4.13 - Codes & Standards Committee Monthly Report for June 2025
June was a relatively busy month for the committee. In a follow-up to the April ICC committee hearings, the chair submitted public comment to the IRC-Building Committee seeking to get our big code modification reconsidered in the subsequent second round of hearings in October. Modification AMD43-25 for the 2027 model code had been divided into two parts to be heard by separate committees because it would impact multiple model codes. The IRC-Building Committee heard it first, but did not like two provisions and disapproved it. We responded to those objections by submitting floor modifications that revised the proposal when it was considered later by the ADMIN Committee for the IBC and IEBC. The modification was approved by the ADMIN Committee with those changes. In the recent public comment submission, we revised the language for reconsideration by the IRC-Building Committee to match what ADMIN had approved. Here is the final form:
R106.1 Submittal documents. Submittal documents consisting of construction documents and other data shall be submitted in two or more sets, or in an approved digital format where allowed or required by the building official, with each application for a permit. The construction documents shall be prepared by a registered design professional where required by the statutes of the jurisdiction in which the project is to be constructed. Where special conditions exist, the building official is authorized to require supplemental construction documents to be provided to explain how the proposed design complies with this code.
Exception: The building official is authorized to waive the submission of construction documents and other data if it is found that the nature of the work applied for is such that reviewing of the waived construction documents is not necessary to obtain compliance with this code.
Add new definitions, as follows:
SPECIAL CONDITION. An element of the construction site or design that is outside the parameters upon which the code is based or exceeds the prescriptive guidance found in the code and is unique to the project rather than generally applicable within the project area.
SUPPLEMENTAL CONSTRUCTION DOCUMENT. A construction document not normally provided as part of the standard permit application package for the type of work proposed that demonstrates how the proposed design addresses a special condition presented by the project so as to meet the intent of the code.
We are hopeful the revisions will result in it being approved by the IRC-Building Committee, particularly since it has already been approved for the IBC and IEBC and consistency across the codes is highly desired by the ICC.
Closer to (my) home, the Florida Building Commission's technical advisory committee, at its June meeting, rejected similar modifications we submitted for the next issue (2026) of the Florida Building Code. Like the ICC, they have a second round of meetings in the fall where we can seek reconsideration; however, the committee approved only one of the many proposed modifications, and it was just to update the address of a referenced standards-setting agency. No actual code modification was endorsed. Perhaps including the positive results of the ICC process will be persuasive in Round 2 later this year.
In other Florida news, a set of proposed local amendments submitted by the chair to the Broward County Board of Rules and Appeals (BORA) will be considered at their July 10 meeting. Those amendments seek to duplicate the ICC modification discussed above and repeal the existing local amendments that require all construction documents to be prepared by a registered design professional. If they actually follow through this time and keep it on the agenda (see later discussion), it will be the first time we have been able to get our issue before the agency's board.
Our opposition to BORA's local amendments is a continuing saga. As you may recall, BORA originally scheduled our challenge to the local amendments for their May 8, 2025 board meeting, but decided to remove it from the agenda. I appealed this decision to the Florida Building Commission. That agency is currently set to consider my appeal on August 12. They are not actually supposed to decide on the merits of the issues raised but on whether the removal of the challenge from the BORA agenda constituted a final agency action that can be appealed. BORA's expected decision to reject the proposed amendments at the July 10 meeting may help us in the appeal hearing by showing that they have, in fact, reached a decision on the substantive points raised in the challenge.
We are hopeful the revisions will result in it being approved by the IRC-Building Committee, particularly since it has already been approved for the IBC and IEBC and consistency across the codes is highly desired by the ICC.
Closer to (my) home, the Florida Building Commission's technical advisory committee, at its June meeting, rejected similar modifications we submitted for the next issue (2026) of the Florida Building Code. Like the ICC, they have a second round of meetings in the fall where we can seek reconsideration; however, the committee approved only one of the many proposed modifications, and it was just to update the address of a referenced standards-setting agency. No actual code modification was endorsed. Perhaps including the positive results of the ICC process will be persuasive in Round 2 later this year.
In other Florida news, a set of proposed local amendments submitted by the chair to the Broward County Board of Rules and Appeals (BORA) will be considered at their July 10 meeting. Those amendments seek to duplicate the ICC modification discussed above and repeal the existing local amendments that require all construction documents to be prepared by a registered design professional. If they actually follow through this time and keep it on the agenda (see later discussion), it will be the first time we have been able to get our issue before the agency's board.
Our opposition to BORA's local amendments is a continuing saga. As you may recall, BORA originally scheduled our challenge to the local amendments for their May 8, 2025 board meeting, but decided to remove it from the agenda. I appealed this decision to the Florida Building Commission. That agency is currently set to consider my appeal on August 12. They are not actually supposed to decide on the merits of the issues raised but on whether the removal of the challenge from the BORA agenda constituted a final agency action that can be appealed. BORA's expected decision to reject the proposed amendments at the July 10 meeting may help us in the appeal hearing by showing that they have, in fact, reached a decision on the substantive points raised in the challenge.