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Insights Category: Technical Information

Since the adoption of 9th Edition of 780 CMR in January of 2018, our industry has been adapting to the requirement for a Third-Party Firestopping Inspector within high-rise or risk category II or IV buildings. Code Red Consultants has highlighted these requirements in blogs such as Firestopping Frequently Asked Questions and Firestopping Special Inspections: More Than Just a Spot Check. As enforcement of this provision continues it is important to understand when a destructive inspection is regard and how such inspections are required to be documented.

When are destructive inspections required?

A common question that we see from our clients is how destructive inspections are documented. Before answering that question, it is important to recognize that both ASTM E2174 and ASTM E2393 provide options for either witnessing installation of systems or performing post-installation destructive inspection on installed systems.

ASTM E2174 allows two different inspection methods for each penetration fire stop systems:

  1. The inspector shall be on site during installation and randomly witness a minimum of 10% of each type of fire stop being installed, or (ASTM E2174 10.12.1);
  2. The inspector shall conduct a post-installation inspection, which shall require destructive type verification of the fire stop and repair of the fire stop. A minimum of 2%, but not less than one penetration, of each type of fire stop shall be inspected per 10,000 ft2 inspection area (ASTM E2174 10.12.2)

Similarly, ASTM E2393 allows two different inspection methods for fire resistive joint systems:

  1. The inspector shall be on site during installation and randomly witness a minimum of 5% of total linear feet of each type of fire resistive joint system installed or (ASTM E 2393 10.12.1);
  2. The inspector shall conduct a post-installation inspection, which shall require destructive type verification of the fire stop and repair of the fire stop. A minimum of one sampling per type of joint system shall be inspected per 500 linear feet (ASTM E 10.12.2.2).

It must be clarified that witnessed installations include actively observing all portions of the identified firestopping assembly being installed and the witnessed installation requirement cannot be satisfied by means of post-installation visual inspections.

How are destructive inspections documented?

Per ASTM E2174 and ASTM E2393, “An inspection form shall be written and clearly describe the results of the inspection and any deficiencies.” This documentation includes both visually observed deficiencies as well as the results of either the destructive or witnessed inspections per the requirements outlined above. Deficiencies are required to be documented on the inspection form including physically identifying the location where the required firestop or fire resistive joint did not conform with the provided fire stop assembly submittal through visual or destructive inspection. Additionally, each inspection form is required by the applicable standards to be submitted within one working day of the inspection.

Have any other questions related to Firestopping Special Inspections or need Firestopping Special Inspection performed on your project? Feel free to reach out to info@crcfire.com for additional information and see the following link for more information about required frequently asked questions (Firestopping Frequently Asked Questions)

 

Understanding BDA Coverage & Frequency Requirements:

In Massachusetts, the requirements for emergency responder radio coverage in buildings are governed by §916 of the Massachusetts State Building Code (780 CMR). This section is fully amended such that it is unique to Massachusetts.

In accordance with 780 CMR §916.1, emergency responder radio coverage is to be provided throughout all new buildings. This often necessitates the installation of a Two-Way Radio Communications Enhancement System. Installing such a system may be avoided where a radio coverage survey test verifies that a minimum signal strength of -95dBm is achieved both into and out of the building in at least 95% of all areas. As radio signal strength is strongly impacted by building construction such as floor assemblies and wall assemblies, the need to install an enhancement system typically cannot be confirmed until late in construction.

Where a system is required to be installed, a Bi-Directional Amplifier (BDA) system is commonly implemented. This typically consist of a distributed antenna system (DAS) installed throughout each floor of the building and wired to amplifier equipment; the amplifier equipment then connects to an exterior donor antenna which communicates with the municipalities public safety communications systems.

Where a new BDA system is installed, general building areas must be provided with radio coverage in 90% of the floor area when tested in accordance with 780 CMR §916.5.3. Critical areas providing a means of egress or life safety equipment such as a fire pump room, Fire Command Center, or Fire Service Access Elevator Lobbies must have 99% floor area radio coverage per NFPA 72 (2013) §24.5.2.2.1. In all measured areas, inbound and outbound signal strength must be a minimum of -95dBm. Again, radio coverage is greatly impacted by building construction such as floor assemblies and wall assemblies and should be taken into consideration when a radio signal survey is conducted.

Two-Way Radio Communications Enhancement Systems generally need to accommodate several different radio frequencies in order to address the responding fire department’s needs (dispatch channel, fireground/tactical channels, mutual aid channels, etc.) as well as any frequencies required by other emergency responders that require radio coverage. Ultimately, the fire code official is charged with maintaining the list of frequencies currently required to be supported. However, if at any point in the future municipal frequencies are changed or added by the FCC or an AHJ, the system is expected to be modified or expanded to accommodate these changes at ownership’s expense per NFPA 72 §24.5.2.4.2 & 780 CMR §916.6.2.

Final confirmation of the need to install a BDA system often comes late in construction, at a point where installation of associated equipment, wiring and antennas can be disruptive and costly. Further, where a system is provided, the system is expected to be able to accommodate future expansion to cover new or changing frequencies. The associated cost impacts may come in the form of additional equipment, labor and schedule delays.  All of these risks should be taken into consideration during BDA system design.

 

Mezzanines are common features that can be incorporated into building design to provide additional floor area and open space at an intermediate elevation between two stories. There are a number of provisions that outline criteria to regulate and restrict how mezzanines are constructed. These provisions limit the overall hazard of mezzanines, as well as impact the means of egress, fire protection system coverage, accessibility, structural nature, openness, and the allowable area of the mezzanine.

The size of a mezzanine will dictate if an additional space is classified as a “mezzanine” or as a “story” from a code perspective. The detailing of the area evaluation required for mezzanines can raise frequent questions, with several common ones addressed below.

The first step in determining the classification of a mezzanine is to evaluate the area of the space being considered. This process consists of finding the ratio of the area of the mezzanine in relation to the area of the room or space in which the mezzanine is located. In determining these two areas, the IBC provides the following guidelines:

  • The area of the mezzanine includes all area at the respective elevation. Enclosed rooms, means of egress, and other building features at the mezzanine level are to be included in determining the total mezzanine area.
  • The area of the room or space in which the mezzanine is located does not include any enclosed spaces at the floor in which the mezzanine is located.
  • The area of the mezzanine is not permitted to be included in the area of the room or space in which the mezzanine is located.

Note that spaces not otherwise included in determining the total building area (i.e. exterior courts, roof decks without horizontal projection of the roof, etc.) are not included in determining the area of either the mezzanine, or the floor or space in which the mezzanine is located.

Once the areas outlined above are determined, the aggregate area of a mezzanine or mezzanines within a room or space is not permitted to be greater than one of the following (IBC §505.2.1):

  • One-third the floor area of the room or space in which they are located;
  • One-half the floor area of the room or space in which they are located, provided the building is of Type I or II construction, equipped with a code-compliant automatic sprinkler system throughout, and provided with an approved emergency voice/ alarm communication system; or
  • Two-thirds the floor area of the room or space in which they are located, provided the building is of Type I or II construction and houses special industrial occupancies in accordance with IBC §503.1.1.

The area evaluation of mezzanines varies on a case by case basis, but the process of determining the area of the mezzanine and the area of the room or space in which the mezzanine is located remains consistent for all arrangements.

Transformer vaults and switch gear rooms present unique hazards, such as high voltage and explosions, and as such, providing safe and adequate means of egress is a critical component to ensure timely evacuation during a fire or other emergency event. In addition to the prescriptive requirements of the Massachusetts State Building Code (780 CMR), the Massachusetts Electrical Code (527 CMR 12.00) also contains provisions to ensure workers and maintenance personnel are provided with quick exit access from these specialized rooms. The egress provisions from 527 CMR 12.00 to be considered for transformer vaults and switch gear rooms include the following:

  • An exit is required at both ends of the room where the switchgear and control panels exceed 6 feet in width unless:
    1. the location permits a continuous and unobstructed way of exit travel; or
    2. the depth of the working space is twice that required by NFPA 70 Table 110.34(A) (NFPA 70, 110.33(A)(1)).
  • The exit access doors are required to swing in the direction of egress and be equipped with listed panic hardware where the transformer vault / switch gear room contains equipment rated 800 A or more and the exit access doors are less than 25 feet from the nearest edge of the working space (NFPA 70, 110.26(C)(3)).

In addition to the requirements of 527 CMR 12.00, 780 CMR requires a transformer vault to be provided with traditional exit signage as well as floor proximity exit signage. The top of the floor proximity exit signs are required to be located 18” off the floor and adjacent to the opening side of the door. The last measure which is required for appropriate egress from these hazardous areas is the installation of egress illumination. The egress illumination can be achieved by providing emergency lighting in accordance with 780 CMR Section 1008 or luminous egress path markings in accordance with 780 CMR Sections 1025.2 through 1025.5.

As the life sciences industry continues to see significant growth in response to COVID-19, laboratory fitout projects within existing office buildings have become increasingly common as a means to satisfy the high demand for lab space. This raises the question: what does it take to convert an office building into a laboratory? There are several major factors that should be considered when determining the feasibility of a lab conversion project, including the following:

  • Construction Type. The construction type of the existing building will impact its ability to support control areas for chemical storage and use. Control areas are generally required to have 2-hour rated floors and supporting construction (with some exceptions). If an existing building has 1-hour rated or non-rated floors, this will affect the control area strategy of the building and the corresponding maximum allowable quantities of chemicals that are permitted to be present within the laboratories.
  • HVAC Design. NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, requires a dedicated ventilation system for laboratory spaces in which flammable gases, vapors, or particulate matter are present. In addition, depending on how chemicals are used within the building, it may be necessary to provide a hazardous exhaust system in accordance with the mechanical code. The need for these systems will likely warrant additional shaft space and larger fans to be provided. Exhaust air from such spaces is also not permitted to be recirculated. If energy recovery devices that have the potential to recirculate vapors are present, modifications may be required to meet this requirement.
  • Fire Protection. Given the hazards associated with the presence of chemicals, laboratory spaces and chemical storage rooms require greater sprinkler densities. Any existing sprinkler systems will need to be evaluated to determine if they are capable of supporting the required densities.
  • Structural Loads. Laboratories generally have greater live loads than office space. A structural engineer will need to determine whether the building is capable of supporting the loads associated with laboratory use.
  • Electrical Service. Laboratories may have several pieces of equipment with large electrical demands. An electrical engineer will need to confirm that the electrical service provided for the building is capable of supporting the larger electrical demand presented by laboratory use. Further, spaces within the laboratory may require classified electrical equipment (e.g. Class I Division 1) to protect certain hazards.

There is a wide of array of types of laboratory tenants that will have varying needs based on the nature of their research and chemical hazards they present. In our experience, it is most prudent for an owner to understand the relationship between the building infrastructure and the type or types of laboratory tenants their building may attract. Once this is understood, a basis of design from a multidisciplinary design team can be established for potential adaptive reuse projects. If you have any questions or would like assistance with your laboratory conversion project, please do not hesitate to contact us.

 

What to Know Before Charging your Dry Pressurized Construction Standpipe

What is it?

Many construction sites are provided with dry pressurized, manual standpipes to afford first responders a means to attack a fire.  In certain jurisdictions, said systems require a permit for installation, as it differs from the contract documents.  Boston, for one, outlines expectations for these standpipes by way of the Boston Fire Department Requirements for Air Pressurized Standpipes memorandum.  Though the permanent standpipe(s) are most often utilized, there is no prohibition to use temporary piping in part or in entirety.

When do I need to transition?

There will eventually come a time where the dry-manual, pressurized standpipe will need to be transitioned to a wet-automatic standpipe to facilitate at the design intent as you approach Certificate of Occupancy.  As this temporary system was permitted and approved, you must put the fire department on notice of any changes before any modifications take place.  The best way to communicate/document the reasonableness of this change is by way of an Impairment Plan, which can be an amendment to your site NFPA 241, Construction Safety Plan.

What Goes into An Impairment Plan?

The impairment notification to the local fire department must address the following standard sequences:

  1. Shutdown of the temporary standpipe;
  2. Removal of standpipe air pressurization pack units where applicable;
  3. Removal of temporary fire department connections where applicable;
  4. Installation and connection of the permanent fire department connections and associated distribution piping;
  5. Filling of the standpipe/fire protection distribution system (perhaps exclusive of individual sprinkler systems) with municipal water pressure; and
  6. Supplemental signage that may be provided to assist in notification to the responding FD as to what is/isn’t in service during the transition.

If you have any other questions related to Construction Project NFPA 241 Construction Fire Safety  Impairment Plans, please contact us at info@crcfire.com.  For additional information about required construction standpipes, click here.

The threads for Fire Department Connections (FDCs) are mentioned by the International Building Code and the International Fire Code (Section 912.3 in both), NFPA 13: Standard for the Installation of Sprinkler Systems (Section 6.8.1), and NFPA 14: Standard for the Installation of Standpipe Systems (Section 4.8.2). All four of these documents require the Authority Having Jurisdiction (AHJ) to approve the thread type for an FDC, while the NFPA standards provide a bit more guidance to a designer or installer as to the thread type. What are the options, and why are there choices?

There are two primary types of couplings for fire hose in the United States – threaded and threadless. A threaded coupling is the traditional style of coupling which screws together, similar to that of a garden hose. The other style, which became popular for fire hose in the United States in the early 1990s, is a threadless coupling, also called a Storz coupling. This style of coupling has identical mating surfaces, with two lugs and two notches in each coupling. The lugs and notches engage, and a quarter-turn of the coupling makes the connection. Threadless couplings are generally found on hoses 4 inches and larger, and hoses smaller than 4 inches generally use threaded couplings. Threaded couplings can be found for hoses 4 inches or greater in diameter, but are very rare for hoses that would be utilized to supply an FDC.

While threaded couplings are the most common style, there are variants between them. The most commonly used fire hose coupling is the American National Fire Hose Connection Screw Thread, better known as NH thread. This thread style is described in great detail in NFPA 1963: Standard for Fire Hose Connections, and has been around since 1905 (after mismatched coupling styles complicated firefighting efforts at the Great Baltimore Fire of 1904). Even with the long history of this standard, there are other standards for threaded hose. Some departments use National Pipe Straight Thread, or NPST, also known as “iron pipe thread.” These threads are finer than NH threads, and they will not connect to an NH coupling. Additionally, some cities continue to use their own locally-designed threads.

Most fire departments have their own requirements for FDC coupling sizes – be it 2.5-inch threaded, 4-inch threadless, or 5-inch threadless, to name a few. The couplings usually reflect the specific operational procedures of the fire department. Proximity of fire hydrants, capacity of the water supply, fire department vehicle access, and fire department staffing all play a part in the decision.

Beyond the fire department’s coupling style preference, there are two additional key factors that can play into the decision as to what couplings are used.

The first is the number of inlets that are expected to be fed by a single fire engine. Most fire engines have at least three, and usually up to six 2.5-inch discharges. They also generally only have one large-diameter threadless discharge sized 4 inches or larger. If multiple FDCs are expected to be simultaneously supplied by a single fire engine, the design team and the AHJ should reevaluate what couplings are used to ensure adequate discharges are available on the responding fire apparatus.

The second factor that can change coupling styles is the required pressure for the sprinkler or standpipe system. NFPA 1961: Standard on Fire Hose, details the construction requirements and capabilities for fire hose. Hose that uses 2.5-inch couplings is classified as “attack hose” and has a maximum operating pressure of at least 275 psi, with some hoses exceeding 400 psi or more. Hose that is 4 inches and larger – which uses threadless fittings – is classified as “supply hose” and has a maximum operating pressure of 185 psi. If a sprinkler or standpipe system requires more than 185 psi at the FDC inlet, the fire department cannot use a supply hose to supplement the system at its required pressure, and should not be requiring threadless couplings 4 inches or larger.  This type of condition is commonly encountered in high rise or very large floor area buildings, where greater pressures at the FDC inlet may be required to serve the sprinkler and standpipe systems on upper floors or distant parts of the building.

The bottom line is that speaking with the responding fire department(s) early in the design process to ensure the proper FDC type is specified for a project is imperative – and a code requirement.

When designing a new, or even modifying an existing, fire alarm or fire protection system, it is important to be aware of the implications of all applicable codes and standards. Did you know that beyond the Massachusetts State Building Code, 780 CMR, and the Massachusetts Comprehensive Fire Safety Code, 527 CMR 1.00, there is a series of other requirements specific to fire prevention that could apply to your building? Of particular interest is Chapter 148, Fire Prevention, of the General Laws of Massachusetts (M.G.L.’s), which contains several such sections.

This blog is the second in a series on the requirements and caveats of the various subsections of M.G.L. Chapter 148 Section 26 which specifically address requirements for automatic sprinkler systems, fire warning and smoke detection systems, and carbon monoxide alarms in certain buildings.  For Part 1 of the series focused on M.G.L Ch. 148 S. 26A and 26A½, please see here.

This second part of the series addresses M.G.L. Chapter 148 Section 26G.

M.G.L. Ch. 148 S. 26G: “Automatic Sprinkler Systems Required for Buildings and Structures Totaling More than 7,500 Gross Square Feet” reads as follows (only partial text reproduced – refer to the hyperlink above for the full text of M.G.L. Ch. 148 S. 26G):

Section 26G. Every building or structure, including any additions or major alterations thereto, which totals, in the aggregate, more than 7,500 gross square feet in floor area shall be protected throughout with an adequate system of automatic sprinklers in accordance with the provisions of the state building code. No such sprinkler system shall be required unless sufficient water and water pressure exists. For purposes of this section, the gross square footage of a building or structure shall include the sum total of the combined floor areas for all floor levels, basements, sub-basements and additions, in the aggregate, measured from the outside walls, irrespective of the existence of interior fire resistive walls, floors and ceilings. This section shall not apply to buildings used for agricultural purposes as defined in M.G.L. Ch. 128 S. 1A.

 The head of the fire department shall enforce the provisions of this section.

 Whoever is aggrieved by the head of the fire department’s interpretation, order, requirement, direction or failure to act under the provisions of this section, may, within forty-five days after the service of notice thereof, appeal from such interpretation, order, requirement, direction or failure to act to the automatic sprinkler appeals board as provided in section two hundred and one of chapter six. The board may grant a reasonable waiver from the provisions of this section or may allow the installation of a reasonable alternative or modified system of automatic sprinklers upon reviewing the characteristics of buildings that have architectural or historical significance.

There are two important aspects to this M.G.L.: (1) all buildings exceeding more than 7,500 gross square feet (except for specific exemptions discussed in more detail below) are required to be sprinklered; and (2) this requirement is subject to the enforcement of the head of the fire department in the municipality where the building is located (similar to M.G.L Ch. 148 S. 26A and 26A½ discussed in Part 1 of this blog series).

The methodology for determining the “gross square footage” of a building is specified by the language of the M.G.L. and differs from other common methods of determining the gross square footage of the building.  In particular, in determining whether a building is subject to compliance with M.G.L. Ch. 148 S. 26G, credit is not given to subdividing a building via fire-resistance-rated construction.  Rather, the gross square footage of the building is determined irrespective of such interior fire-resistance-rated subdivisions.  As a practical example, a building addition might be constructed with a fire wall to separate it from the existing building for the purposes of resolving allowable area issues in accordance with 780 CMR.  While such a fire wall would qualify the addition and the existing building to be treated separately for these purposes, the buildings would still be subject to the provisions of M.G.L. Ch. 148 S. 26G based on the aggregate area of the addition plus the existing building.

There are specific exemptions identified in M.G.L. Ch. 148 S. 26G where the installation of automatic sprinkler systems is not required, as listed below.  These specific buildings / conditions do not require the installation of automatic sprinkler systems based on M.G.L. Ch. 148 S. 26G, regardless of the gross square footage of the building; however, it is important to note that automatic sprinkler protection may still be required in accordance with the provisions of other governing codes and standards (e.g. 780 CMR).

  • Buildings where sufficient water and water pressure do not exist to support the installation of an automatic sprinkler system. It should be noted the determination of whether “sufficient water and water pressure” is available will be at the discretion of the head of the fire department and may not hinge solely on whether the installation of sprinklers would require a fire pump and/or water storage tank.
  • Buildings where the discharge of water would be an actual danger in the event of the fire, and where the head of the fire department has approved alternative fire suppressant systems.
  • Rooms or areas of a telephone central office equipment building when such rooms or areas are protected with an automatic fire alarm system.
  • Open-air parking structures, as defined by M.G.L. Ch. 148 S. 26G. Similar to the definition of gross square footage discussed above, what constitutes and “open-air parking structure” is defined by M.G.L. Ch. 148 S. 26G and differs slightly from the 780 CMR definition of “open parking garage”. Specifically, to qualify as an open-air parking structure under M.G.L. Ch. 148 S. 26G, at least 25% of the total wall area is required to be open to atmosphere at each level; while, a structure is only required to have 20% of the total perimeter wall area of each tier open to atmosphere to potentially qualify as an “open parking garage” under 780 CMR.
  • Buildings or additions used for residential purposes.

Lastly, in existing buildings that exceed 7,500 square feet in gross area and are undergoing renovations, M.G.L. Ch. 148 S. 26G would apply when the renovation constitutes a “major alteration”.  The language of M.G.L. Ch. 148 S. 26G does not define what is considered a “major alteration” but based on historic application of the law, this determination should consider both the nature of the work (e.g. does the scope and extent of the work facilitate the installation of sprinklers) and the cost/benefit of the installation of sprinklers (e.g. cost of the alteration compared to the value of the building).  Ultimately, the head of the fire department will make the final ruling on whether a specific project is to be considered a “major alteration” which would trigger compliance with M.G.L. Ch. 148 S. 26G and should be consulted early on in the planning and design phases of such renovation projects in unsprinklered or partially sprinklered existing buildings.

As we quickly approach the start of another school year, many colleges, universities, and other educational institutions are faced with making difficult decisions due to COVID-19. Dormitories are densely packed spaces that in more recent years have been designed as large suites to encourage social interaction. Classroom and office buildings present another challenge with many having open floor plans with collaboration, flex spaces and limited private offices. The reality is that if students and staff are not back to school using the dorms, classrooms and dining facilities, the financial consequences will be real and significant.  So, if schools decide to open, the big question is how they do it safely with consideration given to both fire and life safety as well as COVID concerns?

Every school is approaching this in a different way, but many are going through the same due diligence process, with temporary solutions being sought.  Some common considerations and solutions being evaluated are:

  • Buildings are being evaluated for use as temporary classrooms and dormitory space due to a need for social distancing.
  • Dining facilities are being converted to grab-and-go style only.
  • Dedicated and isolated COVID dormitories are being created should a student or staff show signs of sickness or if they need to quarantine for 14 days.
  • Cubicles are being temporarily modified to have higher walls using combustible materials, i.e. lumber and/or plastic wrap
  • Hand sanitizer, a flammable liquid, is being added at every turn, in addition to bulk storage in select areas.
  • Outdoor tents are being setup for classrooms and other uses.

The underlying questions with all of these temporary changes are: what are the code implications and do these solutions help to mitigate COVID concerns but at the same time create a fire or life safety issue?

Temporary Structures

Building officials have the authority in Massachusetts to grant a permit for temporary structures, such as tents, which conform to the building code for a period not exceeding 180 days (Massachusetts State Building Code (780 CMR) Section 108). Tent structures erected for this period are required to comply with the 2015 International Fire Code (IFC) Section 3103.1. Major requirements in this section include:

  • A building permit is required when the tent exceeds 400 square feet and is intended to be used for the gathering of 10 or more people (IFC Section 3103.2).
  • Locating the tent at least 20 feet from lot lines unless meeting certain exceptions (IFC Section 3103.8.2).
  • An unobstructed fire break passageway or fire road not less than 12 feet wide and free from guy ropes or other obstructions shall be maintained on all sides of all tents and membrane structures unless otherwise approved by the fire code official (IFC Section 3103.8.6)
  • Compliant means of egress, exit signage and illumination are required (IFC Section 3103.12).
  • A detailed site and floor plan is required for tents having an occupant load of 50 or more. Floor plans must delineate the means of egress, the tent location on the site, occupant load, arrangement of seating, and the location and type of heating and electrical equipment (IFC Section 3103.6).
  • Tent materials must be compliant with fire resistance ratings in accordance with NFPA 701 (IFC Section 3104.2).
  • Patio heaters must be used only in well-ventilated areas and away from combustible materials. They are not permitted within tents having enclosed walls. Patio heaters with open or exposed flames are not permitted inside or within 20 feet of tent structures per IFC Section 3104.7. Coordination with the fire department is necessary for the approval and permitting of these appliances, fuel storage and use.

Tents that are erected on buildings, balconies, decks or other structures shall be regulated as permanent membrane structures in accordance 780 CMR Section 3102 (IFC Section 3103.8.4) and additional requirements will apply.

Tent locations are not permitted to obstruct fire department access lanes or egress paths from adjacent buildings. The occupant load of outdoor tent is not permitted to exceed the capacity of indoor plumbing fixtures associated with the tent.

Temporary Emergency Use for Housing/Care

Upon declaration by the Governor of a State of Emergency under St. 1950, c. 639, or of an emergency detrimental to the public health under M.G.L. c. 17, § 2A, a building or space within a building may be used as a temporary emergency use for purposes of housing and/or caring for persons in accordance with procedures established for such purpose as contained in Section 3113 of 780 CMR (780 CMR 108.5). On March 10, 2020, Governor Charlie Baker declared a State of Emergency for Massachusetts due to COVID-19, which remains in effect presently. Therefore, a building may be used as a temporary emergency use for purposes of housing and/or caring for persons, provided the following requirements of Section 3113 of 780 CMR are satisfied:

  • Temporary emergency uses are not permitted to be operated or maintained for any purpose without first obtaining a permit from the Building Department (780 CMR 3113.1.1).
  • A written request for the temporary emergency use change, identifying the address-specific property is required to be provided for the permit (780 CMR 3113.2).
  • A temporary emergency use shall be so identified by a special certificate of use and occupancy as established for such purpose by the municipal or state Building Official in consultation with other appropriate municipal and state officials in accordance with procedures established for such purposes. See the Division of Professional Licensure website here s requirements of 780 CMR 10.00: Means of Egress to the degree practicable (780 CMR 3113.4).

General Reconfiguration Guidelines

When changes are made within the building such as reconfiguration of classrooms, hallways, or the use of rooms for new purposes, it is critical to ensure that these changes maintain the level of fire and life safety required by the building and fire codes. Reconfiguration of space, addition of barriers, and changes to egress, may require a building permit per 780 CMR 105.1.  Some common examples of code issues that arise as part of temporary repurposing / reconfiguration of rooms or spaces are shown below.

  • Continuous or noncontinuous barriers shall not be installed within 18 in. of the bottom of automatic sprinkler heads (2013 NFPA 13: 8.5.5.3).
  • Membrane barriers such as draperies, curtains, and similar loosely hanging furnishings shall be flame resistant in accordance with NFPA 701 (527 CMR 1.00: 12.6.2).
  • Doors required for fire separation may not be held open unless they are configured to close automatically and latch upon activation of the building fire alarm system (780 CMR Chapter 7 and 527 CMR 1.00: 12.3.3).
  • Temporary signage establishing one-way circulation patterns to maintain social distancing must indicate that emergency exiting is always allowed in the direction of required egress, regardless of the one-way circulation patterns.
  • Means of egress and egress pathways within rooms must comply with the provisions of 780 CMR Chapter 10.
  • The repurposing of rooms into additional classroom space must be evaluated for compliance with fire sprinkler and fire alarm requirements as required by 780 CMR Chapter 9.

Hand Sanitizer

The Massachusetts Comprehensive Fire Safety Code (527 CMR 1.00) and 780 CMR regulates the storage and use of alcohol-based hand sanitizer, including limitations for flammable and combustible liquid storage.  At the concentration of alcohol recommended by the Centers for Disease Control and Prevention (CDC) to be effective against COVID-19, alcohol-based hand sanitizer will typically be considered a Class IB Flammable Liquid. A permit is required from the local fire department for alcohol-based hand sanitizer in quantities above 10 gal (527 CMR 1.00: 1.12.8.40 and 1.12.8.50). Quantities of these liquids are further limited depending on where they are being stored within the building (780 CMR 307.1).

Wall-mounted or free-standing alcohol-based hand sanitizer dispenser locations are regulated by 527 CMR 1.00. Whereas some installations may be temporary and portable, it is critical that building owners understand the provisions associated with their safe installation and use if they are moved from their original location. The following are some of the major requirements (527 CMR 1.00: 60.5.2):

  • The maximum capacity of dispensing units in areas open to corridors is 41 oz. (0.32 gal or 1.2 L).
  • The maximum capacity of dispensing units in rooms or suites of rooms and separated from corridors is 67 oz. (0.53 gal or 2.0L).
  • The minimum separation distance between dispensers is 48 in.
  • No dispensers shall be located above, within 1 in. to the side of, or within 1 in. below an ignition source, such as an electrical outlet, or open flame [527 CMR 1.00: 60.5.2(6)].
  • Dispensers may be installed directly over carpeted floors only in sprinklered areas of the building.
  • Dispenser operation must comply with manufacturer’s instructions and 527 CMR 1.00:60.5.2(9).

It is important to note that the provisions of 527 CMR 1.00 Section 60.5.2 apply to the hand sanitizer dispensers only.  Bulk storage of alcohol-based hand sanitizer solution in quantities greater than 5 gallons [527 CMR 1.00: 60.5.2(5)] will be subject to additional requirements of 780 CMR and 527 CMR 1.00 for flammable liquid storage.

Temporary Partitions

Temporary partitions and modified cubicle walls are required to comply with 780 CMR and 527 CMR 1.00. Walls are permitted to be constructed using wood in buildings constructed with combustible construction (Types III, IV, & V). In noncombustible buildings (Type I or II), walls are required to be constructed using non-combustible materials or fire retardant-treated wood (780 CMR 603.1). Regardless of the materials of construction, walls and partitions should not be installed within 18 in. of the bottom of automatic sprinklers (2013 NFPA 13: 8.5.5.3).  Where existing partial-height walls are extended to full-height and/or new temporary full-height partitions are constructed, the spacing of automatic sprinklers and fire alarm equipment in the affected area must also be analyzed to confirm that compliant coverage is still maintained under the temporary conditions.

Interior wall finish materials are required to be classified in accordance with ASTM E 84 or UL 723 based on the occupancies and presence of sprinklers. Interior finishes are grouped in the following classes: Class A – flame spread index 0-25, Class B – flame spread index 26-75, Class C – flame spread index 76-200. All classes must have a smoke-developed index that does not exceed 450. The following are tables for classrooms (Group B  if less than 50 people; Group A-3 if 50 or more people), offices (Group B), dining (Group A-2), retail (Group M) and dormitories (Group R-2).

Areas Protected with Sprinklers

Occupancy Classification

 Exit

Enclosures

 Corridors, Exit Access Stairways/Ramps Rooms and Enclosed Spaces

Group A-2/A-3

Class A or B

 Class A or B Class A, B or C

Group B/M

Class A or B

Class A, B or C

Class A, B or C
Group R-2 Class A, B or C Class A, B or C

Class A, B or C

 

Areas Not Protected with Sprinklers

Occupancy Classification

 Exit Enclosures Corridors, Exit Access Stairways/Ramps

Rooms and Enclosed Spaces

Group A-2

 Class A Class A Class A or B
Group A-3 Class A Class A

Class A, B or C

Group B/M

 Class A Class A or B

Class A, B or C
Group R-2 Class A or B Class A or B

Class A, B or C

 

If these partitions are attached to furniture and are not permanently attached to the building, then the partitions could potentially be classified as part of the furniture and would be exempt from the interior finish requirements.

Additional requirements can be found in the following memorandum from the Division of Professional Licensure and the Department of Fire Services here.

 

When designing a new, or even modifying an existing, fire alarm or fire protection system, it is important to be aware of the implications of all applicable codes and standards. Did you know that beyond the Massachusetts State Building Code, 780 CMR, and the Massachusetts Comprehensive Fire Safety Code, 527 CMR 1.00, there is a series of other requirements specific to fire prevention that could apply to your building? Of particular interest is Chapter 148, Fire Prevention, of the General Laws of Massachusetts (M.G.L.’s), which contains several such sections.

This blog will be the first in a series on the requirements and caveats of the various subsections of M.G.L. Chapter 148 Section 26 which specifically address requirements for automatic sprinkler systems, fire warning and smoke detection systems, and carbon monoxide alarms in certain buildings.

Why is this important to you, you may ask? Because some of these requirements apply to new and existing buildings, sometimes irrespective of ongoing project(s). Furthermore, the requirements of the various codes, standards, and laws do not always align, so it is important to understand the differences such that the most-restrictive requirements can be satisfied.

The first Sections that will be addressed are M.G.L. Chapter 148 Section 26A & Section 26A ½.

M.G.L. Ch. 148 S. 26A: “Automatic Sprinklers in High Rise Buildings; Enforcement; Appeals” reads as follows:

Section 26A. Every building or structure of more than seventy feet in height above the mean grade shall be protected with an adequate system of automatic sprinklers in accordance with the provisions of the state building code, except that sprinklers shall not be required to be installed in patient rooms in hospitals.

The head of the fire department shall enforce the provisions of this section.

Whoever is aggrieved by the head of the fire department’s interpretation, order, requirement, direction or failure to act under the provisions of this section, may, within forty-five days after the service of notice thereof, appeal from such interpretation, order, requirement, direction, or failure to act, to the board of appeals as provided in the state building code and section twenty-three of chapter twenty-three B.

There are two important aspects to this M.G.L.: (1) all high-rise buildings in Massachusetts (except for hospital patient rooms) are required to be sprinklered; and (2) this requirement is subject to the enforcement of the head of the fire department in the municipality where the building is located. At first glance, the initial sentence would appear to be all encompassing for high-rise buildings in Massachusetts irrespective of occupancy (except hospital patient rooms), regardless if the building is new or existing. However, it is important to note that this M.G.L. is supplemented by Section 26A ½ for certain buildings where construction commenced prior to January 1, 1975.  It is also important to note that, while M.G.L. 26A provides an exemption for patient rooms in hospitals, sprinklering of such spaces is still often required by other governing codes and standards (e.g. 780 CMR, NFPA 101, as enforced by the Center for Medicare & Medicaid Services (CMS), etc.).

On a related note, M.G.L. Ch. 148 S. 26A ½ addresses existing high-rise buildings that currently are not provided with sprinkler protection. At the surface, this Section may appear to much of the same as Section 26A; however, this Law specifically addresses buildings constructed prior to 1975. The intent of this Section is to retroactively enforce the installation of automatic fire sprinkler systems in older high-rise buildings. While it is believed that the majority of existing high-rise buildings are, at this time, provided with sprinkler protection, either at the time of erection or via this M.G.L., Section 26A ½ remains in effect to permit the head of the Fire Department to enforce this provision on any nonconforming buildings. Exceptions to M.G.L. Ch. 148 S. 26A ½ include hospital patient rooms, libraries, houses of public worship, and condominium buildings.

In both cases, the requirements of M.G.L. Chapter 148 Sections 26A and 26A ½ require the head of the Fire Department to enforce these provisions. Therefore, it is possible that not all jurisdictions may choose to enforce the decision; however, it is extremely important to note that if the head of the Fire Department does choose to enforce this section of the M.G.L., they can do so at any time even where the building remains occupied without any ongoing or future planned upgrades.