Code Red Consultants

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.

Energy Storage Systems (ESS) are a source of available and reliable power that can provide flexibility to electrical grids during peak usage and assist with load management and power fluctuations. NFPA 855, Standard for the Installation of Stationary Energy Storage Systems, addresses the installation of energy storage technologies and aims to mitigate the hazards related to these systems.

NFPA 855 contains size and separation requirements designed to prevent fire propagation from one ESS to adjacent combustible materials (other ESS, wall assemblies, exposures). These limitations specifically focus on indoor installations in non-dedicated buildings and outdoor installations less than 100 feet from exposures:

  • The maximum stored energy per unit is limited to 50 kWh
  • The separation distance between units and wall assemblies should be a minimum of 3 feet
  • The maximum stored energy of all the ESS units comprising the system is limited to a threshold value based on the battery technology

NFPA 855 also requires most new Energy Storage System (ESS) installations to be listed in accordance with UL 9540, Standard for Safety of Energy Storage Systems and Equipment. UL 9540 provides design, construction, and performance requirements for ESS.

Exceptions in both NFPA 855 and UL 9540 allow for ESS installation with increased stored energy and reduced separation distances. Approvals for larger ESS depend on the results of large-scale fire testing conducted in accordance with UL 9540A, Standard for Test Method for Evaluating Thermal Runaway Fire Propagation in Battery Energy Storage Systems. UL 9540A provides critical information regarding the fire performance of ESS undergoing a thermal runaway event. Fire testing is conducted at the cell, module, and unit level to evaluate the potential for fire spread and toxic gas emissions from the ESS, as well as the performance of the mitigation solutions to limit the consequences of the thermal runaway event.

An extensive amount of data is produced from the UL 9540A testing. Correct interpretation of the results is essential for the AHJ to confidently evaluate the safety of an ESS installation.  We are here to help with the review of UL 9540A test reports and the interpretation of UL 9540A testing data. If you have questions related to ESS fire testing in accordance with UL 9540A, please contact us at

Energy Storage Systems (ESS) are becoming a prevalent solution to anticipate and mitigate electrical grid disruptions for commercial, industrial, and residential applications.  ESS provide energy reserves to reduce power peaks and stabilize fluctuations in energy supply.  Various ESS technologies have been and are being developed.  Hazards related to ESS, such as fire and toxicity, cannot be ignored.

NFPA 855, Standard for the Installation of Stationary Energy Storage Systems, was developed to provide the minimum requirements to ensure safe design, installation, and operation of ESS.  Depending on the technology, the amount of energy stored, the location, the design, or potential hazards in the vicinity of the ESS, a Hazard Mitigation Analysis (HMA) may be required by the AHJ.  The HMA is a systematic method that considers the various hazards related to the installation, identifies potential failure modes as well as their causes and effects, and develops appropriate mitigation solutions.

NFPA 855 requires the HMA to evaluate the consequences of:

  • Thermal runaway conditions
  • Failure of an energy storage management system
  • Failure of a required ventilation or exhaust system
  • Failure of a required smoke/fire detection system, fire suppression, or gas detection system

The AHJ can require the HMA to include additional failure modes.  It can be completed by either a design team or a third-party.  To be approved, the results of the analysis will need to demonstrate that the mitigation solutions of the installation provide proper fire containment, suitable explosion control, safe egress, and adequate toxic and flammable gas management.  If you have questions regarding how to develop an HMA or if you are in need of a third-party HMA review, please contact us at

Energy Storage Systems (ESS) are starting to play a critical role in the development of microgrid systems, the integration of renewable energy, and by improving the utilization and efficiency of such hybrid systems.  They have rapidly gained popularity in commercial, industrial, and residential applications.  Different technologies are currently used to store energy:

  • Pumped hydro storage (hydroelectric power)
  • Capacitors
  • Compressed air energy storage
  • Flywheels
  • Batteries

ESS designs vary greatly depending on the technology used. Over the last few years, Lithium-ion (Li-ion) battery-powered ESS have attracted significant interest due to their high energy density, voltage performance, and long-life cycle.  Two common aspects among the different technologies are the need for an adequate understanding of the hazards involved and appropriate measures to ensure safety. NFPA 855, Standard for the Installation of Stationary Energy Storage Systems, provides requirements for mitigating hazards related to the design, installation, operation, and maintenance of ESS, not only powered by Li-ion technology but also for any ESS that exceeds the energy capacity threshold listed in the standard.

ESS powered by solutions such as Lead-Acid Battery, Sodium Nickel Chloride Battery, Solid State Battery, Iron-air Battery, and Flow Batteries are also required to be designed, installed, and maintained in accordance with NFPA 855. Several of these technologies are new, and risk and mitigation analyses need to be conducted in order to appropriately evaluate the fire and toxic hazards related to these ESS.

Information related to the equipment, its installation, and testing data is paramount to determine the degree of safety offered by the ESS when subjected to different failure modes. Hazard Mitigation Analyses and NFPA 855 Compliance Reviews conducted by the design team, a third-party, or the AHJ offer comprehensive evaluations of the level of safety of ESS installations.

For projects in Massachusetts, multiple dwellings are required to comply with 521 CMR.  In multiple dwellings for rent (not for sale) that contain 20 or more units, at least 5% of the dwelling units must be Group 2A units (521 CMR 9.4).  521 CMR includes unique requirements that designers may not be familiar with based on experience with other requirements such as FHA or ANSI A117.1. Some of these high-level requirements are included below:

  • Bathrooms
    • Wheelchair turning space is required to be provided clear of the door swing.
    • The centerline of the toilet is required to be at least 42” from the farthest side wall or the closest edge of an adjacent fixture. A minimum of 42” clear is required to be provided from the front edge of the toilet.
    • Clear floor space at bathtubs is required to be 30” x 72”. At least 12” of the clear floor space length is required to extend beyond the drain end of the tub.
    • Shower curbs must not be higher than ½” and must be beveled.
    • Bathtub faucets and mixing valves are required to be centered horizontally on the long wall, exactly 28” above the floor. Shower mixing valves are required to be centered horizontally on the long wall, 38”- 48” above the shower floor.
  • Kitchens
    • A counter space at least 15” wide is required to be provided on one side of the sink, cooktop, and refrigerator.
    • Built-in microwave ovens and at least one conventional oven are required to be wall ovens with the floor of the oven exactly 30” above the floor.
    • If corner cabinets are provided in L-shaped or U-shaped kitchens, a built-in lazy susan must be capable of being provided.
    • At least one base cabinet is required to provide a drawer or drawers).
    • Refrigerators are required to be either a unit with two side-by-side doors or a freezer above refrigerator unit.

Note that there may be other accessibility requirements applicable to your project.

Storage of hazardous materials is defined by 780 CMR Massachusetts State Building Code as “the keeping, retention or leaving of hazardous materials in closed containers, tanks, cylinders, or similar vessels; or vessels supplying operations through closed connections to the vessel” (780 CMR Section 202). For buildings utilizing a control area approach to address the inclusion of hazardous materials, such storage of hazardous materials is limited to defined Maximum Allowable Quantities (MAQs) per control area, which are listed in Table 307.1(1) and Table 307.12(2) of 780 CMR.

For most chemical classifications, the quantity of each chemical is permitted to be increased by 100 percent if the building is fully sprinklered, and another 100 percent if the hazardous materials are provided in what is commonly referred to as “approved storage”.  In the context of MAQs for physical hazards, footnote e to 780 CMR Table 307.1(1) specifies that approved storage could include storage in “approved storage cabinets, day boxes, gas cabinets, gas rooms, exhausted enclosures, or listed safety cans.”  For health hazards, 780 CMR Table 307.1(2) permits only approved storage cabinets, gas cabinets or exhausted enclosures for these purposes.  As discussed below, day boxes and safety cans are used for specific physical hazards and therefore are not applicable to health hazards.

Each type of approved storage is required to meet specific requirements, as prescribed by 780 CMR and/or 527 CMR 1.00 Massachusetts Comprehensive Fire Safety Code.

Approved Hazardous Materials Storage Cabinets: Hazardous material storage cabinets used to store solid and liquid hazards materials and are required to meet 527 CMR 1.00 Section which prescribes the following minimum requirements:

  • Metal, double-wall construction with a minimum thickness of 0.044 inches (18 gauge) and minimum 1.5 inches of airspace between the walls.
  • Cabinet joints are required to be riveted or welded and tightfitting.
  • Doors are required to be well-fitted, self-closing, and equipped with a 3-point latch.
  • Entirety of the interior of cabinets are to be treated, coated, or constructed of materials that are nonreactive with the hazardous materials stored.
  • A 2-inch liquid-tight sump is required in cabinets utilized to store liquids.
  • Cabinets are required to be marked in conspicuous lettering that reads “HAZARDOUS – KEEP FIRE AWAY”.
  • Incompatible materials are not permitted within the same storage cabinet.

Depending on the material(s) stored within the cabinets, additional material-specific requirements may also apply.  For example, storage cabinets utilized for flammable or combustible liquids are further regulated by NFPA 30 Flammable & Combustible Liquids Code and require the cabinet be labeled with “FLAMMABLE – KEEP FIRE AWAY.”

Day Box: A day box is a portable magazine designed to hold explosive materials constructed in accordance with the requirements for a Type 3 magazine as defined by 780 CMR Section 202.

Gas Cabinet: A gas cabinet is a fully enclosed, ventilated noncombustible enclosure used to provide an isolated environment for compressed gas cylinders in storage or use (780 CMR Section 202). Gas cabinets are required to meet 527 CMR 1.00 Section 63.2.17 which prescribes the following minimum requirements:

  • Metal, with a minimum thickness of 0.097 inches (12 gauge).
  • Doors are required to be self-closing.
  • Cabinets are required to have self-closing limited access ports or noncombustible windows to give access to equipment controls.
  • Entirety of the interior of gas cabinets are to be treated, coated, or constructed of materials that are compatible with the hazardous materials stored.
  • An exhaust ventilation system is required, designed to operate at a negative pressure relative to the surrounding area.
  • Incompatible materials are not permitted within the same gas cabinet.

Depending on the material(s) stored within the gas cabinets, additional material-specific requirements may also apply.  For example, gas cabinets utilized for toxic, highly toxic, or pyrophoric gases are required to be internally sprinklered.

Gas Room: A gas room is a separately ventilated, fully enclosed room in which only compressed gases and associated equipment and supplies are stored or used (780 CMR Section 202). Gas rooms are required to be designed to the following minimum requirements per 527 CMR 1.00 Section 63.2.4:

  • Gas rooms are required to be provided with an exhaust ventilation system designed to operate at negative pressure in relationship to the surrounding area.
  • A minimum 1-hour separation is required to adjacent areas.
  • Separation of incompatible materials within gas rooms is required.

Exhausted Enclosure: An exhausted enclosure is an appliance or piece of equipment that consists of a top, a back and two sides providing a means of local exhaust for capturing gases, fumes, vapors and mists. These enclosures may include laboratory hoods, exhaust fume hoods and similar appliances and equipment used to locally retain and exhaust the gases, fumes, vapors and mists that could be released. Rooms or areas provided with general ventilation, in themselves, are not exhausted enclosures (780 CMR Section 202).  Exhausted enclosures are required to be designed to the following minimum requirements per 527 CMR 1.00 Section 63.2.18:

  • Noncombustible construction
  • Exhausted enclosures are required to be provided with an exhaust ventilation system designed to operate at negative pressure in relationship to the surrounding area.
  • Sprinkler protection is required within exhausted enclosures.
  • Incompatible materials are not permitted to be stored or used within the same exhausted enclosure.

Depending on the material(s) stored within the exhausted enclosure, additional material-specific requirements may also apply.  For example, the ventilation system serving exhausted enclosures utilized for toxic, highly toxic, pyrophoric, unstable reactive (Class 3 or 4) or corrosive gases are also required to meet minimum face velocities.

It should be noted that the definition of exhausted enclosure in 780 CMR Section 202 identifies laboratory hoods as one type of permissible exhausted enclosure.  However, within laboratories subject to NFPA 45 Fire Protection for Laboratories Using Chemicals, the storage of chemicals in fume hoods is explicitly prohibited per NFPA 45 Section  In such laboratories, MAQ increases are typically achieved by way of approved storage cabinets.

Listed Safety Can: Safety cans may be utilized for the storage of flammable or combustible materials.  Where they are used to increase the MAQs per control area, safety cans are required to be listed in accordance with UL 30 Metallic and Nonmetallic Safety Cans for Flammable and Combustible Liquids.  Safety cans are further required to meet the following requirements, per Section 3.3.244 of 527 CMR 1.00:

  • Maximum capacity of 5 gallons (limited by UL 30 listing which is more restrictive than Section 3.3.244).
  • Safety cans require a spring-closing lid and spot cover designed so that it will relieve internal pressure when subject to fire exposure.