BBRS & 11th Edition News

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Meeting minutes and Agendas linked here

Election of chair and vice chair Motion and second, past electing Reade Milne Chairperson, Motion to elect Luke McNelly vice chair, he gratefully declined due to time commitments, Motion and second passed to elect Sy Nguyen Vice Chair

Board Counsel, Charles Kilb, reported that BCAB decisions are generally being issued in a timely manner, though several delayed matters are currently being addressed.

Counsel also thanked Board members and subcommittee participants for the significant amount of ongoing work related to the 11th Edition code development process and associated technical subcommittee meetings.
 

Sub Committees 

BOCC: Andrew Bobola, Next meeting during SEMBOA Conference 

Fire Prevention and Fire Protection: David LeBlanc, continues on 11th edition review, chapter 4 completed, and the review of chapter 9 has commenced.

Residential Code: Reade Milne, reported ongoing discussions regarding sign posting, formatting, and organization of proposed amendments. Several residential code chapters without proposed amendments were advanced for submission.

Energy Advisory: Ian Finlayson, completed review of IECC 2024 Residential Chapters, begun review of commercial 2024 IECC.

Climate Resiliency: reported completion of review of assigned floodplain and resiliency-related code sections. The committee has also completed review of four related code proposals.

Executive director report: Tamara Gropman, DOL is transitioning toward enhanced digital accessibility standards for web sites, as part of that effort, BBRS agendas and related public documents will continue moving toward new accessible web-based formats.

CSL issuance totals increased significantly compared to prior months and the same period in 2025, improvements in part seem to be due to revisions made to CSL examination questions, ongoing exam review by subject matter experts, and implementation of extended testing time allowances.

Discussion also occurred regarding long-term license renewal trends and the retirement of older CSL holders.

Request for Interpretation (RFI 2026-04) discussion regarding Request for Interpretation 2026-04 concerning when substantial residential renovations require issuance of a new certificate of occupancy.

Extensive discussion occurred regarding the discretion afforded to local building officials, the distinction between interpretation and guidance, and potential future code amendments to clarify the issue. Board members expressed concern that a formal interpretation could unintentionally constrain building officials or create unintended consequences. 

Motion: To take no action on Request for Interpretation 2026-04 because the current language in the code is adequate. Approved unanimously.

 
Energy Advisory Subcommittee Proposals BBRS resumed review of proposed Massachusetts amendments to the 2024 IECC residential provisions.

Extensive discussion focused on formatting and presentation of front-end amendments, including tracked changes, clean versions, and methods for presenting Massachusetts-specific amendments for eventual submission to the Secretary of the Commonwealth.
 

More discussion on the appropriate format for presenting Massachusetts amendments, including the use of color-coding, the distinction between language carried forward from the 10th Edition and new amendments, and the requirements for submission to the Secretary of the Commonwealth.

Additional discussion occurred regarding accessory dwelling units, all-electric buildings, multifamily construction, ENERGY STAR requirements, EV-ready infrastructure, historic building provisions, passive house standards, and affordability considerations associated with proposed energy code amendments.
 

Statutory Public Hearing Pursuant to M.G.L. c. 143, §97 required in May and November for code changes, Staff reported there were no outstanding petitions requiring public hearing. 

Other Business None.

Technical advisory meetings linked here

https://www.mass.gov/info-details/members-of-the-bbrs-technical-advisory-committees

Sub Committee meetings linked here  https://www.mass.gov/board-of-building-regulations-and-standards-advisory-bbrs-committee-meetings

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

Meeting minutes and Agendas linked here

Board Counsel, Charles Kilb, Sub Committees work continues deferred comments, noting that relevant matters would be addressed within the subcommittee reports.

Sub Committees 

BOCC: Andrew Bobola, Normal business, reviewing possible change recommendations 

Fire Prevention and Fire Protection: David LeBlanc, continues on 11th edition review, wrapping up chapter 4 review at this time, will be moving on to code change proposal assigned, hope to complete task by July.

Residential Code: Reade Milne, Approved code change proposals for Chapter 2 definitions, continued discussion on sprinkler requirements for two-family dwellings, discussion on short-term rentals and lodging houses was tabled to allow progress on other priorities. 

Energy Advisory: Ian Finlayson, completed review of IECC 2024 Residential Chapters 1 and 2, finalized proposal forms and front-end amendments for BBRS consideration will be pressing later in the meeting, preparing to begin review of commercial provisions. 

Climate Resiliency: Sarah Alexandra, completed review of IRC Chapters 1, 3, and 4, approved associated code proposal forms, front-end amendments to be presented at an upcoming BBRS meeting. 

Executive director report: Tamara Gropman, & Ross Seavey number of CSL issued 229 and renewals 1779. The CSL exam pass rate increased significantly from the high 30% range to 56%, attributed to improved exam questions and better preparation by training providers. A recent extension of exam time is expected to further improve pass rates.

Code Change Proposal Forms and Front-End Amendments Dwelling Units Below Base Flood Elevation. Seeks to prohibit creation of new dwelling units below the base flood elevation in both the Residential and Existing Building Codes. Discussion, vote to refer the proposal to the Climate Resiliency Technical Advisory Committee for further review, including consideration of change-of-use scenarios. 

Energy Advisory Subcommittee Proposals BBRS reviewed proposals and front-end amendments related to IECC 2024 Residential Chapters 1 and 2. Discussion included definitions such as Accessory Dwelling Unit, All-Electric Building, and Substantial Project, as well as formatting and procedural considerations for front-end amendments.

Extensive discussion centered on the appropriate format for presenting Massachusetts amendments, including the use of color-coding, the distinction between language carried forward from the 10th Edition and new amendments, and the requirements for submission to the Secretary of the Commonwealth. Members also discussed the integration of the IECC provisions with Chapter 11 of the International Residential Code (IRC). 

Given the need for additional clarification and refinement of the amendment format, the Board agreed to table the remaining 2024 IECC residential provisions until the next meeting.

Request 2026-04: Substantial Renovation/New Certificate of Occupancy submitted by G. Pelletier. Discussion occurred; final action to be addressed in subsequent proceedings.

Other Business None.

Technical advisory meetings linked here

https://www.mass.gov/info-details/members-of-the-bbrs-technical-advisory-committees

Sub Committee meetings linked here  https://www.mass.gov/board-of-building-regulations-and-standards-advisory-bbrs-committee-meetings

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

Meeting minutes and Agendas linked here

Board Counsel, Charles Kilb, Sub Committees work continues, working to coordinate the variety and diverse signage requirements of various regulatory authorities, and the how specialized code are references, are they an advisor notice, does the applicant needed other authority review, does the BO need to ensure aproval of the other authority.

Sub Committees 

BOCC: Normal business, reviewing possible change recommendations for 110 R7

Fire Prevention and Fire Protection: David LeBlanc, continues on 11th edition review, working through chapter 4 at this time.

Residential Code: no report

Energy Advisory: Ian Finlayson, working through IECC residential chapters.

Climate Resiliency: Meeting scheduled for Thursday March 11. in Mansfield. 

Executive director report: Tamara Gropman, number of CSL issued 143 and renewals 1431. Testing time for restricted and unrestricted CSL increasing from 3 to 4 hours April 9, those apply for testing until March 31 limit 3 hours after April 9, 4 hours.

Official Interpretations: 

2026-02 Applicability of Section 406 (Motor Vehicle-Related Occupancies)finial version for review and vote next meeting.

2026-03 Design of Transit and Commuter Rail Stations: seemed to be a code edition and reference document issue. Staff and Board Counsel, there is no conflict or interpretation needed refer to 101.4.13 Transit and Commuter Rail Stations: Such stations shall comply with 780 CMR and NFPA 130-2014, chapters 2, 3, 4, and 5. Any references to NFPA 101 and NFPA 220 shall mean reference to 780 CMR. Where conflict exists between 780 CMR and the referenced standard, compliance with the referenced standard shall be required.

Much discussion ensued, applicants should work with state inspectors for the MBTA, apply for a building permit and request action by the Appeals Board if needed.

Motion and second take no action as the code is clear, passed.

2026-04 Substantial Renovation/New Certificate of Occupancy.

Based on the IRC at what point renovations or additions does a new CO need to be issued? Approximately one hour of discussion far ranging including the language in the IBC, when is a building official required to issue a new certificate of occupancy or is the certificate of completion sufficient.

Discussed was the BO may revoke the certificate of occupancy R111.4, building altered R111.1.1, Suggestion made the MFBO be consulted to get a consensus of the BO, discussed was the building official having authority should review the situation evaluate the extent of work done make a decision based on the facts at hand.

Motion and second to refer to the advisory committee, which passed.

Other Business None.

Technical advisory meetings linked here

https://www.mass.gov/info-details/members-of-the-bbrs-technical-advisory-committees

Sub Committee meetings linked here  https://www.mass.gov/board-of-building-regulations-and-standards-advisory-bbrs-committee-meetings

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

Meeting minutes and Agendas linked here

Board Counsel, Charles Kilb, Sub Committees doing good work, following procedures set out and diligent in their work. Brought to the Board attention the variety and diverse signage requirements of various regulatory authorities, looking to coordinate as much as possible.

Sub Committees 

BOCC: Normal business, reviewing possible change recommendations for 110 R7

Fire Prevention and Fire Protection: completed review of chapters 33 and 7 working on chapter 4 for the 11th edition, reviews code change proposal for safeguard during construction, hope to complete 11th edition work by the end of June.

Residential Code: Review of several code change proposals, some have been tabled some have been approved, looking at definition such as short-term rental.

Energy Advisory: Meetings have been held, presentation later in meeting overview of proposed changes.

Climate Resiliency: Kick off meeting held, chairperson elected
 

Executive director report: Tamara Gropman, number of CSL issued and renewals. Request for interpretation form posted online. Ross Seavey report passing rate for CSL moved up some, allowed testing time for restricted and unrestricted CSL increasing from 3 to 4 hours April 9, those apply for testing until March 31 limit 3 hours after April 9, 4 hours, reviewed and updated questions will be uploaded this week.

 Ian Finlayson DOER, overview of energy code happenings, 2027 IECC is open for public comment, they win not be proposing significant changes to this edition, noted the DOER has to present Stretch and Specialty code toe BBRS for consultation, presented 2 possible code change proposals to 11th to the board for referral to Energy Advisor Committee. Vote to Forward Approved.

Official Interpretations: 

2026-02 Applicability of Section 406 (Motor Vehicle-Related Occupancies) to Factory Occupancies with Grade-Level Overhead Doors, 

Should section 406 apply to “factory/industrial occupancies that include grade-level overhead doors but are not proposed for vehicle use?”

A motion was made to issue the interpretation that:

Section 406 does not apply to the elective inclusion of grade-level overhead doors in a factory or industrial occupancy when there is no associated motor-vehicle use. Motion passed with one member in opposition.

2026-03 Design of Transit and Commuter Rail Stations: seemed to be a code edition and or reference document issue. Motion and seconded to send to staff for review and recommendation.

Other Business None.

Technical advisory meetings linked here

https://www.mass.gov/info-details/members-of-the-bbrs-technical-advisory-committees

Sub Committee meetings linked here  https://www.mass.gov/board-of-building-regulations-and-standards-advisory-bbrs-committee-meetings

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

Meeting minutes and Agendas linked here

Board Counsel, Charles Kilb, nothing to report

Tamara Gropman, provided process for Official Interpretations, Voted to Approved

Sub Committees 

Fire Prevention and Fire Protection, A number of meetings have been held, reviews of chapter 1 and 33, possible proposal for A2L refrigerants

Residential Code, no report.

BOCC Normal business

Energy Advisor, meetings been held, presentation later in meeting overview of proposed changes.

Executive director report, Tamara Gropman; Number of CSL issued and renewals.

Code Change proposals. Hazards to Air Navigation Ross Seavey to review and report, discussion, consensus no need to insert language that is in law into the code, Voted to Disapprove request. 

Presentation Ian Finlayson DOER,  base energy code residential part 1, submitted proposed changes to 11th to the board for referral to Energy Advisor Committee. Vote to Forward  Approved.

Other Business

None.

Technical advisory meetings linked here

https://www.mass.gov/info-details/members-of-the-bbrs-technical-advisory-committees

Sub Committee meetings linked here  https://www.mass.gov/board-of-building-regulations-and-standards-advisory-bbrs-committee-meetings

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

Meeting minutes and Agendas linked here

Board Counsel, Charles Kilb, provided an overview of BBRS responsibilities and authority based on significant statues. While major responsibilities were highlighted there are numerous statues that overlap, have sunsetted or modified the laws as written.

Tamara Gropman, provided draft of process for Official Interpretations, presented draft form for consideration, discussion and comments, will return next meeting for acceptance vote.

Sub Committees 

Fire Prevention and Fire Protection, Dave LePointe, progressing with code change proposals, asked for guidance on priority of review, expressed the 6-month time frame for 11ed review along with code change proposal review is ambitious.

Residential Code, 11ed progress with review is slow steady, nothing to report.

BOCC Work continues, review proposed changes to regulations.

Energy Advisor, considering rollover of 10th edition change proposals, 2024 IECC changes.

Executive director report, Tamara Gropman; Number of CSL issued and renewals.

Code Change proposals. Action taken on code change proposals for the 11th edition cycle. 

Change definition of Highrise to 75 feet, exit signage changes and 2 single stair exits for R-2, 6 story or less sent to FPFP.

ACI for concrete testing personnel qualifications and alternative material language sent to Structural Advisory.

Hazards to Air Navigation Ross Seavey to review and report back.

IBC section 105.2.2 repairs change any wall to load bearing walls, voted to take no action.

Discussion all code change proposal will come before the Board for action before distribution if any to subcommittees.

Other Business

Mike McDowell allowed terms is ending, will serve until replacement appointed.

Technical advisory meetings linked here

https://www.mass.gov/info-details/members-of-the-bbrs-technical-advisory-committees

Sub Committee meetings linked here  https://www.mass.gov/board-of-building-regulations-and-standards-advisory-bbrs-committee-meetings

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

Meeting minutes and Agendas linked here

Board Counsel, 2 code change proposal A2L refrigerant and Solar Setback for 10th edition still under internal review process. 

Counsel will provide overview of BBRS responsibilities at a future meeting.

Tamara Gropman, provided draft of process for Official Interpretations, presented draft form for consideration, discussion and comments, will return next meeting.

Sub Committees 

Fire Prevention and Fire Protection, Dave LePointe, progressing with code change proposals, next meeting November 12, 2025.

Residential Code, No report 

BOCC No report 

Executive director report, Tamara Gropman; Number of CSL issued and renewals, urged BBRS member to participate in the Appeals Board.

Discussion of process for notifying BBRS members of hearing dates and notification of members to sit on the Appeals Board.

CSL testing results continues to be monitored, passing rate rising slowly, contract negations for extending time period for testing in process.

Review/Vote NFPA 72 language, proposed language to eliminate confusion or give directions to deal with the discontinuance of NFPA 720 CO Detection (referred to in ICC 2021) standard and its inclusion into NFPA 72, 2019 Edition which now includes the CO installation standards.  

The Board voted to issue a formal interpretation, “NFPA 72 (2019 edition) shall be considered equivalent to NFPA 720 (2015 edition) as far as carbon monoxide detection systems are concerned.” With staff to prepare a short explanation letter for context of the interpretation. 

Code Change proposals. First read of submitted code change proposal for the 11th edition cycle. 2) single stair exits for R-2, 6 story or less, 1) ACI for concrete testing personnel qualifications which was proposed for the 10 edition, 1) accessible stair marking, 1) Change definition of Highrise to 75 feet, 1) in section reference to Tier II shop drawings.

The Board is mindful of the States housing initiatives and how the building code interplays with those goals. 

Other Business

Jeff Clemons suggested the BBRS web site be expanded to include all the Technical Advisory  and the open and filled positions be listed. For that interest in serving on committee send interest and resume to BBRS-MA@mass.gov

Technical advisory meetings linked here

https://www.mass.gov/info-details/members-of-the-bbrs-technical-advisory-committees

Sub Committee meetings linked here  https://www.mass.gov/board-of-building-regulations-and-standards-advisory-bbrs-committee-meetings

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

Meeting minutes and Agendas linked here

Board Counsel, 2 code change proposal for 10th edition under internal review process. 

Sub Committees 

Fire Prevention and Fire Protection, Luke McKneally & Jake Nunnemacher; good progress on code change proposals. Recommend NFPA 270 reference be handled by official interpretation to NFPA 72.

Residential Code, Mike McDowell; getting started, soliciting changes suggestions sent to BBRS staff.

BOCC Reported on the various numbers of building officials certified applied for an extension along various classes approved for credit. 

Executive director report, Tamara Groman; Number of CSL issued and renewals, 3 subcommittees working, expect a number more to be working around the first of the year, notification to members around November 1. 

Request for interpretation from Code Red regarding control areas. Much discussion, M&S to send to FPFP died, more discussion, actual action taken is unsure by this author.

Request for interpretation from Somerville, regarding vegetative roofs. Request had a zoning component to it, discussion no action taken.

Next schedule meeting is November 11, which is a holiday, discuss other possible dates, staff to gather of line consequences. 

November meeting is statutory code change proposal hearing; proposals have to be filed in accordance with process to BBRS prior to the meeting date.

This report is based on the best efforts of Curtis Meskus and is not a transcript or meeting minutes. Errors, omissions and corrections may be sent to  Curt.Meskus@MFBO.ORG 

DOL moved March of 2025 to One Federal Street, Boston. 

Meeting minutes and Agendas linked here

The Board welcomed Reade Milne, Edgartown Commissioner, representing BO of a town and Vineet Nair (possibly mechanical engineer) to the Board.

Board Counsel, nothing to report. 

The 11th edition continues, long discussion on process for previously submitted code change proposals Submitted during the process of the 10th edition and how to handle them moving forward. The proponents of the existing proposals were going to be asked to update them for inconclusion in the 11th edition process. 

ICC has made available in PDF form and other means of access to the 2024 codes as the baseline for the 11th edition.

Fire Prevention and Fire Protection scheduled to meet September 10th, the residential subcommittee had met once for an organizational meeting, there were no other subcommittee reports. 

BOCC Reported on the various numbers of building officials certified applied for an extension along with 13 building officials who had been reinstated for this cycle once proper contact was established.

Executive director report, Tamara Groman with Ross Seavey report, they continue to work with the CSL testing company to ensure the questions asked are valid and answerable. The current pass rate for first time exams is approximately 32% with the retests being at 36%. Consideration is being given to extending the time limit for the exam to three hours as this is an open book test and, in the field, you have unlimited time to find the answer.

Board members raised the point that this is an entry level exam, and we want to encourage passing the exam, so licensed people are available to properly pull permits.

Next meeting is October 14, 2025.

DOL moved March of 2025 to One Federal Street, Boston. 

Meeting minutes and Agendas linked here

Board Counsel, nothing to report. 

The 11th edition continues, appointments to and setting up subcommittees, possibly; Fire Prevention and Fire Protection Advisory Committee, Indoor Agriculture and one other by the end of August. 

Anyone interested in serving on a BBRS subcommittee can submit interest to staff. 

The Chair received a letter as well as DPL from the Governor to be mindful of reducing or where possible remove outdate, unnecessary or extraneous regulation when promulgating the 11th edition. 

Commissioner Wilkinson reported that the Governor has put forth initiative to all executive departments to eliminate outdated and duplicative requirements, repeal unnecessary and onerous barriers to business growth, and rescind regulations that stifle competition and hurt Massachusetts businesses, business owners and consumers.

Suggestions are welcome, discussion to extend CSL licensing to 4-year cycle, has been considered however has a cashflow impact on commonwealth. 

BOCC, July special meeting to discuss expired Building Officials, next regular meeting in August.

Discussion of code change to correct Carbon Monoxide (CO)reference in the 10th edition due to NFPA 720 being merge into NFPA 72. Other options, such as an errata, ICC change, actual need verses the amount of effort and time needed to go through the code change process. were discuss as code change proposal requires considerable work. Motion made, second 9 to 4and past to send to FPFP for review and recommendation.

Next meeting September 9, 2025.

DOL moved March of 2025 to One Federal Street, Boston. 

Meeting minutes and Agendas linked here

Board Counsel reports the proposed code changes moving through process. 

The 11th edition by Lisa Davey, work continues to form and appoint member to the committees. Anyone interest in serving on a BBRS subcommittee reach out staff and submit interest. The Chair received communication from the Governor to be mindful of reducing or where possible remove  outdate, unnecessary or extraneous regulation when promulgating the 11th edition. 

BOCC Andrew Babola reports any Building Official that did not receive enough continuing education credits last cycle and has not received an extension is now listed as null and void. BOCC will not meet in July, next meeting in August

Discuss for a code change to correct Carbon Monoxide (CO)reference in the 10th edition due to NFPA 720 being merge into NFPA 72. The change would have to follow the same process (time, resources, hearings and filings) as any other language change. Jake Nunnmacher took on the task of further researching and language changes between previous CO regulations and most recent standards of NFPA 72.

The proposed solar guidance document (not the proposed code change) discussed last month, was revised, a motion made and seconded not to publish that document passed.

Discussion and decision BBRS will meet as scheduled in July, no meeting August.

DOL moved March of 2025 to One Federal Street, Boston. 

Meeting minutes and Agendas linked here

Thanks to Member Clemons for the notes.

Voted Lisa Davey and David Riquinha as Chair & Vice Chair respectively (Vice Chair Riquinha chaired the remainder of the meeting after this vote)

Discussion regarding other BBRS members participating as members of the BCAB appeals board and the requirement that an appeals board member must participate in all the cases on a docket for a given day.  Ian Finlayson, the DOER Commissioner’s representative on the BBRS requested that an energy code specialist member of the BBRS would only want to participate in energy code appeals as a consultant.  Council advised that an appeals board member would be required to serve for the entire docket.   

Voted to approve a code change proposal to adopt the NFPA 72-2019 as the referenced standard for the installation of Carbon Monoxide Detectors for the 10th Edition of the code.  The requirements were previously found in NFPA 720-2015, referenced in the 9th Edition of 780 CMR, which will no longer be a published NFPA standard for Carbon Monoxide Detectors.  This change was not adopted in the ICC versions of the 2021 code.  The code change must now move through the required processes for a code change before coming back to the BBRS for final approval.

Voted to adopt an amended version of the code change proposal submitted by the Solar Set-back subcommittee.  The sub-committee was tasked with drafting a proposal that is intended to align with requirements found in the Massachusetts Comprehensive Fire Code, Chapter 11, Section 11.12 for rooftop solar installations access pathways.  The vote was 9-3 in favor of the amended draft.  The code change must now move through the required processes for a code change before coming back to the BBRS for final approval.

DOL moved March of 2025 to One Federal Street, Boston.