The ICC Code Change Process

by Jeffrey E. Harper, PE, FSFPE

ASHE has struck a new partnership with the International Code Council (ICC) to consider how to streamline the codes applied to health care facilities. The purpose of this article is to inform ASHE members about the ICC code change process and, most importantly, to help you identify key points in the process when your voice can and should be heard. Many of you are very familiar with NFPA’s code change process, and the ICC process is similar.

As stated on the ICC website (www.iccsafe.org), the role of the newly appointed ICC Ad Hoc Committee on Healthcare (AHHC) is “to comprehensively review and update the provisions in the International Codes relative to both new and existing hospitals and ambulatory care facilities.” Individually, ASHE members can either support the efforts of the Ad Hoc Committee in developing a package of code changes or work independently to submit proposed changes.

The ICC Process in Brief
Any person or group can submit a proposed code change, speak at a code development hearing, submit a public comment supporting or opposing a submitted code change, and speak at the final action hearing. You need not be a member of the ICC to participate.

A form is provided on the ICC website for submitting proposed code changes. Aside from writing clearly understandable proposed code language, the most important part of preparing a proposed code change is explaining the rationale behind it.

The accompanying diagram provides an overview of the ICC process as well as key dates for the ASHE-ICC effort. Please place the dates on your calendar as reminders to participate in the process.

Due to the breadth and depth of the I-Codes and the number of code changes submitted, ICC code development hearings were lasting for more than two weeks. ICC members pushed for a change as the process grew so time-intensive. In response, the ICC recently revamped its code change process, subdividing the codes to be considered for change into two groups, A and B. This means there is just one shot in each three-year code cycle to propose changes. (Previously, there were two opportunities per cycle.)

The 2012-13 ICC code development cycle addresses proposed changes to Group A codes, including the 2012 International Building Code (IBC). For those of you who may be interested in the International Fire Code (IFC) or other Group B codes, that cycle is very similar but starts a year later. Following is a partial list of the codes included in the two different groups:

GROUP A	GROUP B
International Building Code International Fuel Gas Code International Mechanical Code International Plumbing Code	Chapter 1 of all I-Codes International Fire Code International Existing Building Code International Energy Conservation Code

Any individual is eligible to be part of the ICC technical code committees (TCCs), the groups that consider every proposed code change. TCC members  listen to and participate in commentary from the assembly and weigh information presented with that contained in a proposed change. At the code development hearing, once they have heard comments from the assembly, the TCC recommends one of four dispositions for each proposed code change. The committee may elect to accept, reject, accept in part, or accept in principle a proposed change. The latter two options give the TCC leeway to make slight adjustments to submitted proposals.

At the final action hearings, the TCC presides over the hearings, but final disposition of proposed changes is voted on by the ICC Governmental Members present at the hearing. Governmental members are representatives of those municipalities or other government entities  engaged in administration, formulation, or enforcement of laws, regulations, or ordinances relating to public health, safety and welfare. The final action hearings can be accessed via streaming live audio and video webcast.

The IBC has four technical code committees: Means of Egress, General, Structural, and Fire Safety. Each of these groups has responsibility for specific parts of the proposed changes to the IBC.

At the code development hearing, those present are permitted to speak on any given issue. Once the discussions are complete, the TCC responsible for the proposed code change recommends an action on the proposed change. If unhappy with the technical committee’s recommendation, ICC members attending the code development hearing may “call the vote” and participate in a vote of the assembly that, if 2/3 of the assembly present agrees, can overturn the TCC recommendation. You need not be an ICC Governmental Member to participate in the assembly vote, but you must be an ICC member.

Final Thoughts
As stated on the ICC website, the “ICC develops construction and public safety codes through the governmental consensus process. This system of code development has provided the citizens of the U.S. the highest level of safety in the world for more than 80 years.” Defining what the “highest level of safety” is can be difficult and controversial. Proposed changes must demonstrate a level of safety for building occupants and first responders equal to or greater than the level currently offered by the code. Cost economy and cost of compliance are distant considerations, but are addressed in limited circumstances.

Because of the fluidity of the ICC process, those who have a vested interest in making a change in the codes governing the design and construction of your health care facility must become knowledgeable, active participants in the process. Be sure to take advantage of all the opportunities you have to make your voice heard.

This article can also be found in the summer 2011 issue of Inside ASHE.