Building  Owners  and  Managers  Association  International

Building Owners and Managers Association International

International Fire Code

BOMA Position

BOMA International Supports Adoption of the International Fire Code

The International Codes, which BOMA International has strongly supported since their inception, are facing serious competition from rival code organizations.  A key component of the International Codes is the International Fire Code, which contains provisions to regulate fire hazards in existing buildings, as well as provisions for the installation, testing and maintenance of fire protection features in both new and existing buildings.

Background

For decades, state and local governments throughout the U.S. adopted a model fire code to be enforced typically by the fire service.  Four model fire codes have been available for adoption: the National Fire Prevention Code, promulgated by the Building Officials and Code Administrators International (BOCA); the Standard Fire Prevention Code, promulgated by the Southern Building Code Congress International (SBCCI); the Uniform Fire Code, promulgated by the International Conference of Building Officials (ICBO) and Western Fire Chiefs Association (WFCA); and the NFPA 1 - Fire Prevention Code, promulgated by the National Fire Protection Association (NFPA).

With the creation of the International Code Council (ICC) in 1994, repeated efforts have been made to merge these four codes into a single International Fire Code.  These attempts at cooperation have been unsuccessful.  Consequently, the code landscape now has at least two model fire codes: the ICC International Fire Code and the NFPA Fire Prevention Code.

The International Fire Code is a merger of the provisions in the National Fire Prevention Code, the Standard Fire Prevention Code and the Uniform Fire Code.  So while the International Fire Code itself is new, its provisions are not.  They are based on fire codes that have been in use in the majority of the United States for decades. 

Opportunity for Improvement

All government jurisdictions can realize a significant increase in efficiency by adopting a coordinated set of model codes.  The continued lack of coordination between codes, and the conflicts between them, is a source of great concern as it causes needless delays in the construction process and generates redundant fire protection methodologies that affect both the regulators and the regulated.

Contrast with NFPA

NFPA is recognized worldwide for its standards, particularly those dealing with fire fighting operations, fire equipment and appliances.  The NFPA believes that its Fire Prevention Code is a natural extension of its successful standards effort.  As such, NFPA is more concerned with coordinating its fire code with its own standards than with the other codes on which government jurisdictions typically base their regulations – such as a building code.
    
The NFPA Fire Prevention Code is promulgated by NFPA through a "consensus standard process."  While all NFPA members are eligible to vote on the committee’s reports, their vote is strictly advisory.  Final action on all reports is accomplished by another entity, the NFPA
 
Standards Council.  In the ICC process, however, final action on each code change rests with the voting members, who are state and local code officials responsible for public safety.

Arguments Supporting the International Fire Code

Following are four major points that can be used to urge state and local governments to adopt the International Fire Code instead of the NFPA Fire Prevention Code:

1.  The International Code Council (ICC) process that develops and maintains the International Fire Code is superior to the NFPA process.

The International Fire Code was developed through the International Code Council (ICC), an organization representing the three model code organizations (Building Officials and Code Administrators International, International Conference of Building Officials, and Southern Building Code Congress International) whose collective membership numbers 45,000.  The majority of these building officials represent state and local governments.  The ICC code development process is open and accessible to all interested parties.  All hearings and deliberations are conducted in public with opportunities for input throughout.

Although NFPA standards process is designed to be "consensus," it is burdened with the claim of industry domination, particularly by those with interests from the fire equipment and appliance industry. The membership vote is susceptible to narrow interests "stacking the house" to accomplish a successful vote on an issue of concern.

2.  The International Fire Code is designed to work harmoniously with the International Building Code and all other International Codes.

Having codes that are incompatible and contradictory is the most frequent complaint of those responsible for interpreting, applying, and enforcing the codes.  Entities that are subject to those codes deserve a fair opportunity to understand the requirements they are expected to comply with without protracted appeals, hearings and multiple interpretations from different agencies in the same jurisdiction.

The International Codes are being developed to include consistent requirements and expectations, so that, if a building element complies with the International Building Code (IBC), that element will also comply with the International Fire Code.

3.  The International Fire Code has a clearly defined scope, rather than an overlapping and potentially conflicting relationship with other codes. 

The International Fire Code, which addresses fire prevention matters and extraordinary fire risks in existing buildings, relies on the International Building Code for most of its new construction criteria.  The IFC does contain new construction provisions for fire protection systems, but these are replicated in their entirety in the IBC so that conflicts cannot occur.

The NFPA Fire Prevention Code, however, contains criteria for both new and existing buildings. Moreover, it establishes a permit process for the enforcement of its provisions, duplicating the permit processes traditionally utilized by most jurisdictions.

In addition, the new construction requirements of the NFPA Fire Prevention Code are not coordinated with any model building code.  Thus, extensive analysis and amendment is required of any adopting jurisdiction, increasing the likelihood of conflicts and overlaps between the building and fire codes.

These inherent conflicts, overlaps and inconsistencies can contribute to delays in the plan review and inspection process, create unnecessary ‘traps’ for designers and owners, and add unwanted cost and complication to construction.

4.  The International Fire Code recognizes that buildings built in accordance with the building code need not be subject to unreasonable retroactive requirements.

The International Fire Code "grandfathers" existing buildings without the need for further alterations so long as the building and its occupancies comply with reasonable fire prevention provisions and extraordinary fire risks are mitigated.

Under NFPA’s Fire Prevention Code, many buildings constructed and maintained in compliance with the building code would require significant modifications and additional fire protection.  Changing the rules for an existing building when it is already in full compliance with the building code for new construction is an unfair burden on the building owner.  

Action Requested

Adoption of the International Fire Code, in conjunction with the International Building Code, will go a long way to simplifying the building regulatory system.  Governments adopting the IFC will set a precedent for others that will be considering the International Codes.  Given the resulting benefits, it is strongly recommended that BOMA members undertake an intensive effort to influence their state legislature to adopt the International Fire Code rather than the NFPA Fire Prevention Code.

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