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The Independent Fire Code Specialist - Protecting Your Interests

The Independent Fire Code Specialist - Protecting Your Interests

Hotels and Motels

Hotel Fire Safety Explained

Prior to 2007 Hotels were regulated under The Hotel Fire Safety Act.

As of January 1, 2007 hotels became subject to full compliance with the Fire Code. Hotel owners/operators should review the requirements in Parts 1 to 8 of the Fire Code to determine specific provisions that may apply to their building.

Fire Code Retrofit Part 9.9 of the Fire Code was introduced with compliance dates that range from January 1, 2007 to January 1, 2012

The 1st new requirement for compliance was to have a complete Building Audit completed by January 1, 2008. Fire Departments now expect compliance with this requirement.

Part 9 Retrofit Requirements

Part 9 contains minimum mandatory life safety, or Retrofit, provisions for various classes of existing buildings including hotel establishments. The requirements within this Part are intended to ensure a minimum level of life safety to the occupants through the provision of:

Note that Retrofit does not apply to buildings or parts of buildings that satisfy the requirements of the Building Code.
Sections 9.1 and 9.9. are relevant to all existing hotels.
Section 9.1 General
Section 9.1 provides important information regarding:

Hotel establishments owners and operators should be aware that alternative materials, equipment or systems may be approved if in the opinion of the Chief Fire Official they will provide protection for life safety similar to the protection provided by compliance with the requirement.

Fire Code Audit Vs. Life Safety Study

The Fire Code Audit as required by the Fire Code will address all the fire safety features in a building, non-compliant issues, their best corrective solutions and the time frame these deficiencies must be corrected. Generally the fire safety issues can be satisfied under the Fire Code and within the prescribed time frame.

If compliance cannot be achieved through conventional Building and Fire Code practices within the specified time period then a Life Safety Study under Subsection 9.1.4. is an option to address these non-compliant issues. It will describe alternative methods and time frames to meet an acceptable level of life safety for these non-compliant issues. It must be approved by the Chief Fire Official. This Life Safety Study must be prepared by an Architect or Engineer.

Section 9.9 Hotels

Section 9.9 is the Retrofit section addressing minimum mandatory upgrading requirements for existing hotel establishments.

The requirements are organized under the following subsections:

Subsection 9.9.1. Application

This is a very important subsection to familiarize yourself with. Although Section 9.9 applies to all hotel establishments, it provides for some exemptions. For example, except for the need to provide smoke alarms in guest suites, this Section does not apply to a hotel establishment if all buildings on the property containing guest suites are single storey and not more than 300 m2 in building area.

Subsection 9.9.2. Containment

This subsection addresses the need to protect against fire spreading from one area to another. Requirements include fire separation for floor assemblies, guest suites, corridors serving guest suites, service rooms, and major occupancies from each other. To protect occupants exiting the building, corridors and exit stairs are also required to be constructed as fire separations. This subsection also describes requirements for interconnected floor spaces and smoke control.

Subsection 9.9.3. Means of Egress

This subsection addresses the requirements for getting occupants out of a building during emergency situations and includes egress doors, corridors and exits. It prescribes maximum travel distances, minimum number of egress doors, exit signage and mergency lighting. For example, exterior exit stairways and fire escapes are not allowed to serve floor areas above the sixth storey.

Subsection 9.9.4. Fire Alarm and Detection

This subsection addresses early detection of a fire to inform occupants of the need to evacuate. Smaller buildings may require less complex systems than larger buildings.

Subsection 9.9.5. Suppression

This subsection addresses the provision of standpipe systems and sprinkler systems, as well as features to enable fire fighting such as access routes and firefighter elevators. An example is the requirement for access routes to be provided in compliance with the 1994 Ontario Building Code where the building exceeds 3 storeys in height or 600 m2 in building area.

So how does a Hotel operator/owner ensure they are in compliance?

First of all a Building Audit must be prepared by January 1, 2008. This building audit will spell out the requirements and their various compliance dates. Completing a Building Audit will help an owner identify those areas of the building that comply while also identifying those areas that may be deficient and require upgrading. Once the Building Audit is completed; it must be retained and be made available to an Assistant to the Fire Marshal upon request.

For assistance with these Building Audit requirements contact

The Fire Guy Paul Schuster

905 - 884-4423


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The Fire Guy provides building compliance audits to assess, facilitate, implement, and maintain Ontario Fire Code compliance. We are Fire Code experts and our unique services provide building managers, and owners, with a thorough understanding of their responsibilities under the Fire Code. We serve all buildings regulated under the Ontario Fire Code. Many of our clients manage multi-dwelling residential, commercial and industrial buildings which require compliance assurance in general, as well as specific concerns. We will provide you with the quality of service you require in a timely fashion providing building owners and operators a wide range of fire prevention services and life safety requirements.

To Ensure Your Fire Code Compliance and Peace of Mind call The Fire Guy.

The Fire Guy is a Richmond Hill based firm serving the GTA and surrounding areas.