Insights Category: Code Updates

Washington, DC, has taken a significant step toward modernizing its construction code framework by designating the DC Department of Buildings (DOB) as the lead agency for code development. This change shifts responsibility from the Construction Codes Coordinating Board (CCCB) to DOB, streamlining the adoption process and reducing longstanding delays. The transition also coincides with efforts to update construction codes that have lagged behind current national model standards, creating challenges for project teams navigating outdated requirements.

Why This Change Matters 

Many jurisdictions are moving toward more direct alignment with national model code adoption cycles to keep pace with evolving building technologies, safety standards, and performance expectations. In DC, continued development activity, adaptive reuse projects, and housing initiatives have highlighted the need for a more predictable and timely code update process. 

Under the previous framework, code updates often took years to advance from national publication to local adoption. Consolidating authority within DOB is intended to provide clearer leadership, faster updates, and improved coordination across agencies. 

Key Takeaways

  • DOB is now the lead agency for DC construction code development 
  • The District plans to align more closely with the national model code cycles 
  • The 2027 DC Construction Codes are targeted to reflect the latest model codes 
  • Future updates are expected to follow a more predictable schedule 
  • The change supports broader District goals, including development, adaptive reuse, and housing production 

Implications for Project Teams 

For owners, developers, and design teams, this shift signals a move toward a more current and consistent regulatory environment. As DOB advances the 2027 DC Construction Codes, project teams should anticipate updates that more closely mirror national standards, potentially affecting design strategies, permitting timelines, and compliance documentation, particularly for projects in early planning or design. 

Need Help Navigating Code Changes and Approvals? 

Code Red Consultants is here to help. Our team of more than 60 engineers brings extensive experience guiding designers, owners, and developers through complex code changes. Please reach out to learn how we can support your project.  

Two upcoming Massachusetts code updates could affect project planning and permitting timelines in 2026. Project teams should stay informed of publication dates and hearings to plan accordingly.

Electrical Code Update – 527 CMR 12.00 

The next edition of the Massachusetts Electrical Code could be published as soon as April 2026. The update is expected to adopt the 2026 Edition of NFPA 70 (National Electrical Code) with Massachusetts amendments. 

Current Status: 

  • A public hearing is scheduled for March 30, 2026 
  • Draft amendments are currently available for review 
  • The applicable electrical code vests at the electrical permit application date, not the building permit application date 

This vesting distinction is especially important for projects approaching electrical permit filing as the new edition approaches publication. 

Fire Code Update – 527 CMR 1.00 

The next edition of the Massachusetts Fire Code could be published as soon as summer 2026 and is anticipated to adopt the 2024 Edition of NFPA 1 with Massachusetts amendments. 

Current status: 

  • Draft amendments have not yet been published 
  • The amendment package is scheduled for review and vote at the April 2, 2026 BFPR meeting 
  • A public hearing will follow, though a date has not yet been set 

Why This Matters 

With both updates expected in 2026, teams should monitor upcoming hearings and amendment releases, particularly for projects that may span the transition period. Early awareness of vesting rules, permit timing, and potential amendment impacts can help reduce permitting risk and avoid late-stage design changes. 

We will continue to monitor both code development processes and share updates as additional information becomes available. If you have questions about how these updates may affect current or upcoming projects, feel free to reach out. 

Pennsylvania adopted a new version of the International Building Code (and other associated I-Codes) effective January 1, 2026. Now that the new code is officially in effect, here are the key dates to be aware of for the 6-month concurrency period:

Effective Date: January 1, 2026

  • Permits submitted on or after January 1, 2026, must comply with the state-amended 2021 edition of the International Building Code (IBC).
  • 6-Month Concurrency Period: If a design or construction contract was signed before January 1, 2026, applicants may submit for a permit under the 2018 IBC until July 1, 2026.
  • After July 1, 2026: All permit applications must comply with the 2021 IBC, regardless of contract date.

Accessibility provisions will continue referencing:

  • The 2018 International Building Code (Chapter 11)
  • The 2009 edition of ANSI A117.1

This exception remains in place based on a prior Pennsylvania Commonwealth Court ruling.

The City of Philadelphia has followed the state in adopting the 2021 I-Codes. Per a code bulletin dated October 20, 2025, the City of Philadelphia will transition to the 2021 IBC on July 1, 2026.

  • Before July 1, 2026: Permit applications may be reviewed under either the 2018 or 2021 IBC.
  • On or after July 1, 2026: All applications must comply with the 2021 IBC.

Additional information from the City of Philadelphia is available here:
https://www.phila.gov/media/20251021080549/B-2501-Implementation-of-2021-International-Codes.pdf

The Rhode Island Building Code Commission is adopting a new set of codes effective December 1, 2025. These will include:

  • RI Building, Plumbing, Mechanical, and Fuel and Gas Codes based on the 2021 I-Codes;
  • RI Electrical Code based on the 2023 National Electrical Code; and
  • RI Energy Conservation Code based on the 2024 International Energy Conservation Code.

The Joint Committee on the Rehabilitation Building and Fire Code for Existing Buildings and Structures is adopting a new Rehabilitation Code, which will take effect on December 1, 2025. The Rhode Island Rehabilitation Code will now integrate the 2021 International Existing Building Code (IEBC) and Chapter 43 of the Rhode Island Life Safety Code (RILSC), 2021 edition. The adoption of an updated Rhode Island Fire Safety Code has not yet been scheduled. However, on October 28, 2025, the Rehabilitation Code Board issued a blanket variance permitting the use of Chapter 43 of the RILSC, 2021 edition, including all cited references to the RILSC, to coincide with the adoption date of the Rehabilitation Code.

If you are working on a project that requires a permit during this transition period, check in early with your local building official to ensure a smooth process. Under RI General Law §23-27.3-114.3.1, there is a three-month concurrency period specific to the building code for new buildings and structures, allowing projects to continue designing to the current code until March 1, 2026, if:

  • The local building official grants approval, and
  • Plans and/or specs are provided upon request (even if not final).

If you have any questions regarding this code adoption or the information provided in this post, please do not hesitate to contact our team.

Starting January 1, 2026, the California Fire Code will require owners of existing lithium-ion battery energy storage systems (ESS) over 20 kWh to submit a hazard mitigation analysis (HMA) to the fire code official. Among the items included in the HMA, the analysis must evaluate the ability of the installed protection system to provide early detection and notification of a thermal runaway event. Where risks requiring mitigation are identified, a corrective action plan with a timetable for implementation will need to be included with the HMA submission.

Building owners should take a proactive approach to this new requirement to determine if their existing ESS installations will require a corrective action plan and how the implementation timetable could potentially impact their operations.

Not sure if your building’s lithium-ion battery energy storage system requires an HMA, what the process entails, or if your system is posing hazards requiring system improvements?  Please give us a call, and we will be happy to guide you through it.

The New York City Department of Buildings (DOB) has enacted two new rules for battery energy storage systems (ESS), which enable indoor installations and require peer review for all ESS projects. The rules also modify NFPA 855: Standard for the Installation of Stationary Energy Storage Systems to address the unique challenges of New York City. These updates represent a significant step forward for utility-scale developers, commercial and industrial property owners, and their project partners.

A Rapidly Growing Market

New York State is advancing toward its ambitious target of 6 GW of energy storage capacity by 2030, supported by NYSERDA incentives that are accelerating deployment across residential, commercial, and utility sectors. Installed energy storage capacity in the state has already grown by more than 80% year-over-year, underscoring the importance of regulatory clarity to sustain this growth.

Why New Rules Were Needed

Until now, energy storage systems in New York City were primarily governed by the Fire Code and FDNY Rule 3 RCNY 608-01 (which is limited to outdoor and rooftop systems). The DOB Building Bulletins 2019-002 and 2020-023 provided guidance on filing procedures and zoning for accessory ESS installations; however, they did not define allowable system types, sizes, or locations. The new DOB rules, Title 1 RCNY 101-19 and Title 1 RCNY 3616-07, close that gap.

Clear Pathway for Indoor Energy Storage Systems

The rules establish a clear pathway for indoor energy storage systems that were previously subject to case-by-case approval. The allowable aggregate rated capacity for indoor systems has been increased, supporting larger installations, including dedicated-use buildings specifically designed for ESS. Projects exceeding these capacity limits can still proceed through a Hazard Mitigation Analysis (HMA) and DOB approval, maintaining flexibility for higher-capacity systems.

Independent Peer Review Requirement

All energy storage systems must now undergo an independent peer review by a NYS–licensed professional engineer with expertise in Fire Protection Engineering and energy storage systems and applications. The peer reviewer is responsible for verifying compliance with:

  • NYC Construction Codes
  • NFPA 855
  • UL 9540 listing conditions
  • The system’s Certificate of Approval (COA)

Peer reviewers must also confirm that UL 9540A test data has been correctly interpreted and that all site-specific fire and explosion hazards are adequately mitigated.

Other Key Provisions:

  • Large-Scale Fire Testing: Required per UL 9540A for all indoor ESS, except valve-regulated or vented lead-acid and nickel-cadmium batteries.
  • Flood Protection: ESS must be installed above the Design Flood Elevation (DFE).
  • Outdoor/Rooftop Systems: Continue to be regulated under 3 RCNY 608-01.
  • Mobile ESS: Additional documentation is required for permit applications.
  • Parking Garages: Reduced clearance allowances to adjacent exposures.
  • Rooftop Installations: Must maintain FDNY access and exposure clearances.
  • Recycled EV Batteries: Prohibited for ESS use.
  • NFPA 855 Exclusions: Chapters addressing capacitor and fuel cell ESS were not adopted.

Implications for New York City’s Energy Transition

Together, these DOB rules expand the potential applications of energy storage systems in New York City while introducing added complexity to code compliance through new regulatory requirements.

Questions about how these requirements impact your NYC project? Our team is ready to help. Contact us for more information.

As more jurisdictions across the U.S. adopt the 2018 International Building Code (IBC) or later, a significant shift is occurring in how fire and life safety systems are tested and commissioned. One of the most impactful changes is the requirement for NFPA 4 Integrated System Testing, which is now mandatory for both new construction and renovation projects in:

  • High-rise buildings
  • Buildings with smoke control systems

If you’re a building owner, facilities manager, contractor, architect, or engineer, this change could affect your next project’s schedule, budget, and turnover timeline unless you plan for it early.

What Is NFPA 4?
NFPA 4’s primary purpose is to ensure proper integration of a building’s fire and life safety systems. While traditional commissioning tests systems individually, NFPA 4 fills the gaps by requiring end-to-end verification across systems to ensure appropriate handshakes are executed.

What does this mean in practice?
This means that all the systems that activate based on a signal from the fire alarm system minimally need to be tested when impacted by a project. Some examples include:

  • Closure of smoke dampers and fire/smoke dampers upon activation of their associated duct detector
  • Firefighter elevator recall
  • Release of security locking on egress doors

Does this apply to new buildings or work in existing buildings as well?
The requirements apply to new buildings and renovation projects in high-rise buildings or buildings with smoke control systems. Applying NFPA 4 to renovation projects puts stress on the accuracy of existing building information and requires internal testing and maintenance of existing systems. To properly plan and execute integrated testing, project teams must gather:

  • Existing fire alarm matrix and sequence of operations
  • Up-to-date test reports for all systems integrated with the fire alarm
  • Design documentation associated with any modifications to the existing fire alarm sequence of operations planned by the renovation project.

Jurisdictions Are Starting to Enforce New Procedural Requirements
Many jurisdictions, including Boston, now require Integrated System Test Plans at the time of permit application for qualifying projects. Without the proper documentation and planning, you risk:

  • Delays in permitting
  • Delays in occupancy
  • Costly rework or redesign

Code Red Consultants has been performing integrated fire protection system testing for over a decade. If you need assistance in planning and navigating these new requirements, please get in touch with us. We’ll post additional blogs soon focusing on the NFPA 4 requirements that are essential for designers, owners, developers, tenants, property managers, and contractors to understand. Stay tuned!

Massachusetts Issues New Fire Safety Mandates for Assisted Living Residences Following Fall River Tragedy

In response to the recent tragic fire in Fall River, the Healey Administration has announced urgent safety directives to strengthen fire preparedness in Assisted Living Residences (ALRs) across Massachusetts. These measures, issued on July 21, 2025, are part of a statewide initiative to improve life safety standards and emergency readiness in facilities that care for populations who may require verbal and/or physical assistance to evacuate.

WHAT ALRs NEED TO KNOW:
As part of the Gubernatorial mandate, ALRs must comply with the following requirements:

1. Resident and Family Communication
By July 25, all ALRs must issue a written notice to residents and their families. This notice must include:
• Detailed fire safety protocols.
• Clear evacuation procedure.
• Contact information for questions or concerns.

2. Posted Evacuation Information
By July 25, Evacuation instructions and exit routes must be clearly posted within each resident unit and in all common areas throughout the facility.

3. Fire Safety Self-Assessment Survey
The Executive Office of Aging & Independence (AGE) will distribute a mandatory Fire Safety Self-Assessment Survey in the coming weeks. ALRs must complete and submit the survey that reaffirms compliance with applicable codes and standards within 30 days of publishing. Supporting documentation to be included with the survey is understood to be as follows:
• Proof of maintenance of sprinkler systems.
• Current fire drill and evacuation protocols, training, and drilling program.
• Proof of maintenance of fire-rated doors, walls, and locking hardware.
• Statement on life safety system (fire alarm sprinkler, standpipe, etc.) age to assess upgrade needs.

4. Emergency Preparedness Documentation
ALRs must submit their current, site-specific Disaster and Emergency Preparedness Plan to AGE within the same 30-day timeframe. This plan should reflect the facility’s approach to emergency coordination, evacuation logistics, and resident safety during critical incidents.

For additional details, the full press release is available here.

HOW ALRs SHOULD BE PREPARING:
ALRs should begin reviewing fire safety protocols, evacuation procedures, and documentation immediately to ensure timely compliance with these new requirements. Our team is available to support facilities with:
• Help you understand your building’s code compliance strategy. Without clarity about which walls/doors must be rated, it is difficult to prioritize inspections.
• Review door/wall maintenance reports to confirm documentation will be acceptable to AGE. Code Red Consultants can provide the inspections as needed.
• Review life safety system testing reports to confirm documentation will be acceptable to AGE.
• Review your Emergency Preparedness Plan to ensure it meets minimum code/AGE expectations based on your specific building’s design approach. As necessary, Code Red Consultants can prepare a site-specific Emergency Preparedness Plan.

WE WILL KEEP YOU POSTED AS THE GOVERNOR OR AGE ISSUES UPDATES:
Stay tuned for our upcoming blog series, which will dive deeper into the unique regulatory challenges facing Assisted Living Residences, including common building code issues and practical approaches to compliance.

For any immediate inquiries, please get in touch with Joseph Igoe at jigoe@crcfire.com or Caitlin Gamache at cgamache@crcfire.com.

As of June 30, 2025, The Joint Commission announced a significant update to its accreditation standards: beginning in 2026, the Environment of Care (EC) and Life Safety (LS) chapters will be consolidated into a single “Physical Environment” chapter. This change is intended to streamline compliance by eliminating redundancies and aligning more closely with CMS Conditions of Participation (CoPs). While this may appear to reduce the number of standards, most previously applicable requirements will still be enforced in full.

The updated standards are expected to be published in July 2025 and will take effect on January 1, 2026. A transition period is anticipated, during which The Joint Commission is not expected to cite facilities that continue referencing the former format.

Another notable change is that the standards will now be freely available to the public via a searchable online database, improving transparency and accessibility.

Code Red Consultants is available to help your facility understand and prepare for the impact of these updates. Please don’t hesitate to reach out for support.

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.