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Insights Category: Code Updates

Outside of mechanical engineers and contractors, A2L refrigerants may not be widely known within the AEC industry. However, that is beginning to change as many jurisdictions adopt a complex code path driven by the version of a key referenced standard. We wrote this blog to help break down the complexity of this issue and offer practical guidance for navigating it if it comes up on your next project.

The Driver: As of January 1, 2025, a federal mandate requiring the use of refrigerants with lower global warming potential went into effect, prohibiting manufacturers from distributing equipment that uses R-410A refrigerants. In response, the industry is transitioning to A2L refrigerants (i.e R-32 and R-454B).

The Challenge: ASHRAE Standards 15 and 34 directly address these types of refrigerants starting in the 2022 Edition. The compliance challenge stems from the fact that many jurisdictions still adopt building and mechanical codes based on the 2021 (or earlier) editions of the International Building Code (IBC) and International Mechanical Code (IMC). These versions do not directly reference these updated ASHRAE standards and therefore lack a clear code path to utilize provisions intended for modern refrigerants “as of right”. The 2022 Edition of the ASHRAE standards is referenced in the 2024 Edition of the IMC. Until jurisdictions adopt the 2024 codes, a variance or special approval may be required to access these updated provisions.

Fire-rated shaft requirements are particularly relevant between the editions and can significantly impact design.

In Massachusetts, for example, the 10th Edition of the Massachusetts State Building Code is based on the 2021 IBC and IMC. To proactively resolve this gap statewide, the Massachusetts Board of Building Regulations and Standards (BBRS) has issued Advisory Opinion 2024-01: A2L Refrigerants, recommending the use of the 2022 editions of ASHRAE Standards 15 and 34 for refrigerant system design, subject to approval by local code officials.

Solution Strategies: If you’re not in a jurisdiction where a proactive approach has been implemented through amendment, adoption, or interpretation, projects may seek to use alternative compliance methods permitted in the IBC and IMC with their local building and fire officials. Engaging in such discussions early in the design process is recommended, as waiting until the permitting or inspection stages of the project can present schedule and scope risks.

Code Red Consultants has experience pursuing compliance alternatives to support using the 2022 ASHRAE Standards for residential projects throughout New England, New York, and the Mid-Atlantic, helping teams align with evolving code requirements while maintaining design flexibility.

Massachusetts is adopting its 10th edition of 780 CMR, Massachusetts State Building Code, with the conclusion of the current concurrency period slated to end on July 1, 2025. This marks Massachusetts’ completed transition to the 2021 International Building Code (IBC), where it joins the majority of jurisdictions across the country that are now enforcing the 2018, 2021, or 2024 IBC.

One of the new code allowances that is of particular interest relates to changes to the Business Use occupant load factor, especially regarding its impact on the required number of exits from a floor. Historically, office spaces were calculated using a factor of 100 gross square feet per occupant and first changed to 150 gross square feet per occupant in the 2018 edition of NFPA 101, Life Safety Code and then subsequently followed by the International Building Code.

This factor, along with those used to establish occupant loads for conference rooms and breakout areas, could often push larger office floors above the 500-person threshold.  As a result, the number of exits required from the floor would need to be addressed through an additional exit enclosure or, perhaps more creatively, a horizontal exit. We often see office floor plates in the 30,000 SF to 50,000 SF range, historically yielding an aggregate occupant load close to or above the 500-person threshold. For example, a 40,000 SF office floor plate with 3,000 SF of assembly space and 37,000 SF of office space would yield an aggregate occupant load of 570 occupants, requiring three exits. Under the new provisions, this same arrangement would result in an aggregate occupant load for the floor of 447 occupants and a minimum of two exits based on the occupant load.

Both new and existing buildings benefit from this change, as applying the new occupant load factors may enable floor plans to have more rentable square footage (more efficient floor plans) while reducing long-term operational costs for the building. If these provisions are applied to existing buildings, it should be noted that approval of the building department via permit documents should be sought.

In addition, the building code also introduced a new occupant load factor for concentrated business use areas (50 SF/person or lower). This factor is intended for unique office areas with higher densities, including call centers, trading floors, or data processing centers.  The appropriate application of these new concentrated occupant load factors can be nuanced. It should be reviewed by a competent registered design professional who is experienced in applying building, fire, and life safety codes and standards.

For more details on this code change, please see our previous blog post here or contact us for more information.

Effective July 1st, Massachusetts will join other states in adopting an International Building Code (IBC) edition (2018, 2021, or 2024) that requires compliance with NFPA 4: Standard for Integrated Fire Protection and Life Safety System Testing. This change is being implemented as part of the Massachusetts State Building Code 780 CMR 10th Edition.

We previously covered this topic here, but with the effective date quickly approaching, we wanted to revisit it and share key insights and lessons learned from our experience. Below are some of the most critical takeaways from the upcoming requirements:

  • Integrated testing is now required per IBC Section 901.6.2 for all buildings with two or more interconnected life safety systems. These systems may include fire sprinklers, emergency generators, elevators, security systems, etc. The requirement applies to both new and existing buildings.
  • High-rise buildings and other buildings with smoke control systems are subject to more rigorous integrated testing that must be conducted in accordance with NFPA 4. This includes the involvement of an Integrated Testing Agent (ITa)—a qualified individual with expertise in fire protection, life safety systems, and their integration. The ITa should be engaged as early as possible, ideally during the design phase, to support design reviews, develop the integrated test plan, and assist with system coordination.
  • Understanding the requirements and coordinating closely with local Authorities Having Jurisdiction is essential. Formal deliverables such as test plans and final reports will be required for project permitting and closeout and can significantly impact the project schedule if not planned for properly.
  • Proactive testing or recommissioning of existing building systems can help identify issues, reduce risk, and avoid unexpected costs or delays during future renovations or fit-outs that must comply with NFPA 4.

While these new requirements enhance overall building safety and system reliability, they also introduce added responsibilities and will become a key part of a project’s critical path. Prioritizing integrated testing throughout design, construction, and close-out will help support smoother project delivery.

Stay tuned as we continue to share ongoing guidance and real-world lessons learned related to NFPA 4 throughout the summer.

780 CMR, the Massachusetts State Building Code, is an amended version of the 2021 Edition of the International Building Code (IBC) that will go into effect on July 1, 2025.

The new Massachusetts building code requires an NFPA 241 Construction Fire Safety Program to be submitted and approved by both the Building and Fire Officials at the time of the building permit application as part of the project’s building permit documentation. Under the previous versions of the Massachusetts State Building Code, the building code was not clear in establishing when this critical document was to be submitted, leaving enforcement up to local municipalities and their permitting process. Massachusetts utilizes NFPA 1 as its model fire code, and the code change to the building code keeps Massachusetts in line with jurisdictions enforcing Chapter 33 of the 2021 edition of the International Fire Code (IFC), which is referenced by IBC Chapter 33.

Building owners, developers, contractors, and others with a vested interest in the timely approval of permit documents should be aware of this change, as local municipalities may modify their permitting processes to meet Massachusetts’s new standard. This change was intended to reinforce where the NFPA 241 Construction Fire Safety Program fits into the permitting process and may not be a significant change in jurisdictions that have developed more robust NFPA 241 review processes, such as Boston, where NFPA 241 Fire Safety Programs are required at the time the building permit is filed.

This code change underscores the importance of project teams having a well-developed and thoughtful NFPA 241 Construction Fire Safety Plan before filing for building permits. Code Red Consultants has supported the development of more than 1,000 NFPA 241 Construction Fire Safety Programs and is well-positioned to help designers, contractors, owners, and authorities navigate the code requirements associated with NFPA 241.

This blog is part of a series leading up to July 1, 2025, when the concurrency period between the 9th and 10th Editions of the Massachusetts State Building Code expires. Projects applying for a building permit after this date must meet the requirements of the 10th Edition.

If you have questions about how this impacts your project, please get in touch with us at info@crcfire.com.

Reminder – Concurrency Period for 9th Edition ends June 30, 2025!

Code (Red) Alert! For those continuing to design buildings in accordance with the 9th Edition of 780 CMR, the Massachusetts State Building Code, time is running out to file your permit applications. Starting July 1, 2025, all projects filing for building permits in the State of Massachusetts must comply with the 10th Edition of the Massachusetts State Building Code (780 CMR), which is based on the 2021 International Building Code. Code Red Consultants will post informative blog posts in the coming weeks to assist you with this transition. These posts will provide a summary of some of the key impactful code changes in the 10th Edition, including Laboratory Suites, adoption of NFPA 4 Integrated Testing of Fire Protection Systems, occupant load factor changes in business occupancies impacting egress calculations, fire alarm low-frequency devices, mass notification systems, and more.

Have questions on how these code changes impact your projects? Please reach out to discuss!

The Board of Building Regulations and Standards (BBRS) held a special meeting on October 21, 2024 to discuss the concurrency period for the 9th and 10th Editions of the Massachusetts State Building Code (780 CMR). At the meeting the Board voted to extend the concurrency period to June 30, 2025, where projects can elect to file permits under either the 9th or 10th Editions. This extension will not be official until it is reviewed by various State departments and published by the Secretary of the Commonwealth’s State Publications and Regulations Division.

The 10th Edition of the Massachusetts State Building Code (780 CMR) will go into effect October 11, 2024. The Board of Building Regulations and Standards (BBRS) previously approved a concurrency period that ends on January 1, 2025, where projects can elect to file permits under either the 9th or 10th Editions. However, the BBRS intends to discuss extending this concurrency period at their October 8, 2024 meeting due to the delay in adoption. The promulgated version of the 10th Edition amendments will be posted on the BBRS website and published by the Secretary of the Commonwealth. Draft amendments can be found here.

The Board of Building Regulations and Standards (BBRS) has completed a review of the public comments and will likely vote to promulgate the 10th Edition of 780 CMR, the Massachusetts State Building Code at their next meeting on May 14, 2024. If that occurs, the effective date of the new building code will likely be in Q3 of 2024. The BBRS also voted to allow a concurrency ending on December 31, 2024 (regardless of when the 10th Edition formally goes into effect). During this concurrency period, projects can elect to file permits under either the 9th or 10th Editions. Projects filing for permits on or after January 1, 2025, will be subject to compliance with the 10th Edition. The table below shows a comparison of key model codes that are adopted and amended by each Edition.

 

* Applicable to jurisdictions that fall under the Base Energy Code. Refer to 225 CMR 22.00 and 23.00 for Stretch and Specialized Energy Code Municipalities.

The draft of the Massachusetts State Building Code (10th Edition) was approved by the Healey Administration on December 11, 2023, to move forward to public hearings. The dates and locations for the public hearings have been formally announced as follows:

  • Wednesday, February 14, 2024, at 10:00 a.m. (In-Person)
    Reggie Lewis Track and Athletic Center
    1350 Tremont St Boston, MA 02120
  • Wednesday, February 21, 2024, at 10:00 a.m. (Virtual)
    Join on your computer, mobile app, or room device
    Click here to join the meeting
    Meeting ID: 221 842 912 364 Passcode: ZaGJch
    Call in (audio only) +1 857-327-9245,,331233547# United States, Boston
    Phone Conference ID: 331 233 547#
  • Wednesday, February 28, 2024, at 10:00 a.m. (In-Person)
    Springfield Technical Community College
    One Armory Square – B2 Auditorium Springfield, MA 01105
    (use parking lot K/Building 2 Scibelli Hall Auditorium)

Interested Parties will be given an opportunity to present testimony orally or in writing at these hearings. The Board will also accept written comments regarding the regulations sent via email at bbrs-ma@mass.gov or by mail at this address: Board of Building Regulations and Standards Division of Occupational Licensure – Office of Public Safety and Inspections 1000 Washington Street, 7th Floor Boston, MA 02118.

In addition to these hearings, written comments can be submitted to the Board of Building Regulations and Standards (BBRS) by 5:00 p.m. on March 6, 2024. BBRS meetings are scheduled to occur on March 12th, April 9th, and May 14th following the public comment period. It is unknown how many meetings the BBRS will need to finalize and formally vote to adopt the 10th Edition. Given the limited time between the public comment period and the BBRS meeting in March, we anticipate the Board vote to occur during the April meeting and for the 10th Edition to be promulgated by the Secretary of State in either May or June of this year. A 6-month concurrency period is anticipated to be offered following the formal adoption date.

As outlined in previous Insights posts, the Board of Fire Prevention Regulations approved a new edition of 527 1.00 CMR, the Massachusetts Comprehensive Fire Safety Code. This took effect on December 9, 2022. As a result of this update, code users must now refer to the 2022 Edition of NFPA 241 for construction fire safety requirements. This and subsequent Insights posts will discuss significant code changes that have been enacted, affecting pricing, schedule, and risk mitigation.

In recent years, wood frame construction has seen a resurgence in popularity, largely due to its affordability, availability, and the offsite prefabrication of panelized wood framing. These characteristics have led to the construction of numerous apartment communities using either conventional lumber construction or the “stick over podium” style construction. One trade-off for these aforementioned advantages is the increased fire risk in wood-frame buildings under construction, given the inherent combustible nature of the materials used.

The 2013 Edition of NFPA 241, previously applicable in the Commonwealth of Massachusetts, did not provide dedicated construction fire safety requirements for wood frame construction. The 2019 Edition provided additional requirements for Tall Timber buildings. The 2022 Edition of NFPA 241 now provides additional requirements for both Large Wood Frame structures and Tall Mass Timber Buildings. One new requirement for both building types that could have a significant impact on project budgeting  is the need for site security on all Mass Timber and Large Wood Frame construction sites. For Mass Timber projects, an off-hours manned security service is required once the building has exceeded three stories.

For Large Wood Frame projects, manned security is required at all times.

In addition, the Authority Having Jurisdiction (AHJ) can require security where combustible construction is exposed, where construction exceeds 40 feet in height, and when no crews are on site. This service is expected to consist of trained personnel who are aware of notification procedures for notifying the fire department of emergencies, capable of operation fire protection equipment, aware of site hazards, and capable of utilizing construction elevators, if applicable. As these new chapters provide some flexibility of “other methods as acceptable to the AHJ”, a dedicated security plan should be documented as to the projects approach for site security.

As usual, it’s important to be aware of local AHJ requirements when undertaking new projects. Up front coordination with your AHJ not only helps in proactively mitigating potential problems, but also fosters innovative solutions to achieving code requirements.