is required for elevators for “Use by Firefighters” in accordance with Article 3.2.7.9. of the NBCC.

 

  1. Addition of exit signs during renovation of CRU’s in an existing building.

Extent of application of the Article 3.4.5.1. of the NBCC for the projects in existing buildings (for tenant improvement and addition projects) also always raises lots of questions, as some fire or building inspectors are in the opinion that all existing exit signs depicting word “EXIT” must be replaced in the renovated areas, or on contrary – newly installed exit signs should not have a pictogram with “running man”, but must display the word “EXIT”, similarly to the existing exit signs in the renovated areas.

It should be noted, that in an existing building subjected to such scope of work as tenant improvements or additions, only exit signs covered by the scope of each specific project must comply with the pictogram mandated by Article 3.4.5.1. of the NBCC legally adopted by relevant jurisdictions.

All existing exit signs outside of the scope of the renovation/addition project remain as they are (as the current adopted editions of Building Codes are not retroactive).

However, some municipalities may have additional formal requirements for the replacement of the existing exit signs in renovated areas. For instance, the City of Vancouver has published the explanatory Bulletin on application of the Vancouver Building By-Law in respect to use of exit signs with international pictogram in conjunction with renovation projects. This Bulletin explains that for renovation and addition projects in Vancouver some existing signs depicting word “EXIT” (those signs that are located in the required paths of travel from the project area to an exit or a separate fire compartment) would have to be also replaced with the signs containing “running man” international pictogram. In the absence of the formal Bulletins on application of (or amendments to) the local building by-laws, all existing exist signs not impacted by the scope of renovation work, must remain unchanged, and only the exit signs included in the scope of renovation work must have “running man” international pictogram.

 

  1. Protection of emergency conductors against exposure to fire.

Where the scope of addition or renovation work involves installation of the new fire pump in any building or installation of a smoke control and smoke venting equipment in a high building, feeder conductors between the emergency generator and life safety equipment installed under the scope of the project, must be protected against exposure to fire in conformance with provisions of Article 3.2.7.10. of the NBCC. If the existing conductors supplying such smoke control and smoke venting equipment are not impacted by the scope of renovation work, protection of these existing conductors against exposure to fire is not warranted, as the currently adopted editions of Building Codes are not retroactive.

 

  1. Addition of new loads to the existing emergency distribution or a replacement of the emergency generator.

This subject also appears to create lots of questions. There could be various scenarios in such power system arrangements:

(a) If the existing emergency power system already supplies life safety loads via a single automatic transfer switch (as such existing emergency power supply system was installed prior to the changes to Rule 46-108 of the CE Code), and a few non-life safety loads are intended to be connected to the existing emergency distribution by the scope of renovation work, no new automatic transfer switch is required to be provided for the newly installed feeder – to supply these additional non-life safety loads, as such addition of non-life safety loads to the existing emergency distribution is outside of Section 46. It should be also noted that such addition of non-life safety loads does not reduce the existing accepted level of electrical and fire safety. However, the rating of the existing emergency generator should be reviewed – to validate whether it could accommodate the new loads added to the existing emergency distribution.

(b)      If the existing emergency power system supplies life safety loads via a single automatic transfer switch (as this emergency power supply system was installed prior to the changes to Rule 46-108 of the CE Code), and a few life safety loads (required by the NBCC to be provided with the emergency power) are connected to the existing emergency distribution by the scope of renovation work, then newly added life-safety loads must be connected to the existing emergency distribution via a dedicated automatic transfer switch provided in the newly installed feeder that will supply these new life safety loads. This must be done regardless of the fact that an existing emergency distribution is equipped with a single automatic transfer switch. The reason for the addition of the dedicated automatic transfer switch is based on provisions of Rule 46-108, since compliance with Section 46 would be warranted under the scope of this work. And of course, the rating of the existing emergency generator would have to be checked – to ensure that it has sufficient capacity to accommodate the new life safety loads added to the existing distribution.

(c)      If a fire pump is added to the existing distribution, then all applicable requirements indicated in the example 2 above, would have to be met.

(d)      If the existing faulty generator is intended to be replaced by the generator with the identical technical characteristics, there is no need to replace the entire emergency power supply system arrangements – to comply with Clause 5 of C282 and with Rule 46-108 of the CE Code. (see discussion in example 1 above).

(e)      If the existing emergency generator is subjected to upgrade (i.e. generator rating and fuel supply requirements are changed), the entire emergency power supply system arrangements must comply with the currently adopted edition of the CSA standard C282, the generator room must comply with Article 3.6.2.8. of the NBCC, and the existing emergency distribution must be upgraded so, as to comply with Rule 46-108 of the CE Code.

Hopefully, the discussion on this subject is beneficial to the readers. However, as always, local AHJ’s administering legally adopted building, elevator and electrical codes should be contacted for each specific installation project.