MASSACHUSETTS FEDERATION OF BUILDING OFFICIALS, Inc.
P.O. Box 320637, Boston MA 02132
President – Robert Camacho PAST PRESIDENTS
Vice-President – Dan Walsh David Moore - Steve Frederickson - Paul Tacy
Treasurer – Paul Tacy
Secretary - Michael Mendoza
March 4, 2010
To: Rob Anderson, Tom Riley, Mike Quigley
Re: Upfront Amendments to the eighth Edition-Base Building Code
Commenting on the proposed changes, modifications or deletions to the “upfront amendments” for the eighth edition of 780 CMR is extremely difficult. It is difficult to determine what impact any change may have on other sections of the base code, or other related codes. On the national level, it takes three years for this to happen and we are trying to do that over a period of several months with far fewer resources. It would also help if the proposed upfront amendments also came with an “explanation” as to why the changes are being proposed. Validation helps add credibility to those changes. The urgency to modify the IBC before it is even adopted, we find confusing. Perhaps there is a greater danger in hastily acting versus any delayed action. By adopting the IBC, we are taking three steps forward, and by front-loading, the IBC with so many confusing amendments may place us two steps back.
With that being said, on behalf of the Federation I would like to first make a general statement on the upfront amendments and then follow that up with comments submitted to the Federation from building officials who have asked the Federation to pass them on to the BBRS.
As building officials, we are concerned that not all of the proposed up-front amendments may have considered the impact the amendments would have on the implementation and enforcement of public safety.
Not to mention the possible confusion they (amendments) may create with registered design professionals and contractors when applying for a building permit. Trying to follow building code guidelines and determining who has jurisdiction could be challenging for them. A building code should have language that is self-regulating and give definite direction to all those who use and enforce it.
One last concern is that we ask the BBRS and the Advisory Committee for the proposed eighth Edition address time frames for the “upfront amendments”. Does the BBRS or the Advisory Committee have a “plan or procedure” for ultimately adopting an “un-amended code” and eliminating any future upfront amendments? Prolonged amendments would only delay and interfere with the ultimate goal of adopting an un-amended International Building Code. We as building officials would ask for a time frames and procedure for adopting an un-amended code.
We respectfully request you consider these comments in your final decision. Attached you will also find commentary submitted on behalf of other building officials.
Robert F. Camacho – President of the MFBO Certified Building Official
C.B.O. – Inspector of Buildings/Building Commissioner
Cc: Thomas Gatzunis-Commissioner of Public Safety – DPS
March 4, 2010
NOTE: The federation has been asked by several building officials to forward the following comments to the BBRS on the proposed front end amendments to the eight edition of 780 CMR. While the Federation takes no official position on the comments that have been submitted, in general they do seem to mirror our concerns.
Chapter 9, the draft amendment changes are confusing mainly because a reader may think the Fire Chief is the decision maker and MGL 143 has the Inspector of Building/Local Building Official as the authority having jurisdiction. I suggest the following:
Throughout this chapter where reference is made to the “fire official” or “fire department” or “head of the fire department” or “fire code official”, such is to be construed as meaning the “Inspector of Buildings or his / her designee in conjunction with the Fire Chief”.
Chapter 17, the draft amendment proposal is to carry current 7th edition language. This is completely different from IBC 2009. I would need to understand why the 7th changed before I can give a recommendation here. No Change to draft.
Chapter 18, the draft amendment proposal has some changes that suggest some projects are unique and we (Massachusetts) need to include. I suggest we stay with IBC and user has section 104.11 for unique situations.
104.11 Alternative materials, design and methods of construction and equipment. The provisions of this code are not intended to prevent the installation of any material or to prohibit any design or method of construction not specifically prescribed by this code, provided that any such alternative has been approved. An alternative material, design or method of construction shall be approved where the building official finds that the proposed design is satisfactory and complies with the intent of the provisions of this code, and that the material, method or work offered is, for the purpose intended, at least the equivalent of that prescribed in this code in quality, strength, effectiveness, fire resistance, durability and safety.
Chapter 19, the draft amendment seems to alter reference standard ACI 318. ^ and suggest staying with ACI 318, unaltered.
Chapter 24, the draft is adding “Also see MGL c.143 §3T, 3U, 3V”. Recommend this by front-loading to stay consistent, No Change to draft.
Chapter 27, no change as lone as amendment is front-loaded.
Chapter 28, this can be done by front-loading “248 CMR and 527 CMR, the requirements of such Massachusetts specialized code”, NO Change to draft.
Chapter 29, no change if this proposal is a front-end amendment.
Chapter 31, I have no recommendation.
Chapter 32, no change to this proposal provided it is a front-end amendment
Chapter 33, no change to this proposal provided it is a front-end amendment.
Chapter 34, the draft amendment proposal is to carry current 7th edition language. This is completely different from IBC 2009. I need to understand the changes before I can give a recommendation here. No change to draft.
Regulation 7, 780 CMR 110.R7 CERTIFICATION OF INSPECTORS OF BUILDINGS, BUILDING COMMISSIONERS AND LOCAL INSPECTORS draft proposal changes from 7th and concerns me as no information is know to us as to why this is changing. Recommend no change from 7th language.
Appendix 120.XB is the same as Chapter 17 of the 7th Edition of the SBC
For me I am not sure what Quality Assurance During Construction means? What I am getting at is what information is needed to make up this Document?
1701 to 1710 Delete entirely and replace with the following:
1701 Quality Assurance During Construction. Provide quality assurance during construction as specified in Appendix 120.XB. Where the term special inspections is referred to in this Code, it shall be taken to mean quality assurance in accordance with Appendix 120.XB.
Exception for Group R Occupancies only; not rational.
903.2.2- Delete and replace with the following:
903.2.2 Group B. An automatic sprinkler system shall be provided throughout buildings having a Group B occupancies where the aggregate floor area of the building exceeds 7,500 square feet (1115m²).
903.2.3- Delete and replace with the following:
903.2.3 Group E. An automatic sprinkler system shall be provided for Group E occupancies as follows:
Where the aggregated floor area is greater than 7,500 square feet (1115m²) in area.
Throughout every portion of educational buildings below the level of exit discharge.
903.2.4- Delete and replace with the following:
903.2.4 Group F-1. An automatic sprinkler system shall be provided throughout buildings having a Group F-1 occupancies where any of the following conditions exists:
Where aggregate floor area of the building exceeds 7,500 square feet (1115m²).
Group F-1 occupancy is located more than three stories above grade.
Where there is a woodworking operation in excess of 2,500 square feet (232m²) in area that generates finely divided combustible waste or uses finely divided combustible materials.
903.2.7- Delete and replace with the following:
903.2.7 Group M. An automatic sprinkler system shall be provided throughout buildings containing a Group M occupancy where any of the following conditions exists:
The aggregate floor area of the building exceeds 7,500 square feet (1115m2);
The Group M occupancy is located more than three stories above grade;
Bulk merchandising stores are defined in 780 CMR 426.0
903.2.8- Delete and replace with the following:
903.2.8 Group R. An automatic sprinkler system installed in accordance with 780 CMR 903.3 shall be provided throughout all buildings with a Group R occupancy. For use Group R Buildings with an aggregate building area of 7,500 sf or more, the sprinkler system shall be designed and installed in accordance with NFPA 13. For the purposes of 780 CMR 903.2, the aggregate building area shall be the combined area of all stories of the building and fire walls shall not be considered to create separate buildings.
Buildings, other than R-1 Occupancies and R-2 Dormitories, having no more than three dwelling units shall be permitted to have an automatic fire suppression system installed in accordance with 780 CMR 903.3.1.3, provided that every automatic sprinkler system shall have at least one automatic water supply or a stored water supply source in accordance with NFPA-13D where the minimum quantity of stored water shall equal the water demand rate times 20 minutes.
For one- or two-family “stand-alone” dwellings classified as R-3 buildings, refer to 780 CMR5313.5 – Note, however, that townhouses are required to be sprinklered.
903.2.9- Delete and replace with the following:
903.2.9 Group S-1. An automatic sprinkler system shall be provided for Group S-1 occupancies as follows:
Throughout the building where the aggregate floor area of the building is greater than 7,500 square feet (1115m²).
Throughout the building, where a Group S-1 occupancy is located more than three stories above grade.
903.2.9.1- Delete and replace with the following:
903.2.9.1 Repair Garages. An automatic sprinkler system shall be provided throughout all buildings having a repair garages where any of the following conditions exist:
Where the building is two or more stories in height, including basements, and contains a repair garage exceeding 7,500 square feet (1115m²).
The aggregate floor area of the building exceeds 7,500 square feet (1115m²).
A repair garage is located in a basement.
Changes should not be made that “decreases” the authority of the Building Official. This fractures and weakens the ability of a Building Official to enforce the building code jeopardizing Public Safety and the safety of first responders.
Proposed definition: 902.1 Fire Area.
Maintain definition in IBC under 702.1
903.2.01 All New Buildings. Below number 6.
Insert & read: The head of the fire department in conjunction with the building official shall enforce the provisions of this section.
Delete and retain the original
~ Public Safety A Shared Responsibility ~