Code Red Consultants

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.

For our 10th and final post on the 10th Edition Major Changes blog series, we will review more changes related to egress, namely exiting through elevator lobbies, areas of refuge at the level of exit discharge, and handrails at stepped aisles.

Exit Access through Elevator Lobbies

Previous editions of the International Building Code (IBC) have allowed the means of egress to traverse through an enclosed elevator lobby provided alternative path of travel was available. In other words, the sole means of egress from a space could not pass through enclosed elevator lobbies required by IBC Section 3006. This language in Section 1016.2 has been modified in the 10th edition of 780 CMR to allow the sole means of egress from a space to traverse through an elevator lobby where such spaces only require one exit or exit access in accordance with IBC Section 1006.2.1. This will give designers more flexibility in locating smaller spaces near, or adjacent to enclosed elevator lobbies.

Interior Areas of Refuge

Providing an accessible means of egress from the level of exit discharge to a public way can be challenging for buildings situated on steep grade changes. This is primarily because intermediate stairways connecting to grade level are prohibited from serving as part of an accessible means of egress. In these scenarios, it is common to incorporate exterior areas of refuge to achieve a second required accessible means of egress in lieu of providing a prohibitively large ramp. The code has not provided a pathway to locate interior areas of refuge at the level of exit discharge as IBC Section 1009.6.2 generally requires direct access to an exit stairway.

In recognition that these exterior areas of refuge may not be desirable due to weather conditions or spatial constraints, the 10th Edition now gives designers flexibility to locate these at-grade areas of refuge on the interior side of the building. Specifically, an exception has been added to IBC Section 1009.6.2 to allow for an interior area of refuge at the level of exit discharge provided it has direct access to an exterior exit door. All other features required for an area of refuge must also be provided, including sufficient wheelchair space, fire separation, two-way communication, and appropriate signage.

Handrails at Stepped Aisles

Stepped aisles with seating on side have become increasingly popular in assembly or educational type occupancies. The issue in providing these features is that the IBC has not specifically regulated how to incorporate handrails along the stepped aisle without obstructing the path to the seating. This will be clarified in the 10th Edition of 780 CMR as follows:

  • First, IBC Section 1030.16 has been modified to identify when one or two handrails are required for stepped aisles, and where the handrails must be located along the stepped aisle. Specifically, two handrails will be required for stepped aisles having a width of 72” or greater, in which one of the handrails must be located within 30” horizontally of the stepped aisle.
  • Next, IBC Section 1030.16.1 will address the continuity of the mid-aisle handrail, in which 22”-36” gaps or breaks must be provided at intervals not exceeding five rows to facilitate access to seating.

It’s important to highlight that the 10th edition of 780 CMR has not been finalized or adopted in Massachusetts and is potentially subject to further changes. Our current projection for the adoption of the 10th edition is Q2 of 2024 – see our prior post which outlines the overall process and timeline.

At this conclusion to our “10th Edition Major Changes” blog series, we wanted to thank everyone who tuned in – we hope you found it insightful. Our team will continue to provide 10th Edition updates on our blog as changes and adoption timeline are solidified.

Welcome back to our 10th Edition Major Changes blog series. In this post, we will be discussing miscellaneous code changes related to elevators and fire service access elevators (FSAE).

Elevator Hoistway Protection

In the 9th Edition of 780 CMR, in fully sprinklered buildings, elevator lobbies were most commonly required in Group I-2 (health care) buildings connecting more than three stories, or in high-rise buildings where the hoistway is greater than 75 feet. However, the 10th Edition of 780 CMR specifically addresses the elevator hoistway protection requirement for all elevators that open into fire-resistance rated corridors (780 CMR 3006.2.1). Options for compliance for elevator hoistways that open into fire-resistance rated corridors are the same as those for high-rise buildings: protected lobbies, hoistway pressurization, or protection at hoistway doors. This requirement primarily impacts buildings with fire-rated corridors, such as residential buildings.

Egress Through Elevator Lobbies

The 9th Edition of 780 CMR contained ambiguous language regarding whether rooms or spaces requiring only one means of egress were permitted to travel through an elevator lobby as a path to an exit. The 10th Edition explicitly permits egress through an enclosed elevator lobby for spaces that only require one means of egress (780 CMR 1016.2). Where two means of egress are required from a space, at least one is not permitted to travel through an elevator lobby. This code change will be helpful in establishing clear direction for design teams, and also for potential discussions with building officials.

Fire Service Access Elevators (FSAE)

FSAE are not overly common, only being required in a building having its highest floor elevation at greater than 120 ft. Where required, FSAE need to be provided with enhanced FSAE lobbies with direct access into an exit stairway with a standpipe for staging operations. The base code requirement has been that FSAE serve every floor of a building. The 10th Edition will be updated such that fire service access elevators now:

(1) Only need to serve floors above and including the lowest level of FD access (below-grade levels are exempt).

(2) Are not required for elevators that only serve open or enclosed parking and the lobby of the building, and

(3) Do not need to serve top floor(s) of buildings where such floor(s) are only for equipment for building systems (MEP floors)

Thanks for reading – stay connected for more Insights posts as we continue our “10th Edition Major Changes” series as part of CRC’s 10th Anniversary!

Welcome back to our 10th Edition Major Changes blog series. In this post, we will be reviewing the new code provisions for Atriums.

The upcoming 10th Edition of 780 CMR Massachusetts State Building Code, which will adopt and amend the 2021 International Building Code,  introduces additional clarification and changes regarding atriums.

Atrium Definition

In the 9th Edition, an atrium is defined as “An opening connecting two or more stories other than enclosed stairways, elevators, hoistways, escalators, plumbing, electrical, air-conditioning or other equipment, which is closed at the top and not defined as a mall.” The code includes allowances for unenclosed floor openings, such as two-story convenience openings or stairs/escalators protected with draft curtains and closely spaced sprinklers. This definition raised questions about whether all unenclosed floor openings connecting two or more stories were required to be designed with atrium features. To provide clarity, the 10th Edition revises the atrium definition to “A vertical space that is closed at the top, connecting two or more stories in Group I-2 and I-3 occupancies or three or more stories in all other occupancies.”

Smoke Control System Exception

Under the 9th Edition, atriums connecting three or more stories were required to be provided with a smoke control system for most occupancies. The 10th Edition introduces a new exception that allows the omission of the smoke control system if only the lowest two stories are open to the atrium, and all other stories are separated from the atrium with shaft construction. This new exception recognizes the effectiveness of shaft enclosures and the improved egress conditions by having a natural smoke reservoir with a two-story floor opening. The image below illustrates an example of this type of atrium described by the code.

Atrium Separation Exception

In the 9th Edition, atriums typically needed to be separated from the remainder of the building with 1-hour rated construction. The 10th Edition introduces a new exception that allows the omission of a horizontal assembly between atriums and stairs/escalators protected with draft curtains and closely spaced sprinklers. The image below provides an example illustrating this code change.

Atrium Exit Access Stairways

Exit access stairways in atriums are permitted to be used for as a component in a means of egress system under the 9th Edition. However, the path of travel to an exit is not permitted to pass through more than one adjacent story (Sections 1019.3-5 & 1006.3). Interior exit stairways within an atrium are permitted to be unenclosed and there is no limit to the number of stories occupants can traverse for egress (Section 1023.2 Exception 2). A new exception has been added to the 10th Edition that allows egress along exit access stairways to pass through multiple stories within an atrium without being designed as an interior exit stairway.

Atrium Interior Exit Stairways

The 10th Edition adds a new section that outlines requirements for atrium interior exit stairways. These requirements include:

  1. The entry to the exit stairway is the edge of the closest riser of the exit stairway.
  2. The entry of the exit stairway shall have access from a minimum of two directions.
  3. The distance between the entry to an exit stairway in an atrium and entrance to a minimum of one exit stairway enclosed in accordance with Section 1023.2 shall comply with the separation required by Section 1007.1.1.
  4. Exit access travel distance shall be measured to the closest riser of the exit stairway.
  5. Not more than 50 percent of the exit stairways shall be located in the same atrium.

Fire Protective Curtain Assembly

Fire protective curtains are not prescriptively permitted by code to be used as opening protectives. These assemblies have commonly been used over the years as part of the performance-based design for atrium smoke control systems. Though this will not change under the 10th Edition, the code will contain new labeling and performance requirements when curtains are permitted to be used by the Authority Having Jurisdiction (AHJ) as part of an alternative method or performance-based design. These requirements include testing in accordance with UL 10D without the hose stream and installation in accordance with NFPA 80, Standard for Fire Doors and Other Opening Protectives.

Our current projection for the adoption of the 10th edition is Q2 of 2024 – see this which outlines the overall process and timeline.

Stay connected for more Insights posts as we continue our “10th Edition Major Changes” series as part of CRC’s 10th Anniversary!

 

 

 

Welcome back to the 10th Edition Major Changes blog series! This post discusses miscellaneous code changes related to occupied roofs, including provisions on occupancy classification, penthouse definitions, and door locking provisions.

Occupancy Classification

The acknowledgment of occupied roofs was introduced in the 2018 edition of the International Building Code (IBC) due to the industry call for life safety requirements for rooftop amenity spaces that are open to building occupants or the general public. These spaces often include areas such as rooftop swimming pools and lounge decks.

New to the code are the conditions under which certain rooftop occupancy classifications are allowed, which is interrelated to building fire protection systems, construction type, and height and area allowances. The rooftop space is required to be classified based on the use (e.g. Group A-3 for larger assembly spaces). The allowance of such an occupancy is dictated by the following two conditions:

  • If the building is non-sprinklered, the occupancy of the roof deck is limited to that which complies with Allowable Height table for the story below, OR
  • If the building is sprinklered (and the area of the occupied roof is provided with an occupant notification system), any occupancy classification is allowed for the space.

Note that, in either scenario, the occupied roof is not required to be included in the height and area determination. The occupied roof is required to meet the other applicable occupancy provisions of the code.

Penthouse vs. Story

The difference between whether a rooftop structure can be defined as a penthouse vs. an additional building story, which has implications on height and area calculations, depends on the definition and allowable uses of a penthouse in IBC Chapter 15. Related to occupied roofs, the new code will clarify that ancillary spaces used to access elevators and stairways (i.e. enclosed lobbies) still fall within the definition of a penthouse and do not trigger the classification as an additional story. Otherwise, penthouses continue to be limited to use for purposes of shelter of mechanical or electrical equipment, tanks, elevators and related machinery, stairways, and vertical shaft openings in the roof assembly.

Door Locking

Door locking for terrace and rooftop spaces was not previously addressed in the code. To address concerns for security, IBC Section 1010.2.4(8) now permits exit access doors from most exterior spaces to be equipped with an approved locking device, provided that certain features are provided including items such as signage, a two-way communication system, and glazing in the door. These provisions will assist with overall security of the building while still accounting for egress and life safety.

Thanks for tuning in to this week’s 10th Edition blog post. It’s important to highlight that the 10th edition of 780 CMR has not been finalized or adopted in Massachusetts and is potentially subject to further changes. Our current projection for the adoption of the 10th edition is Q2 of 2024 – see our prior post which outlines the overall process and timeline.

Stay connected for more Insights posts as we continue our “10th Edition Major Changes” series as part of CRC’s 10th Anniversary!

Welcome back to our 10th Edition Major Changes blog series. In this post, we will be discussing NFPA 4, The Standard for Integrated Fire Protection and Life Safety System Testing.

The upcoming 10th edition of 780 CMR Massachusetts State Building Code (which will adopt and amend the 2021 International Building Code (IBC)) includes requirements for integrated testing of life safety systems via the adoption of NFPA 4, 2021 Edition.

High-rise buildings and buildings with smoke control systems, under 780 CMR §901.6.2.1 and §901.6.2.2, must undergo integrated testing per NFPA 4. NFPA 4 defines integrated testing as a, “Test performed on fire protection and life safety systems to confirm that operation, interaction, and coordination of multiple individual systems perform their intended function”. The testing shall be performed by the Integrated Testing Agent (ITa), “A person or entity, identified by the owner, who plans, schedules, documents, coordinates, and implements the testing of the fire protection and life safety systems and associated subsystems”. The ITa shall have skills that demonstrate an experience or knowledge of integrated operations of the design, installation, operation and maintenance of the type of fire protection and life safety systems installed.

The inclusion of this requirement may increase risk to a projects schedule and\or budget if building owners, design teams, and construction managers, are not tuned into these requirements.   This risk can be mitigated through early involvement on projects so that integrated system design reviews can be performed in advance of construction occurring.  Once construction begins, early development of test plans and along with setting clear expectations with the construction team, are key to successful integrated testing.  Continued coordination between the ITa, the construction manager, and the building owner will ensure that this testing can be completed thoroughly and effectively at the end of a project. The AHJ may request the ITa testing documentation as part of the certificate of occupancy closeout process.

Check back next week for another Insights post as we continue our “10th Edition Major Changes” series as part of CRC’s 10th Anniversary!

Welcome back to the 10th Edition Major Changes blog series. This post is Part 2 on Means of Egress, focusing on changes associated with delayed egress locking, classroom locking, and door sizing requirements.

Delayed Egress Locking

Delayed egress locking systems are intended to be used where security is a concern, but egress needs to be maintained. The 2015 edition of the International Building Code (IBC) permits delayed egress locking in doors serving occupancies other than Group A, E, or H in buildings equipped throughout with an automatic sprinkler system or an approved automatic smoke or heat detection system.

The 10th edition of 780 CMR will expand use of delayed egress locking to secondary exits of courtrooms (Group A-3). Given the complex circulation and egress arrangements in courthouses, delayed egress locking is preferred to prevent unauthorized occupants from accessing secure spaces in the building from the courtroom where the public, inmates, and courthouse employees can be located simultaneously.

Group E classrooms with less than 50 occupants will now also be permitted to be provided with delayed egress locking. This change is driven by the need to prevent wandering children while maintaining a fully functioning means of egress.

Classroom Locking

There continues to be heightened sensitivity in trying to balance the security of a school classroom with classroom egress. With traditional classroom lock sets, teachers are required to leave the room to lock the door for a defend-in-place strategy which puts teachers at risk. However, modified locking devices that have been developed and used over the years do not allow for free egress. The new code will allow Group E and Group B educational occupancies to be provided with special locking arrangements under the following conditions:

  1. The door can be unlocked from outside the room with a key or from a remote location.
  2. The door can be opened from inside the room when locked.
  3. Modifications to listed panic hardware, fire door hardware, or door closers are not permitted.

This code change aims to create a balance between security and egress.

Door Sizing

Currently, the width of a swinging door leaf is not permitted to exceed 48 inches nominal. The next code will remove this maximum door width requirement and instead defer to the door opening force requirements that already exist. Essentially, the size of the door will be inherently limited by door opening force, creating more of a performance-based requirement that may provide more flexibility to designers.

Thanks for tuning in to this week’s 10th Edition blog post. It’s important to highlight that the 10th edition of 780 CMR has not been finalized or adopted in Massachusetts and is potentially subject to further changes. Our current projection for the adoption of the 10th edition is Q2 of 2024 – see our prior post which outlines the overall process and timeline.

Stay connected for more Insights posts as we continue our “10th Edition Major Changes” series as part of CRC’s 10th Anniversary!