We’re finding ourselves asking this question a lot lately. How temporary is temporary? Perhaps it’s as a result of the current COVID-19 pandemic, or is this a new trend of something that we are going to continue to see?
Per our friend Webster, temporary is defined as “lasting for a limited time”. For us who navigate the Code on a regular basis, these ambiguous statements result in an interpretive nightmare!
Temporary is defined as “lasting for a limited time”
Webster’s Dictionary
Why is this important?
Let’s first assess some of the challenges associated with temporary structures. Recognizing that temporary structures have a lifespan, the permanent life safety systems within the Building Code may not be feasible for the design. For example, is it reasonable to sprinkler a structure that will only be in place for a day? How about a week? Or maybe a year? Where do we draw the line in the sand? At what point is the structure required to comply with the full requirements of the Code? And further to this, is it the responsibility of the local municipality to establish a lifespan for temporary structures? So many questions……
Let’s talk of the times…
We have all learned a lot from the current COVID-19 pandemic; specifically with respect to emergency provisions. This pandemic resulted in the enactment of the Emergencies Act and a declaration of a Public Welfare Emergency. Perhaps this is the reason why “temporary” has become such a prevalent term lately. The Act is riddled with the word “temporary”:
The Emergencies Act is riddled with the word “temporary”
So under the Emergency Act, what rules apply? When “special temporary measures” are permitted, how do you build safely under this ambiguous allowance? This is such an unusual period, with everyone pivoting to accommodate/adjust. To assist our healthcare workers, field hospitals, building conversions and other spaces are being renovated to provide for additional patient beds. Office workers are now working remotely. Residential shelters are being constructed and other facilities are being repurposed to move people out of shelters or crowded living spaces.
“When this is all over, we’ll go back to normal. But, what happens with all these newly constructed facilities?”
Temporary: “Lasting for a limited time”
The adage seems to be “when this is all over, we’ll go back to normal”. But, what happens with all these newly constructed facilities? Will they be torn down or converted back to their original use? NFPA issued a white paper in April 2020 titled “Considerations for Temporary Compliance Options in Health Care Environments During COVID-19”, recognizing that there was a gap in requirements for these temporary facilities. This document speaks to lifespan requirements by mandating that these facilities be converted back to their original purpose, or dismantled when the pandemic subsides.
When we first started constructing temporary facilities, before we fully understood the magnitude of the pandemic, temporary was understood to be 3 to 6 months. Come the fall, the new design goal became “winterization”. Let’s insulate these facilities so that we can use them for the winter. With this, “Temporary” became a one-year term. It’s almost a year now and most of these facilities are still necessary. So is temporary a 2-year thing?
Let’s look to the restaurant industry. To support small businesses, many jurisdictions permitted patios and sidewalk tables. Previously, many local by-laws mandated that a minimum sidewalk clearance be maintained. So when this pandemic is over, what is going to happen? Most likely, these patios will need to be removed, unless a permit to construct is applied for, and approved. But will the by-laws pivot too? So is the time limit for restaurant patios defined as when the pandemic is over?
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Complexities with Construction
We are in unprecedented times. Exceptions have been made. Special temporary measures are allowed. But when it comes to construction and life safety, even under the Emergencies Act, we cannot cut corners. Therefore, how do you build a facility that doesn’t fit within the typically prescribed requirements of the Building Code?
Let’s do a deeper dive on that field hospital example. To accommodate additional patients, hospitals have erected tents within their parking lots, with full hospital resources and staff. The National Building Code includes provisions for tents under Section 3.1.6. that can be applied to these facilities. Ontario even goes as far to state under Article 3.14.1.1. as applicable to tents, “except as provided in this Subsection, tents are exempted from complying with the requirements of this Division”. To clarify, this would be Division B, which contains the acceptable solutions of the Ontario Building Code. At least the Building Code(s) still provide a cross reference to additional Subsection 3.3.3. requirements, but a lot of the fire and life safety requirements are otherwise exempt. There is clearly a gap.
Further to this, the Note to NBCC Subsection 3.1.6. defines a “tent” as intended to refer to a temporary shelter which is used at an open air event such as a fair or exhibition. There’s the word temporary again.
Therefore, when constructing these temporary facilities, it is important to assess the associated risks, and engineer a solution that would achieve an equivalent level of safety. As a baseline, the requirements of the Building Code should be implemented where feasible. To fill in the gaps, performance-based approaches, equivalencies or alternative solutions will be required.
Using our hospital tent example, how do we sprinkler this facility? In Canada, the construction requirements of Subsection 3.2.2. do not permit the construction of an unsprinklered Group B (care occupancy) building. This is where the ambiguity of the Emergency Act, the limitations of the Building Code, and good engineering judgment all collide. Under the Emergency Act, this could be considered a special temporary facility that would allow the building to be unsprinklered. Under the Building Code, the construction requirements mandate a sprinkler system, but as a tent, sprinklers are not required. Good engineering may stipulate that additional compensating measures be incorporated.
“the ambiguity of the Emergencies Act, the limitations of the Building Code, and good engineering judgment all collide”
What’s after temporary?
2020 resulted in a lot of temporary construction. Field hospitals were quickly constructed to accommodate the anticipated need for an increased number of patients. Patios were built to keep restaurants afloat. Conference centres were re-purposed and temporary modular housing has been approved to address a housing crisis. Most of these facilities are unconventional and would not normally have been permitted, as constructed, except as authorized by the Emergency Act.
So what happens when the pandemic subsides and the Emergency Act provisions expire? Will what we built in 2020 be deemed “not quite safe enough” and these temporary facilities will be required to be either upgraded or dismantled? They were only temporary right? They were built with a purpose of pivoting to address the COVID-19 pandemic, built to last for a limited time and set to expire with the Emergency Act.
Only time will tell….
Has anyone else had this experience with temporary facilities? If so, we would love to hear it in the comments section below.
Dive Deeper
CodeNext shared this post with us last year, about their experience working on a temporary Pandemic Response Unit in Ontario.
One Response
1.I would allow that anything built temporary during a declared emergency would have the same life as that emergency regardless of how often it’s extended.
2. Emergency construction/accommodation seems to include a temporary cancellation of access to egress with some doorways blocked to limit entrances as well as numerous screens and choke points being introduced in exit pathways. I balance this observation with the fact that occupant loads are reduced.
3. I live in SW Saskatchewan where compared to other places everything we build is temporary.