Concerns about the safety of the public and first responders have led to increased regulatory enforcement and oversight of laboratory buildings in many major urban markets, with cities such as Boston and New York City establishing dedicated Laboratory Inspection Units within their fire departments. While many of these enforcement mechanisms may feel new, the requirements they are based on have been in the Building and Fire Codes in some form for decades. Since COVID, rapid lab development in some residential areas and shifting office space use have heightened safety concerns, drawing greater scrutiny from Authorities Having Jurisdiction (AHJ).
As laboratory real estate evolves and enforcement activity increases, building owners are under growing pressure to manage compliance at the base building level while preserving the marketability and flexibility of laboratory space. In multi‑tenant environments, compliance challenges are increasingly emerging during lease execution, permit renewals, and renovation planning. This dynamic underscores the criticality of early, building‑wide coordination in avoiding downstream permitting or occupancy delays and/or unanticipated tenant operational constraints.
Priority Action Items for Owners
Document the base building hazardous materials framework:
Maintain a current Base Building Hazardous Materials Report (aka “414 Report”) that defines how the building supports control areas (International Building Code (IBC) Section 414), laboratory suites or laboratory units (IBC Section 428 or NFPA 45), and/or Group H, High Hazard occupancies (IBC Section 415). Maximum Allowable Quantities (MAQs) per chemical compartment should be clearly documented in this Report, including allocations for any shared chemical storage or use areas.
Establish base building emergency action protocols:
Provide a Base Building Emergency Action Plan (EAP) that tenants can use as the foundation for their own emergency procedures, ensuring coordination with building systems and response protocols.
Align lease commitments with building constraints:
Ensure lease language related to hazardous materials, compartmentation strategies, shared chemical spaces, and compliance responsibilities ties back to the documented base building capabilities.
Track owner managed hazardous materials:
Account for hazardous materials maintained by the owner, such as generator fuel storage or pH-neutralization systems, and ensure these quantities are documented, permitted, and included in the overall building limits.
Periodically review tenant permits, quantities, and emergency plans:
Conduct routine reviews of tenant hazardous material permits to confirm aggregate quantities remain within site and license thresholds. Review the tenants’ Emergency Action Plan and tenants’ Hazardous Material Management Plan (HMMP) for consistency and coordination with the base building documentation and lease agreements.
Maintain and document life safety systems:
Ensure required testing, maintenance, and corrective actions are completed for base building fire protection, fire alarm, smoke control, egress, fire rated construction, and other laboratory-related life safety systems, with clear documentation.
How Code Red Consultants Can Help
Code Red Consultants partners with AHJs, laboratory owners, and tenants to create compliance programs and strategies. We conduct laboratory inspections and support the laboratory permitting process. Our engineers, with practical field experience and expertise from serving on NFPA 30 and NFPA 45 committees, help owners reduce risk, clarify tenant responsibilities, and drive compliance, all of which support long-term portfolio flexibility.