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Insights Category: Technical Information

On February 11th, the Board of Building Regulations & Standards (BBRS) released an official interpretation to clarify requirements for existing buildings. This latest interpretation is one of the most significant to date as it addresses 4 key points associated with 780 CMR 34 (2009 International Existing Building Code with MA Amendments). Here’s what you need to know:

  1. Compliance Alternatives – Compliance Alternatives, developed for existing buildings where the code for new construction cannot be met, are NOT required to be issued by a registered design professional. With that said, the services of a registered design professional may be warranted for complex issues that require a specific knowledge or area of expertise.
  2. Sprinkler Protection in Existing Buildings Undergoing a Change in Use – The extent of sprinkler protection required in existing buildings undergoing a change in use has been widely misunderstood. IEBC Section 912.1.1.2 specifies that the extent of sprinkler protection is limited to the area undergoing the change in use where separated by fire rated construction from the remainder of the building. However, this approach conflicts with the general notion in Massachusetts that multiple fire areas cannot be created to prevent sprinkler requirements as noted in 780 CMR 903.2. The interpretation clarifies that the extent of sprinkler protection required may be limited to only the areas undergoing the change in use in the existing building by using the building separation method as described in IEBC Section 912.1.1.2. Note that sprinkler protection may still be required throughout the entire building by MGL Chapter 148 Section 26G if the building totals more than 7,500 gross square feet and is undergoing a “major alteration”. Official guidance on MGL Ch.148 S.26G can be found here: http://www.mass.gov/eopss/docs/dfs/osfm/boards/asab-official-approved-26g-guidance.pdf
  3. Multiple Levels of Alteration – A project issued under a single permit may indicate several different levels of alterations. For example, a building being altered with a portion of the electrical system being replaced on the first floor and the construction of a new room on second floor would be classified as a Level 1 Alteration and a Level 2 Alteration. The work occurring on the first floor would be considered as a Level 1 Alteration due to the replacement of an existing system serving the same purpose, and the work on the second floor would be considered as a Level 2 Alteration due to the addition of new walls. Note that although a single permit can include multiple alteration levels, more than one compliance method (such as Work Area Compliance Method and Prescriptive Compliance Method) cannot be used on a single permit.
  4. Definition of Reconfigured Space – The determination of the level of alteration under the Work Area Compliance Method is contingent upon the defining what is considered as the work area. Per IEBC Section 202, the work area is defined as “…all reconfigured spaces as indicated on the construction documents.” Until now, the term “reconfigured space” was ambiguous and left to the building official to interpret. The BBRS has clarified that space is considered as reconfigured if it changes the manner in which occupants egress from the space in terms of travel or distance to exits. This is an important concept to recognize because the work area of a building does not necessarily include all of the areas where work is being done. In the past example in Item #3 above, the work area would consist of the reconfigured room on the second floor only since this is the only space where egress travel and distance has changed. Although work is occurring on the first floor due to replacing the electrical system, this does not include any reconfigured space and thus is not included in the determination of the work area.

Here’s a link to the official BBRS interpretation, which contains useful diagrams illustrating which constitutes reconfigured space: http://www.mass.gov/eopss/docs/dps/buildingcode/inf3/2014-01-official-interpretation-existing-buildings-approved-february-11-2014.pdf

At the end of January 2014, the Joint Commission released an article Found Here clarifying the storage requirements for freestanding nonflammable medical gas cylinders. The main update is that once a cylinder valve is opened, the cylinder is no longer permitted to be stored with the full, unopened containers even if gas remains in the cylinder. This clarification means that a cylinder, even if newly opened, should be segregated from full (unopened) cylinders. Facilities are required to segregate cylinders into three racks – full (unopened), partial, and empty. Each rack should have cylinders securely stored and clearly labeled so users can quickly identify the proper containers in the event of an emergency. Facilities should review their medical gas storage policies against this clarification as it will likely be a point of emphasis in future inspections.

While we’re on the topic, here are a few other important items to note relative to medical gas cylinder storage:

  • The 2005 Edition of NFPA 99 Section 9.4.3 limits the total volume of nonflammable gases that are not stored in enclosures to 300 cubic feet (12 cylinders) within a smoke compartment.
  • Oxygen cylinders that are mounted on gurneys, wheelchairs, and medical equipment, but are not actively being used by patients are considered to be in use and do not count towards this threshold. See CMS S&C-07-10 for CMS position on this issue which has been endorsed by the Joint Commission.

The holiday season is upon us again and that means one thing for hospitals: decorations. From artificial trees and wreaths to paper snowflakes and ornaments hanging from the ceiling, hospitals provide a variety of decorations throughout the holiday season. Despite the memos that are typically circulated throughout hospitals to remind staff of their facility’s policies that limit decorations to only those that are flame retardant, facility managers constantly struggle with staying on top of non-compliant decorations. Thanks to the new categorical waivers permitted by The Centers for Medicare and Medicaid (CMS) and The Joint Commission (TJC), there is more flexibility in restrictions on combustible decorations than have been allowed in the past.

The 2000 Edition of NFPA 101 Section 18/19.7.5.4 states that “combustible decorations shall be prohibited in any health care occupancy unless they are flame-retardant.” There is an exception for combustible decorations, such as photographs and paintings, in such limited quantities that a hazard of fire development or spread is not present. This provision appears to be cut and dry requiring all decorations to be flame-retardant, but leaves it up to the Authority-Having-Jurisdiction (AHJ) to determine if the decorations constitute a fire development hazard. Given the number of AHJs assigned to a hospital coupled with varying interpretations, the most conservative approach has been for facilities to require all decorations to be flame-retardant regardless of size.

On March 9, 2012, the CMS Survey & Certification Group issued memorandum S&C-12-21-LSC which provided instructions for waivers of specific requirements contained in the 2012 Edition of NFPA 101. Section 18/19.7.5 on Furnishings, Mattresses, and Decorations was one of four sections which CMS allowed a waiver to be elected. The provisions of this section were revised and expanded in the 2012 Edition of the Code to make health care occupancies more homelike. Section 18/19.7.5.6 contains the requirements for combustible decorations which was revised as follows:

“Combustible decorations shall be prohibited in any health care occupancy, unless one of the following criteria is met:

  1. They are flame-retardant or are treated with approved fire-retardant coating that is listed and labeled for application to the material to which it is applied.
  2. The decorations meet the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films.
  3. The decoration exhibits a heat release rate not exceeding 100 kW when tested in accordance with NFPA 289, Standard Method of Fire Test for Individual Fuel Packages, using the 20 kW ignition source.
  4. The decorations, such as photographs, paintings, and other art, are attached directly to the walls, ceiling, and non-fire-rated doors in accordance with the following:
    • Decorations on non-fire-rated doors do not interfere with the operation or any required latching of the door and do not exceed the area limitations of 19.7.5.6(B), (C), or (D) [Items 2, 3, 4 below].
    • Decorations do not exceed 20 percent of the wall, ceiling, and door areas inside any room or space of a smoke compartment that is not protected throughout by an approved automatic sprinkler system in accordance with Section 9.7.
    • Decorations do not exceed 30 percent of the wall, ceiling, and door areas inside any room or space of a smoke compartment that is protected throughout by an approved automatic sprinkler system in accordance with Section 9.7.
    • Decorations do not exceed 50 percent of the wall, ceiling, and door areas inside patient sleeping rooms, having a capacity not exceeding four persons in a smoke compartment that is protected throughout by an approved automatic sprinkler system in accordance with Section 9.7.
  5. They are decorations, such as photographs and paintings, in such limited quantities that a hazard of fire development or spread is not present.”

In order to utilize the waiver for the combustible decorations, a waiver request was initially required to be processed in the regular fashion with input from the State Survey Agency and final approval by the CMS Regional Office. However, CMS released memo S&C 13-58-LSC on August 30th, 2013 which allowed the waivers specified in S&C 12-21-LSC as well as 8 other provisions to be addressed as categorical waivers.

Facilities that want to take advantage of the combustible decoration waiver to utilize the 2012 NFPA 101 provisions must formally elect to use the waiver and document their election decision. As long as the requirements of the waiver are met, the election is not required to be submitted to CMS for approval nor do you need to wait until cited to utilize the waiver. It should be noted that the use of the waiver must be brought to the attention of the life safety surveyor at the entrance prior to the start of a survey. Additionally, TJC requires the election of the waiver to be identified in the additional notes section of the BBI on the electronic Statement of Conditions.

By electing to utilize the waiver for combustible decorations, hospitals are provided with more leniency regarding their allowance for combustible decorations on walls, ceilings, and non-fire-rated doors. Regardless of whether the waiver is utilized, facility managers and their staff should also keep an eye out for the following issues as they perform their daily rounds:

  1. Decorations should not obstruct or block fire extinguishing or fire alarm equipment such as fire extinguishers or manual pull stations.
  2. Decorations should not be hung from sprinklers, or located adjacent to a sprinkler such that it would obstruct the sprinkler discharge pattern.
  3. Decorations should not be placed on fire rated doors having a required rating or 45-minutes or greater, regardless of their size.
  4. Decorations should not obstruct the required clear width of corridors.

The Boston Herald ran an article over the weekend announcing plans for a new 355,000 square foot multi-tenant research, design, and manufacturing facility in the Seaport. While this is certainly exciting news for the expanding “Innovation District”, I couldn’t help but think of the design challenges this type of project presents to the design team and building owner. The hazardous chemicals that are inherent in any pharmaceutical & manufacturing operation bring with them additional regulations beyond that experienced by most commercial buildings from the Massachusetts State Building Code (780 CMR), Massachusetts Fire Prevention Regulations (527 CMR), and referenced NFPA Codes & Standards. As one might imagine, the code prescribed protection features, and associated cost of construction, vary significantly based on the corresponding fire hazard presented by the combination of the physical properties and quantity of the chemicals in use or storage.

The key in delivering a successful project in this type of facility is identifying the owner’s and/or developer’s objectives for the project early on. A client who wants to own and operate this type of facility for a long time will likely desire a shell and core design that can accommodate a wide array of users, including those with significant chemical quantities and hazard types. Alternatively, a client whose objective is to sell the property in the near term may be looking for a building that can accommodate their present tenant’s needs and nothing more.

There are numerous chemical compliance options available in 780 CMR for designers to implement on this type of building to fit the client’s objectives. At one end of the spectrum, there are control areas. Control areas are essentially fire-resistance rated compartments that are permitted to have a certain quantity of chemicals within each. 780 CMR permits a certain number of control areas and a certain quantity of chemicals per floor depending on the ease of fire department access. One benefit of control areas is that they do not change the Use Group classification of the building and when compared with other protection approaches require less specialized protection features. The drawback of control areas is the chemical limits imposed on users. This is especially true in multi-tenant buildings, where separate tenants may be forced to share a control area, creating the operational issue of tracking chemical quantities between neighbors to stay under a single limit.

At the other end of the spectrum are Use Group H, High Hazard Occupancies. While these types of occupancies have much more liberal quantity restrictions when compared with control areas, it comes at a cost. The construction type required to have sizeable H occupancies or H occupancies located above grade is greater than that compared with other occupancies. The hazards presented by chemicals in use or storage will also require specialized protection features such as dedicated mechanical exhaust, classified electrical equipment, explosion control or prevention systems, and spill control and secondary containment systems to just name a few.

The decision to utilize control areas vs. Use Group H occupancies, or a combination thereof, should be evaluated on a case-by-case basis depending on the owner’s and tenant’s needs. For the design community, it’s certainly worth noting that 780 CMR has a requirement in Section 414.1.3 for a report to be issued with the Construction Documents outlining the proposed hazardous material protection approach on the project. Given the code complexities that go along with hazardous materials, this report is often a useful tool to help Building and Fire Officials in their review of the building and also in the operation of the facility post occupancy.

On September 10, The Massachusetts Board of Building Regulations & Standards (BBRS) made the decision to move 14 code change proposals forward for final public comment and possible promulgation at their October 8th meeting. For commercial building designers and owners, the most notable of the proposed changes involves 780 CMR 34.00, Existing Structures which references the 2009 International Existing Building Code (IEBC).

urrently, IEBC users have the choice between three separate compliance methods in Massachusetts which include the: (1) Prescriptive Compliance Method, (2) Work Area Compliance Method, and (3) Performance Compliance Method. Without going into all of the nuances associated with each compliance method (we’ll save that for a later blog entry), the Prescriptive Compliance Method provides a straightforward approach to code compliance for additions, alterations, repairs, and changes of occupancy in existing buildings. Essentially, this method requires all new work associated with an alteration to comply with the new construction requirements of the IBC and permits spaces outside of the designated work area to remain as is (unless deemed hazardous or unsafe by the building or fire official). This approach is particularly useful when performing smaller alterations in existing buildings to prevent users from having to evaluate the entire building outside of the work area.

When Massachusetts adopted the 8th Edition of 780 CMR, there were significant amendments to Chapter 34. One of these amendments eliminated IEBC Section 101.5.1 which required buildings utilizing the Prescriptive Compliance Method to comply with the provisions of the 2009 International Fire Code (IFC). This reference to the IFC was important as Chapters 8 and 46 contain requirements that must be met in all existing buildings including components such as interior finishes, elevator operation, vertical opening protection, means of egress, sprinkler systems, fire alarm systems, etc. These requirements vary depending on the occupancy classification. The intent of the reference in IEBC Section 101.5.1 to the IFC was to ensure that a minimum level of fire and life safety was provided in the existing buildings prior to allowing designers to utilize the Prescriptive Compliance Method since it is such a straightforward approach.

The MA amendment eliminating the reference to the IFC actually (likely not intentionally) made the Prescriptive compliance method in 780 CMR 34.00 significantly less restrictive than the base IEBC since the existing buildings do not currently need to comply with the IFC in order to use this method. The code change proposal to be heard at the BBRS meeting next month aims to re-instate the reference to the IFC in IEBC Section 101.5.1. If promulgated back into 780 CMR, this would require users to evaluate their existing buildings to verify compliance with the IFC prior to using the Prescriptive Compliance Method. Other notable changes associated with the code change proposal include not allowing Group R occupancies to utilize the Prescriptive compliance method or the Performance compliance method unless they comply with the 6th Edition or later of 780 CMR 9.00, Fire Protection Systems. This means that older Residential buildings undergoing alterations would likely be required to utilize the Work Area Compliance Method.

The purpose of this code reference is to make sure existing buildings in Massachusetts provide a consistent minimum level of safety for building occupants and emergency responders. The underlying philosophy of this requirement is that only those buildings providing this level of safety should be eligible to utilize the more straightforward Prescriptive Compliance Method that does require analysis, and may require retroactive upgrades, to portions of the building outside of the work area.

For those that are familiar with the predecessor codes in Massachusetts such as the 6th Edition, Chapter 34 always required minimum levels of compliance with means of egress provisions regardless of the scope of work. While the addition of yet another requirement for building designers to meet is always viewed with skepticism, I would argue the correct perception on this change is that the BBRS is correcting an unintentional oversight to align our codes with not only the national standard, but also the same philosophy that has been employed on existing building projects in the state for years.

Check back in on our blog next month for an update on which code change proposals passed and which were denied at the BBRS monthly meeting.

How to measure the widths of egress components like doors and stairs is one of those questions that code consultants get on a weekly basis. In many cases, there seems to be confusion on the minimum sizes of certain components and how to properly measure their widths properly. Stair egress measurements are commonly misunderstood. Should stairs be measured between handrails since this is where occupants can walk? Or are they based on the entire width of the treads? And what about stringers? Are those included in the measurement as well? This article is intended to address common questions associated with egress width.

Means of Egress Sizing

How wide are my means of egress components required to be?

The 2015 International Building Code (IBC) Section 1005 addresses the requirements associated with means of egress sizing. The section requires the utilization of two separate methods to determine your minimum required egress width, which is required to be the greater of the following:

  • “Component width”, which is the minimum width specified in Chapter 10 for specific egress components such as stairs, doors, corridors, etc. and
  • “Calculated width” which is based on the occupant load served by the component using the egress width factors discussed below.

The larger width determined by the two methods above must be utilized to establish the minimum width for each egress component. In many cases, the minimum egress widths serving buildings with less concentrated occupant loads will be dictated by component widths, not calculated widths.

The table at left illustrates several examples of this methodology for an unsprinklered building.

Egress Width Factors

What factor do I use to determine my “calculated width”?

IBC Section 1005.3.1 requires that “the capacity, in inches, of means of egress stairways shall be calculated by multiplying the occupant load served by such stairway by a means of egress capacity factor of 0.3 inch per occupant”. Section 1005.3.2 addresses other egress components (such as doors, corridors, aisles, etc.) where the language is similar but utilizes an egress capacity factor of 0.2 inch per occupant since the speed of exiting on horizontal components is quicker than descending stairs. There are exceptions for stairway and other egress components to utilize 0.2 and 0.15 inch per occupant, respectively, where the building is sprinklered and equipped with an emergency voice/alarm system for all occupancies other than Group H (High Hazard) and I-2 (Health Care).

Note that earlier editions of the IBC, as well as NFPA 101, differ in terms of the ability to utilize the reduced egress width factors of 0.2/0.15 inch per occupant as well as what protective features are required to do so (i.e. sprinklers only vs. sprinkler and an emergency/voice alarm system) so it is important to review applicable local and state codes to determine which factors are appropriate.

Measuring Egress Width – General

How do I measure my egress widths?

Egress measurements are based upon the clear, unobstructed widths available to occupants along the egress path in accordance with IBC Section 1003.6. Projections would not be permitted within these widths unless specifically allowed by the code, such as panic hardware for doors and handrails for stairs.

Measuring Door Egress Width

How do I measure the “egress” width of a door?

For doors, the egress width measurement is based on the clear width of the opening which is not the same as the “nominal” door width. This is typically measured from the face of the door with the door open 90 degrees to the door stop on the strike side of the frame. For pairs of doors, this would be measured between the face of the doors with both open 90 degrees assuming there are no center mullions or other obstructions between. Since this is a clear width measurement, it is important that door hardware be considered. The configuration of hinges, pivots, etc. can all affect the exact opening measurement. Note that panic or fire exit hardware is an allowable projection up to 4 inches into the clear width where located between 34-80 inches above the finished floor and therefore would not be considered in this measurement (IBC 1010.1.1.1).

When evaluating an existing building, this measurement can simply be made on-site, but conservative assumptions are typically made for those buildings still under design. As a general rule of thumb, a 3” reduction for clear width generally accounts for the 1.75” door thickness as well as any reductions due to door hardware. For example, a 36” door leaf is typically assumed to provide 33” of clear width. This door provides an egress capacity of 220 occupants (33”/0.15” per occupant) and 165 occupants (33”/0.20” per occupant), respectively, for sprinklered buildings with an emergency voice/alarm system and those buildings without such system(s).

Measuring Stair Egress Width

How do I measure the “egress” width of a stair?

IBC Section 1014.8 permits handrails to project up to 4½ inches into the required width of aisles, stairways, and ramps on each side. Therefore, the egress width of a stair is measured as the clear width above the handrails (between obstructions such as a wall, guard, etc.), unless handrails project more than 4 ½ inches into the stair, in which case the stair width is the measurement between the interior surface of the handrails plus 4 ½ inches on each side.

This measurement typically results in stair egress width being measured from outside stringer to stringer as this aligns with adjacent walls and guards, but this can vary depending on wall or guard offsets from the stair. In many cases, there is a gap between the outside portion of the stringer and the adjacent wall or guards which can be counted towards egress width. Alternatively, the guard is sometimes located on top of the stringer, in which case the stringer width would not be counted towards your egress width. The figures below illustrate several examples of how to properly calculate stair egress width.

Handrails project 3 inches on either side of stair. Egress width is measured above handrail height from wall-to-wall, resulting in an effective clear width of 7’-4”.

In this stairway under construction, the handrails project 4 inches from the adjacent wall and guard on either side. The guard is also located on top of the inside stinger. Egress width is measured above handrail height from wall-to-guard, resulting in an effective clear width of 4’-4”.

In this subway station, the stair width measured between handrails is 8’-5”. The handrails also project 9” on either side beyond the adjacent guards. Since handrails are only permissible to project up to 4½ inches on both sides, the effective egress width is 9’-2” (8’-5” + 4½” + 4½”). Note that egress from subway stations are typically calculated under different standards, however this is intended just for illustration under the IBC.

This article cannot address all of the unique configurations one may find when evaluating egress widths of doors and stairs, but hopefully it sheds some light on this often misunderstood issue.

The Massachusetts Board of Building Regulations and Standards (BBRS) meets once a month to discuss topical building code and other related issues. The BBRS relies on a number of advisory committees to assist with carrying out its mission and one of these committees is the Fire Prevention and Fire Protection (FPFP) advisory committee. Most recently, the FPFP committee took up the topic of fire rated duct products to determine how these products comply with the code.

The discussion focused on whether fire rated ducts or similar fire wrap products were being used in a code compliant manner. While not a comprehensive list, examples of such products include 3M’s Fire Barrier Duct Wrap, Conquest Firespray’s FlameBar fire rated duct system and Caswell Firesafe Fire Resisting Ductwork.

Using these types of products for grease ducts is well established and clearly defined in the code; however, these products are being used for performance-based applications with increased frequency. One example of alternative uses includes using fire rated duct products to separate stair pressurization duct work from interior building spaces prior to it reaching the stair shaft enclosure. See 780 CMR 909.20.6.1 (3). Another example where fire rated duct products are used is where ducts penetrate a fire barrier and the use of fire damper is prohibited such as hazardous exhaust.

Fire rated duct products are frequently used as an alternative means of protection to the fire damper in smoke control and laboratory exhaust applications. The common argument for these alternative approaches is that the duct work maintains the fire resistance rating of the wall being penetrated as the duct itself provides continuity of the fire rated separation until the duct terminates at the exterior or it reaches an area where protection is no longer required.

The common question is, how can the duct work maintain the fire rating afforded by a wall when the fire rated duct product has not been tested to ASTM E119? ASTM E119 is a standard used to test the fire ratings of walls, columns, floors and other building members under fire exposure conditions and does not include test requirements or pass/fail criteria for fire rated ducts. Should the same fire rating test requirements used on a wall even apply to a duct? Is it important for the duct to have been tested in the installed orientation or is it important for a duct to have been tested for fire exposure from both inside and outside the duct?

The International Building Code (IBC) does not recognize fire rated duct products as an equivalent to the ASTM E119 test standard and therefore these products must rely on alternative testing methods. This in itself is not a show stopper; however, it does mean that the use of these products cannot be used as of right. These products must be approved by the building official as a modification (780 CMR 104.10), an alternative material, design and method of construction (780 CMR 104.11), as a compliance alternative in an existing building or through the MA state building code appeal process.

Duct products that have been tested to ISO 6944 or ASTM E2816 for horizontal and vertical orientations as well as for fire exposure inside and outside the duct could gain approval through 780 CMR 104.11 as the available test data more closely aligns with testing conducted under ASTM E119. This is a common approach used by manufacturers of foreign products that have been tested to standards that are not yet recognized by US building codes. Justification for using an alternative testing method generally requires drawing parallels between the alternative test methods proposed and those which are recognized by the building code.

Using a modification (780 CMR 104.10) is more likely to be used where the available testing of a product does not completely align with the test standards of the IBC. In these instances, an analysis must be completed on the product in its proposed application. Similar to the approach used for 780 CMR 104.11, parallels between available test data and that required for compliance with the building code must be evaluated. Where gaps exist between code required test standards and those not recognized by the code, a hazard/risk analysis would be necessary to substantiate the use of a product that would otherwise not be permitted as of right. Depending on how a fire rated duct product is being used (stair pressurization, hazardous exhaust, orientation, proximity to hazards, etc.) the appropriateness of using these products can be presented to the building official for approval under 780 CMR 104.10.

The biggest take-way from the efforts of the BBRS and FPFP committees is that with the exception of specific applications identified in the mechanical code, there are no tests recognized by the Massachusetts State Building Code that outright permits carte blanche use of these products as an alternative to fire rated wall, floor or ceiling construction.

Anyone who has spent time in the world of firestopping has undoubtedly dealt with engineering judgements or “EJs” as they are commonly referred to in the field.

What exactly is an engineering judgement?

To answer that question, it is critical to first understand the difference between a listed firestop assembly and a firestopping product. Most people think firestopping products carry the fire resistance rating. This is not true. All major building codes call for listed firestop assemblies where there are penetrating items and/or joints in fire resistance rated walls or floors. The assembly consists of the wall or floor that is being penetrated, the penetrating item(s), the size of the opening and arrangement of the penetrating item in that opening, and the firestopping materials that protect the opening. All of these components are outlined in the listing of the firestop assembly. Each listed firestop assembly has actually been fire tested in this specific configuration and all of these components must be installed correctly in the field for the system to hold the specified fire rating.

Even though most major firestopping manufacturers have over 1,000 listed firestop assemblies in their catalogs, there are inevitably field conditions which do not match one of the listed firestop assemblies available. This is where an engineering judgment can be a very useful and effective solution in lieu of incurring the cost of an expensive fire test. An engineering judgement is an evaluation of the anticipated performance of a proposed firestop assembly that has not been fire tested; engineering judgements are based on the performance of listed firestop assemblies and engineering principles.

Are engineering judgements permitted by the building code?

Section 104.11 of the International Building Code, 2015 Edition permits the use of alternative materials, designs and methods of construction where sufficient data is submitted to the building official to illustrate that an equivalent level of safety is maintained.

What typically constitutes a sufficient level of information to provide to a building official to substantiate an engineering judgment?

The International Firestop Council has published guidelines for evaluating engineering judgements (which can be found by clicking here). These guidelines are extremely helpful to building and fire officials who need to perform these evaluations. Some of the critical information contained in the guidelines are the following:

  • Include the date the EJ was issued, who wrote the EJ, and their contact information;
  • Reference the tested firestop assemblies the EJ was based on;
  • Identify the specific job name, project location, and firm the EJ is being issued to. Note: EJs should not be carried job to job since they are a snap shot in time evaluation of a specific installation.;
  • Identify any conditions that are outside the EJ evaluation.

Anyone writing an EJ should have knowledge of the fire testing of the listed assemblies the EJ is based upon and be able to use engineering and mathematical principles to interpolate performance. For this reason, a vast majority are written by the firestop manufacturers technical service department engineers.

A common issue we experience in the field when performing special inspections for firestopping assemblies per ASTM E2174 and ASTM E2393 (for more information on special inspection requirements click here) is that the engineering judgements are not being submitted to the building official for approval and are simply being recorded in a project submittal log. Upon receiving these EJs during inspections, we often encounter notes that make statements such as “Cold Smoke Seal Only”, “May not provide T Rating per UL 2079” and “Dependent upon performance of fire rated beam in fire conditions”. These statements should be evaluated carefully when looking at the appropriateness of the application relative to the minimum code requirements that apply. Unfortunately, far too often details with these types of notes get installed without any review and discussion on the merits of the assembly.

The frequency of special inspections for firestopping assemblies is increasing dramatically due to a requirement, first adopted in the 2012 IBC, that requires special inspections in all new firestopping installations in high rise buildings and other “high risk occupancies” such as: hospitals, first responder occupancies, large assembly occupancies, and college and university buildings with more than 500 occupants. The special inspector is not authorized per the ASTM standards to approve engineering judgements. That power is still held by the building official. However, the special inspector should be evaluating if the engineering judgements provided meet the minimum code requirements for where they are being applied and if there are obvious issues, discuss them with the approving authority.

Code Red Consultants employs over 20 fire protection engineers and has 6 staff members that are certified third party firestop inspectors per the IFC. Please do not hesitate to contact if you are in need of firestopping special inspectors or further education on the topic.