A common concern raised with some renovation projects is that level 2 alteration work needs to be limited to 50% of the building area; otherwise, the project will be classified as a level 3 alteration and the building will need to be brought up to full compliance with the current code. This is a common misconception that can lead to increased costs and schedule delays both in design and construction. To understand why, it is important to know the following three classifications/definitions from the 2015 International Existing Building Code (IEBC):
- A level 2 alteration includes the reconfiguration of space, the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment (2015 IEBC 504.1).
- Level 3 alterations apply where the work area exceeds 50 percent of the aggregate building area (2015 IEBC 505.1).
- A “work area” is defined as the portion or portions of a building consisting of all reconfigured spaces as indicated on the construction documents. Work areas exclude other portions of the building where incidental work entailed by the intended work must be performed and portions of the building where work not initially intended by the owner is specifically required by the IEBC code (2015 IEBC 202).
To have a level 3 alteration, the project needs to have a work area (consisting of reconfigured spaces) that exceeds 50 percent of the aggregate building area. A project could have level 2 alterations in 100% of the building area and not trigger a level 3 alteration. An example would be the installation of a new sprinkler system throughout the building without any other alterations occurring.
Another concept is that the work area does not include unintended work. For example, if the project triggers upgrades in other areas of the building, such as accessibility upgrades, these areas would not be considered part of the project work area – and therefore not contribute to the 50% calculation.
Lastly, if the project does include a level 3 alteration, the building is not required to be brought up to full compliance with the current code. The requirements associated with level 3 alterations are intended to improve the safety of certain building features beyond the work area and in other parts of the building where no alteration work might be taking place. Similar to going from a level 1 alteration to a level 2 alteration, there are additional requirements when a project changes to a level 3 alteration; however, the code does not require the entirety of the building to be brought up to full compliance with the code for new construction.
To fuel the progress of construction across the city, access to electrical power is needed by General Contractors and Sub-Contractors to perform everyday operations. In some cases, access to adequate permanent electrical power is simply not achievable. Thus, your construction may be provided with a portable generator in lieu of permanent electrical power. Should this be the case, the General Contractor is required to pull a generator permit via the City of Boston Fire Prevention online portal. Specifically, this application will require the submission of both:
- A specification sheet for the generator being used; and
- A general site plan for the location of Fuel Storage that shows both the location of relevant equipment and the fuel storage
As a reminder, access to permit requirements and the online application portal may be found at the following link (https://www.boston.gov/departments/fire-prevention/fire-forms-permits-applications-and-fees#construction-related). Additionally, the following is a list of permits that general contractors will likely need at the beginning of the project’s construction phase:
- Construction Fire Safety Permit
- Temporary Dumpster Permit
- Bagging Smoke Detectors
- Fuel Storage
- Temporary Heat
- Emergency Generators – temporary for the project
Both the presence and the location of these pieces of equipment must be captured with the project’s NFPA 241 Construction Fire Safety Plan. Have any questions related to Construction Project NFPA 241 Construction Fire Safety Plans? Feel free to reach out to info@crcfire.com for additional information.
As the number of laboratory fit out projects has increased over the years, one requirement in particular has stood out as commonly being overlooked, yet remains one of the most critical when determining the feasibility of a project: the floor rating requirement for control areas. The building code requires that floor assemblies of control areas and all supporting construction extending down to the foundation of the building have a 2-hour fire-resistance rating. Numerous laboratory fit out projects have been proposed in buildings with 1-hour or non-rated floor construction, leading to unanticipated complications that potentially have a major impact on the overall feasibility of the project.
Part of the confusion stems from the fire-resistance ratings specified in Table 414.2.2 of the IBC. For Levels 1-3 above grade plane, the required fire-resistance rating for fire barriers is shown to be 1 hour. Further, there is a footnote indicating that the fire-resistance rating is to be applied to fire barriers and horizontal assemblies to provide separation from other portions of the building. However, as noted in the IBC commentary, these ratings are not intended to apply to floor construction, but rather to the walls of the control area and the horizontal assembly above the control area. The required rating of the floor construction is specified in Section 414.2.4, which states that “the floor assembly of the control area and the construction supporting the floor of the control area shall have a fire-resistance rating of not less than 2 hours.”
Are there any exceptions?
The building code does allow control areas to have 1-hour floor construction and supporting construction in cases where all of the following criteria are met:
- The building is Type IIA, IIIA, or VA construction (all of which require 1-hour floor assemblies)
- The building is three or fewer stories above grade plane; and
- The building is equipped throughout with an automatic sprinkler system in accordance with NFPA 13.
What options are available?
If a laboratory fit out is proposed within a building that does not have the required 2-hour floor construction, there are a few options available, including but not limited to:
- Utilizing a multi-story control area approach in cases where lower chemical quantities are needed. For multi-tenant buildings, the feasibility of this option depends on the other tenants within the building, as a multi-story control area is shared among building occupants and is often dependent on the lease agreement.
- Limiting the location of chemical usage within a building (e.g. on the first floor only) such that control areas are not needed on the upper levels.
- Rating the floor assembly and supporting construction to provide the required 2-hour rating. This can be the entire floor or a small portion of the floor to be used as centralized chemical storage.
- Constructing a High-Hazard Group H occupancy to accommodate larger quantities of chemicals.
If you have any questions or would like assistance with applying these options to a project, please do not hesitate to contact us.
Elevator recall for firefighter operations is a required function in all automatic elevators per 524 CMR, the Massachusetts State Elevator Code, which is an amended version of ASME A17.1 – 2013 Edition. Elevator recall is comprised of two distinct phases, each with their own controls, actions, and requirements.
Phase I Elevator Recall
Phase I elevator recall is an automatic sequence initiated by the fire alarm system to relocate an elevator cab to the designated recall floor. Activation of an automatic fire alarm initiating device located directly adjacent to an elevator door, an elevator hoistway, or within rooms or spaces containing elevator machinery and/or controls will result in associated automatic elevators initiating Phase I recall.
- Phase I recall will bring all elevators to the primary floor, with or without passengers.
- In the event that smoke is detected immediately adjacent to the elevator doors on the primary floor, Phase I recall will take the elevator to the alternative floor.
- The Fireman’s hat will illuminate steady when the elevator car is placed in Phase I recall. The Fireman’s hat will extinguish when the associated elevator car is put back into normal operation. The fireman’s hat will illuminate intermittently when the fire is in the hoistway or in the equipment/control room.
- Activation of the Fire Service Switch in the lobby will return the car to the primary floor.
Phase II Elevator Recall
Phase II elevator recall describes the fire department’s manual operation of elevators.
Fire Alarm Requirements
Every elevator (or group of elevators in the same hoistway) will need the following fire alarm devices:
- Smoke/heat detector in each elevator lobby on each floor;
- Smoke/heat detector in the elevator equipment room;
- Heat detector in hoistway, if permitted, if hoistway is sprinklered (Note: Sprinklers are not permitted in hoistways in MA)
- Relay for Primary Recall;
- Relay for Secondary Recall;
- Relay to illuminate Fireman’s Hat;
- Relay for Shunt Trip, if hoistway is sprinklered (Note: Shunt trip is not permitted in hoistways in MA)
- Monitor or zone for Shunt Trip Power Fail, if hoistway is sprinklered
*Please note that hoistway ventilation is no longer required under the newest edition of 524 CMR. Please find our other insight on elevators here for more information on this topic.
Since 1995, the Joint Commission required hospitals to maintain their Basic Building Information (BBI) and Plan for Improvement (PFI) as part of their Statement of Conditions (SOC). The BBI summarized various life safety-related features associated with the facility, while the PFI allowed hospitals to manage self-identified deficiencies which could not be immediately corrected related to NFPA 101, Life Safety Code and construction projects. The PFI was particularly a useful tool, as it prevented surveyors from citing deficiencies which were already sufficiently identified and managed by the hospital in accordance with their interim life safety measurement (ILSM) policy. In August 2016, the Joint Commission changed their survey approach and stated that all deficiencies identified would now be cited during a survey, without any special consideration given to those listed already on the PFI. The PFI list continued to remain as a tool for hospitals to manage their NFPA 101 deficiencies, however most facilities chose to no longer use this process part of the SOC, instead relying on their own internal work order or tracking system. The BBI also remained as an optional tool, however was no longer being reviewed as part of the survey process.
As of January 1, 2020, the Joint Commission has added the BBI back as a requirement and it will now have its own Element of Performance (EP). LS.01.01.01, EP 7 will require that “the hospital maintains current basic building information (BBI) within the Statement of Conditions (SOC)”. In addition to the past information required, the BBI will also now be required to include specific square footages of the hospital’s building(s). The intent behind the accurate square footages is to assist the Joint Commission in more accurately determining the number of days required for the organization’s building tour.
It is important that hospitals dust off and update their existing BBI, especially if it has not been re-visited since 2016. This should include making sure that the construction types and occupancy classifications align with that identified on the life safety plans so all information is accurate and consistent. Accurate square footages should also be added to ensure that all facility information is complete and up-to-date. Not sure if your BBI is accurate? Please don’t hesitate to contact us if you need someone to review this information prior to your next unannounced survey.
The 2010 ADA requires swinging door and gate surfaces within 10 inches of the finish floor or ground measured vertically to have a smooth surface on the push side extending the full width of the door or gate. Parts creating horizontal or vertical joints (paneled doors, door shoes, kick plates, etc.) must be within 1/16 inch of the same plane as the rest of the door. This requirement often creates compliance issues for paneled doors, door locks located at the bottom of the door and door hardware that run vertically along the door.
Section 404.2.10 offers the following four (4) exceptions, with Exception 2 being the most utilized for new construction and renovations.
- Sliding doors shall not be required to comply with §404.2.10.
- Tempered glass doors without stiles and having a bottom rail or shoe with the top leading edge tapered at 60 degrees minimum from the horizontal shall not be required to meet the 10 inch (255 mm) bottom smooth surface height requirement.
- Doors and gates that do not extend to within 10 inches (255 mm) of the finish floor or ground shall not be required to comply with §404.2.10.
- Existing doors and gates without smooth surfaces within 10 inches (255 mm) of the finish floor or ground shall not be required to provide smooth surfaces complying with §404.2.10 provided that if added kick plates are installed, cavities created by such kick plates are capped.
Have additional questions? Contact us at info@crcfire.com for more information.
The Massachusetts Architectural Access Board (MAAB), 521 CMR, is adopted through 780 CMR, the Massachusetts State Building Code, and serves as the accessibility standard for Massachusetts. Note that Massachusetts deletes ICC A117.1 in its entirety. With 521 CMR as the governing accessibility code, designers are generally presented with challenges that are not always prevalent in other jurisdictions. Therefore, it is common to find misunderstandings for scoping standards, and more specifically, the scoping for design of residential apartments and condominiums and the number of accessible units that are required to be provided in the building.
521 CMR addresses the scoping for residential apartments and condominiums in Chapter 9, Multiple Dwellings. The scoping criteria will require either Group 1 or Group 2A units, or a combination of both. It should be noted that this discussion does not include references to Transient Lodging Facilities (hotels/motels, inns, dormitories, etc.).
The following are the accessible units in defined in 521 CMR. The dimensional requirements for elements in these units are found in 521 CMR Chapters 42-47.
- Group 1 units: Applies to dwelling units that have features that can be modified without structural change to meet the specific functional needs of an occupant with a disability. Important to note that accessible routes throughout the unit are required in Group 1 units.
- Group 2A units: Applies to dwelling units that have features similar to Group 1, but have the additional feature of greater floor space to accommodate the needs of occupants who need such space due to their disability.
- Group 2B units: Applies to dwelling units that contain features that provide, at the time of initial construction, full accessibility without need for further modification.
The following is the criteria for number of accessible units vs. total number of units provided in each residential occupancy.
- New Construction
- Where 20 or more units for rent, hire, or lease are provided, 5% must be Group 2A.
- Remaining are required to be Group 1
- Where units are for sale (i.e. condominiums), 100% Group 1 are required (Group 2A are not required).
- 2% hearing impaired units (up to one unit is permitted to be both Group 2A and hearing impaired)
- Exception for townhouses, for Group 2A units only:
- Permits a fully accessible flat of comparable size, amenities, etc. to other townhouses
- Provide space for future installation of a wheelchair lift
- Provide space for the future installation of a residential elevator
- Existing Construction (assumes no addition)
- 5% Group 2A (if renovation exceeds 30% of the full and fair cash value of the building)
- Remaining are not required to be accessible (i.e. Group 1 not required).
It should be noted that on January 27, 2014 the Board voted to clarify the definition of a townhouse. The townhouse shall be defined as “a single-family dwelling unit constructed in a group of three or more attached units in which each unit extends from foundation to roof with a yard or public way on not less than two sides. This is impactful to projects that include multi-story units within larger apartment buildings as these types of units are not considered townhouses per 521 CMR.
If you have any questions or concerns about the scoping details for different residential occupancies, please do not hesitate to contact us.
Given their unique hazards and challenges, “Nightclubs”, special requirements are included in the building code in the State of Massachusetts.
“Nightclubs” are specifically defined as “An assembly occupancy with a high occupant load density that is generally characterized by at least two of the following: low lighting levels; music generating above-normal sound levels; nighttime operating hours; tables and seating that create ill-defined aisles; a specific area designated for dancing; or service facilities for beverages with limited food service.”
As part of a state-specific amendment, Massachusetts regulates the following aspects of all nightclubs that have 50 or more people:
- Sprinkler protection required throughout buildings containing a nightclub
- Limitations on the use of foam plastics and interior finishes within nightclubs
- Activation of the fire alarm system will automatically turn on all house and means of egress lighting, as well as stop all other sounds (e.g. music, etc.) and visual distractions (e.g. dance lighting, etc.) throughout the nightclub and means of egress therefrom
- Main exit required from the nightclub, which is sized to be a minimum of 72” (or as required by 780 CMR Section 1029.2, whichever is greater) and consists of a pair of side-hinge swinging doors without a center mullion
The application of the nightclub classification can be interpretive and prove to be relatively far-reaching given the broad definition in 780 CMR, and the specific requirements can be hugely impactful to a project’s design. Questions on the application of the above definition or requirements? Give us a call.
Many construction sites require the overnight storage of flammable and compressed gasses/liquids to accommodate welding and other operations. This is not permitted in many jurisdictions without a permit from the authority having jurisdiction. Specifically, in Boston, this necessitates a BFD General Permit to allow for overnight storage. This general permit is in addition to the hot work permit, which allows for the operations to be performed by the applicant. The General Permit should be sought by either the general contractor or subcontractor. As part of the application, supplemental information justifying the quantity, location, proposed mitigation, and reasonableness of the proposed storage arrangement is required.
One commonly sought approach is to store gas cylinders and liquid containers in “stalls” overnight as to reasonably protect the noncompatible materials and separate those materials from each other, adjacent properties, and the building under construction. The minimum recommended arrangement is as follows:
- Cylinders/containers will be stored in “stalls,” that extend at least 18-inches above and beyond the tallest cylinders on the sides. The partitions will be 1-hour fire rated, though there will not be a front or ceiling to the “stall.” The cylinders will be kept upright and secure by means of chains or other approved means;
- Incompatible materials will be located within separate stalls:
- Acetylene
- Oxygen
- Propane
- Gasoline/Diesel
- The stalls will be located in an area that allows for ventilation such that the buildup of flammable gas is less likely, and if stored within a building mechanical ventilation may be necessary;
- Said cylinders will not be located closer than 35-feet from any combustible materials;
- The cylinders will be located in a manner where they are less likely to be affected by construction operations.
If you require assistance in developing a fire safety plan to accompany your fuel storage permit or are interested in learning more, email peterh@crcfire.com .
The 9th Edition of 780 CMR, which adopts and amends the 2015 International Building Code (IBC), requires that all new buildings be provided with emergency responder radio coverage unless otherwise approved by the AHJ to use wired communication systems. All radio systems must therefore be installed in accordance with 780 CMR Section 916 as well as NFPA 72 Section 24.5. We are often fielding questions about these systems, particularly associated with the required rating of the components where a bi-directional amplifier (BDA) system is installed.
In accordance with Section 24.3.6.8 of NFPA 72. What is commonly missed in NFPA 72 is that the rooms which contain the BDA signal booster panel are also required to be located within a 2-hour fire-resistance rated enclosure.
