Insights Category: Technical Information

There are several new changes affecting health care design and construction associated with the upcoming 9th Edition adoption. The 9th Edition of 780 CMR is an amended version of the 2015 International Building Code (IBC). These changes include smoke damper omissions, occupancy classifications, smoke compartment and suite sizes, and third party firestopping inspections.

Smoke Dampers

Likely the most impactful change in the upcoming 9th Edition is the new exception in Section 717.5.5 that allows the omission of smoke dampers at HVAC duct penetrations in smoke barrier walls in Group I-2 occupancies. To qualify for the exception, the HVAC system must be “fully ducted” per Section 603 of the International Mechanical Code and the area is required to be protected with quick response sprinklers in accordance with Section 903.3.2 of the IBC. These conditions should be easily satisfied in new construction. Note that this new exception aligns with the requirements of NFPA 101 which have allowed smoke dampers to be omitted at smoke barrier walls since 1991. Read more about this change in our previous blog post here.

Occupancy Classifications

The use and occupancy classifications of buildings and structures are located in IBC Chapter 3. Hospitals, nursing homes, and behavioral health institutions have historically been classified as Group I-2, Institutional Occupancies. Under the 9th Edition, Group I-2 occupancies will now be separated into 2 different occupancy conditions. Condition 1 includes facilities that provide nursing and medical care but not emergency care, surgery, obstetrics, or in-patient stabilization units such as nursing homes and foster care facilities. Condition 2 includes facilities that provide emergency care, surgery, obstetrics, or in-patient stabilization units such as hospitals. The code requirements for the two conditions vary as indicated in IBC Section 407. This is an organizational change in the Code, however should not affect the code requirements in the built environment.

Smoke Compartment Size

Under the 8th Edition, the maximum smoke compartment size is limited to 22,500 square feet. This size is increased to 40,000 square feet in hospitals under Section 407.5 of the 9th Edition. Although this is a substantial change, it should be noted that most hospitals receive funding from the Centers for Medicare and Medicaid Services (CMS) and therefore are also required to comply with the 2012 Edition of NFPA 101, Life Safety Code. NFPA 101 Section 18.3.7.1 requires smoke compartments in new construction to not exceed 22,500 square feet and therefore this more stringent requirement still applies. Note that at the 2017 NFPA Conference & Expo earlier this month, the proposed code change to increase the smoke compartment size to 40,000 square feet in the 2018 Edition of NFPA 101 passed, however it still needs to be adopted by CMS in order to designers to utilize this less restrictive requirement.

Suite Size

The 9th Edition Section 407.4.4 allows considerable size increases for patient care sleeping and non-sleeping suites. These include permitting sleeping suites to be increased from 5,000 square feet to 7,500 square feet (10,000 square feet if full smoke detection in suite), and non-sleeping suites to be increased from 10,000 square feet to 12,500 square feet (15,000 square feet if full smoke detection in suite). However, like smoke compartment sizes, NFPA 101 is more restrictive in their suite size limitations. NFPA 101 Section 18.2.5.7.2 permits both sleeping and non-sleeping suites to be a maximum size of 10,000 square feet, which is more restrictive than the IBC for non-sleeping suites. This is another example of why hiring a life safety consultant like Code Red Consultants, that is familiar with both IBC and NFPA 101 provisions, is so critical to the success of your health care project.

Third Party Firestop Inspections

There is a new requirement in the 9th Edition which requires a special inspector for firestop systems in fire-resistance rated assemblies that are tested and listed where required by Chapter 7 of the Code. Section 1705.17 of the 2015 IBC requires the third party inspections for high-rise buildings as well as those buildings assigned to Risk Categories III and IV which includes all Group I-2 occupancies. Read more about this significant change in our Special Inspection article contained within this newsletter or on our blog.

There is a new special inspection requirement in the 9th Edition that owners, developers, contractors, and Authorities Having Jurisdiction (AHJ) will want to be prepared for when the new code comes into effect. Section 1705.17 of the 2015 Edition of the International Building Code (IBC), which is the basis of the 9th Edition, requires a special inspector for through-penetrations, membrane penetration firestops, fire-resistance joint systems, and perimeter fire barrier systems that are tested and listed where required by Ch. 7 of the Code.

Where does the requirement apply?

The new requirement will apply to high-rise buildings and to buildings assigned a risk category of III or IV per Section 1604.5 of the IBC. This table includes occupancies such as large assembly with occupant loads in excess of 300, educational occupancies with occupant loads over 250 occupants, most hospitals, jails/prisons, buildings with Group H, High Hazard Occupancies, and facilities housing emergency responders, among others. The requirement applies to any joint (i.e. head of wall intersection with floor construction), through penetration or membrane penetration of fire resistance rated walls, floors, and ceilings as specified on the project construction documents.

How do I know if I am installing the right firestopping prior to inspection?

Firestopping systems are approved assemblies and not products. The assemblies consist of the wall /floor construction itself, the penetrating item(s) or joint details, and the firestopping components utilized. The assemblies utilized are required to meet certain fire test standards and be listed by an approved testing agency. The tests illustrate that the specific assembly listed has passed the required fire test standard for a specified amount of time (i.e. 1-hour). The inspector’s role is to compare the installations viewed in the field with the details of the approved assemblies. All firestopping assemblies utilized should be included in an approved submittal for both the installer’s and inspector’s use.

How must the Inspections be Performed?

The code states that the inspections are to be performed in accordance with two ASTM Standards; ASTM E2174 governs penetration firestop systems and ASTM E2393 applies to joint systems. Some highlights on how the inspections are to be performed include:

  • Inspector is to witness the installation of 10% of each type of firestop system or perform destructive testing of 2% of each type of firestop system per floor or for each area of a floor when a floor is larger than 10,000 ft2.
  • Complete submittals showing all listed firestop assemblies are required to be provided to the inspector before they perform their inspections. This includes any engineering judgements that may be needed for assemblies which don’t meet all the details of a listed assembly.

Who can serve as the special Inspector?

The IBC states that the inspections are to be performed by an approved agency, which is defined as “An established and recognized agency that is regularly engaged in conducting tests or furnishing inspection services, where such agency has been approved by the building official.” The ASTM standards provide additional guidance on the qualifications of an inspector and state that an inspector should have a minimum of 2-years experience in construction field inspections and have education, credentials, and experience that is acceptable to the authorizing authority. The document goes on to address conflicts of interest and stipulates that the inspector should be independent from and not in competition with the manufacturer, contractor, installer, and supplier of the firestopping products.

The engineers at Code Red Consultants are all degreed fire protection engineers and have been engaged in performing fire stop inspections and evaluating firestop assemblies for over a decade. If we can be of assistance in evaluating if this requirement applies to your project or serving as the special inspector please do not hesitate to contact us.

Where is emergency egress signage required to be provided with the illuminated International Symbol of Accessibility?

The Massachusetts Architectural Access Board issued an interpretation on February 17, 2016 which clarified that all emergency egress signs, which are required to be illuminated and are part of an accessible means of emergency egress, are required to include the illuminated International Symbol of Accessibility.

It should be noted that this interpretation specifically references an accessible means of emergency egress per 521 CMR Section 5. 521 CMR Section 5 defines an accessible means of egress as one that complies with 521 CMR and does not include stairs, steps or escalators, as shown at left.

This definition is different than 780 CMR, which would recognize a stair as an accessible means of egress. However, since the interpretation is specific to the 521 CMR definition, exit signs with the International Symbol of Accessibility are required at the accessible building exits at the level of exit discharge only under the following scenarios:

  1. New construction
  2. Existing buildings undergoing a renovation that triggers 30% or more of the full and fair cash value of the building
  3. Existing buildings undergoing a renovation where new exits signs are being provided

The 2017 National Electrical Code was recently adopted by Massachusetts on January 1, 2017. Under this code, meeting rooms with an area of 1,000 square feet or less are now required to be provided with a minimum number of electrical outlets as follows:

  • Wall outlets shall be provided such that no point measured horizontally along the floor line of any wall space wider than 2 feet is more than 6 feet from an outlet (NEC 210.71(B)(1) & 210.52(A)). Floor outlets within 18 inches of the wall may be counted towards this requirement (NEC 210.52(A)(4)).
  • A meeting room that is at least 12 feet wide and that has a floor area of at least 215 square feet shall have at least one receptacle outlet located in the floor at a distance not less than 6 feet from any fixed wall for each 215 square or major portion of floor space (NEC 210.71(B)(2)).
  • Where a room or space is provided with movable partition(s), each room size shall be determined with the partition in the position that results in the smallest size meeting room (NEC 210.71(A)).

Once the minimum number of fixtures is determined, the outlets can be located as determined by the designer or building owner, and don’t necessarily have to fall within the dimensions above (NEC 210.71(B)). An example of two compliant layouts are shown at left. Due to the glass partitions in the lower room, the preference may be to locate the wall outlets to the stud wall.

Depending on your project, installing floor outlets may also create challenges, especially in existing buildings. Existing assembly spaces are permitted to remain as is; however new assembly spaces in existing buildings are subject to compliance with this requirement.

If you’re running into this on your project and are having difficulties developing a solution, please do not hesitate to contact us.

A major code change in the 2015 International Building Code (IBC), which will be the basis for the soon to be adopted 9th Edition of the Massachusetts State Building Code, that designers, contractors, and facility managers will want to be aware of is a new exception that allows the omission of smoke dampers at HVAC duct penetrations in smoke barrier walls in Group I-2 occupancies (Hospitals). To qualify for the exception, the HVAC system must be “fully ducted” per Section 603 of the International Mechanical Code and the area is required to be protected with quick response sprinklers in accordance with Section 903.3.2 of the IBC. These conditions should be easily satisfied in new construction. If you’re looking at removing existing smoke dampers from service based on this requirement, documentation would need to be submitted to the building official that the new construction requirements are met. Section 701.2 of the International Existing Building Code (IEBC) only permits the removal of existing life safety devices where the requirements of new construction are satisfied and the work is approved by the authority having Jurisdiction (AHJ).

Accredited Hospitals are also subject to NFPA 101, The Life Safety Code, 2012 Edition as adopted by the Center of Medicare and Medicare services. An exception has existed in NFPA 101 since 1991 to omit smoke dampers at penetrations of smoke barrier walls.

The ICC formed an Ad Hoc committee with the American Society of Healthcare Engineers (ASHE) in an effort to get better alignment of the code requirements between the building code and life safety code.

The impact of this code change is significant. A smoke damper requires relays to the electrical and fire alarm systems in a building and can cost anywhere from $5,000-$10,000 per damper installed. A new hospital construction can often require dozens of dampers per floor, so the upfront cost savings can be impactful. Further, facility managers are required to test smoke dampers 1 year after initial installation and every 6 years after that. This exception will also reduce the future testing and maintenance costs.

The basis of this code change is seated on the premise that the elimination of these devices is not negatively impacting the life safety in the building. Historical fire data and experience in hospitals shows the combination of quick response sprinklers with redundant levels of compartmentation are effective in preventing the spread of smoke and hot gas beyond the area of origin.

This exception applies to Group I-2 occupancies only and thus, ambulatory care facilities would not qualify. Additionally, smoke dampers would still be required at penetrations of elevator lobbies and 2 hour shafts, horizontal exits, and occupancy separations.

If you’re interested in learning more on how to implement this requirement in your facility, please do not hesitate to contact us.

Do you remember the last time you tested your building’s smoke control system?

Since the 1980’s, 780 CMR, The Massachusetts State Building Code, has required existing smoke control systems to be tested on a periodic basis to ensure continued functionality and performance. As a means of enforcement, when work is occurring within an existing building containing a smoke control system, the Boston Fire Department’s Certificate of Occupancy Division is now requiring evidence that these systems are being maintained and tested when requesting occupancy. Certificate of occupancies may be held up if proof of inspection and testing by a certified inspector cannot be provided. Having this documentation readily available is critical to ensure that the Certificate of Occupancy for your next TI project is not delayed.

What are the applicable codes where this is required?

527 CMR, the Massachusetts Comprehensive Fire Safety Code, requires that all smoke control systems be maintained in accordance with the manufacturer’s instructions and the building code to ensure that the system can control smoke for the required duration.

Further, a written record of testing and maintenance is required to be retained on the building’s premises.

As is required for all new systems, we recommend creating an inspection and maintenance plan that will serve as a guide to maintaining the building’s smoke control system. This document can be used to create a consistent testing methodology from year to year allowing for streamlined, cost effective testing.

How often is this required?

Dedicated smoke control systems are required to be tested semi-annually. Non-dedicated smoke control systems (shared with building’s normal HVAC) are required to be tested annually.

Who is Required to Test?

NPFA 92 requires testing to be performed by persons who are thoroughly knowledgeable in the operation, testing, and maintenance of the systems. New systems are required to be tested by a 3rd Party Special Inspector. Retesting should be performed by similarly competent entities. Smoke control system design has fundamentally changed in the codes over the past 30 years and finding individuals who are experienced with the specific types of smoke control systems in your building is critical to ensuring the appropriate testing is completed.

Contact Code Red Consultants at info@crcfire.com to assist with retesting your building’s smoke control system.

Metal stud cutting is one of the more typical practices on a construction site. Although common, metal stud cutting and its relation to hot work is not as clearly understood and/or applied. NFPA 51B defines hot work as “work involving burning, welding, or a similar operation that is capable of initiating fire or explosions”. Stud cutting falls under this definition particularly as a result of the sparks generated during the cutting process. This rationale is enforced by Boston Fire Department.

Below you will find a brief Q&A to help address some common questions associated with this practice.

Question: Is stud cutting considered hot work?

Answer: Yes, metal stud cutting meets the definition of hot work as prescribed in NFPA 51B (see above).

Question: Does stud cutting require an internal hot work permit per NFPA 51B?

Answer: Yes, all hot work requires an internal hot work permit.

Question: Does stud cutting require a BFD hot work permit?

Answer: No, BFD does not require a hot work permit for metal stud cutting.

Question: Is a dedicated fire watch always required for chop saw metal stud cutting even if a City hot work permit is not required?

Answer: A fire watch is always required for hot work operations, regardless if the city necessitates a permit from their office, and the chop saw metal stud cutting must be logged as required by NFPA 241. That said, there are some jurisdictions, such as Boston, that recognize that a separate dedicated fire watch is not warranted if specific safeguards are implemented. First, a fire extinguisher must be located at the chop saw table. Second, the chop saw operator must have a BFD certification for Hot Work. Third, the chop saw setup should occur on a noncombustible table, such as Baker staging. The chop saw work area should be encapsulated fully on three sides with DensGlass or the equivalent. The DensGlass should be tall enough to capture any sparks created by the metal stud cutting operation.The entry side should be encapsulated with DensGlass as well, but an opening is permitted to allow for a worker to comfortably cut the metal studs. The top photo is a representation of this type of chop saw arrangement. The bottom photo represents a metal stud cutting configuration that would require a fire watch, as the DensGlass surrounding the chop saw is not adequate to capture the sparks created by the metal stud cutting.

Effective January 2017, the City of Boston will require any individual applying for a hot work permit to first obtain a Hot Work Safety Certificate, as detailed in the BFD Hot Work Permit Application. Additionally, all persons performing hot work on the site will also be required to possess this certificate. The certificate can be obtained by attending a hot work training class, which is conducted by instructors who have been trained by NFPA, National Fire Protection Association. Upon successful completion of the class and the follow-up exam, individuals will be provided with said Hot Work Safety Certificate.

As a result of this change, hot work permits will not be distributed to anyone who do not possess the Hot Work Safety Certificate. If individuals conducting hot work are found to not hold a current Hot Work Safety Certificate, warnings, fines, or otherwise may be levied by city inspectors per the Boston Fire Prevention Code.

The good news: NFPA has just announced new training sessions that run through January 2017 on their website. Individuals who would like to sign up for January classes can do so here:

http://catalog.nfpa.org/Hot-Work-Safety-Certificate-Program-P16766.aspx.

More information on anything from the definition of hot work to the BFD-specific requirements of such can be found on the NFPA website:

http://www.nfpa.org/training-and-events/by-topic/hot-work.

The AGC MA Code Committee will be hosting a program on January 19th at 8:00AM titled Navigating the City of Boston Permitting Program. The panelists will include ISD inspectors, permit expediters, construction managers, and our very own Chad Farrell. Join the program and learn about the various types of permits from different agencies you must coordinate in order to receive your building permit. We hope to see you there!

Register Here

Given the colder temperatures, it is much more likely that the need for utilizing a hawk heater on a construction site is necessitated. As defined by NFPA 51B, this operation is classified as hot work and should be treated as such by the fire prevention program manager. In short, a BFD Hot Work permit should be sought in addition to a BFD General Permit, which allows for the storage of flammable gases on site. The General Permit must include any quantities that will not leave the site at the end of the day, including propane tanks for the hawk heaters. Like any hot work activity, any instances should be logged and a dedicated fire watch with a fire extinguisher should be present. In no case should propane be left unattended or stored inside a building, as regulated by the Boston Fire Prevention Code.