Insights Category: Technical Information

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 and life safety 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 and life safety 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. 

 

Effectively addressing the genuine fire hazards associated with large wood building construction is a critical part of project planning. For jurisdictions adopting NFPA 241 (2019 and 2022 editions), a completed fire exposure analysis should be provided along with the balance of the project’s Construction Documents.

Specifically, NFPA 241 Section 12.3 (2019 edition) and NFPA 241 Sections 12.3 and 13.3 (2022 edition) states: “Before construction begins, a study shall be conducted to ensure that the installation of passive and active fire protection systems, combined with the separation provided between other structures on the same or adjacent lots, are adequate to allow safe egress and to prevent fire spread to the exposed structures.”

Per the 2022 edition of NFPA 241, a large wood-frame structure is defined as a wood structure that meets one of the following criteria:
• Up to three stories and greater than 150,000 sq ft (13,935 m2) aggregate total floor area
• Over three stories, or over 40 ft (12.2 m) above the lowest level of fire department vehicular access, and greater than 50,000 sq ft (4645.2 m2) aggregate total floor area.

The fire exposure analysis should not just be viewed just as a box to check to secure a permit; rather, it is an essential tool intended to mitigate real construction fire risks, such as rapid fire spread, compromised egress routes, and greater exposure hazards for adjacent structures. By thoroughly evaluating fire risks unique to large wood-frame projects and implementing tailored strategies, project teams and the responding fire departments can better safeguard construction sites and protect the surrounding community.

The expectation of NFPA 241 is that this fire exposure analysis, along with a project-specific Fire Prevention Program, is submitted to the Authority Having Jurisdiction at the time of permit submission.

Are you doing work with wood-frame construction and have questions about how this requirement may impact your project? Contact info@crcfire.com for additional information.

780 CMR, The Massachusetts State Building Code 10th edition, is an amended version of the 2021 Edition of the International Building Code (IBC) that will go into effect on July 1, 2025.  With the promulgation of the 10th edition building code, Massachusetts will join other jurisdictions that have modified their building and fire codes to enable more flexible laboratory compliance strategies in new and existing buildings.

Not without similarities to California Building Code (CBC) Section 453: Group L, and New York City Fire Code Section FC 5006: Non-Production Chemical Laboratories, Massachusetts introduces its own variation of laboratory suite compliance through the amendment of IBC Section 428.

The MA amendments could allow owners and developers to improve the marketability of their research and development laboratory buildings by permitting quantities of flammable and combustible liquids more akin to those permitted by NFPA 45 than a control area approach permitted by IBC Section 414.

For example, laboratories located on the 6th and 7th levels above grade could see Class I Flammable Liquid quantities increase substantially, provided the hazard has been adequately mitigated by applying passive and active fire protection strategies.

With this new code change, we are often asked how existing laboratory spaces can employ the new laboratory suite provisions and benefit from the increased chemical quantities enabled under the 10th Edition of 780 CMR. While this process is nuanced, there are fundamentally three significant aspects to the implementation of laboratory suites in an existing building:

  1. Verification that the use of laboratory suites is appropriate for the specific application. For example, process rooms and chemical storage rooms are generally not permitted to be classified as laboratory suites because they do not constitute “laboratory work areas”.
  2. Confirmation that the building’s infrastructure is appropriate, including fire-resistance-rated separations, and supporting systems (e.g. mechanical, electrical, fire protection, etc.).
  3. Obtaining proper permits and approvals associated with the new laboratory suite code approach and any new work required to implement a laboratory suite approach fully. Even if no renovation work is being performed to convert to a laboratory suite, minimally, an existing building Investigation and Evaluation Report (aka “Chapter 34 Report”) should be submitted to the Authority Having Jurisdiction to document the code approach.

In 2022, Edwards Fire Safety announced that it would discontinue support for the Edwards EST3 Fire Alarm Control Unit (FACU) due to challenges in sourcing electronic components. As of December 31, 2023, Edwards has stopped accepting new orders for UL/ULC-listed EST3 systems. While they intend to support existing installations with replacement parts as long as possible, the dwindling supply and eventual end of support are becoming increasingly evident.

The EST4, launched in 2019, offers backward compatibility with many Edwards Signature Series components, wiring, and control unit back boxes. For many facilities, the shift from an existing EST3 system to the newer EST4 system could seem straightforward; however, the transition comes with challenges that necessitate significant pre-planning to minimize impairments, particularly in occupied buildings.

Challenges in Transitioning from EST3 to EST4:
1. Component Compatibility: Many buildings with existing EST3 systems still include some legacy System Sensor devices and modules; the EST3 can interface with these legacy components via the 3-AADC1 loop card. The EST4 system does not support or provide an alternative to this loop card and, therefore, does not support such devices, which can complicate the upgrade process.
2. Network Integration: The EST4 and EST3 systems cannot share network communications directly, making multi-node system upgrades complex and necessitating a carefully managed transition plan to avoid extended operational downtime.

Strategic Approach for a Smooth Transition:
A comprehensive, building-specific migration plan ensures a seamless transition from EST3 to EST4, especially in active buildings. Here’s a structured approach:
1. Prioritize Upgrades: Start by identifying and prioritizing the critical steps in the migration process. Address high-priority tasks first to ensure essential functions are upgraded promptly.
2. Phased Installation: It is considered a phased migration in facilities where continuous operation is essential, such as hospitals or systems with multiple nodes. It is best to install the EST4 system alongside the existing EST3 system, allowing for a gradual transition. This phased approach enables circuit-by-circuit migration, reducing the impact on day-to-day operations.
3. Minimize Downtime: Design the upgrade process to allow EST3 and EST4 systems to operate concurrently at the various stages of migration. This approach maximizes flexibility and minimizes operational disruption during the transition.

Why Partner with Us?
Our team has extensive experience managing such upgrades, having successfully completed similar projects across the greater Boston area. We specialize in designing customized solutions to ensure that transitions are as smooth and efficient as possible.

Whether you’re planning a new project or need assistance with an ongoing upgrade, we’re here to help navigate the complexities of the EST3 to EST4 migration with expertise and precision.

Recently, there has been an increase in the construction of high-rise buildings designed for office and laboratory use. In new high-rise buildings in Massachusetts, 780 CMR requires all stairwells/elevator hoistways built over 70 feet tall to be equipped with a smoke control system. The laboratory environment in these high-rise buildings typically dictates specific ventilation requirements, which uniquely impact the required smoke control systems.

The required smoke control systems (usually stairwell and elevator pressurization) operate by providing supply air within the stair/elevator shaft to pressurize the shaft and keep smoke out while allowing the doors to open without undue force. These smoke control systems must achieve this performance on both Normal and Emergency (generator) building power.

There are two variables that contribute to the pressure readings in the stair/elevator shafts: 1, the amount of supply air provided inside the shaft, and 2, the airflow conditions in the building. In laboratory environments, the building airflow can vary significantly depending on whether the building is on normal or Emergency power. Typically, both supply and exhaust air run, creating a balanced/neutral environment. Regardless, under emergency building power, it is typical for the building supply air to shut down and only the building exhaust air to continue running, resulting in a negative airflow condition and potentially drastically changing the pressure and door force values.

Both the smoke control and lab air systems must function properly to ensure the safety of building occupants, requiring careful coordination and commissioning to ensure the systems work properly in all scenarios.

Laboratory environments typically need a minimum exhaust flow setpoint to meet the applicable ventilation requirements. To minimize negative impacts on the differential pressure and door opening force readings on Emergency power, the building exhaust air could be programmed through the Building Management System (BMS) to ramp down to this minimum exhaust flow setpoint (as established by the laboratory ventilation system design) on Emergency building power, rather than continuing to run at the Normal building power flow setpoint. This typically results in a building environment compatible with the required smoke control systems, as the building is not too negatively pressurized.

Alternatively, the HVAC systems could be programmed to shut down the supply air any time the smoke control system is active. This makes the normal power airflow condition and the emergency power condition match, allowing the stairs to be balanced, knowing they will meet the specs in both power conditions. Under this approach, care must be exercised to ensure that maximum door-opening forces have not exceeded due to negative pressure conditions.

In summary, stair or elevator pressurization systems within high-rise office/laboratory occupancies can introduce complications when commissioning the smoke control systems. By reviewing the potential issues during design and startup, the system can be adjusted appropriately to avoid problems and delays during final Commissioning and turnover. If you have questions regarding how these requirements apply to your project, please contact us at info@crcfire.com.

With the adoption of 527 CMR 1.00, the Massachusetts Comprehensive Fire Code, in 2022, the 2022 Edition of NFPA 241 is now incorporated by reference in lieu of the previously referenced 2013 Edition. This updated edition of NFPA 241 includes two new chapters that provide rules and regulations specific to construction operations in Tall Mass Timber Wood Structures (Chapter 12) and Large Wood Frame Structures (Chapter 13). Both new chapters reference the need to conduct a study that is defined as a fire exposure analysis prior to the commencement of construction.

Sections 12.3 and 13.3 of NFPA 241 outline a fire exposure analysis, “Before construction begins, a study shall be conducted to ensure that the installation of passive and active fire protection systems, combined with the separation provided between other structures on the same or adjacent lots, are adequate to allow safe egress and to prevent fire spread to the exposed structures.”

Per NFPA 241, Section 13.1.2, and the Boston Fire Department, a large wood frame structure is defined as a wood structure that meets one of the following:

  • Up to three stories and greater than 13,935 m2 (150,000 ft2) aggregate total floor area
  • Over three stories, or over 12.2 m (40 ft) above the lowest level of fire department vehicular access, and greater than 4645.2 m2 (50,000 ft2) aggregate total floor area

Specifically, the Boston Fire Department has announced the expectation of a fire exposure analysis to be submitted along with an NFPA 241 Fire Prevention Program to their email alias for any new construction projects that meet the definition of a large wood frame building (bfd241@boston.gov).

The BFD Fire Exposure Analysis Guidelines are included via the following link: https://www.boston.gov/sites/default/files/file/2023/09/Fire%20Exposure%20Analysis_0.pdf

Are you doing work in Boston or other communities in the Commonwealth of Massachusetts and have questions about how this requirement may impact your project? Contact info@crcfire.com for additional information.

When considering doors that form part of an egress route, such as those in a common area or corridor, there is a common misconception that they can be locked as long as they automatically unlock upon activation of the building’s fire alarm system. However, this belief is incorrect as there are no such provisions within the 2021 IBC that permit egress doors to be locked and only released during a fire alarm event.

Egress doors are required to be readily available and operable from the egress side without requiring a key or special knowledge (2021 IBC Section 1010.2). This requirement ensures that in non-fire emergencies (i.e., natural disasters) requiring building evacuation, occupants can readily exit without delays caused by locked doors. Any listed exceptions to the above can be found in 2021 IBC Section 1010.2.

Understanding and complying with this requirement is crucial to ensuring the safe and swift evacuation of building occupants during emergencies.

Fire pumps are an important piece of life safety equipment, used to supplement water-based fire suppression systems where adequate water pressure is not available. They are often necessary to meet NFPA design requirements. This blog addresses the importance of fire pumps and how to determine if a fire pump is needed.

Does my building need a fire pump?
It depends. During the planning and design phases of a construction project, the fire protection designers should address this question. As a fire suppression system is designed, its water demands will be compared to the local municipality’s available water supply. A fire pump will be required if the available water supply cannot meet the system pressure requirements.

How are fire pumps designed and tested?
NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, addresses the design, installation, and testing of Fire Pumps. Chapter 14 “Acceptance testing, performance, and maintenance,” requires that fire pumps must be formally commissioned and tested in accordance with the pump manufacturer prior to formal acceptance of the fire suppression system and prior to building occupancy.

This test is critical in confirming that the fire pump operates as intended according to the manufacturer’s performance curve and in line with the design specifications. Additionally, it provides transparency that the performance meets the approval of the manufacturer, installing contractor, building owner, engineer of record, and the Authority Having Jurisdiction (AHJ). Once accepted, fire pumps are required to be regularly tested in accordance with Chapter 8 to make sure they continue to perform as intended. Depending on the type of fire pump (i.e. electric driven or diesel driven), specific testing criteria may vary..

Why are fire pumps important in high-rise applications?
City water supplies often do not have adequate pressure to supply water to tall buildings, and a pump is frequently required.  The pump must be capable of providing water to the highest portions of the building to serve both the sprinkler systems and the standpipes for firefighting operations (both of which could be operating simultaneously).   High-rise system design requires careful consideration of pump, piping, flows, and pressures to ensure proper operation of systems in all areas and all levels of the building.

To learn more about fire pumps or for assistance with fire protection system design, email us at info@crcfire.com.

With the increasing number of laboratory buildings of varying sizes, ages, and conditions, the pending 10th Edition of the Massachusetts State Building Code (780 CMR) continues to generate industry excitement regarding the Laboratory Suite approach. This new chemical compartmentalization approach will allow for more significant quantities of flammable and combustible liquids within R&D laboratories than the Control Area approach recognized by the currently adopted 9th edition of 780 CMR.

In a previous post, we introduced the concept of Lab Suites and the associated implications for new construction (link to the article is provided at the end of this post). What about using lab suites in existing laboratory buildings that currently employ a Control Area approach?

To implement a Laboratory Suite approach in an existing building, several critical protection features are anticipated to be required for prescriptive compliance and may necessitate upgrades to existing building infrastructure. Such features include, but are not limited to:

  • Rated interior partitions
  • Rated floor assemblies with supporting construction
  • Automatic sprinkler protection
  • Laboratory ventilation
  • Standby power

Consideration should also be given to the following items when evaluating the feasibility of using a Laboratory Suite approach within an existing building.

(a) A Lab Suite approach can be partially or wholly implemented on a floor(s) in existing and new buildings. Partial implementation may lessen any infrastructure upgrades necessary within existing structures.

(b) Fitout projects planned to be permitted under the 10th edition can prescriptively utilize the Lab Suite approach within base buildings that have been (or are anticipated to be) permitted under a previous edition of the MA Building Code. Before this occurs, the building infrastructure will need to be evaluated to determine if the features required to support a Laboratory Suite are provided or if the building can support the necessary features.

(c) Implementation of Laboratory Suites before the adoption of the 10th Edition of 780 CMR would necessitate local AHJ approval or a state variance.

Previous Blog Post Link:

https://coderedev.wpenginepowered.com/insights/10th-edition-updates-laboratory-suites/