Insights Category: Technical Information

This blog is the second in a series on Evacuation Planning, specifically addressing egress posting requirements.  For Part 1 of the series focused on Emergency Action Plans, please see here.

In the state of Massachusetts, evacuation maps are required to be provided as a condition of building occupancy.  They are required to be posted by the owner on all floors of every building, except High Hazard, Factory, Correctional Facilities (780 CMR Section 111.5.2). In addition to the minimum per floor requirement, all rooms used as a place of assembly or as an R-l (i.e., hotel) sleeping space must include evacuation maps. Said placards are required be securely fastened to the building or structure in a readily visible place, showing exiting paths per floor.

Specifics associated with the placement, number, and composition of such evacuation maps are ultimately subject to the approval of the local building official, but are minimally recommended to include the following:

  • Illustrate a primary and secondary egress route;
  • It is recommended to orient floor plan to match;
  • Provide a “You are Here” designation;
  • Mark available “Exits”;
  • Provide a key/legend.

 

Emergency Action Plans, also referred to as Emergency Management or Evacuation Plans, are required in many jurisdictions, including those such as Massachusetts that adopt NFPA 1, Fire Prevention Code.   Such a plan must be submitted to the authority having jurisdiction (AHJ) as a condition of occupancy, whether initial or longstanding.

Though considered best practice for any and all commercial properties, the Code only mandates the Emergency Action Plan if you are classified as one of the following building/occupancy types (NFPA 1, Section 10.2):

  • High-rise;
  • Healthcare or ambulatory healthcare;
  • Residential board and care
  • Hotels and dormitories;
  • Assembly;
  • Special amusement buildings;
  • Educational (i.e., K-12);
  • Bulk merchandising retail buildings;
  • Underground and windowless structures;
  • Facilities storing or handling hazardous materials as defined by NFPA 1, Chapter 60; or
  • Where required by the AHJ.

The Plan is required to be submitted to the AHJ and updated when requested.  The Plan should be unique to the specific building in question, with consideration given to its architectural configuration, occupancy program/arrangement, ability of staff on site to act swiftly in an emergency to assist in evacuation and features of fire protection.

Specifics associated with the length, arrangement, and content of the Plan is at the discretion of the AHJ, but is minimally required to include the following (NFPA 1, Section 10.8.2):

  • Procedures for reporting of emergencies;
  • Occupant and staff roles and responsibilities in different emergencies;
  • Evacuation, relocation and/or shelter-in-place procedures appropriate to the building, its occupancy, emergencies, and hazards (this is often supplemented with evacuation diagrams);
  • Accommodations to assist occupants/staff with disabilities;
  • Appropriateness of the use of elevators;
  • Design and conduct of fire drills; and
  • Description of all features of fire protection and life safety systems.

Be mindful of additional expectations of the AHJ, which may be memorialized in amendments to the Code or city ordinances.  Boston, for example, scales the expectation for a Plan to additional building types (Boston Fire Prevention Code (Section 72-1-02)).  Said buildings are as follows:

  • That house building occupants below grade of such total numbers that their movement under emergency evacuation in fire conditions;
  • Buildings that include significant amounts of combustibles that would make it difficult or impossible to evacuate the occupants in a fire condition;
  • Buildings where a particular configuration (height, length, width, depth, type of construction, or topography) would hinder effectiveness of fire department operations;
  • Buildings 70-feet in height; and
  • Apartment buildings and hotels.

If you would like additional information or would like assistance in preparing an Emergency Action Plan, please contact info@crcfire.com.

As micro units and efficiency dwelling units become more prominent in architectural design, specific code requirements related to room size and minimum dimensions have become increasingly important. In Massachusetts, a few of these requirements come from 780 CMR, Massachusetts State Building Code, and 105 CMR 410.00 State Sanitation Code, which are used to establish the minimum required habitable area for dwelling units.

When sizing individual dwelling units, the following key code requirements must be used together to ensure that all necessary provisions are met:

Massachusetts State Building Code

  • All habitable spaces, other than a kitchen, must not be less than 7 feet in any plan dimension, §1208.1.
  • Every dwelling unit must have at least one room that is at least 120 square feet in net floor area. Furthermore, other habitable rooms are required to be at least 70 square feet in net floor area, §1208.1.

State Sanitation Code

  • Every dwelling unit shall contain at least 150 square feet of floor area for its first occupant, and at least 100 square feet for each additional occupant, which is calculated on the basis of total habitable room area (note that this applies to total area of the dwelling unit);
  • In a dwelling unit, every room occupied for sleeping by one occupant shall contain at least 70 square feet of floor area, and every room occupied by more than one occupant shall contain at least 50 square feet of floor space for each occupant (i.e. 70 square feet total for one occupant, 100 square feet total for two occupants);
  • In a rooming unit (i.e. dormitory), every room occupied for sleeping by one occupant shall contain at least 80 square feet of floor area, and every room occupied by more than one occupant shall contain at least 60 square feet of floor space for each occupant (i.e. 80 square feet total for one occupant, 120 square feet total for two occupants).

If you are considering a development that includes micro units or have any additional questions on this topic, send us an email at info@crcfire.com.

 

In accordance with the 9th edition of 780 CMR Massachusetts State Building Code, an interior exit stairway is defined as a means of egress component that “provides for a protected path of egress travel to the exit discharge or public way.” Where “land-locked” interior exit stairways do not have direct access to the building exterior, use of an exit passageway to connect the interior exit stairway to the building exterior is permitted by 780 CMR Chapter 10, and is a common approach to code-compliance. These exit passageways are designed to maintain the fire-resistance rating of the interior exit stairway(s) which they serve in accordance with the construction requirements of 780 CMR §1024.3.  In high-rise buildings, there is an added complication in that stairways are often pressurized as a means of satisfying the smokeproof enclosure requirements of 780 CMR §1023.11.  Where exit passageways are utilized to extend pressurized exit stairways, the exit passageway may require pressurization in the same fashion as the interior exit stairway, too, depending on its configuration.

Where interior exit stairways are pressurized, the termination of the pressurized exit stairways are subject to the requirements of 780 CMR §1023.11.1 ‘Termination and Extension.’  Exit passageways are specifically permitted to extend the smokeproof stair enclosure to the exit discharge, but are required to be “without openings” to adjacent building spaces.  In other words, the language of 780 CMR §1023.11.1 requires that exit passageways serving this function connect and communicate only with the interior exit stairway and the exterior of the building.  This configuration would not require the exit passageway to be pressurized; however, in practice it is often impractical or infeasible to avoid openings from adjacent building areas for egress purposes from those spaces.

In recognition of this practical challenge, Exception 1 to 780 CMR §1023.11.1 permits openings (from normally occupied spaces) into the exit passageway serving the smokeproof stair enclosure, when such openings are protected and the exit passageway is pressurized in the same manner as the smokeproof enclosure. The code requirement defining the performance criteria for stairway pressurization systems is 780 CMR §909.20.5, which requires 0.10 – 0.35 inches of water column be maintained throughout the interior exit stairway, relative to the building.  To qualify for Exception 1 to 780 CMR §1023.11.1, all doors communicating between the exit passageway and the adjacent building spaces would similarly need to meet the performance criteria of 780 CMR §909.20.5.

Pressurization of the exit passageway can be accomplished in a variety of ways such as the use of air transfer grille(s) in in the walls between the interior exit stairway and exit passageway, installation of ductwork connecting the two areas, or by installation of a separate fan for the exit passageway. In all cases, certain equipment and construction requirements will apply to ensure protection of the pressurization equipment and the integrity of the fire-resistance-rated enclosures are maintained.  Additionally, smoke detectors for the purposes of activating the pressurization systems are required outside of each exit passageway door in accordance with 780 CMR §909.20.6.

If you have any questions related to the requirements associated with pressurized exit passageways, please feel free to reach out to us and request additional information.

 

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 third 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. Part 2 of the series focused on M.G.L Ch. 148 S. 26G, can be found here see here.

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

M.G.L. Ch. 148 S. 26C: “Certain public accommodations; automatic smoke or heat detectors” reads as follows:

Apartment houses containing six or more dwelling units, hotels, boarding or lodging houses, or family hotels which are not regulated by section twenty-six A or twenty-six B shall be equipped with automatic smoke or heat detectors as provided by the rules and regulations of the board of fire prevention regulations.

The head of the fire department as defined in section one shall enforce the provisions of this section.

It is important to note that this section applies to rentable units of long-term housing when 6 or more are grouped within one building or to transient (short-term) housing buildings, where the building in either case is not considered to be a high-rise. When a building falls into one of these two categories, it is required to be provided with smoke and/or heat alarms/detectors as described within 527 CMR 1.00, Massachusetts Comprehensive Fire Safety Code, which is an amended version of NFPA 1.

This law does not apply to new buildings as new construction must comply with the requirements of the current editions of 780 CMR, Massachusetts Building Code, and 527 CMR 1.00. Instead, this law is meant to apply to existing, noncompliant, residential buildings that have been built prior to January 1, 1975 (and not altered since), that otherwise do not comply with the codes applicable today. In this instance, noncompliant buildings are those that are not currently provided with smoke and/or heat alarms/detectors in areas of the building that would otherwise require them.

In April of 2018, the State Fire Marshal released an advisory on the application of M.G.L. Ch. 148 S. 26C, which can be viewed here, where these buildings are required to provide a minimum level of safety. This level of minimum protection was detailed within the superseded version of 527 CMR 1.00 Section 13.7.4.5, which was based on the 2012 Edition of NFPA 1. The provisions included the following items to be installed in accordance with NFPA 72:

  • Single- and multi-station interconnected smoke alarms within each dwelling unit
  • Manual pull stations
  • Hard wired and interconnected smoke detectors in the common areas and hallways
  • A fire alarm system which is monitored
  • Notification throughout the building

The advisory document also outlined how the original M.G.L. was approved November 17, 1989 and provided compliance deadlines for various community population thresholds, all of which have passed as of November 17, 1994.

The current publication of 527 CMR 1.00 is based on the 2015 Edition of NFPA 1 which no longer prescribes the minimum level of protection discussed above since it was believed by the BFPR committee to be unnecessary as the compliance deadlines had long expired (over 25 years ago). If the language has been removed from 527 CMR 1.00, why should all of this matter to you?

The State Fire Marshal’s advisory document was published to bridge the gap between M.G.L. Chapter 148 Section 26C and the currently adopted 527 CMR 1.00, which no longer specifically addresses this topic, as many residential buildings have been found to remain noncompliant with this M.G.L. Therefore, if it is discovered that any pre-January 1, 1975 residential building fall under the purview of M.G.L. Ch. 148 S. 26C, the Head of the Fire Department still maintains with authority to mandate retroactive compliance with this Law even if no other alterations or renovations occurring in the building.

It is important to note that other codes may come into play when considering the necessary fire alarm upgrades outlined in M.G.L. Ch. 148 S. 26C, such as 780 CMR. An example includes existing, Use Group R-2, residential buildings that contain more than 3 dwelling units and are not currently provided throughout with automatic sprinkler systems. These specific buildings are also required to be provided with system-type heat detectors within 6 feet of each dwelling unit entry doorway, per the Massachusetts Existing Building Code, 780 CMR Chapter 34, Section 302.10.

For any proposed work regulated by 780 CMR 34.00, the building owner is required to have the existing building to be investigated and evaluated in accordance with 780 CMR 34.00 (780 CMR 34, Section 104.2.2.1) and accurately ascertain the effects of the work on the structural, means of egress, fire protection, energy conservation, lighting, hazardous materials, accessibility, and ventilation for the space under construction. The results of said investigation and evaluated are required to be presented to the building official in written report form.

Sequencing Inspection Requests: Shaft Wall Penetrations

Over the years as we continue to perform third party fire stop and fire-resistant joint inspections, a common sequencing question that continues to be asked is when does the inspector need to be called for the first wave of inspections as interior building construction commences. One of the driving factors for this sequencing is typically related to when shaft wall construction commences by the drywall sub-contractor.

As referenced in our Firestopping Special Inspections: More Than Just a Spot Check Blog Post, Section 10.8 of both ASTM 2174 and ASTM 2393 requires that “The inspector shall verify and document that the firestop systems required in the inspection documents have been installed.” The implication of this requirement when it comes to scheduling inspections is that shaft wall penetrations will require two rounds of visual and destructive inspections with the first prior to drywall installation such that the shaft layer portion of the firestopping assembly may be inspected and the second after drywall installation such that the drywall portion of the firestopping assembly may be inspected. Note that this is specific to where the submitted firestopping assembly from the manufacturer specifies firestopping at both the shaft wall and drywall layer (see examples below where firestopping application is required at both layers).

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)

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.