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Insights Category: Technical Information

In addition to being required at the edge of certain walking surfaces within the interior of a building, there are various locations which guards are required at the roof level of a building, which may not be found on every project. The inclusions of these guards are in general related to either the protection of maintenance personnel servicing equipment on the roof, or for the protection of fire department personnel in the event firefighting operations are required on the roof. Roof level guards are required in the following locations:

  • Roof Hatches: Where a roof hatch opening is provided within 10 feet of the roofs edge (780 CMR 1011.13). These guards are required around the entire perimeter of the roof hatch.
  • Mechanical Equipment Access: Where mechanical equipment the requires service is located within 10 feet of the roofs edge (IMC 304.11). These guards are required between the mechanical equipment and the roofs edge, and must extend 30 inches beyond the mechanical equipment in each direction.
  • Interior Courts: Where interior courts are provided (surrounded on all 4 sides) which are not protected by either a skylight or a roof (527 CMR 10.11.4). These guards are required around the entire perimeter of the court, whether it is an interior light well, or large court one may find interior to a school or residential amenity space.

The guards at these locations are required to be installed in accordance with 780 CMR Section 1015, including a minimum height of 42” and maximum opening width of 21” as the guards are solely provided at mechanical equipment access points and therefore not intended for access by the general public.

Do you have any unique roof access points which may warrant the inclusion of a guard? Feel free to contact us to discuss your specific project!

 

Means of egress lighting is essential for the safe and quick evacuation of buildings. It is for this reason that the building and fire codes have strict requirements on illumination levels within and outside of buildings under both normal and emergency conditions at all times that buildings are occupied with limited exceptions.

Along the entire means of egress, a minimum lighting level of 1 footcandle is required to be maintained. The lighting intensity provided by 1 footcandle is approximately equal to that found outdoors during twilight. To put it in perspective, a sunny day has an intensity of approximately 10,000 footcandles.

It is important to remember that “means of egress” is defined as consisting of three parts: the exit access, the exit, and the exit discharge. This results in lighting being required along the entire path of travel from within occupied spaces to the public way including open plan egress (i.e. open office), exit access aisles, corridors, stairs, exit doors, exterior doors, and along the entire path of travel from the exterior door to the public way. This may require many low level lighting appliances to be provided along exterior walkways until an egressing individual reaches a public way such as a city road.

Under emergency power loss conditions, emergency lighting is required to provide an average illumination intensity of 1 footcandle at walking surfaces for a 90 minute period of time. The areas provided with illumination are not as extensive as are required for normal egress lighting. For instance, areas such as the exterior discharge path are not required to be provided with emergency lighting. Certain rooms, regardless of their occupant load or egress arrangements, which are critical to life safety are required to have emergency lighting including fire command centers, fire pump rooms, large bathrooms, generator rooms, and electrical equipment rooms.

Common Questions

1. Can we provide an average illumination of 1 footcandle along walking surfaces?

1 footcandle is required as a minimum intensity under normal conditions. An average illumination is only permitted under emergency power.

2. Is means of egress lighting required at all times?

Means of egress illumination is required at all times the building is occupied. Lighting is not required to be provided if people are not inside.

3. Is illumination required within assembly spaces?

For assembly spaces such as theaters and auditoriums there are allowances for reduced lighting during performances.

Please do not hesitate to contact us if you have means of egress lighting questions and how they apply to your specific project.

The Cities of Boston and Cambridge have introduced their own respective timelines and regulations for reopening construction sites. Both cities have based their regulations off of the requirements of the Baker-Polito administration for the reopening of Massachusetts, as well as guidelines outlined by the CDC and respective federal agencies.

The City of Boston concluded its citywide shutdown on May 26th, with all construction sites now permitted to open, but with site and operational changes in response to COVID-19. The city is permitting any construction project currently allowed by the Commonwealth, and requires that all general contractors sign a COVID-19 Safety Affidavit as well as develop and implement a COVID-19 Safety Plan. This includes those which had obtained permits from either BFD or ISD prior to the shutdown, as well as all future permit submissions

The City of Cambridge is currently implementing its construction reopening strategy, with the timeline outlined below. The dates outlined are preliminary, with each phase expected to last a minimum of three weeks, and are subject to change based on public health data throughout the Commonwealth, which will be regularly updated and re-evaluated to determine when to move to the next phase of reopening.

Phase 1, which began on May 25th, allowed site safety preparation work to commence for projects previously permitted by Inspection Services (ISD) and Public Works (DPW). Amendments to the City’s Temporary Emergency Construction Order issued on March 18 modified the definition of essential construction to include work associated with COVID-19 restaurant modifications needed to allow them to safely reopen;

Phase 2, which began on June 1st, added horizontal construction, city building projects, 100% affordable housing developments, and larger buildings (over 25,000 square feet) previously permitted by ISD or DPW;

Phase 3, tentatively beginning on June 15th, will add all remaining existing construction previously permitted by ISD and DPW; and

Phase 4, tentatively beginning on June 29, will allow construction on projects not previously permitted to commence. Permit applications can be submitted, and pre-reviews will occur at any time, but permit applications will not be formally reviewed or issued until this date.

In addition to the Commonwealth’s requirements, Cambridge is also requiring sites in the city to conduct twice-daily decontamination of high-contact surfaces, limiting the number of persons within worksites (4 per every 2,000 ft2 of enclosed space, and an additional 1 person per every additional 500 ft2), and prohibiting non-essential persons on worksites. All contractors are additionally encouraged to conduct site-specific risk analyses to determine if enhanced measures are necessary for more complex projects.

If you have any questions about construction in the Metro Boston area or have any other concerns associated to this topic, please feel free to reach out to info@crcfire.com for additional information.

 

Spray foam insulation serves as an alternative to more traditional building insulation material such as fiberglass. Due to its ease of application and effective insulating properties, it is often specified for use in concealed spaces such as attics or cavity spaces. The use of spray foam insulation within buildings, however, has implications that must be addressed from not only the perspective of the building code, but also NFPA 13 Installation of Sprinkler Systems.

Per the International Building Code (IBC), when spray foam insulation is installed within a building it is required to be separated from the building interior by means of a thermal barrier or ignition barrier, except for specific exempt situations (2015 IBC 2603.4). This is often achieved by encasing the foam in an intumescent paint tested via NFPA 275 Standard Method of Fire Tests for the Evaluation of Thermal Barriers; however, the presence of a barrier is not required if the materials themselves have been tested (in the manner intended for use) in accordance with NFPA 286 Standard Method of Fire Test for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth, FM 4880 Approval Standard for Class 1 Fire Rating of Insulated Wall or Wall and Roof/Ceiling Panels, Interior Finish Materials or Coatings and Exterior Wall Systems, UL 1040 Fire Test of Insulated Wall Construction, or UL 1715 Fire Test of Interior Finish Material (2015 IBC 2603.9).  The primary intent of these provisions of the IBC is to delay involvement of the foam material in a fire.

NFPA 13, on the other hand, addresses scenarios where concealed spaces which contain combustible materials or surfaces (such as spray foam insulation) are exempt from sprinkler protection.  The 2013 edition of NFPA 13 (currently adopted in the Commonwealth of Massachusetts) allows for omission of sprinklers in such concealed spaces where “…rigid materials are used and the exposed surfaces have a flame spread index of 25 or less, and the materials have been demonstrated not to propagate fire more than 10.5 feet when tested in accordance with ASTM E84 The Standard Test Method for Surface Burning Characteristics of Building Materials or ANSI/UL 723 Standard for Test for Surface Burning Characteristics of Building Materials, extended for an additional 20 minutes…” (2013 NFPA 13-8.15.1.2.10).

What is important to note is that the NFPA criteria to omit sprinklers within a concealed space which contains spray foam insulation are different than the basic IBC criteria for mitigation of the foam within the same space. As such, while a particular product may be adequate to demonstrate compliance with IBC Chapter 26 provisions, it must be further verified that the product also satisfies NFPA 13 requirements if sprinklers are to be omitted from the space.

In order to facilitate compliance with the provisions of NFPA 13, the corresponding section of the 2019 Edition of NFPA 13 (not yet adopted in the Commonwealth of Massachusetts) has been modified to allow two options for omission of sprinklers in such concealed spaces (2019 NFPA-13 9.2.1.1):

  1. Rigid materials that have a flame spread index of 25 or less, and not propagate fire more than 10.5 feet when tested in accordance with ASTM E84, extended for an additional 20 minutes; or,
  2. Rigid materials that comply with the requirements of ASTM E2768 Standard Test Method for Extended Duration Surface Burning Characteristics of Building Materials.

The newly referenced ASTM E2768 test is comparable to the ASTME E84 test, except that it has a standard duration of 30 minutes and thereby allows for a clearer way to demonstrate and document compliance with these provisions.

Over time, it is expected more products will be tested against ASTM E2768, making it easier to comply with the NFPA criteria. In the meantime, products currently tested per ASTM E84 can still be used provided the manufacturer is able to furnish documentation demonstrating adequate performance during an extended ASTM E84 test.  When selecting and reviewing products, its important to be aware of the above requirements for both the IBC and NFPA 13 in order to solicit and verify the correct testing data from a product manufacturer.

One additional consideration is the definition of “rigid materials”, as used above in the context of concealed spaces in NFPA 13. Determination of what constitutes “rigid material” can be subjective, especially in the context of foam materials. Ultimately the interpretation of the definition is subject to the discretion of the Authority Having Jurisdiction and the Registered Design Professional based on the proposed products and specific applications.

If you have any questions about concealed space allowances or have any other concerns associated to this topic, please feel free to reach out to info@crcfire.com for additional information.

Model building and fire codes are consistently being updated to increase the level of safety for occupants by adding and revising code requirements. One important term that has evolved over the years is “Change in Occupancy”. Due to various code changes for clarification and confusion between the terms occupancy and use, it may appear that this term has changed through the years, when in fact the intent has remained the same.

The following is the definition for change in occupancy from the 2003-2012 editions of the International Existing Building Code (IEBC)

2003-2012 IEBC: A change in the purpose or level of activity within a building that involve a change in application of the requirements of this code.

This definition was changed in the 2015 IEBC to clarify the intent of the code and remove the vagueness are the phrase “purpose or level of activity” as follows:

2015 IEBC: A change in the use of the building or a portion of a building. A change of occupancy shall include any change of occupancy classification, any change from one group within an occupancy classification or any change in use within a group for a specific occupancy classification.

This code change clarifies the original intent by changing the term purpose or level of activity to use. It also highlights that a change is occupancy can occur without actually changing the occupancy classification.

Another point of confusion centers around the terms use and occupancy. Use and occupancy are often used interchangeably, but do not mean the same thing in the eyes of the code. An occupancy is one of the classifications found in Chapter 3 (A, B, M, etc.) and these classifications can be broken further down into groups (A-1, A-2, A-3, etc.). The use is the actual function of the building or space and is what determines the occupancy group (office (B), night club (A-2), dormitory (R-2), etc.). For example, a gymnasium may have an occupancy classification of Group A-3, but the use of the space is a gymnasium. If the gymnasium is changed to a bowling alley, the occupancy would remain the same, but the use of the space would change, triggering a change in occupancy. Though the definition for change in occupancy has changed through the years, this concept remains the same.

In the 2018 IEBC, the definition was reorganized as a list to make it clear that any of the conditions could be classified as a change in occupancy. The third item in the list was expanded to include the phrase “change in application of the code”, which was the original code language/intent in the earlier versions.

2018 IEBC: A change in the use of a building or portion of a building that results in any of the following:

  1. A change of occupancy classification.
  2. A change from one group to another group within an occupancy classification
  3. Any change in use within a group for which there is a change in application of the requirement of this code.

Looking forward, the definition in the 2021 IEBC will be changed yet again. A new definition for change in use has been added, using the language in item 3 from the 2018 IEBC definition above, and item 3 is changed to simply state change in use (shown below). Even with this new change, the original intent from the 2003 IEBC to the 2021 IEBC remains the same.

2021 IEBC: Change of Occupancy: Any of the following shall be considered as a change of occupancy where the current IBC requires a greater degree of safety, accessibility, structural strength, fire protection, means of egress, ventilation or sanitation than is existing in the current building or structure:

  1. A change in the occupancy classification of a building or structure.
  2. Any change in the purpose of, or a change in the level of activity within, a building or structure.
  3. A change of use

Change of Use: A change in the use of a building or a portion of a building, within the same group classification, for which there is a change in application of code requirements.

 

 

The use of Modular Construction (Manufactured Buildings) provides project teams with schedule and construction advantages and has come under increased interest over the past few years.

Buildings constructed using this manufactured/modular approach are required to be evaluated per all requirements of the state building and fire codes, unless considered as a temporary structure in accordance with 780 CMR Chapter 31. In addition, special rules and regulations for manufactured buildings are contained within 780 CMR Chapter 110 Section R3. These regulations focus on the manufacture, certification, and inspection protocols that need to be followed, including the following:

  • Certification of the manufacturer, including a comprehensive quality assurance manual by the manufacturer outlining all aspects of project execution.
  • Third-Party Inspector Agency (TPIA) meeting certain registration requirements who will serve as the eyes and ears for inspections at the manufacturing facility.
  • Detailed document submittal requirements including contents and formatting.
  • Coordination with the local AHJ for submittals, permits, on-site inspections, etc. will still be necessary.

While modular buildings are subject to different inspection protocols, variances are still able to be sought at the State level if there are design aspects that do not meet the prescriptive requirements of the state code(s). Such variances should be pursued and received prior to final submission to the TPIA, to allow them to be captured in the review.

As more projects pursue the use of modular construction, stay tuned for additional information about this exciting method!

Remembering the Tragic Event

 March 26, 2020 marked the 6th Anniversary of the Line of Duty Deaths of Boston Fire Lieutenant Edward Walsh and Firefighter Michael Kennedy. These firefighters died in the performance of their duties at a 9-Alarm fire at 298 Beacon Street, a Brownstone in Boston’s Back Bay neighborhood. An additional thirteen firefighters suffered non-life-threatening injuries as a result of the fire.

Lt. Edward Walsh was a Watertown, MA native and a second-generation firefighter, following in his father’s footsteps. Lt. Walsh was a 10-year veteran of the Boston Fire Department having been appointed in 2004 and was promoted to the rank of Lieutenant in 2012. Lt. Walsh is survived by his wife and three children.

Firefighter Michael Kennedy was a U.S. Marine and Iraq War Veteran prior to joining the ranks of the Boston Fire Department. Firefighter Kennedy spent his time volunteering with numerous organizations including the Boston Burn Foundation, Wounded Warriors, Home for Our Troops, and Mass Fallen Heroes, as was well volunteering as a “Big Brother.” Firefighter Kennedy is survived by his father, mother, and step-father.

The cause of the fire was determined to be non-permitted & careless performance of hot work operations at a construction site.

Nothing about this fire was ordinary; Fire Commissioner Joseph Finn (Ret.) stated “In 30 years, I’ve never seen a fire travel that fast, escalate that quick, and create such havoc, in such a short period of time.” Strong winds fueled extreme fire conditions which resulted in the fire hose used by Lt. Walsh and FF Kennedy burning through, leaving them trapped by the fire in the basement without water. Firefighters fought valiantly to control the fire while simultaneously attempting to rescue their colleagues.

Resulting Changes in Regulation, Enforcement, and Certification.

The subsequent response to this fire has not been ordinary, either. It is all too often that fires occur where “lessons learned” are forgotten or are not acted upon. In the 6 years following this fire, significant advancements have been and continue to be made in the following areas:

  • Fire Hose Research: Efforts lead by The Last Call Foundation, Worcester Polytechnic Institute (WPI), the National Fire Protection Association (NFPA), the Fire Protection Research Foundation, and the Boston Fire Department, amongst others, continue to evaluate the performance of fire hoses. These efforts include performance testing of existing hoses and researching potential materials for use in fire hose construction. NFPA 1961, Standard for Fire Hose, was also changed to require hose manufacturers to test new fire hose for radiant and conductive heat resistance.
  • Construction Fire Safety: In 2015, with the adoption of an amended version of NFPA 1 as the Massachusetts State Fire Prevention Code, the City of Boston continued to require comprehensive Construction Fire Safety Plans as a condition of obtaining a building permit application.  This was followed with subsequent enforcement by way of periodic inspections completed by Boston Fire and Inspectional Service Department officials. This approach was quickly adopted by surrounding metro-Boston cities and towns with continued widespread enforcement across the Commonwealth.
  • Hot Work Safety Requirements: In January of 2017, the City of Boston required any individual applying for a hot work permit to first obtain a Hot Work Safety Certificate and all persons performing hot work onsite to possess the same certificate. Subsequently, Massachusetts implemented a statewide requirement in July of 2018 requiring that persons performing, permitting, or overseeing hot work operations to attend a state-approved hot work safety training.

For those interested, below please find links to non-profit charity organizations started the families of these firefighters:

https://www.lastcallfoundation.org/accomplishments

http://edwalshfoundation.org/

A major factor that affects the design of dormitory buildings is the number of required accessible units. Both the IBC and the ADA require a certain number of accessible units based on the total number of dwelling units or sleeping units. Traditional dormitories were designed with multiple sleeping rooms accessed from a common corridor and group bathrooms that are shared by the entire floor. Determining the minimum number of accessible rooms for this type of configuration is simply based on the number of sleeping units. However, the design of dormitory buildings has changed in the past 10 to 15 years to include many more suite or apartment style units. These units are configured with multiple bedrooms having dedicated bathrooms, kitchens or both within the suite or apartment. Similar to the evolution of design, the code has also evolved, which can be costly to projects if missed.

Section 1107.6.2.3 of the 2015 IBC was changed to address suite and apartment style units. The following sentence was added at the end of the section:

Where the sleeping units are grouped into suites, only one sleeping unit in each suite shall be permitted to count towards the number of required Accessible units.

 The commentary for this section states the following:

The new style of dormitory living is groups of bedrooms that share a common living space, sometimes with a kitchen or kitchenette. If these are counted as dwelling units instead of sleeping units, the number of Accessible rooms available may be less, or multiple bedrooms in the same suite would be interpreted to all be Accessible units. Administratively, when housing students, the universities still treat this style of units as the old-style dorm rooms down a long hallway. The last sentence is intended to make clear that for the purpose of determining the number of Accessible units, the bedrooms in any congregate residence must be counted separately. In a suite configuration, only one of the sleeping units can be counted as part of the required number of Accessible units.

Though not specifically stated in the 2015 IBC, the commentary states that each bedroom in a suite or apartment should be counted separately when determining the minimum number of required accessible bedrooms. Also, the code language only allows one bedroom in each suite/apartment to count as an accessible unit. The language in the 2015 IBC is specific to sleeping units, which can be interpreted in different ways if the dormitories are dwelling units (with kitchens and bathrooms). To clarify this the 2018 IBC was revised as follows:

Bedrooms within congregate living facilities, dormitories, sororities, fraternities and boarding houses shall be counted as sleeping units for the purpose of determining the number of units. Where the bedrooms are grouped into dwelling or sleeping units, only one bedroom in each dwelling or sleeping unit shall be permitted to count toward the number of required Accessible units (2018 IBC 1007.6.2.3).

Though it is open to interpretation under the 2015 IBC, it is clear under the 2018 IBC that (1) each bedroom in a suite/apartment is counted separately when determining the minimum number of required accessible units and (2) only one bedroom in each accessible suite/apartment can count towards the minimum number of required accessible units. Since most suites/apartments tends to have 4 to 6 bedrooms, this can result in having many more accessible suites/apartments than most design professionals would plan under legacy codes.

Smoke control equipment is subject to the signage requirements contained in Chapter 9 of 780 CMR, the Massachusetts State Building Code.  Section 909.14 states that “detection and control systems shall be clearly marked at all junctions, accesses, and terminations”.  Section 901.9 requires fire protection equipment and room signage to be constructed of durable materials, permanently installed, with letters and symbols of at least 2” in height with coloring of a contrasting background visible from a distance of 10’ away.  The Boston Fire Prevention Regulations further elaborates on color contrast requirements, where signage should incorporate red letters on a white background or white letters on a red background.

The following should be considered as it relates to smoke control equipment marking and identification.

  • Fan signage should be located such that it can be read from no less than 10 feet away and should be conspicuously located to allow for easy identification by first responders and building engineers. It should indicate the fan tag and system it serves. e.g. “Stair 1 Pressurization Fan (SPF-1)” or “Atrium Smoke Exhaust Fan (SEF-1)”.
  • If the placement of the fan sign is not adjacent to it’s service disconnect, the disconnect should be identified with markings suitable for the size of the disconnect. e.g. “SPF-1 Disconnect”
  • Motor controllers or Variable Frequency Drives should clearly indicate the fan and system it is associated with. e.g. “SPF-1 VFD – Stair 1 Pressurization”. This signage should be as large as reasonably practical for the room it’s located within.
  • Labeling on fire alarm monitor modules, control relays and other associated fire alarm devices should be provided.
  • Junction boxes containing power or control wiring should be labeled in accordance with NFPA 70 and clear as to the smoke control system it serves.
  • Access hatches that provide a means of servicing concealed smoke control equipment should be signed.

Make sure to check with the local fire department to understand any specific life safety system signage expectations.

Cambridge has joined Boston in shutting down all nonessential construction sites due to COVID-19. Construction sites have until Saturday, March 21, 2020 to stop all construction activity and transition only to make-safe work. By 5:00 PM on Thursday, March 26, all make-safe work must be completed. Any work continuing beyond the above dates must be deemed “essential” by the Commissioner of Inspectional Services or the Commissioner of Public Works.

Cambridge has additionally stopped the issuance of building permits, trade permits, and licenses from ISD or PWD effective Thursday, March 19, 2020, except for essential work.

The City has defined “essential work” as the following:

  • Emergency work to address leaks or utility failures
  • Utility connections or repairs if stopping work is a health or safety hazard,
  • Essential to maintain life safety systems,
  • Maintaining safety and connectivity of the transportation network,
  • Emergency work to make a building safe or sanitary (repair to failed heat, plumbing, or electrical systems)
  • Work in connection with providing health services related to COVID-19
  • Work directly associated with COVID-19 mitigation such as shelters, temporary health care facilities, or related laboratory research,
  • Maintenance of make-safe measures previously completed at job sites
  • Authorized building or utility work to render occupied buildings habitable,
  • Work determined by the Commissioners of Inspectional Services or Public Works as essential

Any of the above exceptions still need to be authorized by the Commissioners, as the approval is not automatic.

Construction of one-, two-, or three-family residential structures that was already permitted is not impacted by the moratorium.

For additional information on safely securing work sites and/or assistance in modifying your NFPA 241 Plans to represent this intermediary state, please click here.