Up to Code

BOMA Speaks for Commercial Real Estate at ICC Code Development Hearings


BOMA continues to serve as the only national real estate trade association with an active building codes advocacy program. BOMA staff is involved in code development from the moment the drafting process begins and remains fully engaged as states and local jurisdictions work to adopt and implement code changes.

This past year was critical for the future of building codes. BOMA International’s codes team spent 2019 working hard to shape the International Code Council’s (ICC) 2021 Group B code development process. Throughout the year, BOMA International’s Building Codes Committee reviewed more than 1,300 proposed code changes. Apart from the continuing challenges on the energy front, the cycle was very productive in advancing a range of code changes—particularly those regarding existing buildings.

BOMA started the second round of the code development cycle very strong, kicking off at the spring ICC Committee Action hearings in Albuquerque, New Mexico, where 90 percent of BOMA-supported proposals for the existing building codes, administrative provisions and structural codes were affirmed.

Along with moving BOMA-supported proposals forward, the committee action hearings were also successful in defeating and modifying proposals found unnecessary or detrimental to the industry. In one such case, a proposal was defeated that would have mandated existing building compliance with the International Fire Code retrofitting provisions before any alteration could even be considered. If adopted, the proposal would have significantly increased alteration costs for existing building owners. BOMA’s codes team succeeded in negotiating a modification to the original proposal, limiting its application to the portions of the building being altered and only in states and localities where the retrofitting provisions of the fire code have been


By October, these efforts moved from the Committee Action Hearings to the next step in the adoption process: the ICC Public Comment Hearings in Las Vegas. During this period, BOMA International’s codes team was effective in testifying on behalf of the industry and working to gain support on close to 100 positions.

Among other victories, a proposal was approved to clarify 2018 code language regarding a change of occupancy in existing buildings. The change ensures that, in the case of an occupancy change, building owners are not made to renovate areas outside of a tenant space that do not present a risk to the life safety or welfare of the tenants. This change reinforces that the purpose of the International Existing Building Code (IEBC) is to allow existing buildings to be renovated and occupied while making incremental upgrades that enhance the building safety, rather than retrofitting the space entirely to meet today’s codes. In other words, a space changing from a 40-occupant nail salon to a 40-occupant office should not be required to add new lighting, electrical outlets and so on.

Another important clarification to the IEBC also moved forward, making code requirements regarding work areas more accessible. The clarification provides detailed examples of what a work area includes and excludes to avoid mixed interpretations amongst industry members.

BOMA International released an updated version of the 2021 ICC Building Codes Voting Guide for BOMA members to share with their local code officials, so that they could be fully informed about the potential ramifications of their vote on the commercial real estate industry. Voting for the Group B Codes cycle occurred at the end of 2019 and the results will be released later this year.

BOMA International’s code advocacy efforts have farreaching benefits for the industry. Unwarranted or confusingly written codes can place a costly burden on building owners that impacts the economic health of the industry. As this code development cycle continues, BOMA International’s codes team will be working vigilantly with members and code officials to ensure BOMA’s positions on the outlined changes are adopted.

For more information about BOMA’s building codes efforts or for assistance with finding out who your code official is, contact BOMA International’s Senior Codes Consultant John Catlett at codes@boma.org.

This article was originally published in the January/February 2020 issue of  BOMA Magazine.