Frequently Asked Questions: Objective-Based Codes

• What is an objective-based code?
• When did objective-based codes come into effect?
• Do objective-based codes increase the liability of municipalities and municipal building officials?
• Do objective-based codes force local authorities to evaluate alternative approaches that don't, at first glance, appear to comply with the code in question?
   
• If a building official accepts an alternative solution that doesn't nominally comply with the NBC, how do fire officials enforcing the NFC recognize this... ?
• What training programs were put in place to equip users to implement objective-based codes?
• Isn’t it cumbersome to have to flip back and forth between two divisions of the codes (Division A and Division B)?
• How can one determine whether a proposed building product, design approach or safety measure is sufficient to limit the probability of a hazard occurring to an "acceptable" level... ?
   
• If a design or product fully complies with an acceptable solution in Division B, does it automatically satisfy the objectives and functional statements attributed to that acceptable solution?
• Can a requirement be added to the Codes that is not related to one of the stated objectives?

What is an objective-based code?

An objective-based code includes objectives or goals that the Code is meant to achieve. In an objective-based code, every technical requirement achieves one or more of that code’s stated objectives (e.g. Safety, Health, Accessibility, Fire and Structural Protection of Buildings).

The 2005 Codes contain most of the 1995 Code provisions as well as new provisions. Applying these provisions is one option for compliance since they meet one or more of the Code’s stated objectives by default. The other option is the use of alternative solutions, which is an option similar to the use of equivalents allowed in the 1995 Codes. An alternative solution must satisfy at least one of the Code’s objectives.

When did objective-based codes come into effect?

The NBC, NFC and NPC were published in objective-based form for the first time in 2005, following extensive consultation with the provinces and territories.

Do objective-based codes increase the liability of municipalities and municipal building officials?

No. Liability results from responsibility. The NBC establishes what characteristics the finished building must have but it does not establish who is responsible for achieving those characteristics. Responsibility is established in several other ways—such as architect and professional engineer Acts, other provincial or territorial legislation and regulations, contractual arrangements and civil liability laws. The objective-based version of the NBC does not change this.

Objective-based codes, which are intended to be more accommodating to innovation, may increase the frequency of submission of proposed alternative solutions by designers and builders, and liability issues associated with approving these solutions may therefore arise more frequently. In any given situation, however, the liability associated with code compliance is exactly the same under objective-based codes as it was under the previous prescriptive approach of the Codes.

Do objective-based codes force local authorities to evaluate alternative approaches that don't, at first glance, appear to comply with the code in question?

Because they are intended to be more accommodating to innovation, objective-based codes may increase the frequency with which alternative solutions are encountered by local authorities. However, experience in other countries has indicated that there is not likely to be a dramatic increase in the number of alternative solutions submitted; most people continue to follow the prescriptive solutions.

In addition, local authorities had to evaluate alternative solutions under the "equivalents" provisions of previous editions of the Codes (e.g. Section 2.5. of the 1995 NBC). The additional information that objective-based codes provide makes it easier to deal with alternative approaches: building officials have a clearer picture of what must be assessed and proponents have a better understanding of what is expected of the alternative solution earlier in the design process.

If a building official accepts an alternative solution that doesn't nominally comply with the NBC, how do fire officials enforcing the NFC recognize this and know what extra fire-safety-related measures have been implemented in the areas where the building varies from the specific provisions of the NBC?

For exactly this reason, the acceptance of alternative solutions creates a need for additional documentation. These documentation needs were clearly laid out in a paper prepared by building and fire official members of the Task Group on Implementation of Objective-Based Codes. The advice found in this paper, which is entitled Recommended Documentation Requirements for Projects Using Alternative Solutions in the Context of Objective-based Codes, is reflected in Appendix A of Division C of the 2005 NBC and may be used to determine specific documentation requirements.

What training programs were put in place to equip users to implement objective-based codes?

Traditionally, the provinces and territories took responsibility for all Code-related training. However, the provinces and territories agreed that it would be logical for any training related to the introduction of objective-based codes to be nationally coordinated. Accordingly, a National Steering Committee on Training and Education for Objective-Based Codes developed a training course for building, fire and plumbing regulatory officials. Training is delivered through the provincial and territorial governments or designates. Basic awareness courses are also available on the national codes web site.

Isn’t it cumbersome to have to flip back and forth between two divisions of the codes (Division A and Division B)?

Most of the time, most users use the Code provisions in Division B. Only when designing or evaluating an alternative solution, or when seeking to better understand the legal framework of the Codes, do they consult Division A for the definitions of the applicable objectives and functional statements.

How can one determine whether a proposed building product, design approach or safety measure is sufficient to limit the probability of a hazard occurring to an "acceptable" level? In other words, what does "unacceptable," as used in the definitions of the objectives, mean?

If you have complied with the acceptable solutions in Division B, then you have done enough. In other words, the acceptable solutions in Division B define the boundary between "acceptable" and "unacceptable."

The word "unacceptable" was included in the definitions in recognition of the fact that hazards are always present; the Codes can only strive to limit them to a level deemed "acceptable" by Canadian society. This level has been identified over time by the consensus process out of which the National Model Construction Codes have evolved.

If a design or product fully complies with an acceptable solution in Division B, does it automatically satisfy the objectives and functional statements attributed to that acceptable solution?

All that is necessary to comply with the Codes is to satisfy the acceptable solutions in Division B. This constitutes automatic achievement of the objectives and functional statements.

If you're proposing an alternative solution, it need only satisfy the objectives and functional statements attributed to the acceptable solution it is replacing. The role of the objectives and functional statements, in this context, is to establish the minimum level of performance expected of the alternative solution.

Division B also establishes boundaries on the application of Division A. For example, consider the following NBC sub-objective, Safety in Use:

OS3 Safety in Use An objective of this Code is to limit the probability that, as a result of the design or construction of the building, a person in or adjacent to the building will be exposed to an unacceptable risk of injury due to hazards. The risks of injury due to hazards addressed in this Code are those caused by— OS3.1 - tripping, slipping, falling, contact, drowning or collision OS3.2 - contact with hot surfaces or substances OS3.3 - contact with energized equipment OS3.4 - exposure to hazardous substances OS3.5 - exposure to high levels of sound from fire alarm systems OS3.6 - persons becoming trapped in confined spaces OS3.7 - persons being delayed in or impeded from moving to a safe place during an emergency.

This sub-objective could conceivably cover a wide range of hazards, including, for example, falling in a shower or bathtub. However, there are no provisions in Division B that address this hazard. It is therefore not necessary that an alternative solution deal with this hazard to satisfy this sub-objective.

Can a requirement be added to the Codes that is not related to one of the stated objectives?

The simple answer is "no". In an objective-based code, every requirement is related to at least one of that code's stated objectives.

Of course the existing objectives of the National Model Construction Code Documents are not necessarily frozen for all time. It is conceivable that other objectives could be added or that one or more of the existing objectives could be dropped. However, this would constitute a major change and would only happen if extensive consultation with the provinces and territories and other stakeholders indicated a broad consensus that such an expansion or contraction of the Codes' scope should occur. An energy efficiency objective is being developed in conjunction with the updating of the National Energy Code for Buildings.