Insights Category: Technical Information

Rubberized asphalt melters are useful for roofing material application during construction, however open flame associated with such operations on roofs are specifically prohibited by 527 CMR in high rise buildings. Rubberized asphalt melters have an exposed burner flame and operate at temperatures up to 500 degrees Fahrenheit. These burners are fired by flammable gas/liquids, which further complicate the process as the storage of said materials inside a building is generally prohibited.

As a result, one must consider seeking permission from the authorities having jurisdiction. We suggest applying 527 CMR Section 1.4, which permits the use of equivalencies, alternatives, or modifications. Self-contained rubberized asphalt melters are not currently included in NFPA 1, however the practicality of this option has been recognized recently in several jurisdictions such as Florida.

Rubberized asphalt melters have a fully enclosed burner flame and typically operate at temperatures between 350 degrees Fahrenheit to 380 degrees Fahrenheit. The melters typically range in size from 100 gallons to 230 gallons and only utilize either diesel or gasoline for fuel. These melters are equipped with temperature controls and only run on a properly operating control system. The membrane material used in these melters has a lower melting point than traditional asphalt based products and is less flammable and combustible.

These rubberized melters have been approved within the City of Boston in the past with the appropriate required permits. These permits include a General Permit to permit fuel storage on the roof, as well as a Hot Work Permit to provide an avenue to secure a uniformed fire watch.

If you have any questions about how you can achieve alternative means of compliance for roof melters, please contact us!

Emergency wash systems are required by 248 CMR, Massachusetts Uniform Plumbing Code in every school, college, university, or building laboratory where corrosive or flammable liquids are handled, chemicals are stored or used, or open flame devices are used (248 CMR 10.13 (l)(1)). The systems are required to include drench/deluge showers, hand held body/face washers and deck mounted drench hoses. The permanently mounted showers are required to be located as close to the main door of the laboratory as possible, but must not be located more than 50 feet from an experimental area. The systems are required to be installed in a manner that prevents stagnation of water in the piping that supplies permanently mounted showers and face/eye wash stations.

Enacted on June 29, 2016, the Board of State Examiners of Plumbers and Gas Fitters issued an interpretation for the installation requirements of emergency eyewash and emergency showers to better align the requirements with ANSI Z-358.1. The Board voted to make the following changes:

  • The Board now allows emergency shower products to be accepted with a minimum flow of 20 gpm for 15 minutes. Previously, 248 CMR 10.13(1)(l)(4) required a 30 gpm continuous spray.
  • The Board now allows a water temperature range of 60 – 90 degrees Fahrenheit based on documented data showing an increase in bacteria growth in water above 70 degrees. Previously, the water was required to be tempered to between 70 – 90 degrees Fahrenheit.

On July 28, 2017, the Centers for Medicare & Medicaid Services issued a memorandum on required annual inspection of swinging fire door in healthcare occupancies (Click Here for the full memo). The memo extends the deadline for compliance with the annual fire door inspections for swinging fire doors from July 5, 2017 to January 1, 2018.

The extension is being granted due to conflicting information that was issued regarding the code path and subsequent nature of the door inspections that were required to be performed. The memo clarified that Section 7.2.1.15.1 of NFPA 101 2012 Edition would not apply to healthcare occupancies. This does not mean that these occupancies are not subject to the annual testing requirements of NFPA 80 but rather that they are not subject to the additional requirements layered on top of the NFPA 80 requirements contained in Section 7.2.1.15.1. In addition to swinging fire doors, 7.2.1.15.1 also applied to doors with panic hardware, electronically controlled egress locks, and doors with special locking arrangements such as delayed egress locks and access control locking system. Nonrated doors that contain such devices are not required by NFPA 101 or NFPA 80 to be inspected annually.

Hospitals are still subject to the annual inspection of swinging fire doors from NFPA 80 via Section 8.3.3 of NFPA 101 2012 Edition.

Previously Joint Commission and CMS had issued notices that 7.2.1.15.1 was applicable to Healthcare Occupancies. Due to the confusion created by this clarification, CMS has extended the deadline for compliance.

If you need assistance creating an inventory of fire doors or performing NFPA 80 testing please do not hesitate to contact us. Unlike many fire door inspectors, our work as code consultants and fire protection engineers gives us the expertise to examine your life safety drawings and understand the necessity for walls and doors to be rated by NFPA 101 and the applicable building codes.

Lt. Chris Towski of Cambridge Fire Department has been instrumental in educating the design/build/enforcement industry on the newly enforced NFPA 241, Standard for Safeguarding Construction. Most recently, Lt. Towski was published in Fire House Magazine, which circulates to fire services on a national level. In this article, his vantage point as authority having jurisdiction (AHJ) offers a fresh perspective to a subject matter that cannot be ignored on our construction sites. The article can be found here: http://www.firehouse.com/article/12349715/fire-prevention-safety-for-buildings-under-construction-firefighter-training-education

One of the most significant changes in the upcoming 9th Edition adoption relates to fire service access elevator requirements.

8th Edition 780 CMR

The current Massachusetts State Building Code (8th Edition; also known as 780 CMR) is an amended version of the 2009 IBC. The 8th Edition 780 CMR requires a fire service access elevator (FSAE) in buildings more than 70 feet in height above grade plane. In order to serve as the FSAE, an elevator must satisfy the following conditions (780 CMR 3007):

  • The FSAE must serve every floor of the building;
  • The FSAE must be open to a lobby that is:
    • 150 ft2 minimum with an 8-foot minimum dimension on every floor except the street floor.
    • Enclosed by 1-hour smoke barriers with 3/4 –hour doors.
    • Provided with direct access to an exit enclosure.
  • A Class I standpipe hose connection must be provided in the exit enclosure having direct access from the FSAE lobby;
  • FSAE must be continuously monitored at the fire command center; and
  • Normal and standby power must be provided in accordance with 780 CMR Chapters 27 & 30

9th Edition 780 CMR

The 9th Edition 780 CMR is an amended version of the 2015 IBC. The 9th Edition 780 CMR, significantly changes the requirements related to FSAEs. Specifically, in buildings with an occupied floor more than 120 feet above the lowest level of fire department vehicle access, no fewer than two fire service access elevators, or all elevators, whichever is less, is required to be provided. The impact of this code change is twofold in that buildings less than 120 feet in height above the lowest level of fire department vehicle access no longer require a FSAE; however, buildings exceeding this threshold now need two FSAEs instead of one. It is important that this code change be considered early in design based on the considerable impact on building core configuration.

In addition to the above code change, the 9th Edition 780 CMR also introduces the following notable changes:

  • Under the 8th Edition 780 CMR it was required that a Class I standpipe hose connection be provided in the exit enclosure having direct access from the FSAE lobby. This requirement has been updated such that the exit enclosure containing the standpipe must have access to the floor without passing through the fire service access elevator lobby. A change was made to this requirement in order to prevent the passage of smoke from the floor to the FSAE lobby and hoistway when firefighters run hoses from the standpipe to the floor (2015 IBC 3007.9.1).
  • Access to not less than one of the required exits from the floor must be provided without travel through enclosed elevator lobbies (2015 IBC 1016.2).
  • A pictorial symbol designating which elevators are fire service access elevators must be installed on both sides of the hoistway door (2015 IBC 3007.6.5).

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.