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Insights Category: Code Updates

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.

As outlined in our previous Insights Post, “MA Fire Code Update”, the Board of Fire Prevention Regulations approved a new edition of 527 1.00 CMR, the Massachusetts Comprehensive Fire Safety Code, which took effect on December 9, 2022. Consequently, code users must now refer to the 2019 edition of NFPA 51b, Fire Prevention During Welding, Cutting, and Other Hot Work, and the 2022 Edition of NFPA 241 for additional requirements concerning hot work on construction sites. Significant code changes have been enacted, affecting pricing, scheduling, and risk mitigation. This will be outlined in this and future Insights posts.

The 2014 edition of NFPA 51b, which was referenced by the edition of 527 CMR 1.00 applicable prior to December 9, 2022, required that a fire watch for the duration of the hot work operation and an additional ½ hour after the completion of hot work operations to detect and extinguish potential smoldering fires. This duration could be extended where required by the Permit Authorizing Individual (PAI).

With the new reference to the 2019 edition of NFPA 51b, the duration for maintaining a fire watch has been increased to a minimum of 1 hour after the completion of hot work, irrespective of the hot work operation, location, occupancy, or construction type. Additionally, NFPA 51b Section 5.6.3 introduces a new provision requiring fire monitoring within the hot work area for up to an additional 3 hours after the completion of the 1-hour fire watch, as determined by the PAI.

In addition to the extended baseline fire watch duration, the 2022 edition of NFPA 241, also newly reference by 527 CMR 1.00, increases the duration of fire watches for specific hazardous operations and building construction types. Section 16.19.1.4.2 of 527 CMR 1.00 requires a 2-hour fire watch after torch-applied roofing operations. New chapters in NFPA 241, addressing the construction of large wood and tall mass timber buildings, increase the minimum fire watch duration to 2 hours (as indicated in 527 CMR 1.00 Section 16.24.8 and 16.25.7). Notably, both chapters prohibit the use of torch applied roofing for these construction types.

The strategy for meeting the new fire watch requirements should be reviewed on each project, as the manpower, budget, and scheduling implications could have significant implications.

Code Red Consultants will continue to monitor these code adoptions and provide updates as more information is released.

​​The new Massachusetts Uniform State Plumbing Code (248 CMR 10.00) was recently adopted with an effective date of December 8, 2023. Electronic versions of the new and old code can be found here. Listed below are some of the major changes from Section 10.10: Plumbing Fixtures: 

  • ​The most significant change to the plumbing code is the new allowance to provide Multi-User / Gender Neutral Toilet Rooms under the following criteria:

    1. ​At least one single-user restroom must be provided on the floor within 300 feet of the multi-user restroom.  
    2. ​Each toilet is required to be separated by lockable partitions that extend from floor to ceiling to provide privacy. This may have implications on fire protection coverage, fire alarm notification, exhaust, etc., that should be reviewed. 
    3. ​The number of fixtures is required to be calculated based on equal number of individuals per gender. 
    4. ​Multi-User / Gender Neutral Toilet Rooms are not permitted to be installed for one gender and not the other.  
    5. ​Existing multi-user restrooms are permitted to be converted to Multi-User / Gender Neutral Toilet Rooms without changing the partitions. Any new partitions installed in the future are required to be full height. 
    6. ​The code is silent on whether urinals are permitted within these rooms (new or existing).
  • ​New occupancies have been added to the table such as agricultural buildings (occupied/unoccupied), quasi professional stadiums, casino gaming and small structures (occupied/unoccupied).  
  • ​In general, the number of required lavatories has increased for most occupancies. 
  • ​The travel distance for reach restrooms has increased in most instances to 400 feet. 
  • ​All occupancies are permitted to go up or down one story to reach the required restrooms (except core facilities in a house of worship, K-12 student restrooms, and multi-story retail). 
  • ​Separate restrooms are no longer required for post-secondary students and staff. 
  • ​Urinals are no longer required for K-12 and post-secondary. Instead, urinals are permitted to be substituted for required toilets similar to other occupancies. 
  • ​Under the previous code, the number of fixtures was permitted to be calculated based on the actual number of occupants. The new code specifies how to determine the number of occupants for certain occupancies such as hospitals, medical buildings, places of business, retail, and public beaches. 
  • ​High/low drinking fountains are only permitted to count as one fixture.

​The changes above are specific to plumbing fixture counts only. Contact the plumbing engineer on your projects to determine any code changes which may impact the plumbing system design. For additional information or to request for assistance on your project, please contact us at info@crcfire.com.