Code Red Consultants

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.


Members of the Board of Building Regulations & Standards (BBRS) continue to work towards the statewide adoption of the 10th Edition of 780 CMR. At the BBRS Meeting on December 14th 2021, an updated timeline was reviewed and approved and includes the following milestones toward adoption:

  • April 2022 – Special hearing for general public to offer comments on draft 10th Edition (draft amendments can be found here)
  • May – June 2022 – BBRS reviews public comments for potential incorporation into 10th Edition
  • July 2022 – BBRS votes to move 780 CMR into Executive Order 562, Administrative Review Process
  • February 2023 – Administrative review process complete with approval to promulgate
  • March 2023 – BBRS takes final vote to promulgate new code and is sent to Secretary of State
  • May/June 2023 – 10th Edition promulgated

Please note that due to various parties involved, as well as complexities associated with adopting a new code that this timeline is subject to change. We will provide further updates as new information becomes available.

Click here to view the original post from June 2020.

For jurisdictions that adopt the 2018 Edition of NFPA 101, Life Safety Code, there are new means of escape requirements for New Apartment Buildings per Chapter 30 unless specifically amended.  Grab bars are now required for all bathing fixtures including bathtubs, bathtub-shower combinations, and showers in New Apartment Buildings.   There is an exception that would allow the grab bars to be omitted if the bathing fixture is a roll-in shower with slip resistant floor.

This requirement is a means of escape requirement to ensure safe walking conditions out of a bathing fixture that has a threshold of more than ½” and flooring that is not slip resistant.  This grab bar requirement found in Chapter 30 of NFPA 101 is in addition to grab bars that may be required for accessibility compliance within the bathroom.

If you have questions on means of escape grab bars and the applicability to your project, please reach out to our office at to find out how we can assist.

There are several reasons developers and architects are contemplating using Mass Timber for their next project – most notably sustainability, speed and ease of construction and reduced weight of materials. An additional benefit remaining at the forefront of Mass Timber is the exciting aesthetic that comes with exposed wood beams, columns, ceilings, and walls. Given this element, understanding the allowances and limitations of the new Type IV-A, IV-B, and IV-C construction types in the 2021 IBC is important, with each type carrying a prescriptive requirement related to the amount of exposed wood.

Type IV-C construction provides the most opportunity to expose the Mass Timber elements in the future code, is allowed to have all walls, ceilings, and structure be 100% exposed, provided that the required fire-resistance ratings for the building are achieved. At the other end of the spectrum, Type IV-A construction is required to have all wood concealed behind gypsum wallboard, as a trade-off for superior building heights (which can reach up to 18 stories for most occupancies).

In the middle, Type IV-B construction is allowed a partial exposure of floors and ceilings. The Type IV-B exposure allowance is approximately 30% across walls and ceilings, with specific regulations as follows:

  • Exposed ceilings, including attached beams, are limited to a maximum area equal to 20 percent of the floor area in any dwelling unit or fire area.
  • Exposed walls, including attached columns, are limited to a maximum area equal to 40 percent of the floor area in any dwelling unit or fire area.
  • Where both ceilings and walls have exposed portions, the exposure is required to comply with the equation shown below. This equation requires the ratio of total exposed ceiling area (Utc) to allowable exposed ceiling area (Uac) plus the ratio of total exposed wall area (Utw) to allowable exposed wall area (Uaw) to be less than one. (If this approach seems familiar, it is the same concept that is used for separated mixed-use occupancy area calculations in Chapter 5.)

The exposed ceiling area is required to include beams, and the exposed wall area is required to include columns. However, beams and columns that are not an integral part of floor/ceiling or wall assemblies, respectively, do not count toward these calculations, and are permitted to be exposed.

It should be noted that the 2021 IBC will not be applicable in Massachusetts until the 10th edition of 780 CMR is adopted, which, as of this writing (December 2021), is still likely over a year away. However, with this coming trend, it is important to understand the new 2021 IBC requirements related to Mass Timber construction, especially as they may be able to be used in the meantime to justify building code variances to the 9th edition of 780 CMR.

If you are considering Mass Timber for your next project, please reach out to

Click the links below to view the other Insights in the Mass Timber series:

Mass Timber – Concealed Spaces

Mass Timber – CLT & Glulam Char Depth Calculations

Photo credit: Jones Architecture and DCAMM



With the adoption of the 10th edition of the Massachusetts State Building Code (MSBC) and an anticipated increase in projects utilizing Mass Timber, it is important to understand the new 2021 IBC requirements related to this type of construction. This Insight will focus on new code provisions related to allowance and protection of concealed spaces in Type IV construction.

In the 9th Edition of the MSBC (based on the 2015 IBC), buildings constructed of Type IV construction are prohibited from having any concealed spaces at all. All other construction types are allowed to contain concealed spaces, which are otherwise required to be protected via MSBC Section 718. The prohibition of concealed spaces in Type IV construction is unrealistic for modern buildings, almost all of which have concealed space in some locations.

In the 2021 IBC, however, concealed spaces are prescriptively permitted in Type IV construction. For the new Type IV-A, IV-B, and IV-C tall mass timber construction types, concealed spaces are allowed, but must comply with the following provisions:

  • Such spaces must not contain any combustibles other than electrical, mechanical, fire protection, or plumbing materials and equipment permitted in plenums in accordance with International Mechanical Code
  • Concealed spaces within any combustible construction within Type IV-A and IV-B construction must be protected with noncombustible protection with a minimum assigned time of 80 minutes
  • Concealed spaces within any combustible construction within Type IV-C construction must be protected with noncombustible protection with a minimum assigned time of 40 minutes

For the legacy Type IV-HT construction type in the 2021 IBC, concealed spaces must not contain any combustibles as described above, and must be protected with one or more of the following:

  • Sprinkler protection in accordance with NFPA 13
  • Be filled with noncombustible insulation
  • Surfaces within concealed spaces must be fully sheathed with not less than 5/8-inch Type X gypsum board

If concealed spaces are within any interior walls/partitions that possess a 1-hour or greater fire-resistance rating, no additional protection is required.

These new updates allow for more flexibility in the design of Type IV buildings and will hopefully help owners, developers, and architects to further consider Mass Timber for building projects. If you require assistance with your Mass Timber project, please reach out to

Click the links below to view the other Insights in the Mass Timber series:

Mass Timber – CLT & Glulam Char Depth Calculations

Mass Timber – Exposed Wood in Type IV-B Construction

The occupancy of a space plays a major role in fire alarm system design; each type has different requirements for system initiation/activation and occupant notification. The types and quantities of fire alarm initiating devices needed for a self-storage warehouse are different from those needed for an office building. The types of occupant notification appliances needed to serve a large assembly space are much different from those needed in a hospital. However, some of the most distinctive and complicated occupancies relative to fire alarm design in the International Building Code (IBC) are Group R-1 (transient residential occupancies) and Group R-2 (permanent residential occupancies). When dealing with these occupancies, the fire alarm requirements can be daunting and therefore easily missed. This is particularly true of the requirements surrounding low frequency notification.

Low frequency notification (producing a low frequency tone of 520 Hz ± 10 percent) is used to alert occupants that are asleep or are hard-of-hearing. Research has indicated that low frequency tones are six times as effective as the more standard 3kHz signal when it comes to waking high-risk occupants (such as people over 65 who are hard of hearing, school-age children, and people who are alcohol impaired).

IBC Section 907 generally requires Residential occupancies to be provided with fire alarm systems designed and installed in accordance with NFPA 72, National Fire Alarm & Signaling Code (IBC Section 907.2). In Group R-1 and R-2 occupancies, notification for building fire alarm system activation and notification for local in-unit smoke detector activation are governed by separate requirements.

For notification of a building fire alarm system activation, Group R-1 and R-2 occupancies must be provided with (IBC Sections 907.5.2.1 and 907.5.2.3): Audible appliances (typically system speakers and/or horns) to provide notification to all occupiable spaces within the building; and visible appliances in all common areas. As well as, in Massachusetts, locations required by 521 CMR, Architectural Access Board. From Chapter 18 of NFPA 72, all audible notification appliances serving sleeping areas must produce a low frequency tone.

A separate requirement typically applies for notification of smoke detector/alarm activation within a residential unit. Chapter 29 of NFPA 72 (specifically Section 29.3.8 and associated subsections) requires low frequency tones where notification appliances are provided voluntarily for those with hearing loss or are required by other governing laws, codes, or standards for people with hearing loss. In Massachusetts, 521 CMR Sections 8.6 and 9.7 provide scoping for areas where such appliances must be provided. Specifically: In permanent residential occupancies, 2% of the total units must be provided with features for hearing impaired persons; and in transient residential occupancies the quantity of units that must be designated as hearing impaired varies proportional to the number of guest rooms in the building (in accordance with the table in 521 CMR Section 8.4.5).

Why is this important?

In Massachusetts, the current (9th Edition) 780 CMR, Massachusetts State Building Code is based on the 2015 Edition of the IBC. However, the 10th Edition of 780 CMR is currently being developed and will be based on the 2021 Edition of the IBC (skipping the 2018 Edition).

Under the 2015 IBC, the requirements for low frequency notification discussed above are all currently located in referenced standards (NFPA 72, 521 CMR), not directly within the building code. The revamped content in the 2021 IBC will now include much of this scoping for low frequency tones directly within the body of Section 907.5.2. While this minor change should simplify finding and understanding these requirements, there was a more impactful change in the body of the 2021 IBC as well: The IBC (2021) will now require low frequency notification to be provided for all residential units upon activation of smoke detectors/alarms in that unit, where this would have only been required in hearing impaired units under previous editions. This requirement would take precedence over the language and scoping of NFPA 72 and 521 CMR, in accordance with the Applicability section of 2021 IBC. This is a significant change as there are limited options on the market to purchase notification appliances capable of producing low frequency tones other than those devices listed to be part of the fire alarm system.

There are of course many other fire alarm system requirements for residential (and all other) occupancies. Please feel free to contact the Code Red office for more information by emailing as at!



Why Are There New UL 268 and UL 217 Editions and How Does It Impact Me?

First, let us explore what UL 268 and UL 217 apply to:

UL 268 is the Underwriters Laboratories (UL) Standard titled Smoke Detectors for Fire Alarm Systems and it applies to smoke detectors which are connected to a Fire Alarm Control Unit. These devices detect the presence of smoke and (via the building fire alarm system) sound the notification appliances to alert occupants of a smoke event. A related standard that is also undergoing revision is UL 217, Standard for Smoke Alarms, which applies to smoke alarms which are typically powered by 110/120V line voltage. This type of device is traditionally used in residential occupancies and contain both the smoke sensing element and the notification function (typically horn) internal to the smoke alarm device.

So Why Are the UL 268 and 217 Standards Being Revised?

UL announced that the new editions include criteria to reduce nuisance alarms and address differing smoke characteristics between fast moving and smoldering polyurethane foam fires. Research shows that smoke characteristics have changed, and escape times have reduced (from an average of seventeen minutes several decades ago, now down to three or four minutes), largely due to changes in materials used in furnishings and construction. The updates to UL 268 and 217 are intended to better address these changes (compared to the previous 2009 and 2015 editions, respectively).

Reducing nuisance alarms, thereby reducing the temptation to disconnect smoke alarms, is another objective of the updated editions.  Based on a 2010 report by U.S. Consumer Products Safety Commission smoke alarms were not operating or were intentionally disabled in almost half (46%) of home fires. Nuisance alarms are reported to be the leading reason behind residential occupants disabling their smoke alarms. Specifically, according to the National Fire Protection Association (NFPA), the most commonly reported reason for occupants disabling a smoke alarm is nuisance alarms associated with cooking.

The new editions of UL 268 and 217 include more than 250 technical changes to the standards compared to the previous editions. The technical updates are consolidated into about 50 lab tests to verify the effectiveness of smoke detectors and smoke alarms.

Three of the new, more challenging, performance tests (Flaming Polyurethane Foam Test, Smoldering Polyurethane Foam Test and Cooking Nuisance Smoke Test) are targeted at: (1) reducing nuisance alarms from cooking; while (2) efficiently identifying smoke originating from new synthetic materials. The Cooking Nuisance Smoke Test includes broiling a frozen hamburger to initially produce light grey small smoke particles and then later produce larger particles representing those most commonly produced in kitchen fires. During this test, the smoke detector is subjected to the smoke and must alarm within a predetermined time after the smoke percentage reaches a minimum threshold; the detector must not alarm too quickly, or at too low a smoke percentage.

The other two tests that were added to the UL standards included the introduction of smoldering polyurethane foam fires and flaming polyurethane foam fires to more appropriately represent a fire that would be expected from modern furnishings.  The Flaming Polyurethane Foam Test produce small black dense smoke particles and the Smoldering Polyurethane Foam Test produces medium brownish smoke particles.  For both polyurethane tests, the smoke detectors must alarm within specific time limits and smoke densities.

Existing smoke detector/alarm designs which had been manufactured in accordance with the previous editions of the UL 268/UL 217 standards generally will not meet the more stringent requirements of the new editions. As such, manufacturers have needed to implement new technologies or combine existing technologies into their smoke detectors/alarms to satisfy the new UL requirements.

What is The Impact to Existing Smoke Detectors, Smoke Alarms and Facilities?

The new UL 268 7th Edition standard becomes effective on June 30, 2021 and the UL 217 8th Edition standard becomes effective on June 30, 2022. The effective dates of these two standards does not trigger an automatic replacement of all smoke devices; only that those devices manufactured after this date must be compliant with the new editions of the standards to receive the UL Listing. It is important to note that devices already manufactured prior to the effective date can still be sold with the UL listing received when manufactured.  Many manufacturers have already begun selling the new edition compliant devices and have information on their websites.

It is recommended that owners who maintain fire alarm systems which utilize smoke detectors in their buildings consult with their service providers to review how the implementation of these new smoke detectors will impact their existing systems. Some manufacturers have made announcements regarding new UL Listed compliant devices requiring panel upgrades or in some instances replacement of all devices due to compatibility requirements which could be a significant impact.

If you have additional questions, please do not hesitate to contact us