There are two primary components to maintain a fire-safe construction site:
Phase 1
Development of a relevant Construction Fire Safety Plan (hereafter referred to as “the Plan”). The Plan must be specific to the project means/methods, associated hazards, proposed mitigation, logistics, etc. that will be present on a particular project(s). This Plan may be requested at the time of permit application. In any case, the Plan should be submitted to the authorities having jurisdiction (AHJ) proactively. The Plan must remain current based on changing site conditions and must remain available at the project location. The qualifications of the responsible party who authors the Plan is at the discretion of the AHJ and will vary based on the complexity of the project.
Phase 2
Implementation of the Plan. Every construction project must identify an individual(s) who is responsible for the implementation of the Plan. This individual(s) is referred to as the Fire Prevention Program Manager(s) (FPPM(s)). Depending on whether the construction project is a new development or is occurring in an existing building, the FPPM(s) will either be employed by the general contractor, owner, or third party. The reasonableness of who is serving in this capacity is at the discretion of the AHJ. Implementation is most often the most important function for achieving compliance with NFPA 241 and, more importantly, construction fire safety.
To learn more about writing an appropriate Plan for your project or how to implement said plan with ever-changing logistics, contact peterh@crcfire.com.
527 CMR and 780 CMR both require every outside opening accessible to the fire department that opens directly on any hoistway or shaftway communicating between two or more floors be plainly marked with a sign. The sign must have red letters on a white background that reads “SHAFTWAY” with letters that are at least 6 inches high. All required signage must be readily visible from the outside of the building. The purpose of the requirement is to warn responding personnel that such openings would be unsafe for landing a ladder on or gaining access through. The applicable requirements are found in 527 CMR 10.11.2 and 780 CMR 914.1. The figure at left is taken from the 2015 IBC Code Commentary – Volume 1, Figure 914.1.1.
The permit process can often be a challenging endeavor and one that can often impact project timeframes bottom lines. Understanding the required documentation at each step along the permitting process can help mitigate unnecessary pitfalls that are commonly felt by the applicant.
In Massachusetts, the document submittal process includes three (3) tiers of submittals per 780 CMR §901.2.1, Massachusetts State Building Code:
- Tier I – Construction Documents
- Tier II – Shop Drawings
- Tier III – Record (As-Built) Drawings
Prior to altering an existing building or erecting a new building, a building permit must first be acquired from the building department. In order to obtain a building permit, Tier I Construction Documents must be submitted and approved by the building department.
Tier I Construction Document packages are required to be produced by a Registered Design Professional and must contain sufficient information to completely describe each fire protection system(s) for which a permit is requested. This information is typically conveyed via the following documents:
- Design Drawings, stamped by the RDP
- Specification(s)
- Design Narrative Report, stamped by the Registered Design Professional (RDP)
- Minimally includes the design methodology, sequence of operations, and testing criteria
Tier II Shop Drawing packages are then generated by the installing contractor and are submitted to both the building and fire departments prior to installation/demolition or alterations to systems once the building permit has been issued. Tier II documents typically include the following:
- Design Narrative Report from the RDP
- Shop Drawings
- Generally includes of greater detail than that of the Tier I drawings
- Details depicting the interface to fire safety control functions and classification of supervising station for fire alarm projects
- Contains the installing contractor’s name, license number and license expiration date
- Manufacturer’s Data Sheets for all equipment and material(s)
- Calculations
- Hydraulic calculations for water-based fire protection systems
- Battery calculations and voltage drop calculations for fire alarm systems
Once the Shop Drawings are approved, the system(s) can be installed. The only way to close out a Tier II permit is for the building and fire officials to accept the installed system(s) which generally includes a final acceptance test with the AHJ and/or a 3rd Party present.
Tier III documents are generated by the installing contractor and are required to be submitted to the building owner. The drawings must indicate the approved, as-built condition of the system(s), which may deviate from the Tier II Shop Drawings. These documents must be provided to the building owner prior to any acceptance testing.
The requirements for building permits are often overlooked and misunderstood. 780 CMR, Massachusetts State Building Code, Section 105 addresses when building permits are required. Building permits are essential to help ensure that work is being completed correctly and safely. It is illegal and unlawful to complete work without first filing an application with the building official and obtaining the required permit, unless the work is otherwise exempt.
In general, a permit is required for most activities that are regulated by the Code and its referenced standards, and these activities cannot begin until the permit is issued by the building official. There are some cases where work such as repairs and finish work do not require a permit, although the work must still be completed in accordance with the applicable codes. The Q&A below has been developed to help clearly understand when building permits are required, when permits aren’t required, and examples of such work. These requirements are related to the Base (Commercial) Volume of 780 CMR.
When Is A Building Permit Required?
A permit is required to construct, reconstruct, alter, repair, remove or demolish a building or structure; or to change the use or occupancy of a building or structure, or to install or alter any equipment which is regulated by 780 CMR, Massachusetts State Building Code (780 CMR 105.1). The permit must be granted by the building official prior to performing any work. Where replacement and repairs must be performed in an emergency situation, the permit application must be submitted within the next business day to the building official (780 CMR 105.2.1)
When Is A Building Permit Not Required?
A building permit is not required for ordinary repairs to structures (780 CMR 105.2.2). A repair is defined as “the reconstruction or renewal of any part of an existing building for the purpose of its maintenance or to correct damage.” (780 CMR 202). Ordinary repairs do not affect the structure, egress, fire protection systems, fire rating, energy conservation, plumbing, sanitary, gas, electrical or other utilities. A building permit is also not required for the following activities:
- One-story detached accessory structures used as tool and storage sheds and similar uses that are less than 120 square feet;
- Fences not over 7 feet high;
- Oil derricks;
- Retaining walls that are not over 4 feet in height;
- Water tanks supported directly on grade if the capacity is not greater than 5,000 gallon and the ratio of height to diameter or width is not greater than 2:1;
- Sidewalks and driveways not more than 30 inches above adjacent grade and not over any basement or story below and are not part of an accessible route;
- Painting, papering, tiling, carpeting, cabinets, counter tops, and similar finish work;
- Temporary motion picture, television, and theater stage sets and scenery;
- Prefab swimming pools accessory to Group R-3 that are less than 24″ deep, are not greater than 5,000 gallons, and are installed entirely above grade;
- Shade cloth structures constructed for nursery or agricultural purposes, not including service systems;
- Swings and other playground equipment accessory to one- and two-family dwellings;
- Window awnings in Group R-3 and U occupancies supported by an exterior walls and do not project more than 54 inches from the exterior wall and do not require additional support;
- Nonfixed and movable fixtures, cases, racks, counters and partitions not over 5’9” in height;
- Greenhouses covered exclusively with plastic firm used for agricultural purposes only;
- Replacement or repair of any component or components of a fire protection system, where such does not affect system performance and compatibility. Note that permits are required related to the impairment or temporary disconnecting of fire protection systems by the fire official.
What Are Samples of Work Requiring a Building Permit?
- Installation, removal, or reconfiguration of a wall, partition, door, or window.
- Installation, removal, or modification of any structural column, beam, or other load-bearing supports.
- Removal or change of any required means of egress including security or door-locking hardware.
- Rearrangement or change in occupancy that affects egress, mechanical systems, or other requirements affecting public health.
- The addition, alteration, replacement, or relocation of fire protection systems such as sprinkler, standpipe, or fire alarm systems.
Note that additional permits may be required the State Fire Code, State Plumbing Code, and Electrical Code.
Under the Massachusetts State Building Code, 780 CMR, the width of a stairway is typically measured from outside stringer to outside stringer. Stairways are required to have a minimum width of 44”. Handrails are permitted to project into the required minimum width by a maximum of 4 ½” on each side of the stair.
If a floor has a total occupant load of less than 50 people, the minimum width of a stairway can be reduced to 36”.
In non-sprinklered buildings, stairways serving as an accessible means of egress are required to provide a minimum width of 48” between the handrails. Additionally, exterior stairs serving as a means of egress for an exterior area for assisted rescue are also required to provide a minimum width of 48”’ between handrails.
Have questions on how this affects your design? Contact us with questions regarding minimum stair widths!
What is “egress convergence” and when am I required to evaluate it?
Egress capacities are typically evaluated on a floor-by-floor basis, with the occupant load of each story considered individually in calculating the required capacity. The exception to this approach is where egress convergence results in two floors arriving at a component simultaneously (see image at top left).
Egress convergence occurs where the means of egress from stories above and below converge at an intermediate level, with occupants from multiple floors discharging through an egress component simultaneously. For example, in the second image, the egressing occupants from the 1st and 2nd Floors converge at the exit discharge door from Stair 1.
Where egress convergence occurs, the capacity of the means of egress component following the convergence is required to be the larger of (1) not less than the largest minimum width, or (2) the sum of the required capacities for the stairways or ramps serving the two adjacent stories (780 CMR 1005.6).
Egress convergence can result in drastically reduced egress capacities and allowable occupant loads from floors unless accounted for. When calculated, egress convergence may result in an increase in exit discharge door width, or the need for a double door at the exit discharge instead of a single door.
(Source: International Building Code (2015) Illustrated)
Through Floor Penetrations of Non-Rated Floor/Ceiling Slabs
A commonly asked question is whether or not penetrations of floor slabs, floor/ceiling assemblies, and roof/ceiling assemblies that are otherwise not required to be fire resistance rated, require protection by an approved through-penetration firestop system to maintain the integrity of the floor slab. In accordance with 780 CMR 714.5, the protection of such penetrations is dependent on the type of penetrant and the number of stories penetrated as outlined below:
1. All combustible penetrating items connecting more than two-stories and all noncombustible penetrating items connecting more than five-stories are required to be protected within a shaft in accordance with 780 CMR 713.
2. For all penetrating items connecting not more than two stories, the annular space of the penetrating item is required to be fireblocked in accordance with 780 CMR 718.2.5 to resist the free passage of flame and products of combustion (780 CMR 714.5.2). Such materials include batts or blankets of mineral wool or mineral fiber installed such as to be securely retained in place or cellulose insulation installed as tested for the specific application without requiring the application to be a listed firestopping assembly (780 CMR 718.2.1).
3. For all noncombustible penetrating items connecting not more than five-stories, the annular space of the penetrating item is required to be fireblocked in accordance with 780 CMR 718.2.5 to resist the free passage of flame and products of combustion or be filled with a fill, void, or cavity material that is tested and classified for use in a through-penetration firestop system (780 CMR 714.5.1). As such, these penetrations may either be protected as outlined by Item 2 above or the annular space may be filled with a listed product such as intumescent firestopping without requiring the application to be a listed firestopping assembly.
Continue to monitor the Code Red Consultants Blog for code updates and search “Firestop” for more information on firestopping assemblies are when Third Party Firestopping Special Inspections are required.
The 9th Edition of 780 CMR requires existing buildings to comply with the Flood Load requirements of Section 1612 if the building is undergoing substantial improvements, is being restored due to substantial damage, or is undergoing a substantial repair of a foundation. Section 1612.1 reads as follows:
1612.1 General. Within flood hazard areas as established in section 1612.3, all new construction of buildings, structures and portions of buildings and structures, including substantial improvement and restoration of substantial damage to buildings and structures, and substantial repair of a foundation shall be designed and constructed to resist the effects of flood hazards and flood loads. For buildings that are located in more than one flood hazard area, the provisions associated with the most restrictive flood hazard area shall apply.
Substantial improvement, substantial damage, and substantial repair of a foundation are defined in Chapter 2 of 780 CMR and by Federal Regulations. Substantial improvement is work that equals or exceeds 50% of the market value of the building before the improvement is started. Substantial damage is damage of any origin that requires restoration to the building to its before-damaged condition that would equal or exceed 50% of the market value of the building before the damage occurred. Substantial repair of a foundation includes work to repair or replace 50% or more of the perimeter along the base of the foundation measured in linear feet, or repair or replacement of 50% or more of the piles, columns or piers of a pile, or column or pier supported foundation.
If compliance is required, the existing building must comply with 780 CMR and the 2014 Edition of ASCE 24. Note that the 9th Edition of 780 CMR amends the definition of Design Flood Elevation to be the same as Base Flood Elevation.
This past June we posted a blog on the significant changes to the 9th Edition of 780 CMR which is based on the 2015 International Building Code (IBC). One of these posts included a requirement for a firestopping special inspections within high-rise or risk category III or IV buildings. A link to this blog post can be found here.
Since the posting of this blog, there have questions as to how these requirements would apply to existing buildings. The answer to this question is regulated by the requirements 780 CMR 34.00, Existing Building Code of Massachusetts, which references the 2015 International Existing Building Code (IEBC). There is a fundamental requirement of 780 CMR 34 that requires both additions and alterations to existing buildings to comply with the requirements of 780 CMR for new construction. As such, an addition or renovation project in high-rise or risk category III or IV buildings that includes firestopping as part of the project work will require firestopping special inspections in accordance with 780 CMR 1705.17. The special inspections would be limited only to newly installed firestop systems. Existing-to-remain firestop systems would not fall within the scope of the firestop special inspections.
If you are in need of help on firestopping inspections in either a new or existing building, please do not hesitate to give us a call.
It’s become a relatively common place occurrence for designers to utilize sprinklers on glass windows in place of a fire rated wall that is required by the International Building Code or 780 CMR, the Massachusetts State Building Code. Under the 2015 International Building Code (IBC), which is adopted as the basis of 780 CMR 9th Edition, the compliance path to utilize sprinklers on glass in place of a fire-resistance rated wall has changed and may be more challenging than it was in the past to get them approved.
Section 703.4 of the 2015 IBC states that automatic sprinklers are not permitted to be utilized when determining the fire resistance of a wall assembly in accordance with the ASTM E119 or UL 263 fire test standards. The section continues to clarify that while it is not permitted by Ch. 7 of the IBC, such wall assemblies may be approved under Section 104.10 and 104.11 as an alternative method where approved by the building official. The Tyco WS Window Sprinkler is a common product designers utilize on a glass wall in place of a traditional fire rated wall. This product does have test data illustrating that it was tested in accordance with the ASTM E119 test and achieved a 2-hour rating with heat-strengthened or tempered glass although specific design limitations apply. It is critical to provide the necessary product data to the building official for their review and approval. The change to Chapter 7 of the IBC does not explicitly prohibit use of this product or similar ones, but puts the path to approval through Chapter 1, where evaluation and the documented approval of the approach is at the discretion of the approving authority.
It’s worthy to note that this requirement does not apply to atrium boundaries, as there is a separate exception specifically for atrium walls that allows the use of a glass wall with sprinklers spaced 6-feet on center that are designed to wet the entire surface of the glass in accordance with Section 404.6 of the IBC. This exception is not subject to the requirements of the language in Ch.7 because it is located within the special use and occupancy section of the code and exists for atriums because of the other protection features required to be provided, such as smoke control systems. This exception cannot be utilized for walls located outside of an atrium.
Do not hesitate to give us a call if you need help evaluating if you can utilize a glass wall assembly with sprinklers on your project.
