Code Red Consultants

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 went into 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. Significant code changes have been enacted that will affect pricing, schedule, and risk mitigation, which will be outlined in this and future Insights posts.

The 2013 and 2019 Editions of NFPA 241 did not include provisions for emergency lighting on construction sites. The 2022 Edition now provides minimum requirements for emergency lighting, depending on how the construction site is normally illuminated. In all instances, emergency lighting is required to illuminate paths of egress for construction personnel.

For construction sites without electrical infrastructure, areas served by natural lighting are permitted to use natural lighting as emergency lighting during daylight hours. If natural lighting is used, supplemental lighting is required in shielded areas or when natural lighting is unavailable.

All areas provided with temporary lighting must also have supplemental emergency lighting. The means by which this emergency lighting is provided should be reviewed for each project, as hazards may dictate varying levels of emergency lighting.

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

In response to the ongoing laboratory and biotech development boom, the Watertown Fire Department has outlined a new laboratory registration and permitting process, which became effective in January 2023. These new processes are intended to document the manner in which laboratory spaces and laboratory buildings are maintaining compliance with the applicable codes to which they’ve been built, and that laboratory operations are being conducted in a safe, compliant manner.  All new laboratories filing for registration after January 1, 2023, are subject to the new process and documentation requirements; while existing laboratories with active laboratory registrations have until September 30, 2023, to update their documentation to align with the new requirements.

In addition to various laboratory operations, emergency response, and reporting documentation, as part of this new process the Watertown Fire Department is requiring additional documentation to outline the laboratory tenant applicant’s operations, anticipated chemical inventory, and compartmentation into control areas and/or laboratory units.  Further, a separate document describing the base building’s hazardous materials compliance approach is required.

The Watertown Fire Department defines these two new documents as follows:

  • Building Hazardous Materials Report: The purpose of a Building Hazardous Materials Report (708 CMR 414.1.3) is to identify each Control Area and or Laboratory Unit within a building and outline the hazardous materials strategy for the building. Detailed in this report is the maximum allowable quantities (MAQ) of hazardous materials permitted in each control area and the code required fire protection features of the building. This report shall be prepared by a qualified person, firm, or corporation.
  • Laboratory Compliance Report: To keep pace with the growing life science industry in the City of Watertown, Watertown Fire Department is requiring technical assistance from approved Fire Protection Engineers (FPE) per 527 CMR section 1.15. All new laboratory registrations, or ones requiring significant changes to an existing registration, shall utilize an approved FPE to generate a laboratory compliance report. The report will verify that the hazardous/flammable and combustible permit request is compliant with applicable fire codes and is consistent with building design based on the Building Hazardous Materials Report. The report will meet the requirements of 527 CMR Chapter 60.

Additional information related to the updated Watertown Fire Department laboratory registration and permitting process, including a complete list of the required documents, can be found on the Watertown Fire Department’s website, here.


With the 2018 and 2021 editions of the International Building Code (IBC) being more widely adopted, it is important to understand the specific changes, eliminations, or revisions that may occur to code sections within each respective edition. This blog post focuses on significant changes of those two code editions associated with fire protection systems that will impact the design of open parking garages.

First, there is now an area threshold (48,000 gsf) above which sprinkler protection is required for open parking garages (2021 IBC, Section 903.2.10). In the two previous editions of the IBC, sprinkler coverage has been permitted to be omitted from open parking garages, regardless of area n a related note, the 2018 IBC provisions that once allowed the omission of an automatic sprinkler system within open parking garages in high rise buildings or open parking garages greater than 55 feet above the lowest level of fire department vehicle access have been eliminated from the 2021 IBC (IBC Section 403.3, 903.2.11.3). These are important code updates, as the omission of a sprinkler system within an open parking garage was once a key benefit of pursuing an open parking garage design rather than an enclosed parking garage.

The other significant change relates to standpipes in parking garages. Various exception language used to exist in Section 905.3.1 regarding required types of standpipe (Class I or III), whether it could be manual or automatic, and whether it could be wet- or dry-pipe. The 2021 IBC now simply permits Class I standpipes to be installed in parking garages, regardless of height, and effectively leaves the wet/dry and manual/automatic provisions to NFPA 14, Standard for the Installation of Standpipe and Hose Systems, which is adopted via the IBC and otherwise addresses such matters.

Of course, designers always need to consider local amendments or laws which may modify such requirements, such as M.G.L’s in MA, which also include provisions on these subjects.

On February 17, 2023, the Massachusetts Department of Fire Services and Board of Fire Prevention Regulations (BFPR) published and promulgated a new edition of 527 CMR 12.00, the Massachusetts Electric Code. 527 CMR 12.00 is an amended version of the 2023 Edition of the National Electric Code (NEC), produced and published by the NFPA as NFPA 70. The new version of 527 CMR 12.00 is effective March 1, 2023 and applies to all electrical permits applied for following this date.

Notably, the new edition of the 2023 NEC includes changes relating to Energy Storage Systems (Article 706) and the interconnection between various types of on-site power supplies (e.g. electric utility power, storage batteries, PV systems, etc.), GFCI and emergency disconnect requirements in residential electrical systems, hazardous locations in industrial cannabis facilities, and much more.

Massachusetts-specific amendments in the new version of 527 CMR 12.00 address wiring protection, installation methods, and materials (Chapters 2 & 3), GFCI protection for certain appliance types (which was addressed by an emergency amendment passed on January 26, 2023, under the previous version of 527 CMR 12.00), and Article 700, Section 10(D) regarding protection of emergency system feeder circuits in areas protected by an approved fire protection system, to name a few.

For any project that necessitates an electrical permit, note that the applicable Massachusetts Electrical Code vests with the application date of the electrical install permit, rather than the date a building code permit may have been applied for.


As outlined in the MA Fire Code Update Insights Post, the Board of Fire Prevention Regulations approved a new edition of 527 1.00 CMR, the Massachusetts Comprehensive Fire Safety Code, which went into effect as of December 9, 2022.

As part of this adoption, code users are now referenced to the 2022 Edition of NFPA 241 when it comes to construction fire safety. This new edition includes a restructuring of the previously applicable 2013 Edition of NFPA 241 and brings in many new code requirements that may change the manner in which construction managers will price, schedule, and manage risk on their projects.  Stay tuned for future Insights posts outlining specific impactful changes as to how buildings are built in Massachusetts.

Have questions on how these changes may impact your project already under construction or seeking a building permit soon? Request additional information at

As of December 9th, 2022, a new fire code has taken effect in Massachusetts. 527 CMR. 1.00 Massachusetts Comprehensive Fire Safety Code is based on the 2021 Edition of NFPA 1 with several Massachusetts specific amendments. Any permits pulled after this date are subject to compliance with the new code. The authority having jurisdiction has the authority to allow a compliance alternative in the event that strict prescriptive code compliance is not feasible, and the intent of the code is met by the proposed design.

The MA Amendments and a memo prepared by the State Fire Marshal summarizing the major changes can be downloaded from the State website at the following link.

It is also expected that the new electrical code (527 CMR 12.00) will be adopted in January of 2023, based on the 2023 Edition of NFPA 70 with Massachusetts specific amendments. A draft of the proposed amendments can be downloaded from the State website at the following link.

Code Red Consultants will continue to monitor these code adoptions and provide updates as more information is released. For additional information or request for assistance on your project, please contact us at


Our previous post in November 2021, “Mass Timber – Exposed Wood in Type IV-B Construction”, provided insight into the allowances for exposed mass timber elements, specifically with Type IV-B construction, based on the 2021 IBC.

The proposal G147-21 has been approved as submitted for changes to Section 602. to be included in the 2024 IBC, expanding the allowable percentage of exposed mass timber elements in dwelling units or fire areas of Type IV-B buildings. The approved provisions are as follows:

  • Ceilings are permitted to expose an area less than or equal to 100% of the floor area.
  • Walls and attached columns are permitted to expose an area less than or equal to 40% of the floor area.
  • A mix of both exposed walls and ceilings are permitted, using a mixed unprotected area equation, provided in Section 602.

This code change follows the recommendations from the ICC Tall Wood Building Ad-Hoc Committee, based on tests from the Research Institute of Sweden with fully exposed mass timber ceilings demonstrating satisfactory results with respect to performance objectives set for these building materials.

It should be noted that the 2024 IBC has not been finalized, and the base code will not be adopted for years; however, the approval of this code change provides opportunities for potential variances to allow for more exposed mass timber elements in Type IV-B buildings. For additional information or request for assistance on your project, please contact us at



At the most recent Board of State Examiners of Plumbers and Gas Fitters meeting, the Board voted to finalize the proposed amendments for 248 CMR 10.00. The promulgation of such code will likely be as soon as 2023.

Draft amendments were discussed in the Board’s April 2022 open listening meeting. Some of the draft changes include:

  • In places other than residential, restrooms will have a travel distance of 400 feet and in multi-story buildings, access to the restroom is limited to one vertical story.
  • New minimum plumbing fixture factors for places including greenhouses, bed & breakfasts, and public beaches.

These updates are not yet finalized, however may impact designs so designers should be mindful of its approaching promulgation.

Code Red will continue to monitor the adoption process of the next edition of 248 CMR 10.00 and update this post as more information becomes available. For additional information or request for assistance on your project, please contact us at

The Massachusetts Electrical Code Advisory Committee is currently reviewing the 2023 National Electric Code (NEC) for amendments and eventual adoption as the 527 CMR 12.00:  Massachusetts Electrical Code. The 2023 NEC could be applicable as soon as January 2023.

Projects should be mindful that the applicable Massachusetts Electrical Code vests with the application of the electrical install permit rather than the building code permit.

Code Red Consultants will continue to monitor this review process and update as adoption dates are finalized.  For additional information or request for assistance on your project, please contact us at

The current building and fire codes that are applicable in Connecticut are based on the 2015 Editions of the International Code Council (ICC) documents. In 2020, the State was in the process of moving towards the next version of the codes based on the 2018 ICC documents; however, this was put on hold due to COVID-19. Two years later, they have shifted their original intent and are in the process of moving to the following codes, effective October 1, 2022:

  • 2022 Connecticut State Building Code (CSBC)
  • 2022 Connecticut State Fire Safety Code (CSFSC)
  • 2022 Connecticut State Fire Prevention Code (CSFPC)

These codes will adopt and amend the following national standards:

  • 2021 International Building Code (IBC) by the ICC
  • 2021 International Existing Building Code (IEBC) by the ICC
  • 2021 International Energy Conservation Code (IECC) by the ICC
  • 2021 International Mechanical Code (IMC) by the ICC
  • 2021 International Plumbing Code (IPC) by the ICC
  • 2021 International Residential Code (IRC) by the ICC
  • 2021 International Swimming Pool & Spa Code (ISPSC) by the ICC
  • 2020 NFPA 70 National Electrical Code (NEC) by NFPA
  • 2017 ICC A117.1 Accessible and Usable Buildings and Facilities by the ICC
  • 2021 International Fire Code (IFC) by the ICC
  • 2021 NFPA 101 – Life Safety Code by the NFPA
  • 2021 NFPA 1 – Fire Code by the NFPA

Historically, a concurrency period has not been provided in CT when switching code editions without approval of a state modification. There have been discussions about offering one for this cycle, however, no formal word has been provided at this time.