CAC Submission to the Standing Committee on Regulations and Private Bills
Bill 52 – An Act to amend the Building Code Act, 1992 with respect to the height of wood frame buildings on behalf of the Cement Association of Canada
May 30, 2012
Presented by Michael McSweeney, CAC President and CEO, on behalf of the Cement Association of Canada
(Check against delivery and or transcript)
Thank you for this opportunity to appear before the committee to provide the thoughts and perspectives of cement manufacturers in Ontario on Bill 52.
Economic Contribution to Ontario
The cement and concrete industries employ over 16,000 Ontarians and generate over $6 billion of economic activity in the province. They also allow the province to be fully self-sufficient in meeting cement demand. This is important given the vast amount of spending by both government and the private sector.
Cement, concrete and aggregates facilities are located in most ridings across Ontario and are important industries supporting a $37 billion construction industry.
But our industry has been significantly affected by the recession.
But we also know that we aren’t the only industry affected. We know that there has been a decline in the wood industry as a whole – something that has affected the forestry industry’s competitiveness.
The same macroeconomic forces that have hurt the forest industry have affected other materials suppliers as well.
Other industries – such as cement and steel – are located in the same cities, small towns and communities across Ontario and have been equally and negatively impacted by the current economic climate.
Our members have experienced the largest declines in Canadian and US cement consumption since the Great Depression.
We too continue to struggle with declining demand in both domestic and export markets.
Our exports are down by over 40% and are very slow in coming back.
The high Canadian dollar and rapidly increasing electricity and labour costs have led to competitive pressures on the cement industry.
Our industry is having a tough time competing with imports from the US and other countries.
Mr. Chairman and Committee Members, everyone has been affected by the recession, not solely the wood industry.
As manufacturers of a fundamental and essential building material, the cement industry is committed to sustainability.
We believe it is important to quantify and assess the environmental and economic impacts of infrastructure development over the long-term.
Our motto is “build it once, build it right, build it to last”.
I want to highlight a quote from the President and CEO of the Earth Rangers Centre for Sustainable Technology. Earth Rangers is a non-profit charitable organization dedicated to educating children and their families about biodiversity loss.
When talking about their own building, President and CEO Mark Northwood states,
Quote“We chose concrete as the material of choice for our building because of its comparatively low impact on biodiversity, its longevity, and thermal qualities. We also believe in aggregates as a top choice for building materials because of the cement industry’s ability to recover, and, in most cases, increase the state of biodiversity on their properties.”Unquote We agree with what Earth Rangers has to say. We don't have to clear cut a forest to provide the construction materials needed needs to build our cities, our infrastructure, our public transit for example.
We believe that cement and wood are complimentary building materials. We respect the wood industry and we are partners with them in the construction industry.
Having said that, what is paramount is that all construction materials should operate on a level playing field and in a fair, competitive and open economic environment.
We support the philosophy of using the right material for the job.
And we also support the fundamental concept that it should be left to the licensed experts, the architects, the engineers, the Insurance Bureaus and not legislative bodies, to decide what building materials should be used in building projects.
We believe that policies such as “Wood First”, that artificially promote one material over others, should be avoided. Governments should not be robbing Peter to pay Paul, as the saying goes.
Changes to the Building Code
Today I want to talk to you about the proposed changes which would allow amendments to the Ontario Building Code with respect to the height of wood frame buildings.
The Cement Association of Canada believes that it is important to ensure that any proposed changes to the Ontario Building Code, address the best interests of Ontarians. It is essential that all proposed changes go through the proper code development process with due oversight prior to any changes being adopted.
There is a well established code development system in Canada that has served the best interests of Canadians for decades. We must take politics out of the decision. Politicians are simply not equipped to make these kinds of decisions.
During last spring’s meetings of the Ontario Part 3 and 4 Technical Advisory Committees, both committees rejected the proposed mid-rise wood frame construction code changes. And today, despite these decisions, we are dealing with a Private Member's Bill seeking to overturn the recommendations of those technical experts to whom we entrust public safety. This Mr. Chairman is, at best, an extremely regrettable situation.
If you want to wade into this discussion it would be prudent to review those recommendations from the experts. First and foremost it must be ensured that all safety concerns are addressed before any changes are used to circumvent the technical decisions already on record at the MMAH.
Buildings that could be affected by these changes include those that house the most vulnerable of our citizens, retirement homes, and nursing homes.
We have heard in the news recently those examples of elderly individuals in retirement homes who have died as a result of a fire and the resultant call for sprinklers in these facilities. A recently released coroner’s report called for retroactive installation of sprinklers in the 4300 facilities for vulnerable people like retirement and nursing homes.
We commend the government for announcing in April that the Office of the Fire Marshall would undertake a “technical consultation” to identify fire safety improvement in residences for seniors, people with disabilities and other vulnerable groups. We hope that the government will look at other PMBs from the past, like those from Michael Prue that called for, at the very least, concrete stairwells so that residents and fire fighters could enter and exit safely.
It is important consultations like these carefully consider the effects of a 50% increase in wood-storey frames from 4-to-6 storeys. It is about the safety of individuals in the residence and the safety of the firefighters that are called upon to fight the potential fires.
Currently the National Research Council and the Canadian Wood Council are involved in an extensive two year research projected entitled, “Wood and Wood-Hybrid Mid-rise Buildings”.
This project will investigate the mid-rise wood changes recently adopted in BC.
The results of the test program will form the basis for any changes that are proposed for the 2015 National Building Code.
If Ontario is intent on proceeding with changes to the code that appear to focus on politics then it would be wise to wait until this work is done – before rushing to accept untested applications in Ontario.
Above all, we need to ensure that the safety of our citizens, especially the most vulnerable, is not compromised on the basis of artificial job protection legislation in one particular sector of the economy.
All potential changes to the Ontario Building Code must address all safety and fire implications.
The fire in BC's first 6-storey wood frame building, which was under construction at the time, highlights possible unrecognized consequences of moving too quickly on Code changes.
Many associations – firefighters, fire safety, masonry, precast, cement, concrete, and steel – have also highlighted the need to put safety first.
We must take politics out of this and leave it to the experts. Safety is too big a concern to do otherwise.
In closing, I want to stress these two key points:
First, let’s ensure that we’re allowing the experts to choose the right material for the right project. If wood is the right material – then use it. If concrete is the right material – then use it. And if steel is the right material – then use it. But it’s not for government to decide. Please take the politics out of building safety issues.
Second, we believe any building code changes must go through proper channels and ensure that all fire and safety implications are addressed. The health and safety of Ontarians is too important.
We respectfully request that you defer any proposed Ontario Mid-rise Wood Frame changes until after the 2015 NBCC, allowing time for proper assessment and coordination with the National Building Code of Canada.
I am sure you would agree that political expediency should never trump public safety, especially with the evidence currently before us.
Thank you for your time today.