As the 2018 I-codes gain adoption, tent professionals can help advance the code development process.
Tent professionals can help shape fire and building codes at the local, state and national levels by building relationships with enforcement officials and professionals who represent related industry groups, according to Paul Armstrong, P.E., C.B.O.
Armstrong, IFAI’s Tent Rental Division (TRD) code consultant, led a session on building and fire codes at TRD’s Tent Conference in January (see page 8).
“A lot of what we do in the code development process—and it’s a very dry, long, arduous process—is build relationships,” he said. “Because what we have to do is win people to our position. To gain support for the code changes we’re putting forward or, frankly, and in some way more importantly, to gain opposition to the code changes we oppose.”
The building and fire codes enforced by states and local jurisdictions are based on model codes developed by the International Code Council (ICC) and the National Fire Protection Association (NFPA). The code revision process is a three-year cycle that works several years out; for example, code revision proposals for the 2024 I-codes are due to the ICC in January 2021. Codes aren’t in effect, however, until they are adopted by a state or local governmental body. States, cities and counties may also amend the codes to suit their needs, Armstrong said.
The 2018 ICC model codes have been published and are being adopted by jurisdictions now. The development process for the 2021 model codes wrapped up in late 2019; those codes are set to be published in mid-2020.
Occupied roof decks
TRD will evaluate the 2021 model codes once they are published and determine if any changes warrant revision proposals from TRD in the next cycle, Armstrong said. This review can include areas of the code beyond chapter 31 of the International Fire Code (IFC), which covers the installation of tents and temporary structures.
Armstrong offered the example of a 2018 building code revision related to occupied roof decks. The new code states that “elements or structures enclosing the occupied roof areas shall not extend more than 48 inches above the surface of the occupied roof.” The code provides exceptions for elevator and stairway enclosures and cell phone towers, but it does not address temporary tents installed on rooftops—a popular addition for restaurants and other hospitality venues. This raises the question as to whether a temporary tent would be viewed as an additional story, which could cause buildings to go out of compliance.
“We need to get an interpretation from ICC on this, and from local jurisdictions, certainly local fire marshals, about how they are going to view tents on top of roofs now,” Armstrong said. “Because if it creates an additional story, there’s another set of regulations that come alongside that potentially could be impacted.”
While the code development process is exacting, codes are never so thorough that there is no room for interpretation at the local level, Armstrong said.
“This is where a lot of our relationships come into play,” he said. “If officials are reading these codes, and they don’t really understand our industry, they are basically guessing. They are trying to use their experience and apply it to tents.”
The most significant code revision in the 2018 I-codes for tents and temporary structures requires site or engineering documentation for tents with either 1,000-person occupancy and/or 7,500 square feet. Other changes relate to umbrella structures, automatic sprinkler systems in special amusement buildings, and the location of propane cylinders in relation to tents.
Armstrong, who will represent TRD at upcoming ICC meetings, offered tent professionals several suggestions for building relationships with code enforcement officials that will help promote industry-friendly codes and ease the permitting process.
On the local level: Get to know your local building inspectors and fire officials before you need a permit. Attend local association meetings for these officials and offer to present an educational session on tent installations. If possible, develop a “standard plan” for your typical installations in jurisdictions where you work frequently. “If they have a comfort level with you and the way you do business, then it’s going to help expedite things,” Armstrong said.
On the state level: Reach out to your state fire marshal and get to know the staff in the state fire marshal’s office.
On the national level: Join the TRD Code Committee and get involved in the ICC code development process (see sidebar). This work can include conducting research; identifying issues with existing codes; developing and submitting code revision proposals; and working with other national industry groups that submit proposals, such as the National Propane Gas Association and the California Fire Chiefs Association. “Those are groups that are important to what we do, and if they don’t understand what we do or have had a bad experience with what we do, then they may be on the opposite side of what we do,” Armstrong said. “You gain support when they believe you are trying to be proactive and part of the solution.”