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Insights Category: Code Updates

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

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

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

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

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

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

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

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

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

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

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

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

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

If you have additional questions, please do not hesitate to contact us info@crcfire.com.

The Fair Housing Act (FHA) requires that multifamily housing buildings constructed after March 1991 contain accessible features for persons with disabilities.  The U.S. Department of Housing and Urban Development (HUD) recognizes various safe harbors for compliance with the FHA design and construction requirements.

Effective March 8, 2021, the 2009 International Building Code (IBC) and the 2009 Accessible and Usable Buildings and Facilities (ICC A117.1) will be a new allowable safe harbor.  The ruling made by HUD also designates the 2009, 2012, 2015 and 2018 editions of the IBC as safe harbors.  This is the first update to the safe harbor list in 15 years and will help streamline regulatory requirements in many states that reference ICC A117.1 by way of the state building code.

If you have questions on accessibility compliance, please reach out to our office to find out how we can assist.  Contact us at info@crcfire.com for more information.

On January 29, 2021, the Maine Technical Codes & Standards Board unanimously voted to incorporate the 2021 International Building Code (IBC) code provisions related to tall mass timber construction into the current version of the Maine Uniform Building & Energy Code (MUBEC) via an amendment. The amendment process could take upwards of 90 days to finalize language and accommodate a public comments period before the code change becomes official.

The implications of adopting these provisions are significant for those looking to utilize cross-laminated timber (CLT) and other mass timber materials on new projects. Three (3) new construction types will be available (Type IV-A, IV-B, and IV-C)  allowing for mass timber buildings of up to 18 stories tall. There are several considerations relative to fire protection, life safety, and construction materials that require careful consideration early in the design process.  This is especially important when the aesthetically pleasing mass timber elements are desired to be architecturally exposed. Designers now have an ‘as-of-right,’ prescriptive code compliance path at their disposal which is a game changer!

Code Red Consultants has endeavored to remain on the forefront of the mass timber movement and construction technologies, including the greatly expanded options introduced by the 2021 IBC. Please reach out to us at info@crcfire.com if we can be of assistance on your mass timber projects.

The concurrency period had allowed building permit applicants to choose to have designs comply with the provisions with either the 2015 or 2018 editions of the International Energy Conservation Code (IECC), with Massachusetts amendments. As of November 7, 2020, the concurrency period has ended. The ending of the concurrency period means that all designs submitted for permit must now be in accordance with the 2018 MA Energy code provisions as laid out in the revised 780 CMR Section 13.00.

 

See our previous blog posts here on the timeline of the Board of Building Regulations and Standards Committee’s actions regarding the Energy code concurrency period extensions.

 

Please reach out for assistance with Energy code scoping provisions and big picture implications of the new 780 CMR 13.00 amendments and the 2018 IECC.

 

Based on the Massachusetts amendment to Sections C401.2 and C402.1.5 of the 2018 IECC, the IECC component performance alternative (sometimes referred to as the “backstop calculation”) is required in Massachusetts for projects following ASHRAE 90.1-2016 Appendix G (or ASHRAE 90.1-2013 Appendix G if following the Stretch Energy Code).  This will require a minimal prescriptive compliance for the exterior envelope in addition to the thermal performance established by using Appendix G.  The impacts of this amendment diverge from previous iterations of energy efficiency design compliance and should be reviewed by key project stakeholders including the project architect, mechanical engineer, and envelope consultant.

Please do not hesitate to contact us if you have energy code scoping questions and how they apply to your specific project

A recent warehouse explosion on May 16th, 2020 close to downtown Los Angeles resulted in 11 firefighters injured, according to news articles. Those news articles indicated that the warehouse is believed to be owned or connected to a company that sells products related to cannabis oils, utilizing butane in the process.

With the recent legalization of cannabis, the Commonwealth of Massachusetts has seen an increase in buildings and tenant spaces being repurposed for the cultivation, processing, and/or extraction of cannabis plants in response to the growing market and demand. Among other unique hazards, these buildings or spaces may contain fertilizers, fumigation gases, pesticides, and various chemicals utilized for extractions processes (such as ethanol or butane). The current 9th edition of 780 CMR Massachusetts State Building Code and 527 CMR 1.00 Massachusetts Comprehensive Fire Safety Code did not include any specific requirements related to the unique operations associated with this new industry at the time of legalization.  This resulted in general concerns over the level of fire life safety associated with these facilities as well as the potential for inconsistent code application and enforcement.

At the time of legalization in the Commonwealth of Massachusetts, 527 CMR 1.00 was based on the 2015 edition of NFPA 1 Fire Code which similarly did not include any specific requirements related to cannabis operations; however, the 2018 edition of NFPA 1, included a chapter dedicated to these cannabis-related activities – Chapter 38.  In response to growing concerns over the design and construction of these new and unique facilities, the Commonwealth of Massachusetts adopted an emergency amendment to 527 CMR 1.00 in October 2019. Among other new requirements, these amendments incorporated the requirements of the 2018 version of NFPA 1, Chapter 38 into 527 CMR 1.00 under a new chapter – “Chapter 38 Cannabis Growing, Processing or Extraction Facilities.”  Per the scoping provisions of Section 38.1.1, this chapter applies to new and existing buildings where the growing and processing of cannabis is involved. These new requirements specifically address many of the unique hazards encountered within cannabis facilities including fumigation, pesticides, and the storage and use of hazardous materials.

With the adoption of these new requirements, 527 CMR 1.00 now includes clear direction on the design and construction of facilities housing cannabis-related activities with the ultimate goal of promoting consistent enforcement across the Commonwealth and reducing the potential for dangerous mishaps to occur, such as those that recently befell the warehouse in Los Angeles.

 

In our blog post on June 10th, we identified that the Board of Building Regulations & Standards (BBRS) agreed in principle to extend the concurrency period for the 2018 International Energy Conservation Code (IECC) adoption to January 1, 2021. The next logical questions you might have about the new code adoption is: (1) how does it affect the compliance options that are available for my future projects? and (2) what are the major impacts that I need to be aware of? This blog post is intended to answer Question #1 by outlining the updated scoping requirements for applying the commercial energy efficiency provisions. A future blog post will highlight a major code impact that all designers need to be aware of, so stay tuned!

There are multiple compliance methods for energy efficiency outlined in 780 CMR Chapter 13. There is a sequential order of evaluation that should be followed to determine the applicable scoping requirements for a given project.

1. Stretch Energy Code Application (IECC C401.2(1)(b)) – if the project meets the following criteria, the Stretch Code will apply and energy use per square foot on either a site or source energy basis must be demonstrated to be 10% below the energy requirements of ASHRAE 90.1-2013 Appendix G. The additional Efficiency Package Options selected as per IECC C406.1 should be included in calculating the baseline building performance value.

a. Is located in a Stretch Code Community

b. Is a new construction project

c. Is any building > 100,000 GSF or is a supermarket, laboratory, or conditioned warehouse > 40,000 SF

Note that the project must also comply with 780 CMR 13.00 including sections C401.2, C402.1.5, C402.3, C405.3, C405.4, C405.9, and C406.

2. Non-Stretch Energy Code Application (IECC C401.2) – Commercial buildings not subject to the Stretch Energy Code have the option to comply with one of the following methods:

a. ANSI/ASHRAE/IESNA Path: Apply ANSI/ASHRAE/IESNA 90.1-2016 edition

i. General: As modified by IECC C402.3, C405.3, C405.4, C405.9, and C406.
ii. Appendix G: As modified by the sections above as well as IECC C401.2 and C402.1.5.

b. IECC Prescriptive Path: Follow the requirements of the IECC Sections C402 through C405. In addition, buildings are required to comply with Section C406 and tenant spaces with Section C406.1.1.

c. IECC Certified Performance Path: The requirements of IECC C407, C402.3, C405, and C408 apply, which outline a calculated methodology.

3. Additional Efficiency Packages – Where any option above except for Option 2c (IECC Certified Performance Path) is selected, at least three of the following enhancements are required to be selected for use on the project (IECC C406.1):

a. More efficient HVAC performance in accordance with Section C406.2

b. Reduced lighting power density system in accordance with Section C406.3

c. Enhanced lighting controls in accordance with Section C406.4

d. On-site supply of renewable energy in accordance with Section C406.5

e. Provision of a dedicated outdoor air system for certain HVAC equipment in accordance with Section C406.6

f. High-efficiency service water heating in accordance with Section C406.7

g. Enhanced envelope performance in accordance with Section C406.8

h. Reduced air-infiltration in accordance with Section C406.9

i. Renewable space heating in accordance with Section C406.10

j. Type IV Heavy Timber construction in accordance with C406.11.

Please don’t hesitate to contact us if you have energy code scoping questions and how they apply to your specific project.

In this week’s issue of the Return to Work Tool Kit issued by the Boston Real Estate COVID Consortium, Chris Lynch, P.E. weighs in on various code compliance topics relating to the re-opening of offices. Topics include points of caution with installing door locking devices, modifying signage as it relates to egress, and creating sprinkler obstructions if installing temporary partitions. Additionally, Chris discusses the various allowable options for determining the 25% head count limitation. The article also contains great information on office furniture changes and signage and graphics authored by other Consortium team members. Read the full article here.

Update as of 10/15/2020:

Contrary to initial indications, there will be no extension of the energy code concurrency period beyond the previously-approved November 7, 2020 date. All projects submitted for permit after this date will be required to comply with the 2018 IECC and associated Massachusetts amendments, which can be found here.

Update as of 7/15/2020:

The energy code concurrency period will officially be extended to November 7, 2020, at least at first. At their 7/14 meeting, the BBRS approved the maximum extension possible under an emergency amendment, which is 90 days. This extension applies to both commercial and residential energy provisions as well as Stretch Code application. It appears probable that the period will get extended further (to January 1, 2021) under an additional, future emergency amendment. Stay tuned for more updates.

Most designers are aware that the 2018 International Energy Conservation Code (IECC) has been adopted in Massachusetts through amendments to 780 CMR 13.00. The amendments dictate an energy code ‘concurrency period’ that started on February 7, 2020 and is scheduled to end on August 7, 2020 – building permit applications filed during this period can identify either the 2015 or 2018 IECC as the applicable energy code for a given project.

COVID-19 has obviously disrupted much of the AEC industry over the past several months. At the June 9th Board of Building Regulations & Standards (BBRS) meeting, the Board agreed in principle to extend the concurrency period to January 1, 2021. This decision will require an emergency amendment, slated to be voted on at the July BBRS meeting. The decision will not be finalized until that point, but all signs point to an extension of the use of the 2015 IECC in Massachusetts.

Please reach out to Code Red Consultants for assistance with energy code scoping provisions and big-picture implications of the new 780 CMR 13.00 amendments and the 2018 IECC.

Last week, we posted a blog discussing a CMS Waiver allowing modification for testing intervals for certain physical environments requirements in health care and ambulatory health care occupancies. That blog can be found here.

On May 11, CMS amended several other requirements that were not included in the previous waivers. The requirements now included in the waivers include the following:

  • Alcohol-based Hand-Rub (ABHR) Dispensers: [CMS] are waiving the prescriptive requirements for the placement of alcohol based hand rub (ABHR) dispensers for use by staff and others due to the need for the increased use of ABHR in infection control. However, ABHRs contain ethyl alcohol, which is considered a flammable liquid, and there are restrictions on the storage and location of the containers. This includes restricting access by certain patient/resident population to prevent accidental ingestion. Due to the increased fire risk for bulk containers (over five gallons) those will still need to be stored in a protected hazardous materials area.

Please note that this allowance strictly relates to the locations of ABHR dispensers to be used by patients, staff, and visitors due to the added levels of infection control that hospitals and other facilities are implementing. As stated, bulk storage containers are still required to be within the maximum allowable code quantities. Due to the increased use of alcohol based hand rub, many facilities are increasing their storage quantities or even mixing their own utilizing ethanol. Great caution should be taken with the storage and/or dispensing of flammable liquids. Applicable fire codes contain regulations pertaining to the protection of these hazards which should be consulted if adjustments to storage quantities or the introduction of new processes are occurring.

  • Fire Drills: Due to the inadvisability of quarterly fire drills that move and mass staff together, CMS will instead permit a documented orientation training program related to the current fire plan, which considers current facility conditions. The training will instruct employees, including existing, new or temporary employees, on their current duties, life safety procedures and the fire protection devices in their assigned area.
  • Temporary Construction: CMS is waiving requirements that would otherwise not permit temporary walls and barriers between patients.

It is recommended that these provisions are only used for relief where necessary and all instances are documented accordingly when used. If you or your facility have any questions regarding these added provisions to the 1135 Waivers, please do not hesitate to contact us.