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Fire Safety Plans for Residential Properties, Rooming Houses & Airbnbs in Toronto

Sep 29
6 min read

Fire Safety Plans for Residential Properties, Rooming Houses & Airbnb's in Toronto


Fire safety requirements for residential properties can become much more complicated when a home is rented to multiple tenants, converted into a rooming house, used as a short-term rental, or divided into separate dwelling or sleeping areas.

Property owners are responsible for ensuring their buildings comply with applicable requirements of the Ontario Fire Code, Ontario Building Code and, where applicable, municipal licensing requirements.


For owners of rooming houses, multi-tenant properties, Airbnb's and other residential rental properties in Toronto and the GTA, understanding whether a formal Fire Safety Plan is required is an important part of operating the property safely and legally.


What Is a Fire Safety Plan?


A Fire Safety Plan is a building-specific document that establishes the procedures and responsibilities necessary to protect occupants in the event of a fire or emergency.


Where required under the Ontario Fire Code, a Fire Safety Plan must be prepared, approved and implemented. The plan can include:


- Emergency procedures for occupants

- Procedures for calling the fire department

- Occupant evacuation procedures

- Responsibilities of supervisory staff

- Procedures for assisting occupants who may require assistance

- Locations of fire protection equipment

- Procedures for maintaining fire protection systems

- Fire drill procedures where applicable

- Control of fire hazards

- Alternative measures when fire protection equipment is temporarily out of service

- Building and floor plan diagrams showing important fire and life safety features


The Ontario Fire Code also requires applicable Fire Safety Plans to be reviewed as often as necessary and at intervals not greater than 12 months.


Fire Safety Plans for Residential Properties


Not every single-family home requires a formal Fire Safety Plan submitted to the fire department.


However, the requirements can change significantly when a property contains multiple dwelling units, has a larger occupant load, is being operated as a rooming house, or has undergone a change in use.


Toronto's guidance identifies Fire Safety Plan requirements for certain residential occupancies, including residential buildings where the occupant load exceeds 10 people and qualifying rooming houses.


Owners of residential rental properties should also consider whether their building has:


- Basement apartments

- Multiple separate rental units

- Shared kitchens or washrooms

- Bedrooms rented individually

- Altered exits or escape routes

- Converted living spaces

- Sleeping rooms in basements

- Multiple unrelated tenants

- Fire alarm or sprinkler systems

- Emergency lighting

- Fire separations between suites or rooms


A property that was originally constructed as a single-family home may be subject to additional Building Code and Fire Code requirements if its occupancy or use has changed.


Fire Safety Plans for Rooming Houses in Toronto


Fire safety is particularly important in rooming houses because multiple unrelated occupants may be sleeping in different areas of the building and may not be familiar with one another or the property's emergency procedures.


The City of Toronto now generally refers to rooming houses as multi-tenant houses.


Toronto defines a multi-tenant house as a property where four or more rooms are rented to separate people who do not live together as a single housekeeping unit.


Under Toronto's current guidance, where a multi-tenant house has more than four tenants, the operator is required to submit a Fire Safety Plan to Toronto Fire Services. Once the plan is approved, Toronto Fire Services may inspect the property to confirm that the building and the provisions described in the plan comply with applicable requirements.


Toronto's city-wide multi-tenant house licensing framework has been in effect since March 31, 2024, and operators are required to obtain a licence.


A Rooming House Fire Safety Plan May Address:


- Number and location of sleeping rooms

- Maximum permitted occupancy

- Exit routes from each floor

- Smoke alarms

- Carbon monoxide alarms

- Fire alarm systems where provided

- Portable fire extinguishers

- Emergency lighting where required

- Fire separations and doors

- Exit signs where applicable

- Furnace, electrical, gas and water shut-offs

- Procedures for occupants during a fire

- Owner or supervisory staff responsibilities

- Fire department access

- Fire safety equipment inspection and maintenance

- Alternative measures during equipment shutdowns


Floor plans and building diagrams are also an important component of many Fire Safety Plans.


Fire Safety Plans for Airbnb and Short-Term Rentals


Airbnb and other short-term rental properties have a different operating model from traditional residential rentals.


In Toronto, a short-term rental generally involves renting a home or room for less than 28 consecutive days. Short-term rental operators must register with the City and the property must be their principal residence. As part of the registration process, operators must declare that the residence complies with the Ontario Fire Code and Ontario Building Code.


Toronto also requires short-term rental guests to be provided with information showing the exits from the building, with an exit diagram physically posted within the rental.


An Airbnb does not automatically require the same formal Fire Safety Plan as a rooming house simply because it is being offered for short-term rental.


However, owners should carefully consider the actual use, occupancy and configuration of the property.


Important fire safety considerations include:


- Clearly identified escape routes

- Posted evacuation diagrams

- Working smoke alarms

- Carbon monoxide alarms where required

- Safe bedroom locations

- Unobstructed exits

- Appropriate fire extinguishers

- Safe cooking facilities

- Proper electrical use

- Emergency contact information

- Safe use of fireplaces, barbecues and heating equipment

- Maximum permitted occupancy


Properties containing several individually rented bedrooms, multiple dwelling units or larger numbers of occupants may be subject to additional requirements beyond ordinary short-term rental rules.


Is Your Airbnb Actually Operating Like a Rooming House?


This is an important question for property owners.


A property advertised through Airbnb or another booking platform does not necessarily avoid other regulatory requirements simply because it is described as a "short-term rental."


The way the building is actually configured and occupied matters.


For example, additional review may be appropriate where:


- Several bedrooms are rented independently

- Guests do not form a single household

- Different occupants share kitchens or washrooms

- Basement bedrooms have been added

- The building has been divided into separate rental areas

- Occupancy has substantially increased

- The original use of the building has changed


Depending on the circumstances, Building Code, Fire Code, zoning and municipal licensing requirements may need to be reviewed.


Common Fire Safety Issues in Residential Rental Properties


Many fire safety concerns are relatively simple to correct once they are identified.


Common issues include:


Blocked or Inadequate Exits


Furniture, storage, locks or renovations can interfere with an occupant's ability to escape quickly.


Missing or Improper Smoke Alarms


Smoke alarms must be installed and maintained in accordance with applicable requirements. Simply having one alarm somewhere in the house may not be sufficient.


Carbon Monoxide Protection


Homes containing fuel-burning appliances, fireplaces or attached garages may require carbon monoxide alarms in prescribed locations.


Basement Bedrooms


Basement sleeping areas can introduce additional concerns relating to exits, windows, fire separations and smoke alarm protection.


Doors and Fire Separations


Renovations can compromise fire separations that are intended to slow the movement of smoke and fire through a building.


Improper Electrical Use


Extension cords, overloaded receptacles and temporary wiring can create significant fire hazards, particularly in heavily occupied rental properties.


Unclear Emergency Procedures


Short-term guests and new tenants may have no idea where exits are located or what they should do during an emergency.


Why Evacuation Diagrams Matter


An evacuation diagram gives occupants simple visual instructions showing how to leave the building safely.


A professionally prepared diagram may show:


- Your current location

- Primary exit route

- Secondary exit route

- Stairways

- Exterior exit doors

- Fire extinguishers

- Fire alarm pull stations where applicable

- Emergency meeting location

- Basic emergency instructions


For short-term rentals, where occupants may only be staying in the building for a few nights, clear evacuation information is particularly important.


Toronto specifically requires exit diagrams to be posted in short-term rental accommodations.


What Happens When Toronto Fire Services Reviews a Rooming House?


For qualifying Toronto multi-tenant houses, the Fire Safety Plan is submitted to Toronto Fire Services for review.


After approval, Fire Services may inspect the property to verify that the conditions described in the plan are accurate and that the property complies with applicable fire safety requirements. Toronto's guidance also identifies the installation of an approved Fire Safety Plan Box as part of this process.


If deficiencies are identified, the owner may need to correct them before the property can complete the applicable licensing process.


How Sterling Safety Can Help


Sterling Safety assists residential property owners, landlords, property managers and short-term rental operators throughout Toronto and the GTA with practical fire and life safety compliance.


Our services can include:


- Residential Fire Safety Plans

- Rooming House / Multi-Tenant House Fire Safety Plans

- Property fire and life safety assessments

- Evacuation diagrams

- Emergency procedures

- Fire department submission support

- Fire Safety Plan revisions

- Fire Code compliance assessments

- Smoke and carbon monoxide alarm reviews

- Fire extinguisher requirements

- Fire safety equipment reviews

- Owner and occupant emergency procedures


For rooming house owners, we can assist from the initial property assessment through preparation of the Fire Safety Plan and supporting drawings.


Need a Fire Safety Plan for a Rooming House or Residential Property?


If you own or manage a rooming house, multi-tenant property, residential rental or short-term rental in Toronto or the GTA, Sterling Safety can review your property and help determine what fire safety documentation may be required.


We focus on practical solutions that help property owners understand their responsibilities and work toward Fire Code compliance.


**Contact Sterling Safety today to discuss your property or request a Fire Safety Plan quote.**


Serving Toronto, Mississauga, Brampton, Vaughan, Markham and communities throughout the GTA.

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