Thank you, Mr. Chair, for the opportunity to share our views on Mr. Canning's Bill C-354 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 C-354, 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.