Insights Category: Technical Information

Fire alarm approvals are often a critical driver of project schedules in New York City. From new construction and renovations to tenant improvement projects, FDNY plan approval and final sign-off are required milestones that can directly impact Temporary Certificates of Occupancy (TCOs), tenant move-ins, and revenue generation. Early engagement with a fire alarm consultant can help project teams understand approval requirements, identify potential risks, and maintain control of key project milestones.

Understanding the Approval Process 

In New York City, fire alarm systems must receive FDNY plan approval before installation and pass a final inspection before occupancy can be granted. Because both milestones directly affect the project schedule, delays in approvals, inspections, or documentation can impact the overall schedule. Common issues in the plan review phase include incomplete submissions, inconsistencies between plans and the riser diagram, failure to meet FDNY requirements or local amendments, and design coordination issues. Even well-designed systems can experience delays when technical requirements and administrative processes are misaligned. Prior to an FDNY inspection, the fire alarm system must be installed and function per the approved plans. Pretesting is an essential part of the process for identifying and resolving defects before inspection, to avoid costly delays.

Why Early Coordination Matters 

Fire alarm permitting in New York City is both a technical and logistical process. Successful project delivery requires coordination among owners, developers, contractors, designers, filing representatives, and FDNY reviewers throughout the project lifecycle. Early third-party plan review, coordinated filings, realistic schedule planning, walkthroughs, and pretesting can help reduce objections, failed inspections, and avoid delaying TCO.

Projects benefit most when permitting, design, installation, and testing efforts are approached as an integrated process rather than a series of independent tasks. This helps teams identify issues before they affect inspections, occupancy milestones, and overall project schedules.

How Code Red Consultants Can Help 

Code Red Consultants partners with owners, developers, contractors, and design teams on fire alarm consulting for projects throughout New York City. Our team helps navigate FDNY requirements from initial filings through final sign-off, providing responsive support and reliable guidance at every stage of the process. Through longstanding experience working with local authorities having jurisdiction, we help teams anticipate potential challenges, streamline coordination, and reduce the risk of approval delays that can affect occupancy and project schedules.

As cities seek to address housing demand and repurpose underutilized office space, office-to-residential conversions are becoming increasingly common. Navigating the landscape of code and jurisdictional requirements for projects involving a change of occupancy can be complex and confusing. Project teams that elect to use a code consultant in the early project planning phases benefit from identifying custom code strategies that meet the project goals and constraints.

Understanding “Change of Occupancy”

Converting from office (Group B Occupancy) to residential (Group R Occupancy) typically results in a higher hazard occupancy classification, as defined in Chapter 34 of the International Building Code (IBC) and International Existing Building Code (IEBC). This shift can trigger upgrades to existing building features, even when not included in the planned project renovation areas. Key systems that are often impacted include means of egress, fire resistance ratings, accessibility, and building performance (i.e., exterior wall energy efficiency). These changes can significantly impact scope, cost, and schedule, putting project viability at risk.

Identifying Code Challenges Early and Navigating a Compliance Path

Full compliance with new construction requirements is often impractical due to existing conditions, cost constraints, and project limitations. Identifying these challenges early allows teams to evaluate alternative compliance strategies, variances, or design approaches that may provide a safe and feasible path forward. It also provides time to coordinate with authorities having jurisdiction before these issues affect key project milestones.

Financial Incentives for Office-To-Residential Conversions

Many jurisdictions are encouraging adaptive reuse to repurpose outdated buildings and increase housing supply. For example:

• Los Angeles adopted the Adaptive Reuse Ordinance 2.0, reducing zoning barriers and allowing the use of the California Historic Building Code for qualifying projects.
• Washington, DC has an “Office to Anything Program” supporting repositioning of obsolete office space.
• Montgomery County, MD, and Alexandria, VA have introduced zoning flexibility and streamlined approvals.
• Boston offers tax and zoning incentives, along with early interagency coordination during design.

While these programs can improve project feasibility, they do not reduce the underlying technical requirements. Office-to-residential conversions are still treated as a change to a higher hazard occupancy, which can trigger provisions related to egress, height, area, and accessibility. Historic and existing building conditions may require additional coordination and alternative compliance approaches to address code requirements.

How Code Red Consultants Can Help

Code Red Consultants supports office-to-residential conversions by bringing a holistic perspective to renovation and change-of-occupancy projects. We work with owners, developers, designers, and authorities having jurisdiction to evaluate requirements, identify constraints early, and navigate compliance within the context of existing buildings. Our experience across project types and jurisdictions helps teams align design decisions with real-world conditions, regulatory expectations, and project goals.

Decisions made during campus master planning and early conceptual design can establish code constraints that become difficult or costly to address later. For architects working on institutional campuses such as healthcare and higher education, early site planning decisions related to building separation, massing, connections, and fire department access can directly influence allowable height and area, construction type, façade design, and interior planning flexibility. Engaging a code consultant early in this process helps project teams understand these constraints before they are embedded in the site and building concept. 

Code Red Consultants has extensive experience supporting higher education and health care campuses where incremental growth, phased development, and long‑range master planning create unique code challenges that differ from single building projects. 

ADDITION VS. SEPARATE BUILDING: EARLY TRADEOFFS
A key early question in campus planning is whether a new structure should be designed as an addition to an existing building or as a separate building connected by exterior circulation, bridges, or tunnels. From a code perspective, this distinction carries significant implications. 

When treated as an addition, buildings may be analyzed as a single structure, allowing project teams to leverage greater allowable height and area, broader construction type options, and fewer exterior wall limitations. This often supports more open interior environments such as multistory lobbies, commons, and shared circulation. However, these advantages require careful evaluation of occupancies, smoke compartments, and fire protection strategies across the combined building. 

Designing a structure as a separate building shifts the analysis toward fire separation distance, exterior wall ratings, and allowable openings. Accurately identifying lot and property lines is critical, particularly on campuses under single ownership, where adjacent properties may be treated differently from typical urban parcels. Early assumptions that later prove incorrect can limit façade design or future expansion. 

ADDITIONAL CONSIDERATIONS FOR SEPARATE BUILDINGS
Where separate‑building strategies are preferred, firewall separations may be used to preserve independent height and area allowances. The 2021 International Building Code introduced additional flexibility by allowing the omission of fire walls between buildings of the same construction type under specific conditions, such as recorded easement agreements. While this can benefit campus planning, it also introduces legal and long‑term coordination considerations that should be evaluated early. 

Separate buildings may also limit interior openness and introduce constraints on exterior walls that influence architectural expression and spatial planning. 

FIRE ACCESS AND BUILDING CONNECTIONS
Fire department access planning is another early consideration that can affect building placement and massing on a site. Apparatus access roads, turning radii, staging areas, and hose reach often influence setbacks and site circulation and may trigger late redesigns if not addressed during master planning. 

Bridges and tunnel connections between campus buildings can further affect perceived building separation, fire ratings, and massing. These elements also play a significant role in campus aesthetics and circulation and should be evaluated early to align life safety requirements with design intent. 

HOW CODE RED CONSULTANTS CAN HELP
Code Red Consultants works with architects and institutions during campus master planning and early design to evaluate building relationships, separation strategies, fire department access, and connection approaches. Our experience across higher education and healthcare campuses helps teams identify code implications early, supporting informed site planning decisions that preserve both design flexibility and long-term campus goals. 

Effective May 5, 2026, health care and ambulatory health care facilities now have a clear, code‑recognized pathway to install weapons detection systems within the means of egress. NFPA has issued an emergency Tentative Interim Amendment (TIA) to NFPA 101 that directly addresses these systems in Health Care and Ambulatory Health Care occupancies, bringing clarity to requirements that were previously driven largely by AHJ mandates rather than explicit code language.

This emergency amendment reflects the growing tension between evolving security expectations and life‑safety requirements. For architects and owners, the TIA helps align security planning with defined egress and corridor width criteria, reducing uncertainty during design, permitting, and review.

WHAT THE TIA CHANGES
The amendment introduces new provisions in NFPA 101 Chapters 18 through 21 governing weapons detection systems located in the means of egress for Health Care and Ambulatory Health Care occupancies.

The TIA distinguishes between existing buildings and new construction. Existing occupancies may utilize reduced clear widths at detection system locations, recognizing the challenges of retrofitting security equipment into constrained corridors. New construction must provide a minimum of 41.5 inches of clear width at the detection system, reinforcing the importance of accounting for these elements early in design.

The amendment is retroactively applicable to the 2012, 2024, and 2027 editions of NFPA 101. Because CMS and accreditation agencies continue to enforce the 2012 edition nationwide, CMS‑licensed facilities may immediately apply this TIA without waiting for a future code adoption cycle.

WHY THIS MATTERS FOR PROJECT TEAMS
Prior to this amendment, project teams were often required to integrate weapons detection systems into egress paths without clear life‑safety guidance, creating potential conflicts with corridor width, egress capacity, and accessibility requirements.

By establishing prescriptive criteria, the TIA allows architects and owners to evaluate weapons detection systems earlier in the design process, reducing the risk of late redesigns, variance requests, or approval delays, particularly in renovations and phased improvement projects.

HOW CODE RED CONSULTANTS CAN HELP
Code Red Consultants supports architects, owners, and health care providers in interpreting and applying this new TIA. We assist with early design coordination, evaluation of egress and width impacts, and navigation of AHJ, CMS, and accreditation requirements to help project teams incorporate security measures while maintaining life‑safety compliance. If you have any questions about the practical application of these systems in a health care environment, please do not hesitate to reach out.

Concerns about the safety of the public and first responders have led to increased regulatory enforcement and oversight of laboratory buildings in many major urban markets, with cities such as Boston and New York City establishing dedicated Laboratory Inspection Units within their fire departments. While many of these enforcement mechanisms may feel new, the requirements they are based on have been in the Building and Fire Codes in some form for decades. Since COVID, rapid lab development in some residential areas and shifting office space use have heightened safety concerns, drawing greater scrutiny from Authorities Having Jurisdiction (AHJ).

As laboratory real estate evolves and enforcement activity increases, building owners are under growing pressure to manage compliance at the base building level while preserving the marketability and flexibility of laboratory space. In multi‑tenant environments, compliance challenges are increasingly emerging during lease execution, permit renewals, and renovation planning.  This dynamic underscores the criticality of early, building‑wide coordination in avoiding downstream permitting or occupancy delays and/or unanticipated tenant operational constraints.

Priority Action Items for Owners

Document the base building hazardous materials framework:
Maintain a current Base Building Hazardous Materials Report (aka “414 Report”) that defines how the building supports control areas (International Building Code (IBC) Section 414), laboratory suites or laboratory units (IBC Section 428 or NFPA 45), and/or Group H, High Hazard occupancies (IBC Section 415).  Maximum Allowable Quantities (MAQs) per chemical compartment should be clearly documented in this Report, including allocations for any shared chemical storage or use areas.

Establish base building emergency action protocols:
Provide a Base Building Emergency Action Plan (EAP) that tenants can use as the foundation for their own emergency procedures, ensuring coordination with building systems and response protocols.

Align lease commitments with building constraints:
Ensure lease language related to hazardous materials, compartmentation strategies, shared chemical spaces, and compliance responsibilities ties back to the documented base building capabilities.

Track owner managed hazardous materials:
Account for hazardous materials maintained by the owner, such as generator fuel storage or pH-neutralization systems, and ensure these quantities are documented, permitted, and included in the overall building limits.

Periodically review tenant permits, quantities, and emergency plans:
Conduct routine reviews of tenant hazardous material permits to confirm aggregate quantities remain within site and license thresholds. Review the tenants’ Emergency Action Plan and tenants’ Hazardous Material Management Plan (HMMP) for consistency and coordination with the base building documentation and lease agreements.

Maintain and document life safety systems:
Ensure required testing, maintenance, and corrective actions are completed for base building fire protection, fire alarm, smoke control, egress, fire rated construction, and other laboratory-related life safety systems, with clear documentation.

How Code Red Consultants Can Help

Code Red Consultants partners with AHJs, laboratory owners, and tenants to create compliance programs and strategies. We conduct laboratory inspections and support the laboratory permitting process. Our engineers, with practical field experience and expertise from serving on NFPA 30 and NFPA 45 committees, help owners reduce risk, clarify tenant responsibilities, and drive compliance, all of which support long-term portfolio flexibility.

When designing or reviewing assisted living facilities, accurately determining the occupancy classification is critical. How residents can safely leave the building in an emergency determines key fire protection and life safety code requirements, from exits to fire protection systems. Misjudging evacuation ability can lead to misclassification and the omission of essential safety features, potentially putting residents at risk. In part 2 of this blog series, we explore how occupancy classifications influence compliance and project design for assisted living facilities.​ 

​ Occupancy Classifications in Assisted Living: What You Need to Know
Assisted living facilities differ from standard residential buildings. While residents receive support with daily activities, the level of care does not reach that of a nursing home. Correctly identifying the occupancy classification is essential for designing and operating these facilities safely.

​How Assisted Living is Classified in the International Building Code (IBC)
​Under the IBC, most assisted living facilities fall under Group I-1 (Institutional) for buildings housing more than 16 residents who receive 24-hour custodial care in a supervised environment. The Group I-1 classification is broken down further into two conditions: 

  • ​Condition 1: Residents can self-evacuate independently. 
  • ​Condition 2: Residents need limited verbal or physical assistance to evacuate. 

​Condition 2 comes with more stringent fire protection and life safety code requirements and is typically the most appropriate classification for both assisted living and memory care units. Occupants within these units generally require limited verbal or physical assistance to evacuate the building, which has now been defined explicitly in the 2024 IBC:

​Describes persons who, because of age, physical limitations, cognitive limitations, treatment or chemical dependency, may not independently recognize, respond or evacuate without limited verbal or physical assistance during an emergency situation. Limited verbal assistance includes prompting, giving and repeating instructions. Limited physical assistance includes assistance with transfers to walking aids or mobility devices, as well as assistance with egress (IBC 202).   

​When proposing Condition 1 for assisted living units, operators must thoroughly assess residents’ evacuation capabilities. Some jurisdictions may also require more restrictive occupancy classifications through licensure or local amendments. 

​Key Takeaway: Engage Code Consultants Early
Selecting the correct occupancy classification is crucial to ensure proper life-safety features, avoid expensive redesigns, and prevent conflicts with authorities. Engage code consultants like Code Red Consultants early in your project for guidance and a smoother, compliant process.

​Stay tuned for our final post in the series, where we will discuss key passive fire protection features to align with typical evacuation protocols for this occupancy type. Want to check out the first post in the series? Click here to read Part 1. 

 

Effectively addressing the genuine fire hazards associated with large wood building construction is a critical part of project planning. For jurisdictions adopting NFPA 241 (2019 and 2022 editions), a completed fire exposure analysis should be provided along with the balance of the project’s Construction Documents.

Specifically, NFPA 241 Section 12.3 (2019 edition) and NFPA 241 Sections 12.3 and 13.3 (2022 edition) states: “Before construction begins, a study shall be conducted to ensure that the installation of passive and active fire protection systems, combined with the separation provided between other structures on the same or adjacent lots, are adequate to allow safe egress and to prevent fire spread to the exposed structures.”

Per the 2022 edition of NFPA 241, a large wood-frame structure is defined as a wood structure that meets one of the following criteria:
• Up to three stories and greater than 150,000 sq ft (13,935 m2) aggregate total floor area
• Over three stories, or over 40 ft (12.2 m) above the lowest level of fire department vehicular access, and greater than 50,000 sq ft (4645.2 m2) aggregate total floor area.

The fire exposure analysis should not just be viewed just as a box to check to secure a permit; rather, it is an essential tool intended to mitigate real construction fire risks, such as rapid fire spread, compromised egress routes, and greater exposure hazards for adjacent structures. By thoroughly evaluating fire risks unique to large wood-frame projects and implementing tailored strategies, project teams and the responding fire departments can better safeguard construction sites and protect the surrounding community.

The expectation of NFPA 241 is that this fire exposure analysis, along with a project-specific Fire Prevention Program, is submitted to the Authority Having Jurisdiction at the time of permit submission.

Are you doing work with wood-frame construction and have questions about how this requirement may impact your project? Contact info@crcfire.com for additional information.

780 CMR, The Massachusetts State Building Code 10th edition, is an amended version of the 2021 Edition of the International Building Code (IBC) that will go into effect on July 1, 2025.  With the promulgation of the 10th edition building code, Massachusetts will join other jurisdictions that have modified their building and fire codes to enable more flexible laboratory compliance strategies in new and existing buildings.

Not without similarities to California Building Code (CBC) Section 453: Group L, and New York City Fire Code Section FC 5006: Non-Production Chemical Laboratories, Massachusetts introduces its own variation of laboratory suite compliance through the amendment of IBC Section 428.

The MA amendments could allow owners and developers to improve the marketability of their research and development laboratory buildings by permitting quantities of flammable and combustible liquids more akin to those permitted by NFPA 45 than a control area approach permitted by IBC Section 414.

For example, laboratories located on the 6th and 7th levels above grade could see Class I Flammable Liquid quantities increase substantially, provided the hazard has been adequately mitigated by applying passive and active fire protection strategies.

With this new code change, we are often asked how existing laboratory spaces can employ the new laboratory suite provisions and benefit from the increased chemical quantities enabled under the 10th Edition of 780 CMR. While this process is nuanced, there are fundamentally three significant aspects to the implementation of laboratory suites in an existing building:

  1. Verification that the use of laboratory suites is appropriate for the specific application. For example, process rooms and chemical storage rooms are generally not permitted to be classified as laboratory suites because they do not constitute “laboratory work areas”.
  2. Confirmation that the building’s infrastructure is appropriate, including fire-resistance-rated separations, and supporting systems (e.g. mechanical, electrical, fire protection, etc.).
  3. Obtaining proper permits and approvals associated with the new laboratory suite code approach and any new work required to implement a laboratory suite approach fully. Even if no renovation work is being performed to convert to a laboratory suite, minimally, an existing building Investigation and Evaluation Report (aka “Chapter 34 Report”) should be submitted to the Authority Having Jurisdiction to document the code approach.

In 2022, Edwards Fire Safety announced that it would discontinue support for the Edwards EST3 Fire Alarm Control Unit (FACU) due to challenges in sourcing electronic components. As of December 31, 2023, Edwards has stopped accepting new orders for UL/ULC-listed EST3 systems. While they intend to support existing installations with replacement parts as long as possible, the dwindling supply and eventual end of support are becoming increasingly evident.

The EST4, launched in 2019, offers backward compatibility with many Edwards Signature Series components, wiring, and control unit back boxes. For many facilities, the shift from an existing EST3 system to the newer EST4 system could seem straightforward; however, the transition comes with challenges that necessitate significant pre-planning to minimize impairments, particularly in occupied buildings.

Challenges in Transitioning from EST3 to EST4:
1. Component Compatibility: Many buildings with existing EST3 systems still include some legacy System Sensor devices and modules; the EST3 can interface with these legacy components via the 3-AADC1 loop card. The EST4 system does not support or provide an alternative to this loop card and, therefore, does not support such devices, which can complicate the upgrade process.
2. Network Integration: The EST4 and EST3 systems cannot share network communications directly, making multi-node system upgrades complex and necessitating a carefully managed transition plan to avoid extended operational downtime.

Strategic Approach for a Smooth Transition:
A comprehensive, building-specific migration plan ensures a seamless transition from EST3 to EST4, especially in active buildings. Here’s a structured approach:
1. Prioritize Upgrades: Start by identifying and prioritizing the critical steps in the migration process. Address high-priority tasks first to ensure essential functions are upgraded promptly.
2. Phased Installation: It is considered a phased migration in facilities where continuous operation is essential, such as hospitals or systems with multiple nodes. It is best to install the EST4 system alongside the existing EST3 system, allowing for a gradual transition. This phased approach enables circuit-by-circuit migration, reducing the impact on day-to-day operations.
3. Minimize Downtime: Design the upgrade process to allow EST3 and EST4 systems to operate concurrently at the various stages of migration. This approach maximizes flexibility and minimizes operational disruption during the transition.

Why Partner with Us?
Our team has extensive experience managing such upgrades, having successfully completed similar projects across the greater Boston area. We specialize in designing customized solutions to ensure that transitions are as smooth and efficient as possible.

Whether you’re planning a new project or need assistance with an ongoing upgrade, we’re here to help navigate the complexities of the EST3 to EST4 migration with expertise and precision.

Recently, there has been an increase in the construction of high-rise buildings designed for office and laboratory use. In new high-rise buildings in Massachusetts, 780 CMR requires all stairwells/elevator hoistways built over 70 feet tall to be equipped with a smoke control system. The laboratory environment in these high-rise buildings typically dictates specific ventilation requirements, which uniquely impact the required smoke control systems.

The required smoke control systems (usually stairwell and elevator pressurization) operate by providing supply air within the stair/elevator shaft to pressurize the shaft and keep smoke out while allowing the doors to open without undue force. These smoke control systems must achieve this performance on both Normal and Emergency (generator) building power.

There are two variables that contribute to the pressure readings in the stair/elevator shafts: 1, the amount of supply air provided inside the shaft, and 2, the airflow conditions in the building. In laboratory environments, the building airflow can vary significantly depending on whether the building is on normal or Emergency power. Typically, both supply and exhaust air run, creating a balanced/neutral environment. Regardless, under emergency building power, it is typical for the building supply air to shut down and only the building exhaust air to continue running, resulting in a negative airflow condition and potentially drastically changing the pressure and door force values.

Both the smoke control and lab air systems must function properly to ensure the safety of building occupants, requiring careful coordination and commissioning to ensure the systems work properly in all scenarios.

Laboratory environments typically need a minimum exhaust flow setpoint to meet the applicable ventilation requirements. To minimize negative impacts on the differential pressure and door opening force readings on Emergency power, the building exhaust air could be programmed through the Building Management System (BMS) to ramp down to this minimum exhaust flow setpoint (as established by the laboratory ventilation system design) on Emergency building power, rather than continuing to run at the Normal building power flow setpoint. This typically results in a building environment compatible with the required smoke control systems, as the building is not too negatively pressurized.

Alternatively, the HVAC systems could be programmed to shut down the supply air any time the smoke control system is active. This makes the normal power airflow condition and the emergency power condition match, allowing the stairs to be balanced, knowing they will meet the specs in both power conditions. Under this approach, care must be exercised to ensure that maximum door-opening forces have not exceeded due to negative pressure conditions.

In summary, stair or elevator pressurization systems within high-rise office/laboratory occupancies can introduce complications when commissioning the smoke control systems. By reviewing the potential issues during design and startup, the system can be adjusted appropriately to avoid problems and delays during final Commissioning and turnover. If you have questions regarding how these requirements apply to your project, please contact us at info@crcfire.com.