Large wood-frame and mass timber projects present significant fire exposure challenges during construction, particularly while combustible construction is exposed and permanent fire protection systems are not yet operational.

For projects requiring an FEA, the analysis is typically developed as part of the permitting process, but treating it solely as a permit document misses much of its value. The conditions that drive construction-phase fire risk change as a project progresses. An effective FEA provides a framework for understanding those changes and determining whether the assumptions and mitigation measures supporting the analysis remain appropriate.

Understanding the Assumptions Behind the Analysis

An FEA evaluates whether a project’s fire protection features, site conditions, and separation distances are sufficient to support egress and limit fire spread during construction. Its conclusions are based on project-specific factors such as fire department access, emergency response capabilities, construction sequencing, temporary and permanent fire protection systems, material storage, site security, and the proximity of exposed properties.

Since these conditions can change throughout construction, project teams should understand the key assumptions supporting the analysis and recognize when those assumptions may no longer apply. Delays to fire protection system installation, access restrictions, schedule changes, or changes to nearby occupancies can significantly alter a project’s risk profile. Rather than treating the FEA as a static report, project teams should recognize when changing conditions warrant reevaluating the strategies used to manage fire risk.

Connecting Analysis to Action

The value of an FEA comes from the actions it informs throughout construction. Effective analyses identify practical measures to help prevent fire occurrence, limit fire growth, and protect exposed properties.

  • Effective mitigation strategies generally seek to:
  • Prevent fire occurrence through measures such as housekeeping, hot work controls, site security and management of temporary systems.
  • Limit fire growth through early water supply and standpipe installation, temporary or permanent fire protection systems, detection and notification, and construction sequencing.
  • Protect exposed properties through appropriate separation, temporary protection, emergency planning, construction sequencing and fire department coordination.

The characteristics, proximity, and vulnerability of adjacent structures can significantly influence both the likelihood and consequences of fire spread. Understanding those exposures can inform temporary protection measures, construction sequencing, emergency planning, and coordination with responding fire departments.

Keeping the Right Stakeholders Connected

An FEA should not be developed in isolation. Owners, contractors, design professionals, emergency responders, insurers, and AHJs may see different risks and bring different information to the analysis. Their involvement can help establish realistic assumptions, appropriate mitigation measures, and clear expectations for how those measures will be implemented.

That involvement should not necessarily ends. On complex projects, changes to access, sequencing, protection systems, neighboring occupancies, or emergency response considerations may require renewed coordination to determine whether the original strategies remain appropriate.

What Makes an FEA Actionable?

The most valuable Fire Exposure Analyses answer a simple question: What must happen during construction for the conclusions of the analysis to remain valid?

An actionable FEA should clearly identify:

  • Critical assumptions supporting the analysis
  • Mitigation measures necessary to manage risk
  • Parties responsible for implementing those measures
  • Construction milestones that may affect the fire risk profile
  • Conditions that may warrant reevaluation

How Code Red Consultants Can Help

Code Red Consultants works with project teams to develop Fire Exposure Analyses and translate their findings into practical construction-phase fire safety strategies. Our work includes evaluating fire exposure conditions, establishing critical assumptions and mitigation measures, and coordinating with project stakeholders as conditions evolve throughout construction.

System behavior, site conditions, and applicable requirements may vary based on the project, surrounding exposures, and Authority Having Jurisdiction. Project teams should confirm applicability for their specific scope of work.

Historic renovations can place two legitimate project goals in tension: protecting significant architectural features and meeting modern fire protection expectations. When a conventional sprinkler layout would require penetrations or alterations to historic ceilings, domes, decorative finishes, or other character-defining elements, performance-based fire engineering can help a project team evaluate whether an alternative approach merits consideration.

BALANCING PRESERVATION AND FIRE SAFETY

Automatic sprinkler systems are a central component of building fire safety. In a historic interior, however, the work needed to install a traditional NFPA 13 layout may affect the very elements the renovation is intended to preserve. The challenge is to determine whether the project can maintain an appropriate level of fire protection and life safety while remaining aligned with code intent within the building-specific constraints.

A performance-based process provides a structured way to examine that question. The process defines fire safety objectives, evaluates a proposed strategy against established criteria, and identifies where supplemental mitigation may be warranted. The resulting analysis gives the design team and the Authority Having Jurisdiction (AHJ) objective technical information for an informed discussion. It does not predetermine acceptance or guarantee approval.

ESTABLISHING THE CODE PATH

Historic building renovations may trigger modern sprinkler requirements even when installation is impractical or could adversely affect significant features. In Massachusetts, project teams may need to consider Massachusetts General Laws Chapter 148, Section 26G, together with the historic-building provisions of the Massachusetts Existing Building Code. MEBC Section 1203.12 provides a basis for alternative approaches to compliance for historic buildings, subject to AHJ review and approval.

The availability of a code pathway does not establish that a particular alternative will be acceptable. Each proposal must respond to the building configuration, renovation scope, hazards, occupancy, preservation goals, and applicable jurisdictional requirements. Early engagement with the AHJ is therefore an important part of the technical process.

USING FIRE MODELING TO EVALUATE ALTERNATIVES

A performance-based sprinkler analysis generally compares a baseline code-compliant configuration with a proposed alternative. Computational Fluid Dynamics (CFD) modeling and sprinkler activation analyses can be used to assess system and fire behavior under defined scenarios. The evaluation is organized around agreed-upon performance objectives and acceptance criteria so the team can compare results and identify whether additional safeguards should be considered.

A clear analysis should document the applicable baseline, proposed configuration, fire scenarios, assumptions, methods, results, limitations, and potential mitigation measures. This transparency helps the design team and AHJ understand both what the analysis demonstrates and what remains outside its scope.

COMMON CHALLENGES

Fire modeling is sometimes misunderstood as a substitute for required protection. In practice, modeling is an evaluation tool. Its value depends on the quality of the inputs, the appropriateness of the scenarios, clearly defined criteria, and transparent communication of assumptions and limitations.

Timing can also create challenges. If preservation constraints, sprinkler routing, ceiling access, detection, compartmentation, means of egress, and potential mitigation measures are considered independently or late in design, the team may lose opportunities for a more coordinated solution. A strategy appropriate for one historic building also cannot be transferred automatically to another. Geometry, construction, fuel packages, occupancy, existing systems, and significant architectural elements can materially affect the analysis.

PLANNING FOR A COORDINATED APPROACH

The strongest process is collaborative from the outset. The owner can define preservation priorities and operational needs. The architect can identify character-defining features and design constraints. The fire protection engineer can establish the analysis methodology and evaluate system performance. The AHJ can clarify review expectations, required documentation, and the basis for acceptance.

This integrated perspective supports creative and constructible solutions that combine engineering rigor with real-world application. It also supports risk-informed decision-making by making tradeoffs visible across life safety, approvals, preservation, schedule, and cost rather than treating any one consideration in isolation.

Early discussions should address:

  • The significant features that must be preserved and the areas where design flexibility remains.
  • The applicable prescriptive baseline and the specific alternative under consideration.
  • The performance objectives, acceptance criteria, fire scenarios, and analysis assumptions.
  • Potential interfaces among sprinklers, detection, compartmentation, egress, and operational controls.
  • Possible supplemental mitigation and the documentation expected by the AHJ.

KEY TAKEAWAYS AND HOW CODE RED CONSULTANTS CAN HELP

Historic preservation and modern fire protection requirements may conflict, but the conflict should be evaluated rather than assumed to be irreconcilable. Performance-based fire engineering can provide objective data to support consideration of project-specific sprinkler alternatives while maintaining focus on fire protection and life safety as well as code intent. Success depends on transparent analysis, early AHJ engagement, and close coordination among the owner, architect, and fire protection engineer. Code Red Consultants supports this process by helping project teams define performance objectives, evaluate complex fire protection conditions, and develop practical, risk-informed strategies grounded in engineering rigor and real-world application.

Construction and renovation projects in healthcare facilities often require temporary impairments to fire protection and life safety systems. While Interim Life Safety Measures (ILSMs) provide an important framework for managing many of these conditions, some impairments introduce risks that extend beyond what a standard ILSM process is designed to address.

This is particularly important in hospitals, where the risk profile is elevated because many patients cannot evacuate independently during a fire. Rather than leaving the building, patients often must remain in place or be relocated by hospital personnel to protected areas within the facility. Fire alarm systems, sprinkler systems, compartmentation, egress, and emergency response procedures therefore function as an interdependent life safety strategy; when any one of these elements is significantly impaired, it can directly affect the staff’s ability to protect and safely relocate patients.

UNDERSTANDING THE RISK

Certain impairment conditions often warrant additional evaluation, including:

  • Fire alarm impairments lasting more than eight hours (NFPA 72).
  • Sprinkler impairments lasting more than ten hours (NFPA 25).
  • Changes to fire department access or emergency response procedures.
  • Significant impacts to egress routes (NFPA 101).
  • Disruptions to smoke or fire compartmentation relied upon by a hospital’s emergency plan (NFPA 101).

In these situations, the challenge is understanding how the impairment affects the facility’s overall life safety strategy, particularly in buildings where occupants may not be capable of self-evacuation.

COMMON CHALLENGES DURING CONSTRUCTION

A common mistake when evaluating an impairment is treating it as an isolated issue rather than assessing its impact on building operations, emergency procedures, and other fire protection features.

Additional challenges can arise when temporary conditions trigger permitting or approval requirements. For example, temporary modifications to elevator recall devices may require coordination with both an elevator official and the fire department depending on the jurisdiction. More jurisdictions are also requiring impairment planning as part of NFPA 241 construction fire safety programs, which are required by both the International Building Code and NFPA 101, the Life Safety Code. Early coordination with facility staff, contractors, designers, and Authorities Having Jurisdiction (AHJs) can help identify these requirements before they impact project schedules.

PLANNING FOR SAFE, CONSTRUCTIBLE SOLUTIONS

Effective impairment planning balances public safety, hospital operations, construction activities, and regulatory requirements. This often requires evaluating the affected systems, duration of the impairment, impacted occupants, temporary mitigation measures, construction sequencing, and approval requirements.
The most successful approaches are both technically sound and practical to implement. By understanding how fire protection and life safety systems interact, project teams can develop solutions that protect occupants while remaining constructible and manageable in active healthcare environments. This reflects the importance of public safety first and engineering solutions grounded in real-world application.

HOW CODE RED CONSULTANTS CAN HELP

Code Red Consultants helps healthcare owners, facility teams, contractors, and AHJs evaluate complex impairment scenarios and develop project-specific mitigation strategies. Drawing on experience with healthcare facilities, fire protection systems, and regulatory approvals, our team helps clients understand risk, navigate jurisdictional requirements, and develop practical solutions that support both life safety objectives and project delivery goals.

Impairment requirements, mitigation measures, and approval processes may vary by project and jurisdiction. Project teams should confirm applicable requirements with the appropriate Authority Having Jurisdiction.

Los Angeles continues to see interest in converting underutilized office buildings into residential housing. While recent adaptive reuse initiatives have reduced zoning barriers, project teams have still faced a recurring question: how will building and fire code requirements be applied when an office building changes occupancy to residential?

To address that uncertainty, the Los Angeles Department of Building and Safety (LADBS) issued Information Bulletin IB-BC-2026-164, Change of Occupancy from Office to Residential, on September 14, 2026. The bulletin does not create new code requirements. Instead, it clarifies how LADBS and the Los Angeles Fire Department (LAFD) intend to apply existing provisions of the California Existing Building Code (CEBC) and California Building Code (CBC) to office-to-residential conversion projects.

Choosing a Compliance Path Early

One of the most significant clarifications in the bulletin is the requirement for project teams to identify a compliance methodology early in the permitting process. Design professionals must select either the Prescriptive Compliance Method under CEBC Section 506 or the Work Area Compliance Method under CEBC Chapter 10 and document that approach in the permit submission.

Because a conversion from office to residential is treated as a change to a higher-hazard occupancy, the selected compliance method can have a substantial impact on project scope. Depending on the approach, required upgrades may extend beyond the immediate work area and affect other portions of the building. While the Work Area Compliance Method may provide additional flexibility for some existing buildings, both approaches require careful evaluation of fire protection, means of egress, accessibility, and structural provisions.

Understanding these implications early can help owners and design teams make informed decisions regarding cost, schedule, and feasibility while reducing the likelihood of unexpected requirements later in the approval process.

High-Rise Fire Protection Requirements Remain a Key Consideration

The bulletin also clarifies several important high-rise requirements that continue to apply when converting office buildings to residential occupancy. Buildings exceeding 120 feet above the lowest level of fire department vehicle access are generally expected to provide at least one fire service access elevator meeting CBC Section 3007 requirements, subject to approved modifications by LADBS and LAFD. Existing passenger elevators are not automatically considered compliant fire service access elevators and may require significant evaluation.

Similarly, converted residential high-rises must comply with applicable requirements for automatic sprinkler protection, fire alarm systems, smoke control, standpipes, fire pumps, emergency power, emergency responder radio coverage, and fire command centers where required by the code. The bulletin also outlines circumstances under which modifications to smokeproof enclosure requirements may be considered for existing buildings.

These provisions demonstrate that office-to-residential conversions often involve much more than architectural modifications. Successful projects require coordination between multiple disciplines to evaluate how existing building systems align with current residential occupancy requirements.

Reducing Uncertainty for Adaptive Reuse Projects

While office-to-residential conversions remain complex, the bulletin provides valuable insight into several topics that have generated uncertainty on recent projects. LADBS confirms that exterior wall ratings generally do not increase because of the conversion, existing non-rated openings may often remain, and buildings without an existing emergency helicopter landing facility are not required to add one solely because of the occupancy change. The bulletin also establishes a documented path for certain smokeproof enclosure alternatives and clarifies expectations related to fire service access elevators.

At the same time, the bulletin reinforces that no guidance document can replace a project-specific code evaluation. Existing building conditions, selected compliance methods, planned renovations, building height, and system capabilities can all influence the feasibility of a proposed conversion. Project teams should view the bulletin as a tool for navigating complexity with greater clarity rather than a substitute for a comprehensive building analysis. This approach supports decisions that balance compliance, constructability, project goals, and public safety.

How Code Red Consultants Can Help

Office-to-residential conversions require project teams to evaluate existing building conditions, understand changing occupancy requirements, and coordinate compliance strategies across multiple disciplines. As adaptive reuse activity continues to grow, early code analysis can help identify potential challenges before they affect project schedules, budgets, or approvals.

Code Red Consultants works with owners, developers, architects, contractors, and authorities having jurisdiction to evaluate existing buildings, navigate complex code requirements, and support adaptive reuse projects from planning through permitting. Drawing on experience across codes, jurisdictions, project types, and stakeholder perspectives, our team helps clients make confident, informed decisions while developing practical compliance strategies aligned with code intent and project objectives.

Code requirements, interpretations, and enforcement practices may vary by project, building condition, and authority having jurisdiction. Project teams should confirm applicability based on their specific scope and location.

Throughout this College Fire Safety Month series, we have emphasized the importance of taking a campus-wide approach to safety, risk management, and emergency preparedness. Renovation and adaptive reuse projects demonstrate why that broader perspective matters.

Unlike new construction, renovation projects must account for existing conditions, previous approvals, aging infrastructure, and changing building uses. Approved occupancies may not reflect current or proposed operations, existing protection systems may not support planned renovations, and undocumented conditions may not be discovered until design or construction is underway.

Proposed changes may also introduce new occupant, egress, accessibility, emergency communication, or operational considerations. At the same time, some or all of the building may need to remain occupied during construction. Because of these realities, renovation projects often require more than a code review of the renovated area. Existing conditions, system capabilities, construction phasing, campus standards, and long-term institutional goals should all be considered together from the outset.

Understanding the Existing Building

An effective renovation strategy begins with a clear understanding of the building that actually exists, rather than assumptions based solely on available drawings or prior approvals.

The approved occupancy, current use, and proposed use should be evaluated alongside existing means of egress, accessible routes, fire alarm systems, sprinkler protection, and other key building features. Available record drawings and prior approvals may need to be reconciled against actual field conditions. Previous alterations, undocumented conditions, connections to adjacent buildings or campus systems, fire department access, and emergency operations may also influence the project strategy.

The goal is not simply to document existing conditions. It is to identify constraints that may affect project feasibility, scope, budget, schedule, and permitting strategy before major decisions are made. While early investigation cannot eliminate every unknown, it can reduce the likelihood that significant issues emerge after design is advanced or construction is underway.

Establish a Holistic Strategy Early

Once existing conditions and proposed uses are understood, the project team can establish a coordinated strategy that supports code compliance, occupant safety, and project objectives.

Changes in occupancy or use may affect egress, fire protection systems, accessibility, emergency communication, and other design considerations. Projects may also need to account for campus standards, future facility plans, continued occupancy during construction, and the expectations of the Authority Having Jurisdiction (AHJ).

Code compliance establishes the minimum requirements, but early planning helps institutions determine how those requirements can be addressed within the constraints of an existing facility. It also helps distinguish between improvements that are:

  • Required by the proposed work
  • Likely to be expected through the permitting and approval process
  • Voluntary enhancements that provide long-term value while the building is already being renovated

Understanding these distinctions early allows institutions to make informed decisions rather than reacting to requirements or existing conditions after project scope, budget, and schedule have been established.

Make Deliberate Improvements

Renovation projects often create an opportunity, and sometimes an expectation from the AHJ, to address conditions beyond the immediate project area. Depending on the project, this may include replacing aging or unreliable equipment, improving fire alarm coverage or emergency communication capabilities, correcting recurring deficiencies, improving documentation, or bringing the building into better alignment with campus-wide standards.

Renovations may also provide an efficient opportunity to prepare infrastructure for future projects. However, not every potential improvement belongs in every renovation. Decisions should be based on applicable requirements, risk, project priorities, available funding, existing system conditions, and long-term campus objectives.

The goal is not to turn every renovation into a building-wide modernization effort. It is to make informed decisions about what should be addressed now and what can be planned for the future.

Manage Risk During Construction

Renovation and adaptive reuse projects create temporary conditions that can be just as significant as the completed design.

  • Fire Protection systems may need to be impaired.
  • Egress and accessible routes may change.
  • Construction logistics may affect occupied areas, fire department access, and emergency response.
  • Temporary partitions, hot work, combustible materials, and active construction operations may introduce additional hazards.

These conditions require coordination among the institution, occupants, contractors, facilities personnel, public safety departments, designers, and AHJs. Impairment management, temporary egress arrangements, occupied-building separation, emergency procedures, and NFPA 241 planning should be incorporated into the construction strategy.

These considerations should inform project phasing and construction logistics from the beginning rather than being addressed only after construction activities or system impairments become necessary.

Complete the Transition Back to Campus Operations

A successful renovation does not end when construction is substantially complete or the renovated area receives approval for occupancy. The institution must receive accurate documentation, understand altered systems, establish any new inspection and maintenance obligations, update emergency procedures where necessary, and communicate relevant information to those responsible for operating the building.

The transition back to campus operations may include record drawings and system documentation, testing and acceptance records, updated inspection and maintenance requirements, training for facilities and public safety personnel, and integration of new equipment into campus asset management systems. Responsibility for unresolved items and continuing obligations should also be clearly established.

A renovated or repurposed building should be reintegrated into the institution’s broader campus fire safety program with the appropriate systems, documentation, procedures, and responsibilities in place.

How Code Red Consultants Can Help

Code Red Consultants helps colleges and universities evaluate existing conditions, identify project constraints, and establish practical code, fire protection, and safety strategies that support both project goals and long-term campus objectives.

Our multidisciplinary team supports renovation and adaptive reuse projects through existing-condition assessments, code and permitting strategies, fire protection planning, campus and AHJ coordination, construction-phase impairment management, testing, turnover, and occupancy.

By taking a holistic view of existing facilities, construction activities, and campus operations, institutions can make informed decisions earlier in the process, reduce risk during implementation, and return renovated buildings to service with the systems, documentation, and procedures needed to support long-term safety and performance.

Please reach out to our team to discuss how thoughtful planning can support your next campus renovation or adaptive reuse project.

As colleges and universities pursue sustainability, resiliency, and enhanced campus mobility, lithium-ion batteries are becoming an increasingly important part of campus life. Whether supporting student transportation through e-bikes and e-scooters or serving as critical infrastructure through Battery Energy Storage Systems (BESS), these technologies provide meaningful benefits while introducing new fire protection and life safety considerations. As campuses continue to incorporate battery-powered technologies, institutions are increasingly focused on understanding associated risks and developing strategies that support both innovation and public safety.

Understanding the Fire Protection and Life Safety Challenge

While lithium-ion battery failures may be relatively uncommon, the consequences can be significant when they occur. Damaged, defective, improperly manufactured, or improperly charged batteries can experience thermal runaway, resulting in rapidly developing fires, intense heat release, smoke, and hazardous gases. For colleges and universities, where thousands of people may live, learn, work, and gather in close proximity, understanding these hazards is an important part of evaluating risk and supporting informed decisions about how battery-powered technologies are incorporated into campus operations and infrastructure.

Beyond Micromobility

While recent attention has focused on fires involving e-bikes and e-scooters, lithium-ion battery risks extend far beyond micromobility devices. From battery-powered maintenance equipment and campus vehicles to research applications and BESS, colleges and universities are incorporating these technologies across a wide range of operations. Although the applications differ, many share similar fire protection and life safety considerations related to charging, storage, emergency response, and operational planning. Evaluating these risks through a holistic, campus-wide lens can help institutions make informed decisions that support public safety while advancing sustainability and resiliency goals.

Taking a Campus-Wide Approach

Successfully managing lithium-ion battery hazards requires more than a single policy or department. Facilities, Environmental Health and Safety, housing, public safety, emergency management, and campus planning teams all play a role in understanding where battery-powered devices are used and whether existing policies, training programs, and emergency procedures adequately address associated risks. A coordinated, risk-informed approach can help institutions evaluate battery technologies holistically while supporting both safety and sustainability objectives.

How Code Red Consultants Can Help

The goal is not to discourage innovation or sustainability initiatives, but to ensure emerging technologies are incorporated into campus operations through a thoughtful, risk-informed approach to fire protection and life safety. As colleges and universities continue to adopt lithium-ion battery technologies, understanding associated hazards and evaluating mitigation strategies become important parts of supporting both public safety and institutional objectives.

Code Red Consultants works with colleges and universities to evaluate lithium-ion battery hazards associated with micromobility devices, BESS, and other emerging technologies. Whether your campus is addressing e-bike use in residence halls or planning for large-scale energy storage projects, our team can help develop practical solutions that support both safety and sustainability goals, including interface with local building and fire departments.

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.