Everything You Need to Know About Building Codes, But Were Afraid to Ask: Part II

Second of a two-part article series on code development in the United States

Who Submits Code Change Proposals?

In the Winter 2007 issue of Modular Housing News we covered the history of code development in the United States. Now, the question issue, how can you as an individual, company, or industry impact the code development process. The answer is simple, anyone can submit a code change proposal to a model building code or standard. Some scenarios that exist include:

• Competing material groups, including but not limited to: steel, wood, and plastic, pursuing market share gains may propose revisions to building codes and standards.

• Builders and developers pursuing avenues of least initial cost, often proposing, encouraging, or supporting the development of codes and standards that are favorable for alternatives to cement-based products and providing the builder or developer with increased profitability.

• Systems manufacturers, such as those producing automatic sprinkler systems, propose, encourage, and support code and standards revisions that reduce the requirements for the use of cement-based products as passive fire protection to justify the additional costs for their systems and gain support from builders and developers.

• Government agencies may propose codes and standards changes that reflect the results of research and development; support their issues and views; or satisfy their obligations to comply with mandates from legislative bodies.

• Building code officials and administrators may propose changes to enhance life safety or to simplify the codes and standards or the inspection process.

• General public and legal counsel may submit changes with the intent of increasing consumer protection.

ICC Model Code Process

Over a thousand code changes are proposed during each cycle of either the International Codes Council (ICC) or National Fire Protection Association (NFPA) code change cycle. Both national model code writing bodies are on an 18-month cycle. While there are some differences in the processes, both the NFPA Compressive Consensus Codes and ICC Code Development Process basically provide opportunities to introduce, review and comment, support or oppose, and challenge actions. The ICC process is:

1. Introduction of Code Changes
A deadline is set for receipt of proposal for code changes. MHI Technical Activities Department staff, directly or by working with other organizations, prepares and submits proposed code changes favorable to satisfying the intent of the building code with cement-based products.

2. Code Change Proposal Reviews
Approximately 90 days before the code development hearings the model code writing body publishes the proposed code changes. MHI Technical Activities Department staff with industry allies share in the review of numerous requests for code changes submitted by others. Priorities are set and assignments made to address code change proposals that have a significant impact on the use of cement-based products. Industry representatives may speak in favor of a code change, request to modify a code change, remain silent on a code change, or oppose a code change. Preparations and technical substantiation are developed for verbal testimony at hearings. On significant issues handouts or other materials are also prepared.

3. Code Development Hearing
At a scheduled time and place individuals are allowed approximately 2 minutes to speak in favor of a code change, modify a code change, or speak against a code change. A committee then decides the action for each code change: approval as submitted, approval as modified, or disapproved. In a coordinated effort MHI staff and industry allies testify at the code development hearings.

4. Report of Hearing
A report of the actions at the hearings is published and public comments are requested. MHI staff and industry allies review the reports to see where proposals favorable to the cement-based products industries are support and where they were challenged. Further testimony, substantiation and handout materials are prepared for the final action hearings. In addition, on key issues, MHI and other industry representatives work to educate government officials on our positions and to provide them with adequate substantiation.

5. Final Action Hearing
Following the public comment period, anyone can testify at the final action hearings. NMHC and allied industry representative provide testimony. Decisions are made to agree or disagree with actions at the previous hearings or to offer further revisions. Decisions are made by vote of the active governmental members of the model code organization.

The standardization process for new technologies and methods usually starts in the form of research, which leads to papers on the topics and then to the development of guides. The guides are used by specific industry interests to assist in gaining code acceptance for new products and applications, typically through a third party evaluation service.

National Reference Standards Development

Due to lack of sufficient time and resources in the model building code process, design and construction provisions for many materials, components and systems are developed by voluntary industry or societal consensus organizations or processes. These standards are then referenced in the building codes.

Many technical aspects of the model buildings codes are addressed in reference publications developed by national consensus standards development organizations (SDO). These standards are not typically transcribed into the body of the building code, but are referenced in the appropriate sections of the building code. Product specification and testing standards are not within the purview of the Codes and Standards Department and are addressed by the Product Technology and Standards Department.
NMHC’s primary standards development work is with:

• American Concrete Institute (ACI)
• American Society for Testing and Materials (ASTM)
• American Society of Heating Refrigerating and Air-Conditioning Engineers (ASHRAE)
• American Society of Civil Engineers (ASCE)/Structural Engineering Institute (SEI)
• International Code Council (ICC)

The primary standard development activities are:

• Fire Resistance of Building Elements
• Structural – Minimum Design Loads (buildings and during construction)
• Structural – Load Resistance Design (concrete and masonry structures and wind and flood resistance)
• Thermal Performance of Buildings
• Structural – Minimum Design Loads
• Minimum Design Loads for Buildings and Other Structures (ASCE/SEI 7) sets minimum load requirements and load combinations for buildings and other structures for strength design and allowable stress design. Addressed are dead, earthquake, fluids, flood, lateral earth, live, roof, rain, snow, wind, and wind on ice loads; weight of ice; and self-straining forces.
• Structural – Load Resistance Design
• Standard for Hurricane Resistant Construction (IS-HRC) specifies prescriptive methodologies of wind resistant design and construction details for buildings and other structures of wood framed, steel framed, concrete or masonry construction sited in hurricane prone areas. The standard being developed is a modification of the Hurricane Resistant Residential Construction (SSTD-10), formerly published by the Southern Building Code Congress International, Inc., currently referenced in the International Residential Code.

Thermal Performance of Buildings
Energy Standard for Buildings, Except Low-Rise Residential Buildings (ASHRAE 90.1) provides minimum energy-efficient requirements for the design and construction of new buildings and their systems and criteria for determining compliance with these requirements. The buildings addressed in this standard tend to have larger space conditioning loads generated internally than through the building envelope or skin.

State and Local Code Development
The national model codes may be adopted by state and local jurisdictions with or without modifications or amendments, depending on their needs. The building code enacted or adopted via a legislative and/or regulatory process at the state or local level becomes the minimum legal requirements to which buildings are designed and constructed.

An area of primary concern since the passive fire protection requirements in the national model building codes have been targeting manufactured homes.

This is an area where you can have an impact. Join your local code or building officials association. Attend the monthly meetings and lunches. As you build these relationship you will be surprised the help you will receive.

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