Code Red Consultants

With the influx of new and repositioned life science buildings coming to market in recent years, a key attribute leading to the success of these buildings has been the ability to maximize available quantities for tenant chemical storage. To achieve this, centralized chemical storage rooms are often provided (designed as either Control Area or Group H, High Hazard storage rooms), allowing chemicals to be remotely stored without detracting from the maximum allowable quantities (MAQ’s) of chemicals available for use within tenant spaces.

Within such rooms, a component that requires significant thought and coordination is the ventilation systems used to mitigate dangerous vapor accumulation. Chemical storage rooms that accommodate small, normally closed vessels may not need as robust of a ventilation system as rooms containing large vessels and/or dispensing operations. Of the latter, two distinct ventilation system types are often found in the larger chemical storage applications:

  • Group H Exhaust (per International Mechanical Code [IMC] Section 502.8), for rooms with large chemical quantities, and
  • Hazardous Exhaust (per IMC Section 510), for rooms with open use operations that generate dangerous vapors.

Group H Exhaust (IMC 502.8.1) is required for any indoor storage area where the quantity of chemicals exceeds the MAQs per Control Area. The requirements for a Group H Exhaust system are outlined in IMC Section 508.1.1, and include, but are not limited to:

  • Exhaust rate of 1 CFM per square foot of room area
  • High/low exhaust (within 12” of the ceiling/floor depending on the weight of expected fumes),
  • Manual ventilation shutoff switch exterior to the room,
  • Continuous operation of equipment, etc.

Also note that specific hazards such as compressed/cryogenic gases, fumes posing health hazards (and associated point-collection systems), and other unique hazards may require additional protection.

Hazardous Exhaust (IMC 510), on the contrary, is not dependent on the MAQs. Rather, IMC 510 is applicable where any one of the following thresholds may be exceeded during normal operations, in the absence of the exhaust system running:

  • A flammable vapor, gas, fume, mist, or dust is present in concentrations exceeding 25 percent of the lower flammability limit of the substance at the expected room temperature;
  • A vapor, gas, fume, mist, or dust with a health-hazard rating of 4 is present in any concentration.
  • A vapor, gas, fume, mist, or dust with a health hazard rating of 1, 2, or 3 is present in concentrations exceeding 1 percent of the medial lethal concentration of the substance for acute inhalation toxicity.

One of the major features of a Hazardous Exhaust system is that it must be independent from other ventilation systems, typically requiring separation by rated shaft construction and/or fire-rated ducts.  Other design requirements may include internal duct suppression, redundant fans, standby power, etc., which should be reviewed with respect to the installation and design goals.

The misconception we often see with the two system types is that they are either thought of as one in the same, or mutually exclusive. To help clarify some ambiguity surrounding these system types, we offer the following:

  • A Hazardous Exhaust system (IMC 510) may sometimes be required in a non-Group H (i.e. Control Area) occupancy, depending on the operations taking place.
  • A Group H room with Group H Exhaust (IMC 502.8) may sometimes also require a local Hazardous Exhaust system (IMC 510) given the operations taking place within.
  • Where both types of systems are warranted, it’s possible to achieve both goals with a single HVAC system designed to meet both criteria.

Existing accredited healthcare facilities are required to maintain the fire-resistance rated walls identified on their Life Safety Plans as part of the ongoing maintenance for Life Safety per the Joint Commission requirements. During State of Condition surveys of existing healthcare facilities, it is common to see citations associated with fire-resistance rated walls or smoke barriers. More specifically, deficiencies associated with opening protectives such as doors, dampers, or penetrations of fire- or smoke-rated walls.

This blog post specifically addresses commonly observed issues associated with dampered ducts penetrating a fire-resistance rated wall. Often, issues are cited relative to the installation of intumescent firestopping applied around the annular space of duct penetrations where fire dampers are installed. A vast majority of fire dampers are not permitted by their fire tests to be installed with an intumescent product in the annular space around the duct penetration. This is caused by the nature of the intumescent firestopping itself – when the product expands in elevated temperatures, as designed, it can deform the duct work and prevent proper closure of the fire damper.

Another common deficiency observed are dampered ducts that do not have angle irons installed. All fire, smoke, or combination fire/smoke dampers are required to be installed per the manufacturer’s listing for its specific use, which typically requires the use of angle irons to rigidly support the duct from deforming. It is common for listings to require non-intumescent materials to be utilized in the installation of the damper, but in some specific listings a firestopping material may be permitted. However, if the installation instructions for the model of damper do not permit the installation of firestopping, it will need to be removed to maintain the listing of the damper.

Lastly, it is commonly observed that damper access panels are not labeled. Damper access panels are required to be identified with the words “Fire Damper”, “Smoke Damper”, or “Fire/Smoke Damper” in letters not less than one inch in height, as required by NFPA 80.

If you have any questions or would like assistance with fire and life safety code compliance related to life safety deficiencies your facility might have, please do not hesitate to contact us at

Atriums are one of the grander features that can be incorporated into a building design. Still, they introduce several design considerations that should be taken into account as a project progresses through design and into construction. This post will present an overview of some of these major considerations.

Sizing and location of the smoke control exhaust and make-up air are paramount

Typically, the exhaust is located at the top of the atrium, and make-up (or supply) air is located toward the bottom of the atrium, such that the airflow path facilitates smoke being efficiently removed from the space. The goal is to clear enough smoke to maintain visibility for exiting occupants at walking surfaces and egress paths. The number and location of exhaust inlets, as well as the location and distribution of supply air, are both critically important to developing a solution suitable for maintaining a tenable environment for those in the atrium. CFD (computational fluid dynamics) computer modeling can often be used to help simulate the various effects of these design factors. CFD model results can also be helpful visual aids when discussing the evaluation with a building or fire official. For more details on makeup-air considerations, please see our prior blog post on the topic found HERE.

What is the atrium boundary and how is it determined?

All spaces within an atrium are required to be separated from any areas not included within the atrium (IBC Section 404.6). This can be accomplished in two prescriptive ways:

  • 1-hour fire barrier walls
  • Sprinklers on glass achieving an equivalent 1-hour fire resistance rating

Additionally, there may be an option to utilize smoke curtains listed under UL 10D & 1784 (with building official approval). These options can also be mixed and matched for flexibility in the overall design. Also of note, the code allows for atrium separation to not be provided between the atrium and the adjoining spaces of up to three floors, if the spaces or rooms are accounted for in the design of the smoke control system.

Are there any specific sprinkler or fire alarm features required for the atrium?

Atriums are required to be provided with both automatic sprinkler protection and a fire alarm system. Both the sprinkler and fire alarm initiating devices serving the atrium are required to be appropriately zoned in alignment with the atrium boundary. This is done so that a fire event outside the atrium does not activate the smoke control system (exhaust fans, makeup air, sprinklers, etc.) within the atrium and vice versa. Therefore, establishing and clearly documenting the atrium boundary within design documentation is important for the success of the project.

Is the smoke control system able to be controlled via the Building Management System (BMS)?

The smoke control system is permitted to be controlled by either the fire alarm system or the BMS; however, splitting controls between multiple systems should be avoided.  In either case, the controlling system is required to be listed in accordance with UL 864 and specifically, subcategory UUKL.

Determining the most cost-effective means to control a smoke control system generally depends upon the complexity of the system, whether the equipment is dedicated to the smoke control system, as well as other design considerations.

What about the smoke control panel?

Every smoke control system requires a firefighter’s smoke control panel, which annunciates equipment status and provides manual control of system components. The smoke control panel for the fire department is required to be in the fire command center if the building requires an FCC. If the building does not have an FCC, the panel is required to be located at a location approved by the AHJ and is often adjacent to the building fire alarm panel. It is always a good idea to consult with the local fire official on the location and design of the smoke control panel before releasing it for production.

What are some other requirements for an atrium outside of the overall design?

Not to be forgotten, a typical requirement for atrium smoke control systems also includes smoke control special inspections through IBC Chapter 17. Special inspections require a comprehensive understanding of system design, performance, and construction schedules to support rather than obstruct the process. Code Red Consultants has experience stemming from dozens of smoke control special inspection projects, should you need such services.

Additionally, depending on local or state requirements, an independent third-party review of the atrium smoke control design may be required. For example, a third-party review of the project’s smoke control rational analysis (which is required to be developed by IBC Section 909) is required in Massachusetts via state code amendments. The third-party review is completed to establish that the design of the atrium smoke control system is consistent with the generally accepted/established principles of engineering and code requirements relevant to the design. The third-party review should be submitted along with the permit application.

In summary, atriums are a desirable but complex part of building design (and construction). We are happy to bring our atrium and smoke control experience to bear to support the design and/or construction side of your next atrium project. Please contact us at for more information.

Emergency Responder Radio Coverage (ERRC), also commonly referred to as a Bi-Directional Amplifier (BDA),  is required by the 9th edition of the Massachusetts State Building Code (780 CMR) Section 916 in certain new buildings.  NFPA 72 Chapter 24 provisions of the two-way radio communications enhancement system are applicable to these systems. NFPA 72 Chapter 24 requires that the riser and feeder coaxial cables and their connections shall be protected within a 2-hour rated enclosure. Since the riser and feeder coaxial cables terminate on the radio amplifiers, the amplifier(s) must also be located within a 2-hour rated enclosure. The coaxial cable terminations to the Distributed Antenna System, Donor Antenna, Fire Alarm System interface, and the Annunciator are not included in the 2-hour rated enclosure requirements.

It is anticipated that the 10th edition of the Massachusetts State Building Code could be adopted as soon as 2024.  The 10th edition of 780 CMR will reference the 2019 edition of NFPA 72 and 2019 NFPA 1221, Standard for the Installation, Maintenance, and Use of Emergency Services Communications Systems. A new term is introduced through the standard, “backbone”, which is defined as “the communications cable in an in-building radio enhancement system that carries wideband signals important to the entire building, from the donor antenna, through the amplifiers, and to the distribution antenna lines” [2019 NFPA 1221: 3.3.10].  NFPA 1221 Chapter 9 requires that the backbone cables and the connections between the cable backbone and antenna cables shall be made within an enclosure that matches the building’s fire rating. For example, in a building that includes fire-resistive ratings up to 1 hour, the backbone and connections are required to be within a 1-hour rated enclosure.

A dry pipe sprinkler system is a water-based fire protection method that typically installed in spaces subject to freezing conditions and cannot constantly maintain a temperature of at least 40°F. Common installation areas for dry pipe systems include parking garages, cold storage spaces, attics, loading docks, and more. Unlike the water-filled piping in wet pipe systems, dry pipe systems use pipes filled with compressed air. This air holds back water at the dry pipe valve, allowing a low air pressure (20 to 30 psi) to hold back over 100 psi of water pressure.

When fire activates the sprinklers, the air in the dry pipe system is released. As the air discharges, the pressure inside the dry pipe valve drops, causing the valve to open and fill the sprinkler piping with water. This process introduces a delay in water delivery compared to wet systems. NFPA 13 provides requirements for the time needed for the dry valve to open, fill the system with water and deliver water through the activated sprinkler head. To mitigate this delay, quick opening devices are utilized.

NFPA 13 requires dry pipe systems deliver water to the most remote point, known as the inspector’s test connection, within specific times based on the protected occupancy hazard. Some exceptions apply. For example, dry systems with interior piping volume less than 500 gallons do not need to meet these delivery times or have quick-opening devices. For systems up to 750 gallons, if a quick-opening device is installed, it negates the need to meet any delivery time requirements. Systems exceeding 750 gallons are required to meet the times listed in NFPA 13 (2019) Table

In addition to the above times, dry systems protecting dwelling units must deliver water within 15 seconds to each dwelling unit (NFPA 13-

Quick-opening devices, like exhauster and accelerators, are used to help meet delivery time requirements. Exhausters were mounted on sprinkler piping, where it would sense a drop in the system air pressure and open a larger valve to allow air to escape, thus draining air from the piping more rapidly. Exhausters are no longer manufactured but may be found on older dry sprinkler systems.

Accelerators are mounted to the dry pipe valve itself as part of the trim package. Similar to an exhauster, an accelerator senses a drop in air pressure and will open a larger valve to the dry valve’s intermediate chamber, letting air inside the dry pipe valve escape and equalize with ambient air pressure. While exhausters removed air from the dry sprinkler pipe, accelerators drop the air pressure only within the dry pipe valve itself – reducing the time it takes for water to begin traveling down the pipe towards the open sprinkler(s).

Older accelerators are mechanically operated and tend to be a component that requires a higher level of maintenance throughout the life of a system. One of the traditional issues with mechanical accelerators is that when they are not properly maintained, they will trip when there isn’t a pressure drop in the dry sprinkler system, activating the dry pipe valve and filling the piping with water. These events also tend to activate the dry pipe system’s pressure switch, causing a fire department response.

Newer accelerators are available that utilize electrical components to operate, which sense a pressure drop electronically and activate the valve. These devices tend to be more responsive and far less prone to accidental activation. Electronic accelerators typically have a higher installation cost compared to their mechanical counterparts; however electrical accelerators have been found to have a lower level of maintenance required through the life of the system.

A well-maintained fire protection system is a crucial piece in protecting properties from experiencing loss from fire events. Each component in these systems play a specific role and must be properly maintained to ensure it will operate as intended. Proper maintenance on a system does not necessarily begin once a system has been installed and put in service, it begins with the design and selection of cost-effective, long-lasting components.

One of the most common accidents within laboratories involves the spilling or leakage of hazardous chemicals. As an added safety precaution to limit the impact of a spill or leak, NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, contains provisions for laboratory flooring in order to contain a spill to the floor of origin and prevent the spread of liquid to any spaces below. For designers, some questions naturally arise: What are the requirements for flooring within a laboratory, and what are the options for compliance?

Section 5.1.5 of NFPA 45 (2019 edition) addresses flooring within laboratories. Specifically, this section requires laboratory floors, floor openings, floor penetrations, and floor firestop systems to be sealed or curbed to prevent liquid leakage to lower levels (i.e., liquid-tight). Further, the sealing material is required to be compatible with the chemicals being stored or used within the laboratory, or a program is required to be in place to inspect and/or repair any sealing materials, if necessary, after exposure to a chemical spill or leak.

The spread of liquid to an area below can be prevented by permanent means such as curbs around floor penetrations, trenches at doors, and/or curbing at the laboratory perimeter to raise the start of the walls. The use of resinous floor coatings such as epoxies or other impermeable floor systems is also recognized as an option. Construction sealants can also be utilized, however, sealants are more susceptible to degradation depending on the specific sealant, the type of chemical spilled, and the exposure time to the chemical, such that an inspection and maintenance regimen may be necessary where using sealants.

Penetrations through floors are also required to be protected to prevent spills from reaching lower levels. While a typical firestop system will prevent the spread of smoke and hot gases, a W-rated firestop system can be utilized to prevent the passage of liquid. These systems may not be chemically resistant, however, they may be able to stop chemical leakage for a sufficient period of time to clean up a spill. As with sealants, an inspection and maintenance regimen may be necessary to ensure the integrity of the system is maintained. If a firestop system is not liquid-tight, other provisions, such as curbing, will be necessary.

If you have any questions or would like assistance with fire and life safety code compliance related to laboratories, please do not hesitate to contact us at


Health Care Facilities that receive their accreditation from The Joint Commission (TJC) are subject to the TJC Standards. These form the basis of accreditation surveys and are intended to provide key performance elements for patient, individual, or resident care and organizational functions so that facilities can provide safe and high quality care.

One of the most critical times to perform a custom evaluation of patient safety within accredited healthcare organizations is during periods of construction. Within the Environment of Care Chapter of the TJC standard the hospital is required to conduct a preconstruction risk assessment (PCRA) to evaluate the impacts to air quality, infection control, utility requirements, noise, vibration, life safety, and other hazards that affect care, treatment and services (EC.02.06.05 EP 2). Given the multi-disciplinary nature of the risk analysis, Hospitals typically form PCRA committees that are staffed by personnel in responsible charge of the various areas of impact. These PCRA committees meet regularly and are required to document their analysis and subsequent approval of all construction activities within the facility.

Life safety is a critical component of a PCRA evaluation. It is paramount that the individual(s) performing the Life Safety evaluation are well versed in impairments of the various life safety systems in the building. Under the umbrella of life safety, impairments to the following systems are included: fire alarm & detection systems, fire protection systems, smoke control system, means of egress, and passive fire protection systems & features (i.e. fire rated walls, doors, and dampers. Furthermore, impacts to first responders should also be included in such evaluations as well as mitigating the risks of increased risks of a fire event inherent with construction (i.e. hot work in areas where combustible materials are stored). If the evaluation done by the hospital finds that the planned work will impair one or more of these systems, an interim life safety measure (ILSM) is required to be implemented for the duration of the impairment(s) based on the hospitals policy (LS.01.02.01 EP1).

Examples of common impairments are:

  • Fire alarm shut down greater than 4 hours
  • Sprinkler impairment lasting greater than 10 hours
  • Reconfiguration of the exit access system
  • Reduction in corridor width
  • Blocked exit
  • Blocked exit discharge
  • Fire rated door removed in rated wall for extended period of time
  • Holes made in fire rated barriers
  • Obstructions to fire lanes

Depending on the complexity of the project, specialized ILSMs that take into account the different phases of the project and number of impairments the project may need to be created.


Did you know that the International Building Code requires high-rise buildings be provided with a Fire Command Center (FCC)?  A fire command center is a room dedicated as the Fire Department response point, and serves as the center for their emergency operations.  The FCC consolidates life safety system components and information to allow responders to efficiently evaluate and manage an emergency in the building.

Though the requirements for the FCC reside in the Fire Protection section of the Building Code (Section 911.1), there are numerous requirements which impact other disciplines and can be inadvertently missed.  Some of these include:

  • Minimum 200 sq. ft. size, with minimum 10 foot width, constructed with 1-hr separation from the rest of the building
  • FCC design review by AHJ prior to installation:
    • Location and accessibility of room
    • Layout of room and equipment
  • Elevator annunciator panel and selector switches
  • Status indicators and controls for air distribution systems
  • Controls for unlocking interior exit stairway doors
  • Dedicated telephone for fire department use
  • Schematic building plans
  • Building Information Card
  • Generator and ATS annunciators
  • Any unique local Fire and Building Department requirements

Parties having involvement in the FCC design and installation can include:

  • Architect
  • Engineer
  • Vertical transportation (elevator) consultant
  • Electrical and fire alarm contractor
  • Mechanical contractor
  • Low voltage and Security designer and contractors
  • Building owner and operator

Coordination early in a project can help avoid painful changes, costs, and delays when FCC deficiencies are found at the time of final inspections.   To view the complete list of FCC requirements, refer to IBC section 911.1.

The classification of sheltered mechanical, electrical, and plumbing (MEP) equipment as a “penthouse” in lieu of a “mechanical floor” provides numerous code advantages at the top level of a building. The main benefits include:

  • Height & Area. Penthouses are considered part of the “story” below such that they are not included when evaluating the building’s height (number of stories or in feet) nor are they included in the building’s area evaluation.
  • Means of Egress. Penthouses are considered a “normally unoccupied” space and are not subject to the means of egress requirements for an “occupied floor”.
  • Shaft Termination. Top of shaft enclosures are not required in penthouses which provides flexibility with the termination of shafts that otherwise cannot be recognized in a typical story, specifically with specialty exhausts that prohibit the use of fire dampers such as lab ventilation hazardous exhaust.

For a rooftop structure to be classified as a “penthouse” and realize the above benefits, there are various use limitations, and all the following requirements will need to be met:

  • Height. Unless the building is of Type I construction, the penthouse is limited to a maximum height of 18 feet above the roof deck. Where the penthouse is used to enclose a tank or elevator, that requirement is extended to 28 feet. Penthouses in Type I buildings are permitted to exceed this threshold.
  • Area. The area of the penthouse is limited to 1/3 the area of the supporting roof deck.
  • Use. Penthouses are limited to mechanical or electrical equipment only. Neither storage nor the use of space for a small office are permitted.
  • Construction. Penthouses are required to be constructed of materials consistent with the building’s construction type.

A building’s continued operation and interior environment rely on the building’s mechanical, electrical, and plumbing systems, which require large equipment. The square footage to locate the equipment may be hard to come by, and when it is found, it comes at the expense of valuable interior building area. Looking to the roof of the building to locate the equipment is a frequent alternative.

From the perspective of the building code, there are three options for rooftop structures to house such equipment:

  1. Equipment directly on the roof and open to sky;
  2. A story housing mechanical equipment; or
  3. A penthouse.




Previously in our Fire Walls, Part 1: What do they get me? post, we had outlined what fire walls do from a code perspective. In addition to what role these assemblies serve, questions commonly arise relative to the construction detailing of fire walls given the number of requirements to consider.

Structural Connection

The building code allows two options for fire wall construction:

  • The first option is a single fire wall assembly that is structurally independent from both buildings (NFPA 221, 6.3 & 6.4).
    • Cantilevered Fire Walls are entirely self-supported and nonbearing. No connections are permitted to building(s) or contents on either side other than to the flashing and should be constructed where there is a break in the structural framework (NFPA 221, 6.3).
    • Tied Fire Walls are centered on a single column line or constructed between a double column line. The structural framing on either side lines up horizontally and vertically, and supports the roof (NFPA 221, 6.4).
  • The second option is the construction of a double fire wall assembly consisting of two back-to-back fire walls. Each fire wall is supported laterally by the building frame on its respective side and independent of the fire wall and framing of the opposite side (NFPA 221, 6.5).

All fire walls are required to be designed and constructed to remain after collapse of the structure due to fire on either side of the wall (NFPA 221, 6.2.1). Specifically, these assemblies are required to be continuous both vertically and horizontally and have specific termination requirements.

Fire Resistance Rating

The required ratings of fire walls are based on the occupancy classifications within a building (IBC Table 706.4). Double wall assemblies are considered to have a combined assembly fire-resistance rating; for instance the equivalent of a 3-hour, single fire wall is 2, 2-hour rated fire walls in a double assembly (NFPA 221 Table 4.5).


The aggregate width of protected openings at any floor level in a fire wall is not permitted to exceed 25% of the length of the wall (780 CMR 706.8). Egress door openings within double fire walls are required to be protected with a pair of doors and a vestibule (NFPA 221,

Whether a single or double fire wall is being explored as part of the design, it is important to review the necessary fire-resistant rating, structural stability, continuity, and opening requirements applicable to both options, as well as detailed criteria from 780 CMR Section 706 and NFPA 221.