Good morning, everybody.
Welcome back. I hope everybody had a productive and enjoyable two weeks in their constituencies or wherever they may have been.
We're back with two sets of witnesses this morning. First, we have Mr. Joseph Galimberti, President, and Ms. Aleksandra Pogoda, Director, from the Canadian Steel Producers Association. We also have Mr. Scott Marks from the International Association of Fire Fighters.
Thank you all for joining us.
The process, in case you're not familiar with it, is that each group gets up to 10 minutes for their presentation, which you can and are encouraged to do in either official language. There are hearing pieces there if you need interpretation. You may be asked questions in French or English afterwards.
After your presentations, we'll go around the table for questions from the members.
My job is to keep time, so if I have to interrupt you or cut you off, I apologize in advance. Unfortunately, that's one of my jobs.
Ms. Pogoda, why don't we start with you to lead us off?
Good morning, honourable members of the committee, and thank you very much for the opportunity to present to you today on behalf of the Canadian Steel Producers Association as regards your study of Bill .
The CSPA is the national voice of Canada's $14 billion primary steel production industry. Canadian steel producers are integral to the automotive, energy, construction, and other demanding industrial supply chains in Canada. Our members produce roughly 13 million tonnes of primary steel and an additional one million tonnes of steel pipe and tube products on an annual basis. This provides direct employment to over 22,000 Canadians while supporting an additional 100,000 indirect jobs.
To start today, I think it's important to state that all of our members support a healthy Canadian construction industry. Wood, steel, brick, concrete, and other construction materials are all important links in a competitive Canadian business environment focused on meeting the needs of domestic supply chain stakeholders. With that open and competitive market balance in mind, the CSPA cannot support Bill as currently constituted. We are concerned that this legislation would create a permanent legislative preference for wood over other construction materials, which would undermine competition and ultimately inflate infrastructure costs by limiting the types of materials available for use on federal projects.
Further, we worry this bill will limit the design freedom of construction professionals in the selection of materials and create potential conflicts with Canada's National Building Code. We worry that the legislation could call into question Canada's obligations under domestic and international trade agreements, and we worry that the legislation threatens green procurement policies by discouraging ongoing assessments of total carbon and life-cycle footprint for the products that the Government of Canada uses in its projects.
The federal government is a significant purchaser of construction material across the country. Its activities affect the national economy and can influence the price and the availability of goods and services, including construction services within the marketplace. Moreover, the Government of Canada's decisions on procurement practices not only influence the practices of other levels of government, but also those of the private sector. As such, any change in federal procurement policy—in this case the creation of a permanent legislative preference for the use of wood over other construction materials—should be carefully considered so as to avoid unintended market consequences.
Our association believes that it is neither good nor acceptable public policy for our governments to promote one building material by excluding alternative, viable, and competitive Canadian materials from Canadian construction markets. We strongly believe that all construction material should operate on a level playing field, and in a competitive, fair, and open economic environment. We believe the proposed Bill to be philosophically contrary to the performance and procurement policies and methods currently employed by the Department of Public Works and Government Services to actively promote and ensure openness, fairness, and transparency. If enacted, we believe the bill would distort these fundamental equalities and send a clear discriminatory signal as regards other construction materials and industries.
As I indicated earlier, Bill will also limit and undermine the freedom of a design professional or experienced contractor to select the most appropriate construction material for an intended function and service. Legislation that compels or influences design professionals to specify the preferred product for use where it is not suited to the function or service has attendant risks. There becomes an increased likelihood of non-performance, permanent failure, and higher initial costs for construction, and elevated ongoing costs for repair and maintenance.
The National Building Code of Canada serves as the basis for specifying materials, testing, design, and construction. It is specifically designed not to limit the application and use of any material, component, or assembly. A “wood first” policy inherently undermines that neutrality by seeking to actively influence a designer's choice of construction material. The selection of appropriate building materials must remain under the purview of those qualified and licensed to practice in the area of building design and construction. The Canadian built environment is founded on that principle.
We also believe the bill implies significant unintended legal and trade consequences. By virtue of the federal Competition Act, the federal government has an obligation to maintain and encourage competition in Canada and to promote equitable opportunities for economic participation. This bill hinders competition and skews the market balance. It clearly violates the spirit of the Competition Act.
We should also be mindful of respecting Canada's trade agreements. The procurement requirements of Bill would likely violate several international trade agreements, including NAFTA, CETA, and the WTO agreement on government procurement.
At this very moment, while the Government of Canada is working to negotiate and implement globally inclusive agreements while at the same time resisting protectionist policies like Buy American, the implementation of a “wood first” policy is inconsistent with the direction of Canada's government and may be seen by other nations as a non-tariff barrier violating several areas of Canada's international agreements on trade.
The bill further seeks to grant preference to projects that promote the use of wood, taking into account the associated costs and reductions in greenhouse emissions. Appreciating that the government is working in partnership with industry across Canada towards a low-carbon economy, this bill remains commercially discriminatory.
Instead of focusing on the permanent establishment of a place of preference for a single building material, the government should consider the implementation of complete life-cycle analyses at the centre of all projects involving construction materials moving forward. A sustainable, circular economy is one in which society reduces the burden on nature by ensuring resources remain in use for as long as possible, and that once the maximum value has been extracted, the resources are then recovered and reused, remanufactured, or recycled to create new products.
As a permanent material that can be recycled over and over again without losing its properties, steel is fundamental to the circular economy and has inherent advantages throughout a full life-cycle analysis. While it is not our intent today to promote the use of steel over any other construction material in government projects, we would rather encourage the government to consider maintaining a fair, competitive construction market.
We would suggest the government can further support the entire domestic construction industry by implementing government-wide procurement policies that give significant recognition to the total carbon and life-cycle footprints of the products it uses in its projects.
In conclusion, while we all agree that we want our domestic economy to continue to grow and for all of our Canadian building products to be more widely used, we would also suggest that it remains our belief that no construction material or assembly should be awarded a legislated priority over others.
Professional judgment, practical application, fair competition, respect for our building codes, and the evolution of construction practices and product innovations should determine the best materials for the application and service.
With this in mind, we respectfully request that Bill or any similar legislation not be recommended for additional consideration by the House of Commons.
Thank you for your time, and I'm happy to take any questions the committee might have.
Thank you, Mr. Chair, for the opportunity to share our views on Mr. Canning's Bill today. It's a pleasure for the International Association of Fire Fighters to return to this committee after our appearance in December.
To briefly introduce our organization, the IAFF represents 310,000 professional firefighters across North America, including 25,000 here in Canada. In Canada's largest cities and towns, our members are on scene in minutes, in any kind of emergency large and small, including structure fires, medical emergencies, water and ice rescues, hazardous materials incidents, and more.
I'd like to reiterate the remarks made by our 13th district vice president, Fred LeBlanc, which were conveyed last December, about our concerns with the expanded use of wood products in construction in the context of firefighter safety. The IAFF certainly supports a vibrant economy and a successful, sustainable wood and wood products industry, including the expansion of the forestry sector and opportunities for its workers both domestically and abroad.
At the same time, as national and provincial building codes are responding quickly to the need for innovation and the expanded use of wood products, we urge the committee to exercise caution and do what it can to regulate or encourage the regulation of adequate fire protection, meaning firefighter and public safety. As fire protection is a municipal responsibility that is also provincially regulated, we suggest that this should be the topic of discussion for the federal government's municipal and provincial partners.
National and provincial building codes currently include provisions for mid-rise, and recently high-rise wood-frame construction. The rush to allow wood-frame construction of up to 12 storeys, which is proposed for the 2020 edition of the National Building Code, has been billed as an economic boost for the forestry sector. As we have formally stated to the Canadian Commission on Building and Fire Codes, and to the federal government, we remain unconvinced about the fire performance of tall wood structures and whether our urban fire departments and front-line personnel are prepared to safely and effectively protect the public in the event of a fire inside of a tall wood structure.
We are aware of studies that discuss the fire performance of cross-laminated timbers and glulam, and the charring effect that supposedly protects these materials from failure. I was a firefighter in the city of Toronto for 28 years, and I can attest to the fact that what happens in a large structure filled with modern combustible materials can be very different than what happens in the confines of a controlled test environment.
Our chief concern is that a majority of urban fire departments in Canada probably lack the equipment, resources, and the training to safely and effectively respond to a fire in a tall or large wood-frame structure. Firefighters may be required to be inside a burning structure long after other occupants have escaped in order to search for and rescue anyone still trapped, and to provide aggressive interior suppression in order to save the building and its contents. That's what the public expects from us. Firefighters will be inside or in close proximity to one of these structures in the event of a collapse.
In our view, there are too many unknowns about the way that a completed six-storey, 10-storey, or 12-storey combustible wood-frame structure would respond in a real fire situation. It's hard to predict the weight load and the fuel load of a particular structure once it's built and populated.
There is also the prospect, as was tragically seen in the Grenfell Tower fire in London, U.K., last year, that modifications—in that case, a flammable exterior cladding—may be added to an existing structure many years later. Neither the National Building Code, National Fire Code, nor respective provincial building codes address fire department response capabilities as they relate to the suitability or safety of a particular structure.
There was no reference in proposals for mid-rise wood-frame construction to any fire protection standards, such as NFPA 1710, a science-based standard from the National Fire Protection Association, that quantifies the adequate fire department deployment in an urban setting. The truth is, very few Canadian cities currently meet the response time and personnel standards for existing two-storey structures, let alone high-density structures made of combustible materials. Even if a community does have adequate fire protection resources to protect a particular structure, there's no guarantee that they will be there during the entire lifespan of that building.
What we are seeing in many communities across Canada right now is the propensity to reduce fire department resources and capabilities for political and budgetary reasons. I can point to numerous communities in Canada, large and small, that have experienced station closures and firefighter layoffs, and many that are contemplating initiatives that would increase response times and decrease the personnel and equipment available to respond.
This common scenario would leave occupants of any given structure with even less protection than builders and authorities anticipated when it was built. Commonly, when these kinds of cuts are made, fire prevention and inspection are amongst the first to be targeted. These are the fire safety individuals on whom occupants of these structures would rely the most to ensure the structure is always in compliance with codes and regulations; for example, when modifications are made.
Firefighter safety is another concern. In our view, the move to permit higher and taller wood-frame buildings in the National Building Code is set against a backdrop of an objective-based code that does not include firefighter safety as an objective. As a result, firefighter safety cannot be used as a basis for a code change request. I would also note that the National Building Code, despite being a model code, establishes an absolute minimum performance that builders are required to achieve. It's not a Cadillac level; it's a minimum
Six-storey wood-frame structures were first permitted under the British Columbia building code. The first such structure was consumed in a massive blaze in Richmond in May 2011, confirming that they are particularly vulnerable when they are under construction.
In December 2013, the four-storey wood-frame student residence under construction in downtown Kingston, Ontario, caught fire, sparking a massive inferno that spread to two adjacent buildings while taxing the city's emergency response infrastructure to its limit for 48 hours. The builders were subsequently charged by the Ontario Ministry of Labour with 22 offences, 11 of which were related to fire safety precautions that were not followed.
Having fire safety regulations and having an existing level of fire protection in the community are not guarantees that any particular structure is safe. The truth is that every working fire represents a danger not only to the public but to the firefighters who respond. Large blazes such as the Richmond and Kingston wood-frame blazes also reduce the resources that fire departments have available to handle simultaneous responses.
In closing, the IFF is not opposed to the context of Bill , but if we are going to give preference in federal procurements to promote the use of wood, we urge a more thorough discussion of firefighter and public safety considerations against the backdrop I have described of inadequate fire protection and the prospect that any given municipality may reduce its fire protection capabilities in the future.
Again, I appreciate the opportunity to present our views to the committee on behalf of Canada's professional firefighters, and I look forward to answering any questions.
Mr. Marks, thank you for being a firefighter for the past 28 years. Thank you for your contribution and for your service to the country. As it happens, I'm also from the city of Toronto.
You just voiced your concern about the use of a combustible wood-frame structure in a real fire situation. Similar to your comments, though, the committee heard from firefighters who have already expressed the concern, from a health and safety perspective, for firefighters and residents from engineered wood buildings.
On the other hand, the past president of the B.C. association for fire chiefs, Mr. Garis, describes this fire safety concern, and I just quote here, as a “red herring”. According to Fire Chief Garis, “Once [wood buildings] are constructed and operating, they are no different than any other building constructed of other material.” As a result, the B.C. association of fire chiefs has already endorsed the B.C. code change as long as the buildings are equipped with a sufficient number of sprinklers and smoke alarms.
Can you give us some comments about the endorsement made by Mr. Garis?
Yes, I'm very aware of Fire Chief Garis's view on the subject. I would not disagree with the statement he made there, which was that once these buildings are made, their fire safety performance is equal. Where I think Mr. Garis and I would differ is with regard to his belief that somehow things will always remain the same.
I've spent a lot of time in high-rise buildings where we had fires, where all sorts of safety precautions were in effect that did not respond or do the job that they had originally been intended to do, in most cases because the occupants in those buildings had made modifications. Some modifications are actually done by building personnel unknowingly doing things that breach the code or that impact the ability of those protections to do what they're supposed to do. More often, it's individuals in a building who decide they want a new cable TV outlet in a bedroom, and they poke a hole through a wall, and now you have a possible breach of the fire protection that's there.
A lot of the wood-frame fire protection relies on using gypsum board and different things to wrap around the combustible materials to ensure that they meet the same kind of standard as other non-flammable materials do. Again, as someone who has spent a lot of time working in the industry, I think that's great, but I also think that there's a huge potential for modifications or vandalism or some other impact or thing to change the ability of that material to perform as it was intended to.
Again, the Grenfell fire in London is an example of how no one really anticipated that wrapping that building would have the impact it did. That's a building that was built with non-flammable materials. Again, I'm not suggesting that this bill would allow something like that to happen, but when you make major modifications to a building 20 or 30 years later, whether or not all the considerations of what was originally put into that building are being looked at when those modifications are being made, you're relying on a lot of different people doing the proper analysis of it. I'm talking about building code people, fire code people, fire inspectors, and fire prevention people. As I said, what we have seen, particularly in the city of Toronto, is that the minute they look at saving money in the city of Toronto, they cut fire inspection jobs, and they cut fire prevention jobs. Those are the people we're relying on to do that.
My name is Michel Dumoulin and I am the Acting Vice-President of the Engineering Division at the National Research Council of Canada.
I'm joined here today by Philip Rizcallah, who is the Director of Research and Development at NRC, within the engineering division.
We are very pleased to have this opportunity to speak with you today. We would like to start by highlighting the NRC's recent contributions to help the Government of Canada achieve its targets for Canada's national model codes, a low-carbon economy, and reduced greenhouse gas emissions.
Initially, I would like to provide you with an idea of the scale and scope of the NRC. Our work covers a broad range of scientific and engineering disciplines, the outcomes of which have changed the lives of Canadians and people around the globe.
We are a national organization with some 3,700 highly skilled and innovative researchers and staff located across the country. Our 14 research centres operate out of 22 locations spanning Canada's geography.
Each year, our organization works closely with industry, conducting research and development work with over 1,000 businesses. We provide technical advice to 11,000 small and medium-size companies, and we collaborate with tens of universities and colleges, research hospitals, federal departments, and international partners.
More specific for today, our organization is the coordinator and custodian of Canada's national model codes, including the model building code and model energy code. We provide administrative support to the Canadian Commission on Building and Fire Codes and perform research in support of the work of its technical committees.
We facilitate uptake in the marketplace of the model codes and new technologies that support the code. We also support development of standards, best practice guides, and tools for the construction industry, as well as pilot projects and techno-economic assessments. Speaking of codes, these evolve in response to advances in construction practices and product innovation.
In working with the Canadian Commission on Building and Fire Codes, we are using an extensive consensus-based process that has involvement from all sectors of the construction community and the public over a five-year cycle. This approach provides a reasonable compromise among stability, flexibility, and economic considerations.
This collaborative engagement ensures that the best available knowledge drives meaningful change. As building codes evolve along with new technologies and materials, this knowledge provides a level playing field that gives construction professionals the confidence to innovate safely, reduces risks, and keeps compliance costs low. Building codes keep these costs even lower by establishing uniform, trusted regulations that keep pace with industry change.
One example of this meaningful change is the NRC's collaboration in the Pan-Canadian Framework on Clean Growth and Climate Change. This framework is Canada's vision for action to help meet its climate change objectives by reducing the carbon emitted by buildings' operations.
The NRC also works closely with the Canadian Commission on Building and Fire Codes and its technical committees to meet the timelines outlined in the pan-Canadian framework. Given the committee's interest, I should add that this process will include wooden structures. Standing committees on energy codes have been created and are undertaking thorough cost-benefit analyses. We are taking into consideration factors such as building types, geographic location, and availability of needed trades and technologies.
Research and validation are ongoing at NRC to support meeting the GHG targets while at the same time identifying costs and benefits. As we work in close collaboration and partnership with Natural Resources Canada, our goals are to make new buildings more energy efficient, to retrofit existing buildings, and to support building codes and energy-efficient housing in indigenous communities. The Canadian Commission on Building and Fire Codes' long-term energy policy was developed in response to the pan-Canadian framework, and the code targets were set to be as closely aligned with the framework as possible.
Relevant for our discussion today is NRC's role in ensuring that the technical and safety research requirements are undertaken and applied to building codes as regards commercial and residential wooden structures. As you know, there is increasing interest by industry in multi-storey wooden buildings. These buildings are often designed to reduce the total carbon footprint while providing added economic benefits for Canada's forest products industry.
In response to this trend, the NRC launched the mid-rise wood buildings research program in 2012. In collaboration with industry, government, and other research organizations, the NRC provided over 1,800 pages of technical information to the codes committees, which enabled changes to the National Building Code to permit wood buildings up to six storeys as an accepted and safe solution. Before the program's completion in 2016, there were over 250 wood buildings between four and six storeys built or under construction across Canada.
As you have heard from the testimony of others, advances in wood technologies, such as cross-laminated timber, have enabled wood buildings to reach even greater heights. One example is the 18-storey Brock Commons Tallwood House at the University of British Columbia. Working with the commission's technical committees, the NRC provides support to develop the unbiased knowledge needed to support changes to the building code. This reduces the time and effort required to design wooden buildings up to 12 storeys tall without compromising safety. Results are expected in time for the 2020 code revision.
The ongoing research at NRC is aimed at first validating the performance and then quantifying the risk of the effects of climate change and extreme events that could have impacts on the performance and durability of tall wood building envelope materials, components, and assemblies. This will permit validated design options for massive wood buildings, including Canadian timber products, in the numerous geographic and climate regions of Canada.
As the government strives to reduce the carbon footprint of government buildings, increasing attention is being given not only to the carbon emitted during operation by considering energy efficiency, but also the carbon used to create the building materials.
Also, we must be cognizant of the additional carbon that may be required to decommission the building when it reaches its end-of-life cycle. To reduce the total carbon footprint of a building over its life requires forethought, good design, and engineering, as well as diligent operation.
In addition to the consideration of long-term impacts, the creation of a low-carbon economy will immediately result in positive impacts in terms of wealth and job creation as we help industry innovate.
To close, it is the NRC's breadth of expertise, our unique scientific infrastructure, and our national scope, all combined, that enable us to convene players and technologies from across Canada and abroad, which should result in the highest chance of innovation success. This will make a difference to Canadians in the decades to come.
Thank you for your interest in the NRC, Mr. Chair. My colleague, Philip, and I will be happy to take questions at this time.
I will try not to get too technical with the response, but generally, when the National Research Council started the project about six years ago on mid-rise, there were a number of tests conducted. We looked at modelling. We looking at fire load in these buildings. We looked at fire spread with this type of construction and encapsulation. How do we protect these structures once they are built? We've continued with that now. That led to a six-storey transition in the building code. Now we're moving towards a 12-storey transition.
Right now, what we've been doing as late as last week is, we would build a room, a compartment, and we would introduce fire for about four hours, and we would see how the structure would react. It has been very favourable. The results have been that they basically self-extinguish.
For four hours the unit is burning. We take measurements. We take smoke. We take all kinds of data from this. We can translate that into technical provisions into our building codes. If the structure failed after one hour, we would say we need this much more protection. If it failed under three hours, we would need this much protection.
There's quite a bit of research. We're working with our United States counterparts as well and taking some of that data and incorporating into our research.
One of the biggest concerns that Scott, one of our colleagues here, mentioned was construction under fire, so we've also been looking at what we need to do to protect a site during construction, because that's the biggest risk. It's not generally when the building is built. Then, it's like any other building. It's protected. It has sprinklers, and everything is fine, but what do we do during construction to save that building from arson or any type of fire condition? We've introduced requirements into the fire code to mitigate that risk as well.