If you have ever used a code or standard, you have probably had ideas about how the document could be improved. Many building enclosure consultants are familiar with the development of standards through organizations such as ASTM, AAMA, SPRI, and others. The International Code Council (ICC) does have a unique process for development of its codes (known as I-codes), but it is not as mysterious as it may seem. This article will outline the steps required to propose a change to one of the I-codes. HISTORY OF THE I-CODES It was not that long ago that there were three model building codes for commercial construction in the United States: • BOCA National Building Code, developed by Building Officials and Code Administrators International Inc. (BOCA) • Standard Building Code (SBC), developed by the Southern Building Code Congress International • Uniform Building Code (UBC), developed by the International Conference of Building Officials (ICBO) In 1994, organizations developing these national model codes were consolidated, and the ICC was formed. The ICC currently develops 14 codes: • International Building Code (IBC) • International Energy Conservation Code (IECC) • International Existing Building Code (IEBC) • International Fire Code (IFC) • International Fuel Gas Code (IFGC) • International Green Construction Code (IGCC) • International Mechanical Code (IMC) • International Plumbing Code (IPC) • International Private Sewage Disposal Code (IPSDC) • International Property Maintenance Code (IPMC) • International Residential Code (IRC) • International Swimming Pool and Spa Code (ISPSC) • International Wildland Urban Interface Code (IWUIC) • International Zoning Code (IZC) Each of the ICC’s I-codes is updated on a three-year cycle. Each of the 14 codes that are updated are placed in either Group A or Group B. For the 2024 update of the I-codes, changes to the Group A codes are handled in 2021, and Group B codes are handled in 2022. Table 1 shows which codes or code sections are considered Group A or Group B. CODE-CHANGE PROPOSALS Code changes can be as simple as adding a reference or fixing an editorial mistake, or as complicated as rewriting an entire chapter. Regardless of the extent of the change, the process is roughly the same. Code-change proposals are submitted through ICC’s online platform, cdpACCESS. You must have an account to submit a code-change proposal; however, you do not have to be an ICC member to have an account. You also do not need to be an ICC 28 • IIBEC Interface June 2021 Photo by Drew Coffman on Unsplash member to submit a code change or participate in the hearings. In addition to understanding the process, it is also important to know the deadlines for action related to certain steps in the process. Many steps in the process are handled online, and if you miss a deadline, you are out of luck until the next code cycle. Table 2 lists some of the important dates and deadlines for the 2024 code-update cycle. Initial Submission of a Code-Change Proposal There is a drop-down menu on ICC’s online platform, cdpACCESS to submit a code-change proposal. If you are making a change to an existing section of a code, you can choose the section, and the online system will auto-populate the existing language. This saves time by not having to retype existing language, while ensuring error-free reproduction of the code text. If you are submitting new text, it will obviously need to be typed into the text box. There are a few important pieces to include with a code-change proposal to better your chances of success. First, code changes to existing language must be shown in strike-through for deleted text and underline for added text. This shows exactly what is changing from the current code language to the new, proposed code language. When working in cdpACCESS with the auto-populated text, this occurs automatically. But it is still important to ensure this translates to the final code change (when reviewing the final submission). Second, a solid technical justification of the change is required. References, figures, and supporting information are all important to include in the reasoning statement for the change. This is the information that the committee reviews prior to the first round of hearings (Committee Action Hearings or CAH), and the public reviews ahead of the second set of hearings (Public Comment Hearings or PCH). It must be noted that no visual aids are allowed during testimony during the hearings, but you can always refer to your reasoning statement. So it is important for it to be robust. Finally, all code-change proposals must include a cost statement as to whether a proposed code change will increase or decrease the cost of construction. Code-change proposals without a cost statement can be thrown out by ICC staff during their initial review. June 2021 IIBEC Interface • 29 2021 Group A Codes 2022 Group B Codes IBC-E: IBC Egress provisions. Chapters 10 and 11 Admin: Chapter 1 of all the I-codes except the IECC, IGCC, and IRC. Also includes the update of currently referenced standards in all of the 2021 codes, except the IGCC. IBC-FS: IBC Fire Safety provisions. Chapters 7, 8, 9 (partial), 14, and 26. Majority of IBC Chapter 9 is maintained by the IFC. IBC-S: IBC Structural provisions. IBC Chapters 15-25 and IEBC structural provisions IBC-G: IBC General provisions. Chapters 3-6, 12, 13, and 27-33 IEBC: IEBC Non-structural provisions IFC: The majority of IFC Chapter 10 is maintained by IBC-E. IECC-C: IECC Commercial energy provisions IFGC IECC-R/IRC-E: IECC Residential energy provisions and IRC Energy provisions that are in Chapter 11. IMC IGCC: Chapter 1 of the IGCC. Remainder of the code is based on the provisions of ASHRAE Standard 189.1, Standard for the Design of High-Performance Green Buildings, Except Low-Rise Residential Buildings. IPC IRC-B: IRC Building provisions. Chapters 1 – 10 IPMC IPSDC IRC-M: IRC Mechanical provisions: Chapters 12-23 IRC-P: IRC Plumbing provisions: Chapters 25-33 ISPSC IWUIC IZW 2021 Group A Codes 2022 Group B Codes Code-change proposals due in cdpACCESS January 11, 2021 January 10, 2022 Committee action hearings April 11-May 5, 2021 March 27-April 6, 2022 Deadline for receipt of public comments in cdpACCESS July 2, 2021 June 30, 2022 Public comment hearings September 22-29, 2021 September 14-21, 2022 Table 2. Important dates in the International Code Council’s 2024 code-update cycle. Table 1. The International Code Council updates its codes on a three-year cycle. Codes in each group for the 2024-update cycle. Testifying at the CAH After all of the code-change proposals are submitted, they are published by ICC in a monograph approximately two months after the initial due date. This monograph is available for download on cdpACCESS. The monograph is organized by code and then by code section. If you have submitted a code-change proposal, it is important to plan to attend the CAH to testify on behalf of your proposal. A committee is formed for each I-code to hear testimony for (proponents) and against (opponents) each submitted code-change proposal at the CAH. Each individual proponent and opponent is given only two minutes to speak for or against any code-change proposal. An additional one minute is granted to each proponent and opponent in rebuttal, if needed. It can be quite hectic at the CAH because proposals are heard on a rolling basis. If a proposal has several proponents and opponents, testimony can take a long time. Conversely, if a proposal has no proponents or opponents, testimony can be over in a couple of minutes. It is important to monitor the pace of the hearings, as well as where the committee is in the agenda to ensure that you do not miss testimony on any proposals that you have submitted or any other proposals of interest. There is no redo. For this part of the process, communication, collaboration, and compromise are key. If a code-change proposal is complicated, it may be impossible to present an argument in two minutes. In these cases, it is helpful to engage colleagues who would support the proposal and can speak to its merits. During the CAH, while most testifiers are in the room, is also the time to discuss any concerns with opponents to a proposal. If a small compromise to the proposed change will reduce or eliminate opposition, it is good to know that ahead of testimony in front of the committee. At the end of the CAH, all code-change proposals will have been approved (with or without modification), disapproved (with or without modification), or withdrawn. Public Comments on Code-Change Proposals At the conclusion of the CAH, all approved or disapproved code-change proposals can be modified or resubmitted during the public- comment period. Any code-change proposals that were withdrawn are ineligible for further consideration. There are several strategies related to public comments on approved or disapproved code-change proposals, but the basic steps are similar to those when originally submitting a proposal. Public comments can be submitted by anyone on any code-change proposal that was either approved or disapproved at the CAH. For example, even if you did not submit a code change or participate in the CAH, you can still submit a public comment on a code change that you consider worthwhile. This is when the code-change process gets really interesting. Public comments can be submitted by opponents to disapprove code changes, to incorporate committee concerns voiced at the CAH, and a wide range of other scenarios. Just like with any original code-change proposal involving existing code language, it is important to include public-comment text 30 • IIBEC Interface June 2021 Regulations pertaining to code-development activities are included in the International Code Council’s (ICC’s) Council Policy (CP) 28, Code Development. CP-28 stipulates that “eligible final action voters include ICC Governmental Member Voting Representatives and Honorary Members.” The ICC Bylaws establish qualifications for governmental members, which are “Governments or Municipalities (includes agencies, departments & units) engaged in administration, formulation or enforcement of laws, regulations or ordinances relating to public health, safety and welfare.” What is a Governmental Official? The author testifies on behalf of IIBEC members at the 2019 public comment hearings. changes (in strike-through for deletions and underline for additions) and provide adequate justification. If a code-change proposal you submitted was disapproved at the CAH, the most important part of this stage of the process is to submit a public comment to either approve the existing proposal or approve it with a change. If you do not attempt to resurrect the proposal during this stage, it may not be brought back by anyone else at the PCH in the current cycle. Testifying at the PCH Just like at the CAH, the PCH allow proponents and opponents to speak on all public comments submitted on code-change proposals. At the PCH, instead of testifying in front of a committee, all testimony is aimed directly at the governmental officials in the audience and watching online. As at the CAH, testimony is limited to two minutes per proponent and opponent for each public comment on each code-change proposal. Each proponent and opponent is also allowed one minute in rebuttal, if needed. At the conclusion of the testimony, an electronic vote is conducted for those governmental officials in the audience. Those in-person totals are added to the online governmental consensus vote (OGCV) that occurs approximately two weeks after the conclusion of the hearings. Code-change proposals must be approved during the OGCV to be incorporated into the next version of the I-codes. IIBEC AND THE I-CODES The code-change process can be daunting to individuals who are not familiar with it. This is one of the reasons why IIBEC has recently formed a Codes and Standards Committee: to facilitate code changes that would be beneficial to the industry. The hope is that this article begins to clarify the process of proposing changes to the I-codes. Whether submitting a proposal, testifying at a hearing, or looking for support for a potential change, members should contact IIBEC if interested in lending support. June 2021 IIBEC Interface • 31 Emily Lorenz, PE, serves as the senior director of technical services at IIBEC. She has experience as an independent consultant in the areas of green structures and practices, energy efficiency, thermal properties, and moisture mitigation. Lorenz also specializes in building code and standard work and advocacy. Emily Lorenz, PE Last year was the worst in recorded history for wildfires in California. Over four million acres burned, more than doubling the total of any other year on record since 1933, when reliable records began being kept. Significant monetary resources have been sunk into firefighting mechanisms, such as purchasing additional helicopters and airplanes and hiring more firefighters. Now, the California government is looking at ways of increasing fire prevention measures, and the Associated General Contractors of California are concerned about possible effects on the construction industry. The Early Budget Action for Wildfire Prevention, a $536-million legislative package agreed upon by California’s government in mid-April, includes provisions for fuel breaks, forest health projects, and home hardening. The Los Angeles City Council adopted a motion to restrict the use of wood-framed construction throughout much of the city. The motion mandates (1) a Fire Protection Plan for “new and significantly altered projects over 150,000 square feet and/or 10,000 square feet if over 30 feet in height; and (2) recommendations to ensure skilled workers are employed for new multifamily and commercial structures within Fire District 1.”1 CEO of the Associated General Contractors of California Peter Tateishi said, “If you’re going to say you can only use steel or cement-type structures in some of these areas, that’s a different kind of build with significant costs associated with it. That can become cost-prohibitive.”2 CAL FIRE/Butte County dispatcher Beth Bowersox explained, “We don’t just want to put out the fires that happen, we want to prevent them from happening in the first place.”3 — ConstructionDive, Sacramento Bee, Action News Now, National Law Review 1. Fraijo Jr., Alfred and Reuben Duarte. 2021. The National Law Review. April 8. Accessed May 6, 2021. https://www.natlawreview. com/article/city-los-angeles-moves-to-increase-building-standards-new-construction. 2. Bousquin, Joe. 2021. ConstructionDive. April 13. Accessed May 6, 2021. https://www.constructiondive.com/news/california-wildfire- plans-limit-development-builders-say/598260/. 3. Downs, Brandon, Deb Anderaos, and Kristian Lopez. 2021. Action News Now. April 12. Accessed May 6, 2021. https://www.actionnewsnow. com/content/news/Gov-Newsom-to-come-to-Butte-County-Tuesday-to-sign-wildfire-prevention-plan-574192421.html. Photo by Patrick Perkins on Unsplash Wildfire Prevention Plans Would Limit Development in California
