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As outlined in the MA Fire Code Update Insights Post, we highlighted that 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. Consequently, code users must now refer to the 2022 Edition of NFPA 241 for construction fire safety requirements. Significant code changes, which will affect pricing, scheduling, and risk mitigation, will be discussed in this and subsequent Insights posts.

The new applicable edition requires that at least half of the required exit stairs must always be available (Section In contrast previous editions only required at least one stair be provided (2013 NFPA 241 Section This change notably affects buildings with three (3) or more stairs. In addition, the stairway must be enclosed once the building exterior walls are in place (Section Local AHJ requirements and building layouts may warrant additional stairs be provided or earlier enclosure of stairs to allow for appropriate emergency egress and fire department operations. Stair construction should be considered and coordinated early into project budgeting and planning to maintain compliance during the early stages of construction.

Stay tuned for future Insights Posts related to standpipe installation and availability during construction, especially concerning stair construction. For inquiries about the implementation of NFPA 241 in relation to your project, please contact our office at


Starting with the 2022 Edition, and carried forward into the 2023 Joint Commission Standards, the retesting of smoke control systems in existing accredited hospitals has become mandatory. These life safety systems activate automatically via an initiating device like a smoke detector or sprinkler water flow switch, triggering HVAC equipment to manage smoke spread during a fire event. Hospitals might possess various smoke control systems, such as stair pressurization systems, elevator shaft pressurization systems, and floor-to-floor smoke control systems, based on their classification as a high rise building, having unenclosed vertical openings (i.e Atriums) or other legacy code requirements. It’s important to distinguish that post-fire smoke removal systems and HVAC systems in anesthetizing locations for vapor control are not categorized as active smoke control systems.

These requirements, set forth by the Joint Commission, are included in their Environment of Care Chapter, under EC.02.05.01, EP 27, and aligned with NFPA 101 18/ (2012 Ed). The mandated periodic testing of engineered smoke control systems aligns with engineering principles as detailed in NFPA 92 Standard for Smoke Control Systems (2012 Ed.). The standard outlines testing intervals and key elements of the testing process but does not stipulate acceptance criteria or operation sequence, which should be based on the original design and applicable codes.

Significantly, the Joint Commission Standards’ inclusion enhances enforcement of regular testing for these essential yet often neglected systems. In the past, smoke control systems were seldom tested as required, due to concerns about operational impact, such as affecting infection control.  Any existing smoke control systems that don’t meet NFPA 101 Life Safety Code (2012 ed.) Section performance requirements may continue operating, but only with the explicit approval of the authority having jurisdiction (AHJs), such as the local building or fire official. While accrediting agencies such as the Joint Commission and the Center for Medicare and Medicaid Services (CMS) are AHJs, it is unlikely that they would grant such exemptions.

See our previous blog on the details of smoke control retesting in accordance with the Requirements of NFPA 92 Here

Massachusetts is currently in a transition period where many of the applicable codes have recently changed or will be changing soon. The following is a list of the recent and anticipated major changes.

The Massachusetts State Building Code, 10th Edition (780 CMR)

Massachusetts is expected to adopt the 10th Edition of the Building Code based on the 2021 I-Codes. On April 11, 2023, the BBRS voted to hold three public comment hearings on the proposed amendments. Two of the hearings will be in-person (Boston and Springfield) and one of the hearings will be virtual. All hearings will be held on separate weeks, and a one-week public comment period will also be provided following the last public hearing. The BBRS will give 45 days of notice prior to the first hearing, which will occur shortly after the proposed draft is approved by the various departments under Governor Bakers executive Order 562 and Accounting and Finance. A draft of the amendments can be found at the following link.

Applicability: We anticipate the 10th Edition won’t be adopted until January 1, 2024 (at the earliest) based on the following hypothetical timeline:

  • June 9, 2023 – Fictitious Formal Announcement of Hearings
  • July 24, 2023 – First Hearing (45 Days After Announcement)
  • July 31, 2023 – Second Hearing
  • August 7, 2023 – Third Hearing
  • August 14, 2023 – Public Comments
  • September 12, 2023 – BBRS Scheduled Meeting – Review/Discuss Comments
  • October 10, 2023 – BBRS Scheduled Meeting – Vote/Finalize Amendments
  • December 10, 2023 – Publish Formal Amendments at the Secretary of State (1-2 Months)

It is our understanding that a 6-month concurrency period will be offered, which would make compliance with the 10th Edition mandatory starting July 1, 2024. Lastly, any “substantial change” to the code coming out of the public comment review would require the code to go back through the State review process, which could add 1-2 months onto this schedule.

Stretch Energy Code/Specialized Energy Code (225 CMR 22 & 23)

The climate act of 2021 moved the authority for the Stretch Code promulgation to the Department of Energy Resources (DOER) and at the same time required the development of a new Municipal Opt-in Specialized Energy Code. The adoption of these codes is independent of the 10th Edition adoption. On January 1, 2023, the residential stretch code was formally shifted from Appendix AA of 780 CMR to 225 CMR 22. This code applies to detached one- and two-family dwellings and townhouses, and residential buildings that are three stories or less in height. On July 1, 2023, the commercial stretch code will formally shift from Appendix AA of 780 CMR to 225 CMR 23. Both codes are based on the 2021 International Energy Conservation Code (IECC).

The Specialized Energy Code is a new option that is adopted as a municipal opt-in code like the Stretch Energy Code process. Cities and towns seeking to adopt will require an active vote by City council or Town meeting to opt-in to the Specialized Energy Code. As of June 6, 2023, sixteen cities/towns have voted to become Specialized Energy Code communities. Once a town votes to become a Specialized Energy Code community, formal adoption will be on either January 1st or July 1st (whichever occurs first more than 6 months after the vote). The following list provides applicability for the first 16 communities:

  • Effective July 1, 2023 (Brookline, Cambridge, Somerville, Watertown)
  • Effective January 1, 2024 (Acton, Arlington, Boston, Concord, Lexington, Lincoln, Maynard, Newton, Sherborn, Stow, Truro, Wellesley, Wellfleet)

The list of communities adopting the specialized energy code is expected to grow. Keep up to date on this list at the following link.

MA Energy Code Community Map

Additional information on the stretch energy code can also be found on the State’s website below.

The 51 cities/towns that currently adopt the base energy code will continue to use the 2015 IECC (with amendments) until the 10th Edition is adopted or the city/town votes to be become a Stretch Code/Specialized Energy Code community.

Applicability: Based on conversations with DOER representatives the date of permit application locks in the applicable edition of the code. It’s recommended that projects impacted by these code changes work with their jurisdiction to confirm their process and necessary documentation to complete the permit application. Lastly, there is no concurrency period for the applicability of these new codes.

The Massachusetts Comprehensive Fire Safety Code (527 CMR 1.00)

On December 9, 2022, the Massachusetts Comprehensive Fire Safety Code shifted to the 2021 Edition of NFPA 1, Fire Code. Unofficial amendments to this code can be found on the State’s website below. It should be noted that additional amendments were promulgated on February 3, 2023, which can also be found in the link below.

Applicability: Effective immediately upon adoption to all new and existing projects.

The Massachusetts Electrical Code (527 CMR 12.00)

On March 1, 2023, the Massachusetts Electrical Code shifted to the 2023 Edition of NFPA 70, National Electrical Code (NEC). Unofficial amendments to this code can be found on the State’s website below. It should be noted that the version posted on the State’s website notes an effective date of February 17, 2023, which was corrected in the MA. Register #1491, 3/17/2023.

Applicability: Date of electrical permit application, not building permit application.

Uniform State Plumbing Code (248 CMR 10.00)

The plumbing board is currently in the process of making updates to the Uniform State Plumbing Code. Preliminary drafts include changes to plumbing fixture factors, occupancy requirements and considerations for group gender neutral restrooms.

Applicability: A timeline for adopting an updated version of the plumbing code has yet to be announced but is expected within the next 12 months.

Massachusetts Architectural Access Board Regulations (521 CMR)

The Massachusetts Architectural Access Board has created a subcommittee that has been working on a complete overhaul of 521 CMR to align with the ADA. The subcommittee meets once a month and is open to the public to listen (schedule in the link below).

Applicability: A timeline for the adoption of this new edition of MAAB has not been announced.

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