Insights Category: Technical Information

New FPPM Requirements in Boston – Updated February 2, 2023

Given the increasing number and severity of construction fire incidents in Boston, the Boston Fire Department (BFD) has established a new training requirement for Fire Prevention Program Managers (FPPMs) on construction sites in the city. Effective January 1, 2023, all FPPMs and Alternate FPPMs serving Boston construction sites are minimally required to have taken the National Fire Protection Association’s (NFPA) online FPPM Training prior to assuming the FPPM or AFPPM role.

This new expectation is driven by recent frustrations experienced by BFD, where many project FPPMs have voiced or demonstrated that they were not aware of the responsibilities of the position. An FPPM is not just a “check in the box,” but is a crucially important part of fire and worker safety on a jobsite. Among the responsibilities are such elements as:

  • Overall responsibility for safeguarding life and property during construction, alteration, and demolition projects;
  • Authority to enforce the NFPA 241 Plan – including speaking with the authority of the GC or the Owner;
  • Knowledge of fire protection codes and standards, available fire protection systems, and fire inspection procedures;
  • Providing training to workers;
  • Supervising hot work permitting;
  • Coordinating impairments

Given these responsibilities, and that FPPMs on many projects in the city do not have the necessary backgrounds to be serving in the role, BFD has set this new training expectation for all FPPMs in the city.

The NFPA FPPM Training is available at the NFPA’s website, a link is provided at the end of this post. The online training program takes approximately five to six hours to complete. This training is currently the only program that is acceptable to BFD.

Separate from the FPPM training, there are new expectations associated with the Construction Fire Safety Plan contents. Specifically, the following must be included with each submission to BFD:

  1. The NFPA FPPM Certificate for the FPPM and any AFPPMs.
  2. For any project that includes a standpipe (new construction of a building with a standpipe, or a renovation, demolition, or tenant fitout in a building that has standpipes), BFD is additionally requiring an affidavit that an FPPM is assigned the project. The affidavit includes contact information for the FPPMs (primary and alternate) and the building owner, and must be signed by the licensed builder responsible for the project. This affidavit is available on BFD’s Fire Prevention Division’s website, a link to the affidavit is provided below.

These new expectations are intended to bolster the already robust construction fire safety requirements in the city. As the pace of construction and the complexity of the projects continues, well-trained FPPMs on projects will help to ensure that the NFPA 241 Plans are followed. This should result in a reduction in hazards that contribute to construction fires and accidents.

If you have questions about this new training requirement, please contact our office at 617-500-7633 or info@crcfire.com to speak with our construction fire safety team.

The link to the NFPA Fire Prevention Program Manager Training:

https://catalog.nfpa.org/Fire-Prevention-Program-Manager-Online-Training-Series-P21761.aspx

The link to the BFD NFPA 241 Affidavit:

https://www.boston.gov/sites/default/files/file/2023/01/NFPA%20241%20Affidavit_1.pdf

The 9th edition of 780 CMR, Massachusetts State Building Code, which is based on the 2015 Edition of the International Building Code (IBC) contains specific state amendments to the required construction type for hospitals, nursing homes, and convalescent homes. 780 CMR contains two separate amendments which further reiterate that hospitals, nursing homes, and convalescent homes are required to be constructed of minimally Type IB construction (2-hour rated structure) regardless of the height and area of the building. Since these provisions are more restrictive than base IBC code requirements, it is important that designers and project teams are aware of these amendments.

The following bullet points highlight these amendments:

  • 780 CMR Section 407.1.1 is amended to include M.G.L. Chapter 111 Section 51 and 71, which require that all hospitals, nursing homes, and convalescent homes be constructed of at least Type IB construction:
    • 407.1 Add subsection as follows:
      • 407.1.1 M.G.L. requirements. Hospitals, nursing homes, and convalescent homes shall be constructed of at least Type IB construction in accordance with M. G. L. c. 111. §§ 51 and 71
  • 780 CMR Section 501.1 is amended to include M.G. L. Chapter 111 Section 51, which requires that all hospitals and nursing homes (Group I-2 occupancy classifications) minimally be constructed of Type IB construction.
    • 501.1 Add three notes, as follows
      • Note 1: Site plans may be required to contain fire lanes in accordance with 527 CMR. Any building fire protection system is governed by 780 CMR with the exception of M.G. L. c. 148 §26 laws.
      • Note 2: In 780 CMR 5.00 requirements for unsprinklered buildings may be overridden by sprinkler requirements of M.G.L. c. 148.
      • Note 3: M.G.L. c. 111 §51 requires hospitals and nursing homes of at least Type IB construction.
  • G.L Chapter 111 Section 51 states that no original license shall be issued to establish a hospital unless it consists of at least Type IB fireproof construction.
    • No original license shall be issued to establish a hospital, except a college and school infirmary, unless it complies with the construction standards of the state building code and is of at least type I-B fireproof construction.
  • G.L Chapter 111 Section 71 states that no original license shall be issued to establish a convalescent or nursing home unless it consists of at least Type IB fireproof construction.
    • Notwithstanding any of the foregoing provisions of this section, no original license for the establishment or maintenance of a convalescent or nursing home shall be issued by the department unless the applicant for such license submits to the department a certificate that each building to be occupied by patients of such convalescent or nursing home meets the construction standards of the state building code and is of at least type I-B fireproof construction provided, however that this paragraph shall not apply in the instance of change of ownership of a convalescent or nursing home at the time of application for a license to operate a nursing home. An intermediate care facility for persons with an intellectual disability shall be required to meet the construction standards established for such facilities by Title XIX of the Social Security Act (PL89-97) and any regulations promulgated pursuant thereto, and by regulations promulgated by the department

This requirement should be considered for projects where new hospitals or nursing homes are constructed, additions are made to existing buildings or a portion(s) of the building are undergoing a change in use to a higher hazard category (per the Massachusetts Existing Building Code).

If you have questions regarding how to apply these requirements to your project, please contact us at info@crcfire.com

During renovation projects it is imperative to maintain the fire-resistive rating of the exit stairs. Improperly maintained stairs may allow for smoke and fire spread between floors and impact larger portions of the building, including other floors under construction or other occupied areas of a building. Some common deficiencies and challenges to maintaining exit stairs during construction are outlined below.

Missing or Inaccurate Floor and/or Stair Identification Signage (780 CMR 1023.9)

When new stair signage is included in a renovation, it is critical to not remove the existing signage prior to the installation of the new signage. Stair signage provides important information for egressing occupants to understand how to exit the building in an emergency. Additionally, stair signage allows the fire department to communicate their location within buildings during emergencies.

New Penetration Firestopping Installation

On some projects it may be necessary to create additional penetrations into the exit stairs. When this is done, these new penetrations should be firestopped with an approved UL system to maintain the rating of the stair. Without an approved firestopping system in place, fire and smoke can enter the stair through the annular space between the wall and penetrating item.

Doors Propped Open (780 CMR Chapter 10 and NFPA 80)

Especially during construction, stair doors are often left propped open to facilitate movement between floors within the building. Similarly to propped open doors, stair doors on floors under construction are often left with damaged or modified hardware which prevents the door from closing and latching properly. This compromises the rating of the stair and may allow fire and smoke to infiltrate the stair and can also compromise the operation of a building’s smoke control systems, where provided.

Pull Station and Smoke Detector Not within Five Feet of Every Exit Doorway

As required by NFPA 72, where a fire alarm system is installed, a pull station is needed at the entrance to each exit stair. If the stair contains a smoke control system, a smoke detector must be installed within five feet on every level. These items are sometimes removed or relocated during construction to mitigate false alarms or to install large mechanical equipment. These devices must be left in place to allow for fire alarm system activation and safe egress out of the building.

These important building features are provided to protect occupants, construction workers, and aid the fire department when responding to emergencies.

If you have challenges with maintaining your exit stairs during construction, contact us at info@crcfire.com for more information.

On large or relatively complex construction sites, wayfinding for first responders can be difficult and is oftentimes exacerbated by continually changing site conditions and tight neighborhoods. This concern applies to the general construction site, the interior of the building itself once vertical construction commences, or even within existing buildings as they are renovated. In the event of an emergency, first responders must be capable of properly orienting themselves in order to effectively coordinate their efforts.

While signage requirements for an occupied building are generally understood (https://coderedev.wpenginepowered.com/insights/building-signage-for-emergency-responders/ ), requirements for a construction sites and buildings under construction are generally less so and are dictated by many different Authorities (Fire, Transportation, Historic, etc.).

NFPA 241, The Standard for Safeguarding Construction, Alteration, and Demolition Operations, provides some requirements related to construction signage. Section 7.5.6.5 states that “All exit stairs shall be provided with stair identification signs to include the floor level, stair designation, and exit path direction as required for provide for safe egress.” Signage meeting the intent of this requirement may look as follows:

Figures 1 and 2: Examples of Stair Egress Signage

However, guidelines for general site signage are not outlined. Therefore, it is imperative that the construction team proactively collaborate with the local Authorities Having Jurisdiction in order to meet expectations in relation to construction signage. Signage may be provided to communicate the most efficient way enter the site/building, for ease of accessing fire protection equipment, or to facilitate response and operations to abutters. Examples of some signage best practices are to denote the project name, address, and gate naming convention at each site entrance, denote the location of the fire command center, provide signage at each FDC outlining what the FDC serves and the required pumping pressures, and provide signage at gates that provide access to site hydrants.

Figures 3 and 4: Examples of Site Wayfinding Signage

All signage should be mounted such that it is readily visible and legible from a distance and isn’t continuously obstructed by ongoing construction operations. It is recommended to coordinate the size, content, and coloring of the signs with each of the authorities.

Providing and maintaining proper signage is an often-overlooked aspect of a construction site. However, ensuring that construction personnel and fire responders are able to properly orient themselves both inside and outside of a building under construction can go a long way in improving the overall safety of a project.

The 2012 Edition of NFPA 101, Life Safety Code, as adopted by the Centers for Medicare and Medicaid Services (CMS) and the Joint Commission states that medical gas storage and administration areas are required to comply with the 2012 Edition of NFPA 99, Health Care Facilities Code. NFPA 99 requires rooms that store nonflammable medical gases with a volume totaling greater than 3,000 ft3 to be stored in a 1-hour fire resistance rated room (NFPA 99 (2012), 5.1.3.3.2).  In addition to this requirement, these rooms are required to be provided with signage that notes the storage of oxidizing gases and positive pressure gases within.

A common finding on regulatory surveys is that medical gas rooms are not provided with signage that meets the requirements of both NFPA 99 and the 2010 Edition of NFPA 80, Standard for Fire Doors and Opening Protectives (based on NFPA 80 Section 4.1.4.1 relative to the total area of signs).  When facilities are cited for inadequate signage, the signs created to resolve this deficiency often overlook the requirements for signage on fire rated doors, which results in the creation of noncompliant signs and ultimately, continued risk on regulatory surveys.

When creating signage for medical gas storage rooms the following code requirements should be considered to ensure that all applicable codes are accounted for:

Medical Gas Signage Requirements for fire-rated rooms (NFPA 99):

11.3.4 Signs.

11.3.4.1 A precautionary sign, readable from a distance of 1.5m (5ft), shall be displayed on each door or gate of the storage room or enclosure

11.3.4.2 The sign shall include the following wording as a minimum:

CAUTION:

OXIDIZING GAS(ES) STORE WITHIN

NO SMOKING

5.1.3.1.8 Locations containing positive pressure gases other than oxygen and medical air shall have their doors(s) labeled as follows:

Positive Pressure Gases

NO Smoking or Open Flame

Room May Have Insufficient Oxygen

Open Door and Allow Room to Ventilate Before Opening

5.1.3.1.9 Locations containing central supply systems or cylinders containing only oxygen and medical air shall have their door(s) labeled as follows:

Medical Gasses

NO Smoking or Open Flame

Signage Requirements on Fire Doors (NFPA 80):

4.1.4.1 The total area of all attached signs shall not exceed 5 percent of the area of the face of the fire door to which they are attached

4.1.4.2 Means of Attachment.

4.1.4.2.1 Signs shall be attached to fire doors by use of an adhesive

4.1.4.2.2 Mechanical attachments such as screws or nails shall not be permitted

4.1.4.3 Signs shall not be installed on glazing material in fire doors

4.1.4.4 Signs shall not be installed on the surface of fire doors so as to impair or otherwise interfere with the proper operation of the fire door.

The above requirements are based on the 2012 Edition of NFPA 101, Life Safety Code, as adopted and enforced by the CMS and Joint Commission. State and Local codes which may adopt newer versions of these NFPA codes should also be referenced. If you have questions regarding how to apply these requirements to your project, please contact us at info@crcfire.com.

 

 

Smoke control systems are an important life safety feature in a building. Although there are many types of smoke control systems, they generally share one or more of the following objectives: (1) limit the spread of the products of combustion; (2) maintain tenable conditions for egressing occupants; (3) remove smoke from area(s) of incident; and (4) allow for safer conditions for first responders. To be effective in achieving these, the systems must be capable of operating in adverse conditions experienced during a fire event.

The International Building Code, Section 909, mandates many design features intended to improve the robustness of smoke control systems, allowing them to operate consistently and for the appropriate duration. A summary of the major smoke control protection requirements is outlined below.

  • Equipment (ducts, fans, dampers, etc.) must be suitable for its intended use and probable exposure temperatures.
  • Ducts must be leak tested to 1.5 times the maximum design pressure and supported directly from fire-resistance rated structural elements of the building by substantial, noncombustible supports.
  • Automatic dampers must be listed and conform to the requirements of approved, recognized standards.
  • Fans must be provided with an increased duty rating and extra belts.
  • Systems must be provided with legally required standby power. The standby power source and its transfer switches must be in a room separate from the normal power transformers and switch gears and ventilated directly to and from the exterior. The room is minimally required to be enclosed in 1-hour fire rated construction.
  • Elements of systems relying on volatile memory (i.e. Building Management Systems) must be supplied by uninterruptable power sources that span 12-minute primary power interruption. Elements of systems susceptible to power surges must be suitably protected by conditioners, suppressors, or other approved means.
  • Controlling equipment (Fire alarm and/or Building Management System) must be UL listed for smoke control use complying with UL 864.
  • Smoke control wiring must be enclosed within continuous raceways.
  • In addition to the above, there are fire rated separation requirements specific to stair and elevator pressurization systems. Certain design objectives of other types of smoke control systems may employ similar strategies.

It is critical that smoke control systems are both reliable and durable in order to achieve their intended performance objectives. Code Red as a wealth of knowledge and experience in consulting on, designing, modeling, inspecting, and testing smoke control systems. Please reach out to us if you have any questions or would like assistance with your existing or new smoke control system.

 

Atrium smoke control systems and their associated mechanical exhaust rates and makeup air often come with a unique and challenging set of design constraints. Mechanical exhaust systems must be designed such that exhaust inlets are distributed and oriented appropriately to prevent plugholing. These design constraints associated with exhaust are generally manageable and can be overcome. Providing makeup air for the smoke exhaust system is often the most challenging constraint to overcome when designing an atrium smoke control system using mechanical exhaust.

Makeup air can be provided from natural (i.e. operable doors/windows) or mechanical sources (i.e. supply air fans). How and where makeup air is introduced can have a significant impact on the atrium’s architectural design and the performance of the smoke control system.

Newly constructed atria smoke control systems are subject to the requirements of the International Building Code or NFPA 92 (Standard for Smoke Control Systems, 2012 edition is used here) and must adhere to the makeup air limitations of NFPA 92, Section 4.4.4.1.4.

The prescriptive requirements of this standard place a significant constraint on makeup air velocity. Specifically, makeup air velocities are not allowed to exceed 200 ft/min where the air may come in contact with the plume (NFPA 92, 4.4.4.1.4).   Makeup air velocities greater than 200ft/min can affect the fire, disrupt it’s plume and consequently produce greater volumes of smoke requiring removal. Identifying adequate area to introduce makeup air at velocities near 200 ft/min (approximately to 2.25 miles/hr.) can be challenging compared to locating exhaust inlets which will have an effective area that is an order of magnitude less than that needed for makeup air.

NFPA 92 does allow for higher makeup air velocities if supported by an engineering analysis, often through the use of a computer fire model. Computational Fluid Dynamic (CFD) fire models (such as the Fire Dynamic Simulator – FDS) simulate fire growth and smoke movement throughout an atrium and allow for the performance of the system to be evaluated based on the specific architecture of the atrium and the arrangement of exhaust and makeup air. Makeup air velocities greater than 200 ft/min are able to be simulated and evaluated to determine effects on the smoke development and performance of the smoke control system. Generally speaking, atrium smoke control systems that are evaluated using a CFD model can often support makeup air velocities in excess of 200 ft/min and thereby may allow for greater flexibility in the atrium’s design.

Atria smoke control system designs are rarely the same from project to project but using a CFD model often yields consistent advantages by allowing for increased design flexibility and cost savings. If you have an atrium that requires smoke control on your project, we’d be happy to discuss it further – please contact us at info@crcfire.com.

 

Laboratory Signage

As a stronger emphasis is being placed on laboratory safety during the permitting process in and around the City of Boston, questions frequently arise regarding the types and locations of signage required within the laboratory space. The following sections highlight the general types of signage required within research and development laboratories from the perspectives of 780 CMR and 527 CMR 1.00.

NFPA 704 Signage

NFPA 704 signage is intended to quickly and clearly communicate chemical hazards to emergency responders. The NFPA 704 placard is a multicolored diamond with numerals to indicate the health, flammability, instability, and special hazards presented by chemicals.

527 CMR requires NFPA 704 signage to be placed on stationary aboveground tanks, stationary aboveground containers, at entrances to locations where hazardous materials are stored, dispensed, used, or handled in quantities requiring a permit, and at other entrances and locations designated by the AHJ (527 CMR 60.5.1.8.2.1).

For R&D laboratories, this means NFPA 704 signage is required at all laboratory entry points, including the main laboratory entrance and any entrances to individual rooms within the laboratory space. In addition, NFPA 704 signage is required at any entry points to support spaces where chemical hazards are present (e.g. chemical storage rooms, waste rooms, gas storage rooms etc.).

There are also cases where the AHJ may request additional signage beyond that discussed above. For example, in the case where multiple tenants share a dedicated chemical storage room and have each been allocated a caged area within the room, certain jurisdictions may require tenant-specific NFPA 704 signage to be placed near each tenant’s storage area in addition to signage at the main door to the room.

In all cases, the NFPA 704 signage must accurately reflect the contents of the entire laboratory or storage area served and continued effort must be made to ensure signage is kept current to reflect the hazards present within the space.

Emergency Signage

Signage identifying locations of emergency equipment including fire extinguishers and eye wash/shower stations is intended to make the locations of such equipment easily identifiable for laboratory occupants. For fire extinguishers, NFPA 10 as referenced by 527 CMR requires that signage indicating the presence of an extinguisher be located in close proximity to the extinguisher and visible from the normal path of travel (NFPA 10, 6.1.3.3.3). For emergency eye wash/shower stations, ANSI Z358.1 as referenced by 527 CMR requires a well-lit sign that is highly visible from within the area served by the emergency eye wash/shower (ANSI Z358.1, 4.5.3 & 5.4.3).

Aside from being affixed properly in the location of the extinguisher or eye wash/shower station, the style of signage that is typically recommended for laboratory applications is the projecting type, which extends perpendicularly or in a V-shape off the wall such that it can be viewed from multiple angles. Further, contrasting colors are typically utilized to enhance visibility, such as red and white for fire extinguishers and green and white for safety showers.

Locations of potential obstructions should be considered when locating emergency signage. Fire extinguisher and emergency wash station signage is often easily obstructed by laboratory equipment such as freezers, refrigerators, or glassware storage. Signage locations may therefore need to be adjusted to avoid obstructions and maintain visibility by laboratory personnel.

Spill Kit Signage

Spill kit signage is intended to clearly identify the locations and types of spill kits for laboratory occupants in the event of a chemical or biological spill. Where provided, it is recommended that chemical and biological spill kits be located in separate, distinct locations from one another. Often times they are located in labelled cabinets under lab sinks or in storage adjacent to emergency eye wash/shower stations. Wherever the spill kits are stored, easily identifiable markings are required to be installed to identify the spill kit and denote whether it is for biological or chemical spills.

If you have any questions or would like assistance with fire and life safety code compliance relative to laboratories, please do not hesitate to contact us at info@crcfire.com.

The exit access configuration within a building is impacted by multiple code requirements to ensure that occupants can safely reach an exit and continue to the exit discharge. One of the major limitations that is required to be evaluated when configuring the exit access arrangement is Exit Access Travel Distance. Exit Access Travel Distances are limitations that identify the maximum distance from any point of a story to an exit. These are measured along the exit path from the most remote point of a story along the natural and unobstructed path of horizontal and vertical egress travel to the entrance to an exit (2015 IBC 1017.3). An exit can include exterior exit doors at the level of exit discharge, interior exit stairways and ramps, exit passageways, exterior exit stairs and ramps and horizontal exits.

Although IBC Section 1017.3 and NFPA 101 Section 7.6 outline how this measurement is taken, there are some common questions raised specific to this process given the different components exit access configurations consist of. The following include a few clarifications to address some these misconceptions while measuring Exit Access Travel Distances:

  1. Travel Distances are measured to the nearest exit, not all exits. The most remote point on the floor is required to be within the exit access travel distance limitations to any one exit on the floor.
  2. Often, travel distances change throughout the design of a project. Introducing new furniture or wall partitions for a tenant fitout or alternate furniture layout on a floor may obstruct an existing exit access path. As a result, the new exit access path could exceed the maximum travel distance beyond what is permitted. As design changes take place, it should be confirmed that compliant exit access travel distances are maintained.
  3. If an exit access stairway or ramp is provided along the path of travel, the Exit Access Travel Distance includes the travel down the exit access stairway/ ramp. The measurement along exit access stairways is required to be made on a plane parallel and tangent to the stair tread nosing’s in the center of the stair and landings. The measurement along ramps is required to be made on the walking surface in the center of the ramp and landings.

It is important to understand how to measure exit access travel distances. If you have any questions on or concerns about this information, please contact our office at info@crcfire.com.

 

This Insights post discusses how a story relative to grade is classified from the perspectives of NFPA 30, Flammable and Combustible Liquids Code and the International Building Code (IBC). With the growing laboratory market in the Northeast, more and more tenants are using and storing flammable & combustible liquids, which may trigger compliance with NFPA 30 depending on the jurisdiction. Because NFPA 30 prohibits the storage of flammable liquids in “basements,” it is important to understand the distinction between what qualifies as a basement per NFPA 30 vs. the building code.

What is an NFPA 30 Basement?

From the perspective of NFPA 30, a Basement is defined as “a story of a building having one-half or more of its height below ground level and to which access for fire-fighting purposes is restricted.” This means that if the area of exterior wall below the surrounding ground surface is greater than half of the total area of all exterior walls on the level in question, the story is considered a Basement in accordance with NFPA 30. An example is provided below (NFPA 30 Handbook, Exhibit I.3.2):

What is an IBC Basement?

Stepping over to the IBC, a Basement is a story that is not a Story Above Grade Plane, which is defined as “a story having its finished floor surface entirely above grade plane or where the finished floor of the level above is either: (1) more than 6 feet above grade plane, or (2) more than 12 feet above the finished ground level at any point.” Where a story does not satisfy one of these criteria, it is considered to be a Basement in accordance with the IBC. Two examples demonstrating the application of the IBC definitions are shown in the figure below (IBC Handbook, Figure 202-21).

Note that the term Grade Plane refers to a reference plane representing the average of finished ground level adjoining the building exterior walls, whereas the term grade refers to the surrounding ground level. The determination of grade plane will be a function of the site topography and may require detailed calculations depending on elevation changes.

 Can a story be both an NFPA 30 “Basement” & an IBC “Story Above Grade Plane”?

There are cases where a story can be considered a Basement per NFPA 30 and still be classified as a Story Above Grade Plane per the IBC. Because this possibility exists, it is important that both definitions are evaluated as part of the design process. The following is an example:

What Does this Mean for My Project?

The classification of a story will impact the code requirements pertinent to the design of a building, such as the allowable height and area, construction type, and chemical allowances. Since the classification of a story differs depending on the code, it is critical to evaluate a building in accordance with each applicable code to ensure that all relevant code requirements are met.

If you have questions regarding how to apply these requirements to your project, please contact us at info@crcfire.com.