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:
- New construction
- Existing buildings undergoing a renovation that triggers 30% or more of the full and fair cash value of the building
- 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.
The Joint Commission has recently announced a new approach for identifying and evaluating risk levels associated with deficiencies cited during surveys. This new approach, referred to as Survey Analysis for Evaluating Risk (SAFER) matrix, is intended to provide organizations with additional information related to the risk of deficiencies to assist them in prioritizing corrective actions. The SAFER Matrix became effective for psychiatric deemed hospitals on June 6, 2016 and will become effective for the remainder of accredited facilities on January 1, 2017. The matrix will illustrate areas of noncompliance at an aggregate level to show the extent (limited, pattern, widespread) and likelihood to harm (low, moderate, high) that cited deficiencies may cause in the event of a fire. At the end of the survey, the facility will be provided with a SAFER matrix within their Accreditation of Survey Findings Report as shown in the figure at left.
The SAFER Matrix replaces the current scoring methodology. Predetermined Elements of Performance (EPs) such as Categories A and C as well as Direct and Indirect impacts will no longer be utilized. Opportunities for Improvement, such as a single Category C finding, will no longer exist. Further, Measures of Success (MOS), which was previously used as an audit to determine if a certain action is effective and sustained, will not be required for certain Category C findings. Instead, surveyors will perform an on-site evaluation of identified deficiencies to place each EP within the appropriate cell according to the extent and likelihood to harm. Deficiencies of higher risk will still require an Evidence of Standards Compliance (ESC) to be developed and submitted by the facility related to corrective actions. Further, Immediate Threats to Life (ITLs) will be identified within the SAFER Matrix which will require the same follow-up process associated with potential Preliminary Denial of Accreditation.
Contact us if you want to know more about how the new SAFER Matrix will affect your future accreditation process.
The City of Boston Fire Department’s Certificate of Occupancy division is correctly holding building owners accountable to properly maintain their standpipe systems. The checklist at left is being passed out at the BFD fire prevention headquarters, which specifically requires proof of standpipe flow test prior to issuance of any tenant improvement project certificates of occupancy.
NFPA 25 (referenced by the NFPA 14) requires a flow test from the most remote hose connection (typically the roof) for each standpipe zone every 5 years. This requirement is to ensure the water supply still provides the required design pressure at the required flow. There is also a requirement for hydrostatic testing every 5 years for manual standpipe systems and semiautomatic dry standpipe systems. However, manual wet standpipe systems that are part of a combined sprinkler/standpipe systems are not required to be hydrostatically tested.
Having this documentation readily available is critical to ensure that the Certificate of Occupancy for your next TI project is not delayed. Questions? Give us a call and we’d be happy to point you in the right direction.
