Insights Category: Technical Information

In the first article of our College Fire Safety Month blog series, we discussed why fire and life safety must extend beyond any individual building. Achieving that broader approach requires more than maintaining fire protection systems. It requires a coordinated, campus-wide program that connects the people, processes, and information influencing life safety throughout each building’s continuous life cycle. 

Responsibilities are often distributed across facilities management, environmental health and safety (EHS), public safety, resident life, design and construction, and institutional leadership. When these groups are not effectively coordinated, fire and life safety issues are far more likely to emerge. 

Disconnected Decisions Create Lasting Challenges 

Fire and life safety issues frequently arise during a single phase of a project, even though their root causes originate elsewhere. A construction project may uncover an existing condition that affects the schedule and cost. A permitting review may raise questions because the fire alarm system information is incomplete. A maintenance challenge may result from an earlier design decision that did not fully account for long-term operations. 

These examples highlight an important reality: buildings operate within a continuous life cycle. Decisions made during design affect construction, construction impacts operations, and operational decisions influence future renovations. When information and responsibilities are not effectively coordinated across these phases, problems can persist and reappear throughout the cycle. 

A Strong Program Connects People and Processes 

A comprehensive campus fire safety program creates a framework for coordinating the people, information, and processes that influence fire and life safety. Rather than focusing only on individual life safety systems or code compliance deficiencies, the program helps institutions evaluate how responsibilities and decisions are managed across departments. 

Effective programs typically connect: 

  • Life safety documentation and existing building conditions 
  • Inspection, testing, and maintenance activities 
  • Design, construction, and renovation processes 
  • Compliance and deficiency management 
  • Emergency planning, policies, and procedures 
  • Staff responsibilities and training 

Clear ownership, consistent documentation, and reliable communication help institutions identify root causes, manage deficiencies, and support continuous improvement. 

Earlier Coordination Supports Better Outcomes 

For new construction, fire and life safety considerations should be coordinated with campus operations, documentation standards, emergency procedures, and long-term maintenance prior to the building being turned over. A building may meet technical requirements at completion but still present future challenges if its systems and records are not fully integrated into campus operations. 

Institutions can strengthen their programs by evaluating how information moves among departments, how deficiencies are assigned and resolved, and how project decisions are transferred to the teams responsible for ongoing operations. Improvements can then be prioritized based on risk, available resources, and institutional goals. 

Keeping public safety at the center of this process helps teams evaluate decisions against code intent and their practical effect on occupants, operations, and emergency response. A coordinated program ultimately enables institutions to identify concerns earlier, make informed decisions, and proactively manage fire and life safety throughout the building life cycle. 

How Code Red Consultants Can Help 

Code Red Consultants works with colleges and universities to evaluate campus fire and life safety design and maintenance standards, identify coordination and documentation gaps, and connect program requirements that can be applied to occupied buildings and capital improvement projects alike. Through risk-informed guidance and an integrated understanding of building systems, codes, and project delivery, our team helps institutions establish practical priorities that support code intent, long-term building performance, and public safety. 

 Please reach out to our team if you’d like to schedule an on-campus consultation. 

September is an important time to focus attention on fire and life safety as colleges and universities welcome students, faculty, and staff back to campus. Recognizing the importance of this issue, Massachusetts Governor Maura Healey proclaimed September College Fire Safety Month. The proclamation provides a timely opportunity to consider the fire and life safety challenges facing colleges and universities in Massachusetts and across the country.

Public safety is a foundational principle at Code Red Consultants. It is also central to our work with colleges and universities, where effective fire and life safety programs must account for a wide range of buildings, occupants, activities, and institutional responsibilities.

Campus-Wide Approach to Fire and Life Safety

Fire and life safety in higher education extends beyond an individual building. Residence halls, laboratories, classrooms, dining facilities, athletic venues, healthcare settings, and assembly spaces each present different challenges. At the same time, students, faculty, staff, researchers, contractors, patients, and visitors move throughout a campus every day. An incident in one location can therefore affect people, operations, and emergency response well beyond the building where it occurs.

This makes fire and life safety a shared responsibility. Facilities teams maintain fire protection systems and building infrastructure, while housing staff support student safety and emergency procedures. Environmental Health and Safety (EHS), emergency management, public safety, and campus leadership also play important roles in identifying risks, preparing for emergencies, and protecting occupants. Communication and coordination among these groups are essential to an effective fire and life safety program.

Why This Matters

College Fire Safety Month provides an opportunity to raise awareness of these issues and encourage discussions around preparedness, risk management, and occupant safety. It also serves as a reminder that fire and life safety programs are most effective when institutions take a campus-wide approach rather than evaluating buildings individually.

Although the formal proclamation is specific to Massachusetts, the underlying issues are not. Colleges and universities everywhere must continually evaluate how changes in facilities, technology, campus activities, and occupant behavior affect fire and life safety.

Looking Ahead

This article introduces a four-part series focused on practical fire and life safety considerations for colleges and universities. The remaining articles will explore:

  • Building a comprehensive campus fire protection program
  • Managing lithium-ion battery risks associated with micromobility devices and energy storage systems
  • Addressing fire and life safety during campus renovations and adaptive reuse projects

The series uses College Fire Safety Month as a starting point for a broader discussion about how institutions can manage fire and life safety as a coordinated, campus-wide responsibility.

Emergency preparedness is a critical component of operating an assisted living facility. Unlike many other occupancy types, assisted living communities often serve residents with varying levels of mobility and cognitive impairments, making evacuation more complex during an emergency. As a result, evacuation planning is not simply an operational consideration. It is a key factor that influences building design, fire protection features, and overall life safety strategy that may not otherwise be prescribed by code minimum requirements.

Understanding The Phased Evacuation Approach

Residents of assisted living facilities generally require some level of verbal or physical assistance during an evacuation. Because of these population characteristics, a full-building evacuation may not always be the safest or most practical response to an emergency.

To address this challenge, many assisted living facilities utilize a phased evacuation approach that allows occupants to be relocated away from the immediate hazard while remaining within the building. The International Building Code (IBC) supports this strategy through smoke compartmentation requirements for Group I-1 Condition 2 occupancies. These smoke compartments help limit the spread of smoke and provide protected areas that support the movement of residents during an emergency.

Design Considerations for Assisted Living Facilities

A phased evacuation strategy requires more than smoke barriers alone. Fire alarm, notification, and fire protection systems must be designed to support how the building is expected to function during an emergency. Early coordination between the operator, AHJ, architect, code consultant, and design team is essential to ensure evacuation procedures align with the building’s fire protection and life safety code features.

When evacuation planning is considered early in the design process, project teams are better positioned to create solutions that support resident safety while meeting operational goals. Delaying these discussions can result in challenges that affect building layout, system design, and overall project coordination.

How Code Red Consultants Can Help

Code Red Consultants partners with operators, architects, design teams, and authorities having jurisdiction to establish a coordinated approach to fire protection and life safety codes for assisted living facilities and other care-related occupancies. Our team helps align building design, fire protection systems, facility operations, and emergency preparedness around a shared understanding of resident capabilities, staffing and operational procedures, evacuation strategies, and applicable code requirements. By bringing these stakeholders together early in the process, we help identify and resolve potential gaps between how a facility is designed, how it will operate, and how occupants will be protected during an emergency. This integrated approach allows project teams to develop practical, code-compliant solutions that prioritize resident safety while supporting operational needs and overall project goals.

Massachusetts, along with many other states across the United States, will be adopting the 2026 Edition of NFPA 855, Standard for the Installation of Stationary Energy Storage Systems. Under previous editions of this standard, a Hazard Mitigation Analysis (HMA) was required only for electrochemical Energy Storage Systems (ESS), including those utilizing Lithium-ion technology, when the ESS’s maximum stored energy exceeded 600kWh. This threshold has been removed, and as such, an HMA should be provided to the AHJ for any indoor or outdoor ESS installation for which the 2026 edition of NFPA 855 is applicable.

Hazard Mitigation Analysis Requirements

The HMA must evaluate the consequences of the following single failures:

  1. Thermal runaway or mechanical failure of a single ESS unit,
  2. Failure of the energy storage management system or protection system,
  3. Failure of a required and/or critical system (thermal management, communication, Battery Management System) that impacts normal operations.

To obtain approval from the Authority Having Jurisdiction (AHJ), the HMA must show that:

  1. Deflagration hazards are suitably mitigated.
  2. A fire involving an indoor ESS does not spread beyond the ESS room for the minimum duration of its compliant fire resistance rating.
  3. Fire and combustion products do not prevent occupant evacuation.

Key Changes in the 2026 Edition

The major revision to the HMA in the 2026 Edition of NFPA 855 involves the evaluation of the consequences related to a thermal runaway failure, which are dependent on the mitigation strategy put in place through fire and explosion (1) prevention, (2) protection, and (3) policy barriers. Therefore, the 2026 Edition of NFPA 855 now requires reliability and survivability analyses for critical safety component systems, including but not limited to the explosion control and prevention system, smoke/fire detection, and fire suppression. These analyses must demonstrate that fire and explosion hazards are suitably mitigated in the event of a thermal runaway.

How Code Red Consultants Can Help

Code Red Consultants helps owners, developers, designers, utilities, and AHJs navigate the evolving requirements associated with energy storage systems. Our team evaluates applicable code and fire protection requirements, identifies compliance challenges early, and supports practical solutions that align with project goals and regulatory expectations. With technical expertise and experience across a wide range of ESS technologies, we help project teams manage risk and advance projects with confidence.

Fire alarm approvals are often a critical driver of project schedules in New York City. From new construction and renovations to tenant improvement projects, FDNY plan approval and final sign-off are required milestones that can directly impact Temporary Certificates of Occupancy (TCOs), tenant move-ins, and revenue generation. Early engagement with a fire alarm consultant can help project teams understand approval requirements, identify potential risks, and maintain control of key project milestones.

Understanding the Approval Process 

In New York City, fire alarm systems must receive FDNY plan approval before installation and pass a final inspection before occupancy can be granted. Because both milestones directly affect the project schedule, delays in approvals, inspections, or documentation can impact the overall schedule. Common issues in the plan review phase include incomplete submissions, inconsistencies between plans and the riser diagram, failure to meet FDNY requirements or local amendments, and design coordination issues. Even well-designed systems can experience delays when technical requirements and administrative processes are misaligned. Prior to an FDNY inspection, the fire alarm system must be installed and function per the approved plans. Pretesting is an essential part of the process for identifying and resolving defects before inspection, to avoid costly delays.

Why Early Coordination Matters 

Fire alarm permitting in New York City is both a technical and logistical process. Successful project delivery requires coordination among owners, developers, contractors, designers, filing representatives, and FDNY reviewers throughout the project lifecycle. Early third-party plan review, coordinated filings, realistic schedule planning, walkthroughs, and pretesting can help reduce objections, failed inspections, and avoid delaying TCO.

Projects benefit most when permitting, design, installation, and testing efforts are approached as an integrated process rather than a series of independent tasks. This helps teams identify issues before they affect inspections, occupancy milestones, and overall project schedules.

How Code Red Consultants Can Help 

Code Red Consultants partners with owners, developers, contractors, and design teams on fire alarm consulting for projects throughout New York City. Our team helps navigate FDNY requirements from initial filings through final sign-off, providing responsive support and reliable guidance at every stage of the process. Through longstanding experience working with local authorities having jurisdiction, we help teams anticipate potential challenges, streamline coordination, and reduce the risk of approval delays that can affect occupancy and project schedules.

As cities seek to address housing demand and repurpose underutilized office space, office-to-residential conversions are becoming increasingly common. Navigating the landscape of code and jurisdictional requirements for projects involving a change of occupancy can be complex and confusing. Project teams that elect to use a code consultant in the early project planning phases benefit from identifying custom code strategies that meet the project goals and constraints.

Understanding “Change of Occupancy”

Converting from office (Group B Occupancy) to residential (Group R Occupancy) typically results in a higher hazard occupancy classification, as defined in Chapter 34 of the International Building Code (IBC) and International Existing Building Code (IEBC). This shift can trigger upgrades to existing building features, even when not included in the planned project renovation areas. Key systems that are often impacted include means of egress, fire resistance ratings, accessibility, and building performance (i.e., exterior wall energy efficiency). These changes can significantly impact scope, cost, and schedule, putting project viability at risk.

Identifying Code Challenges Early and Navigating a Compliance Path

Full compliance with new construction requirements is often impractical due to existing conditions, cost constraints, and project limitations. Identifying these challenges early allows teams to evaluate alternative compliance strategies, variances, or design approaches that may provide a safe and feasible path forward. It also provides time to coordinate with authorities having jurisdiction before these issues affect key project milestones.

Financial Incentives for Office-To-Residential Conversions

Many jurisdictions are encouraging adaptive reuse to repurpose outdated buildings and increase housing supply. For example:

• Los Angeles adopted the Adaptive Reuse Ordinance 2.0, reducing zoning barriers and allowing the use of the California Historic Building Code for qualifying projects.
• Washington, DC has an “Office to Anything Program” supporting repositioning of obsolete office space.
• Montgomery County, MD, and Alexandria, VA have introduced zoning flexibility and streamlined approvals.
• Boston offers tax and zoning incentives, along with early interagency coordination during design.

While these programs can improve project feasibility, they do not reduce the underlying technical requirements. Office-to-residential conversions are still treated as a change to a higher hazard occupancy, which can trigger provisions related to egress, height, area, and accessibility. Historic and existing building conditions may require additional coordination and alternative compliance approaches to address code requirements.

How Code Red Consultants Can Help

Code Red Consultants supports office-to-residential conversions by bringing a holistic perspective to renovation and change-of-occupancy projects. We work with owners, developers, designers, and authorities having jurisdiction to evaluate requirements, identify constraints early, and navigate compliance within the context of existing buildings. Our experience across project types and jurisdictions helps teams align design decisions with real-world conditions, regulatory expectations, and project goals.

Decisions made during campus master planning and early conceptual design can establish code constraints that become difficult or costly to address later. For architects working on institutional campuses such as healthcare and higher education, early site planning decisions related to building separation, massing, connections, and fire department access can directly influence allowable height and area, construction type, façade design, and interior planning flexibility. Engaging a code consultant early in this process helps project teams understand these constraints before they are embedded in the site and building concept. 

Code Red Consultants has extensive experience supporting higher education and health care campuses where incremental growth, phased development, and long‑range master planning create unique code challenges that differ from single building projects. 

ADDITION VS. SEPARATE BUILDING: EARLY TRADEOFFS
A key early question in campus planning is whether a new structure should be designed as an addition to an existing building or as a separate building connected by exterior circulation, bridges, or tunnels. From a code perspective, this distinction carries significant implications. 

When treated as an addition, buildings may be analyzed as a single structure, allowing project teams to leverage greater allowable height and area, broader construction type options, and fewer exterior wall limitations. This often supports more open interior environments such as multistory lobbies, commons, and shared circulation. However, these advantages require careful evaluation of occupancies, smoke compartments, and fire protection strategies across the combined building. 

Designing a structure as a separate building shifts the analysis toward fire separation distance, exterior wall ratings, and allowable openings. Accurately identifying lot and property lines is critical, particularly on campuses under single ownership, where adjacent properties may be treated differently from typical urban parcels. Early assumptions that later prove incorrect can limit façade design or future expansion. 

ADDITIONAL CONSIDERATIONS FOR SEPARATE BUILDINGS
Where separate‑building strategies are preferred, firewall separations may be used to preserve independent height and area allowances. The 2021 International Building Code introduced additional flexibility by allowing the omission of fire walls between buildings of the same construction type under specific conditions, such as recorded easement agreements. While this can benefit campus planning, it also introduces legal and long‑term coordination considerations that should be evaluated early. 

Separate buildings may also limit interior openness and introduce constraints on exterior walls that influence architectural expression and spatial planning. 

FIRE ACCESS AND BUILDING CONNECTIONS
Fire department access planning is another early consideration that can affect building placement and massing on a site. Apparatus access roads, turning radii, staging areas, and hose reach often influence setbacks and site circulation and may trigger late redesigns if not addressed during master planning. 

Bridges and tunnel connections between campus buildings can further affect perceived building separation, fire ratings, and massing. These elements also play a significant role in campus aesthetics and circulation and should be evaluated early to align life safety requirements with design intent. 

HOW CODE RED CONSULTANTS CAN HELP
Code Red Consultants works with architects and institutions during campus master planning and early design to evaluate building relationships, separation strategies, fire department access, and connection approaches. Our experience across higher education and healthcare campuses helps teams identify code implications early, supporting informed site planning decisions that preserve both design flexibility and long-term campus goals. 

Effective May 5, 2026, health care and ambulatory health care facilities now have a clear, code‑recognized pathway to install weapons detection systems within the means of egress. NFPA has issued an emergency Tentative Interim Amendment (TIA) to NFPA 101 that directly addresses these systems in Health Care and Ambulatory Health Care occupancies, bringing clarity to requirements that were previously driven largely by AHJ mandates rather than explicit code language.

This emergency amendment reflects the growing tension between evolving security expectations and life‑safety requirements. For architects and owners, the TIA helps align security planning with defined egress and corridor width criteria, reducing uncertainty during design, permitting, and review.

WHAT THE TIA CHANGES
The amendment introduces new provisions in NFPA 101 Chapters 18 through 21 governing weapons detection systems located in the means of egress for Health Care and Ambulatory Health Care occupancies.

The TIA distinguishes between existing buildings and new construction. Existing occupancies may utilize reduced clear widths at detection system locations, recognizing the challenges of retrofitting security equipment into constrained corridors. New construction must provide a minimum of 41.5 inches of clear width at the detection system, reinforcing the importance of accounting for these elements early in design.

The amendment is retroactively applicable to the 2012, 2024, and 2027 editions of NFPA 101. Because CMS and accreditation agencies continue to enforce the 2012 edition nationwide, CMS‑licensed facilities may immediately apply this TIA without waiting for a future code adoption cycle.

WHY THIS MATTERS FOR PROJECT TEAMS
Prior to this amendment, project teams were often required to integrate weapons detection systems into egress paths without clear life‑safety guidance, creating potential conflicts with corridor width, egress capacity, and accessibility requirements.

By establishing prescriptive criteria, the TIA allows architects and owners to evaluate weapons detection systems earlier in the design process, reducing the risk of late redesigns, variance requests, or approval delays, particularly in renovations and phased improvement projects.

HOW CODE RED CONSULTANTS CAN HELP
Code Red Consultants supports architects, owners, and health care providers in interpreting and applying this new TIA. We assist with early design coordination, evaluation of egress and width impacts, and navigation of AHJ, CMS, and accreditation requirements to help project teams incorporate security measures while maintaining life‑safety compliance. If you have any questions about the practical application of these systems in a health care environment, please do not hesitate to reach out.

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.

When designing or reviewing assisted living facilities, accurately determining the occupancy classification is critical. How residents can safely leave the building in an emergency determines key fire protection and life safety code requirements, from exits to fire protection systems. Misjudging evacuation ability can lead to misclassification and the omission of essential safety features, potentially putting residents at risk. In part 2 of this blog series, we explore how occupancy classifications influence compliance and project design for assisted living facilities.​ 

​ Occupancy Classifications in Assisted Living: What You Need to Know
Assisted living facilities differ from standard residential buildings. While residents receive support with daily activities, the level of care does not reach that of a nursing home. Correctly identifying the occupancy classification is essential for designing and operating these facilities safely.

​How Assisted Living is Classified in the International Building Code (IBC)
​Under the IBC, most assisted living facilities fall under Group I-1 (Institutional) for buildings housing more than 16 residents who receive 24-hour custodial care in a supervised environment. The Group I-1 classification is broken down further into two conditions: 

  • ​Condition 1: Residents can self-evacuate independently. 
  • ​Condition 2: Residents need limited verbal or physical assistance to evacuate. 

​Condition 2 comes with more stringent fire protection and life safety code requirements and is typically the most appropriate classification for both assisted living and memory care units. Occupants within these units generally require limited verbal or physical assistance to evacuate the building, which has now been defined explicitly in the 2024 IBC:

​Describes persons who, because of age, physical limitations, cognitive limitations, treatment or chemical dependency, may not independently recognize, respond or evacuate without limited verbal or physical assistance during an emergency situation. Limited verbal assistance includes prompting, giving and repeating instructions. Limited physical assistance includes assistance with transfers to walking aids or mobility devices, as well as assistance with egress (IBC 202).   

​When proposing Condition 1 for assisted living units, operators must thoroughly assess residents’ evacuation capabilities. Some jurisdictions may also require more restrictive occupancy classifications through licensure or local amendments. 

​Key Takeaway: Engage Code Consultants Early
Selecting the correct occupancy classification is crucial to ensure proper life-safety features, avoid expensive redesigns, and prevent conflicts with authorities. Engage code consultants like Code Red Consultants early in your project for guidance and a smoother, compliant process.

​Stay tuned for our final post in the series, where we will discuss key passive fire protection features to align with typical evacuation protocols for this occupancy type. Want to check out the first post in the series? Click here to read Part 1.