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Insights Category: Code Updates

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 in accordance with 780 CMR 1010.2
  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!

 

 

 

 

 

 

Welcome back to our fourth installment of the 10th Edition Major Changes blog series. This post focuses on industry updates related to energy storage systems (ESS) and battery technologies. We are coming off the heels of a key presentation last week about such technologies and their hazards at the international Society of Fire Protection Engineering (SFPE) conference in Washington DC by two of our in-house experts, Hubert Biteau, PhD, P.E., and Jen Hoyt, P.E.

While the upcoming 10th edition of 780 CMR Massachusetts State Building Code (which will adopt and amend the 2021 International Building Code (IBC)) will only feature one amended provision relative to the topic (radiant energy detection in Chapter 9), note that the latest Massachusetts Comprehensive Fire Safety Code (527 CMR 1.00) now adopts the 2020 edition of NFPA 855, Standard for the Installation of Stationary Energy Storage Systems. While this standard addresses battery energy storage systems that power buildings, building and fire officials continue to demand analyses relative to the use of battery technologies more broadly, including for situations like battery R&D operations or even e-bike storage. NFPA 855 often does not provide prescriptive solutions for such situations, and instead requires that a project-specific analysis be performed and submitted to the AHJ that characterizes the specific hazards and appropriate mitigation measures.

Over the last year, we have developed several posts related to this topic which provide further insight and detail:

Battery storage technology is a linchpin to a clean energy future for society. We are striving to contribute to solutions for how such technology can be developed and deployed with fire safety in mind. Please let us know if we can lend expertise to your next project involving battery technologies.

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 our 10th Edition Major Changes blog series. In this post, we will be reviewing the new code provisions for Tall Mass Timber.

The upcoming 10th edition of 780 CMR Massachusetts State Building Code (which will adopt and amend the 2021 International Building Code (IBC)) includes three new construction types that will allow mass timber construction to be used for high-rise buildings. Currently, we have worked on several mass timber projects that are occupied or under construction. We are also involved in many more that are actively in design, and have participated in several concept studies for mass timber projects ranging up to 24 stories in height.

There are many code changes related to these new types of construction throughout the code which should be reviewed in concert for a new design project. We have been posting on the topic of tall mass timber for several years; please follow the links below to recap the various insights shared:

While tall mass timber has been approved on projects in various capacities in different states, 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 this 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 the intricacies of Laboratory Suites.

The upcoming 10th edition of 780 CMR Massachusetts State Building Code (which will adopt and amend the 2021 International Building Code (IBC)) includes a new design option for laboratory buildings – 780 CMR §428. This design option will allow for increased chemical quantities of flammable and combustible liquids in Research & Development (R&D) laboratory buildings meeting the requirements of 780 CMR §428 as compared with the control area methodology contained in 780 CMR §414.  Quantities of nonflammable / noncombustible hazardous materials (e.g. corrosive, toxic, oxidizer, hazardous gases, etc.) are still subject to standard control area quantity limits of 780 CMR Tables 307.1 (1&2).  This code change is expected to be most impactful within high-rise buildings, allowing more permissive quantities of flammable and combustible liquids to support R&D laboratory operations in buildings up to 20 stories in height.

Laboratory suites are classified based on the quantities of flammable and combustible liquids permitted as Class A (highest), Class B, Class C, and Class D (lowest). Similar to current control area methodology, the number and types of laboratory suites permitted in a building will be regulated based on the relative distance above or below grade.  Fire-resistance-rated separations between laboratory suites will similarly vary.  This trend will be reflected in 780 CMR Table 428.6 reproduced below:

Laboratory suites complying with 780 CMR §428 are still subject to all of the standard requirements of NFPA 45 Standard for Fire Protection of Laboratories Using Chemicals (2019 edition). Additionally, the following features are required in laboratory suites using 780 CMR §428 allowances:

  • Where laboratory suites are utilized, the ventilation system is required to comply with Chapter 7 of NFPA 45 as well as the IMC and ASHRAE 62.1 (780 CMR §428.3.7).
  • Laboratory ventilation systems exhausting air from areas in which flammable gases, vapors, or particulate matter are released in laboratory suites are required to be provided with standby power (780 CMR §428.3.7.1).
  • Where laboratory suites are utilized and located above the sixth story or located in a story below grade, standby or emergency power is required for mechanical ventilation, treatment systems, temperature control, alarm, detection or other required electrically operated systems (780 CMR §428.3.6, §414.5.2).
  • Where laboratory suites are utilized, the sprinkler design is required to meet Ordinary Hazard Group 2 per NFPA 13 with quick response sprinklers, regardless of the laboratory designation, compared to Ordinary Hazard Group 1 which is permitted for certain laboratory designations under the current control area/laboratory unit approach (780 CMR §428.3.9, §903.2.11.7).
  • Class D laboratory suites located above Level 6 are required to be provided with 2-hour fire-resistance-rated separations (780 CMR §428.6).

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 to the 10th Edition Major Changes blog series! As part of Code Red Consultant’s 10th Anniversary celebration, we will be doing a 10-part series on major changes to the 10th edition of 780 CMR, Massachusetts State Building Code.

To kick things off, this post is one of several egress-related entries that highlights some changes associated with egress occupant loads, lighting requirements, and turnstiles.

Occupant Load

The occupant load factor for business areas (i.e. offices) has been increased from 100 to 150 gross square feet per occupant. This change was initially implemented into the 2018 International Building Code (IBC) following numerous studies of current office space layouts and furnishings used within business occupancies. Notably, a study conducted by WPI undergraduate students in collaboration with the NFPA Fire Protection Research Foundation recommended increasing the business occupant load factor and was cited as contributing rationale for the change. This shift results in a decreased calculated occupant load for office spaces, aligning occupant load calculations with NFPA 101, Life Safety Code. For more concentrated business uses, like call centers or trading floors, a factor of 50 gross square feet per occupant (or higher) is permitted where approved by the building official.

Lighting

Exit and exit access stairway lighting requirements have been increased from 1 foot-candle to 10 foot-candles at the walking surface when the stair is in use. This adjustment also aligns IBC requirements with those of NFPA 101. This change will improve safety within a building by enhancing visibility for occupants navigating stair treads and handrails. Note that stairways are not always required to be fully illuminated; illumination can be activated when the stair is in use through the use of a motion detector or similar device.

Turnstiles

Another notable change coming to the 10th Edition pertains to security access turnstiles, often referred to as speed gates. Currently, in the 9th edition, individual turnstiles along the means of egress are always limited to an egress capacity of 50 occupants. The change, first introduced in the 2018 Edition of IBC, allows the egress capacity of a turnstile to be calculated based on its clear width, similar to a door or gate. (Turnstiles providing less than 32” of clear width will still be limited to 50 occupant capacity.) This approach for turnstiles is permitted where the building is fully sprinklered and the turnstile opens (fails safe) during each these conditions: loss of power, automatic fire alarm initiation (excluding manual pull stations), and activation of a manual release device located on the egress side of the gate or other approved location.

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!

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.

https://www.mass.gov/handbook/unofficial-tenth-edition-base-code-draft-780-cmr

Applicability: We anticipate the 10th Edition won’t be adopted until 6 months after it is approved to move  forward by the Governor’s Office (at the earliest).

It is our understanding that a 6-month concurrency period will be offered, after the 10th Edition is formally adopted. 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.

https://www.mass.gov/info-details/building-energy-code

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.

https://www.mass.gov/service-details/massachusetts-fire-code

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.

https://www.mass.gov/service-details/massachusetts-electrical-code

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).

https://www.mass.gov/service-details/aab-2023-meeting-list

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

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 4.12.4.1). In contrast previous editions only required at least one stair be provided (2013 NFPA 241 Section 7.5.6.1). 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 4.12.4.4). 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 info@crcfire.com.