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Insights Category: Code Updates

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.

 

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 18/19.7.7.1 (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 19.7.7.1 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

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.