How Can You Change a Building Code? Part 1
By Ronald L. Geren, RA, CSI, CCS, CCCA

Editor’s Note: This is the first of a three-part series.
I'm sure that most of you who work frequently with one or more of the locally adopted codes have come across a requirement that seems to make no sense, or has been rendered obsolete by new methods or materials. What some of you may not know is that anybody can submit a proposal for a code change. Both the International Code Council (ICC) and the National Fire Protection Association (NFPA) provide open processes that allow changes to their published codes and standards.

Codes are written to accommodate all types of construction at a national, and currently, international level. Specific code requirements can be added, modified, or deleted at the local level to reflect local conditions or laws. Many jurisdictions allow public comment within their local code adoption process. This is a good opportunity to make a change without having to go through the process at the national level.

An excellent example of how anyone can sponsor a code change is illustrated in the story behind the change in use of wired glass.

A Reason for Change
In 1977, the Consumer Product and Safety Commission (CPSC) developed a safety glazing performance standard titled 16 CFR 1201"Safety Standard for Architectural Glazing Material." This standard increased the minimum performance over that required by ANSI Z97.1, the industry standard up until that time. However, wired glass, which was the only fire-rated glazing at the time, could not pass the more restrictive standards of CPSC 16 CFR 1201. So, CPSC established a "temporary" exception that allowed the use of wired glass in fire doors and windows until industry developed products that met the new standard. The model code organizations followed CPSC's lead by inserting the same exception in their respective building codes. More than 25 years later, the "temporary" exception still existed…that is, until Greg Abel became involved.

In January 2001, Greg Abel's son, who was attending the University of Oregon, received severe nerve damage to his arm and fingers when his hand impacted a wired glass door while playing basketball in the school's gymnasium. As a result, Greg Abel started a crusade to have the exception that wired glass has enjoyed for so man y years removed from the codes and standards. He established a nonprofit organization called Advocates for Safe Glass (AFSG), and set out on their first mission to change Oregon law.
With the support of an Oregon State senator, AFSG successfully persuaded the Oregon State Building Codes Division to ban the use of wired glass in hazardous locations where safety glazing is required. The ban, passed in September 2003, came in the form of an amendment to the Oregon Structural Specialty Code. With that success in their pocket, AFSG took on their next challenge: the International Building Code. But, before I go into the details of AFSG's code change journey, I first want to describe the code development process.

Proposing Change
As I previously mentioned, both the ICC and NFPA have processes that allow the public to propose changes to their codes. However, the processes are significantly different in some ways. Since most of the jurisdictions in the state adopt one or more of the International codes, the focus will be on the process used by the ICC. The ICC has available on their website a document for download titled "Code Development Process for the International Codes," which explains their process in detail. Likewise, the NFPA has available for download on their website a document titled "Codes and Standards for a Safer World," which describes their code and standard development process.

Within the ICC process, the main element is the code development cycle. The cycle starts when proposals are requested, and ends with the publication of final action on code change proposals. Until 2002, the ICC was on an annual cycle that resulted in the publication of 2 supplements within the 3-year code publication cycle. To allow more time for preparation by proposers and ICC staff, the cycle was changed to an 18-month period with one interim supplement between code publications. The first 18-month cycle ended in June 2004.

The change proposal is the first step in the cycle. The proponent, who could be either an individual or organization, must complete a proposal form. This is probably the most critical step in the process as an improperly prepared proposal form won't go beyond this step. If the proposal form isn't properly completed, then ICC will notify the proponent of the deficiencies and hold the proposal until a corrected one is received.

The proposal form consists of two equally crucial parts: 1) the text of the proposed change itself, and 2) the supporting information. In preparing the proposed change, the proponent must write the text in the mandatory language used by the code. Additionally, the text should be complete and specific to avoid any potential confusion or misinterpretation.

Content of the supporting information includes the purpose and reasons for the change, any substantiating evidence or information to support the change, and the cost impact the change would have on building construction. For example, let's assume a requirement in the building code is vague to you. In preparing your proposal, the "purpose" would be to clarify the requirement to make it more specific and enforceable. Your "justification" for the change may include several examples of where the requirement was interpreted differently on several of your projects between different jurisdictions, and/or between plan reviewers and building inspectors. The "cost impact" would consist of either "none" or "this proposal will increase cost of construction" depending on the expected material and/or labor costs associated with the specific requirement. If you feel uncomfortable writing the proposal yourself, approach one or more of the building officials you work with, a code consultant, or your local chapter of ICC. They might agree with your proposal and be willing to assist you in drafting the proposal text and collecting supporting information.

Next month, we'll look at what happens to a proposed change.

Ronald L. Geren, RA, CSI, CCS, CCCA is the specification writer and code reviewer for the Phoenix Office of Gould Evans He is a 1984 graduate of the University of Arizona, and has held various technical and managerial positions for military, state, and private agencies. To comment on this article, suggest other topics, or submit a question regarding codes, contact the author at ron.geren@gouldevans.com