Just some initial concerns: (Please add comments as you see fit.)

• What is the past history of loss? NFPA has a few fire investigations that are relevant. The Ste. Genevieve QC Board and Care fire that killed 7 residents in 1996.
• Approval of Fire Safety Plans. (I have attached an OAFC guideline they have prepared on this subject.) There is little guidance in the BC FC on this.
• Wil this be permitted in communities with an aerial device?
• Evacuation Capabilities (better to use term capability for self-preservation) of residents - this is different than the average population found in C occupancies.
• What will be the time frame required for evacuation of the fire zone?
• How do we address new and existing facilities? There will be new facilities constructed to the code that will comply with new. What about previously approved C occupancies of 4 storeys that will now become B3 and existing C occupancies that seek conversion to B3 - what level of change will be required to mitigate the added risk due to diminished capabilities for self-preservation
• What level of sprinklering is appropriate? Are these care occupancies and if so will 13R be adequate or 13 for the added risk?
• I would also want to review what NFPA and ICC building codes have for height and area limitations.
• What does a computerized risk model tell us of this? FireCAM may e applied to check the added risk to occupants.

Essentially if they want to do a risk level review we need to point out many deficiencies in the BC and National Fire Codes. We shall want to shore up some of these provisions before permitting this added risk.