Download - Changing the I Codes
Changing the I Codes
Maureen TraxlerCode Development
ManagerCity of Seattle
Lee Kranz Plan Review Supervisor
City of BellevueChair WABO Technical
Code Development Committee
Tim NoglerManaging DirectorWashington State
Building Code Council
Outline Code development process 30 minutes
o ICCo WSBCC
cdpACCESS Hands On—Voting for real 30 minuteso Work through one as an example; vote as a groupo Each table/person with laptop votes
Writing proposals with exercise 60 minuteso Picking an issueo Formatting your proposalo Reason statementso Code change pitfalls
Why should you care about code development?
You learn a lot—about codes, reasons for code sections, new technologies…
It fixes problems you encounter Keeps codes current for new products and technology You can get the code changed
o WABO’s proposals have a good success rate Code development just got easier with cdpACCESS
o We asked for a way for everyone to participate, now we have it. o You have opportunity to vote; understanding the code
development process will help you understand how to vote Your participation is important
One person can’t do it alone With more people participating, the end result is better
Code Development Process Goals
Open to all parties Not dominated by proprietary or commercial interests Transparent Balance of interests Based on consensus
“Governmental consensus process”
Final vote is consensus of governmental members who have no financial interest in outcomes; represent the general public
“ANSI process” is very different. Used for A117, ASCE 7, ACI & other materials standards, UPC, NEC, NFPA 13
Allows longer debates, industry votes (no group can dominate), less opportunity to participate for people who aren’t on the committee
Fair appeals process
Code Change Cycle (Groups A, B, C)
Codes are divided into 3 groups for each code edition (Groups A, B, & C)
One-year of code development for each group o Group C (2014): IGCCo Group A (2015): IBC except structural, IEBC, IFGC, IMC,
IPC, IPMC, IPSDC, IRC - M, IRC - P, ISPSC, IZCo Group B (2016): Admin all codes, IBC Structural, IECC-
Commercial, IECC-Residential + IRC Energy, IFC, IRC - B, IWUIC
Early January
Proposals submitted
August Comments submitted
Mid March
Proposals posted
Late August
Comments posted
Late AprilCommittee
Action Hearings
Late SeptPublic
Comment Hearings
Mid May Online vote on
assembly actions
Mid OctOnline vote on
final actions
Mid NovFinal
results posted
Early June
Results posted
Phase 1: Proposals & Committees
Phase 2: Public Comments & Final Vote
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One Year of Code Development
ICC staff works w submitte
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ICC Code Development ProcessCommittee Action Hearing Process
Committee votes on each proposal at the hearing
If someone present disagrees with committee vote, they make assembly motion
All ICC members can vote on assembly motions on-line after the hearing
Motions at Committee Hearings
Only Committee members make motions (except for assembly motions)
Possible motions:o AS As Submittedo AM As Modified o D (Disapproval)
Committee must state a reason for the motion.o Reasons published with hearing results
Motions at Public Comment Hearings
Anyone can make a motion Possible motions:
o AS As Submittedo AM As Modified by code development committeeo AMPC As Modified by Public Comment (only mods
published in the agenda are allowed—no floor modifications)
o D Disapproval Process is weighted in favor of status quo
(disapproval) first; committee action second. o Disapproval needs simple majority regardless of
committee action; committee action needs simple majority
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendmentsSTEP ONE: STATEWIDE AMENDMENTS
SUBMITTED
•Proposal proponent completes the ‘Application for Review of a Statewide Amendment’ form.
•assessment of why the amendment is needed based on the listed criteria: critical for life/safety; required by law; needed to address a unique character of the state; fix errors and omissions
•The form is submitted to the SBCC by the yearly March 1 deadline.
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendments
STEP TWO: STAFF REVIEW•SBCC staff checks for complete information
•Staff may request additional information from the proponent if necessary.
•Staff may be directed to conduct or provide additional research on the benefits and impacts of the proposal if necessary.
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendments
STEP THREE: COUNCIL CODES COMMITTEE REVIEW
*ACTION ITEM File CR 101 Notice of IntentNote: Rule Making must follow Administrative Procedures Act
•Council delegates to codes committees for review and public input. Proposals posted on Council website.
•Codes committees recommend proposals be sent either to a TAG for further review or be denied, tabled or deferred.
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendments
STEP FOUR: TECHNICAL ADVISORY GROUP PROCESS
•TAGs appointed by SBCC chair•TAGs review new proposals, and new code edition significant changes, and existing state amendments•TAGs make recommendations on adoption to the SBCC codes committee (AS, AM, D)
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendments
STEP FIVE: WORKGROUP ON ECONOMIC IMPACT
•TAG Chairs and staff present economic findings to the economic workgroup (SBCC members)
•Public may address the workgroup.
•Workgroup may recommend further economic analysis be conducted by the proponent, by staff, or by a third party.
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendmentsSTEP SIX: TAG RECOMMENDATIONS
•Codes committees review proposed amendments•Staff prepares a report to the Council on the economic impacts of all proposals reviewed.•Where an impact on small business is found, the report includes a Small Business Economic Impact Statement on those items. •ACTION ITEMS—
• SBEIS filed with proposed rule according to Regulatory Fairness Act.• Proposed rule filed for public hearing• Proposed rule contains all amendatory language
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendments
STEP SEVEN: COUNCIL REVIEW•Council reviews the proposed rules
•Public may address the Council regarding proposals.
•Council moves to forward proposed amendments to the public hearing process.•ACTION ITEM —File CR 102 Proposed Rule with small business economic impact statement ; sets public hearing dates.
STATE OF WASHINGTON
STATE BUILDING CODE COUNCILProcess for adoption of state amendments
STEP EIGHT: PUBLIC HEARING/ ADOPTION PROCESS
•Members of the public may address the Council regarding the economic (and other) impacts of proposed amendments to the codes.
•The Council makes a final decision on adoption of proposed statewide amendments by December1. •ACTION ITEM– File CR 103 Permanent Rule with cost benefit statement where necessary
cdpACCESS™ Main Features
On line submittal of code change proposals and public commentso Allows collaboration
Remote voting—2x for each code Group1. Committee Action Hearings (mid May)
• Vote on assembly motions following the hearings • All ICC members vote
2. Public Comment Hearings (mid October)• Vote to occur following the hearings• Governmental members only
ESSENTIAL to meet registration deadlines
Reason for cdpACCESS Response to ICC members’ request for a way to
participate in code development w/o travelo Can’t afford time & money to attend hearings
Added benefit: participate at your own paceo 2-week window to vote
Voting with cdpACCESS Voters can view video of hearings, text of proposals
and comments For more information on cdpACCESS™ go to:
http://www.iccsafe.org/cdpACCESS
WABO TCD Works as a group on:
o Drafting code change proposalso Drafting public commentso Reviewing proposals and commentso Testimony for hearingso Issues related to code development
WABO TCD is not the same as WABO Membership:o Does not represent WABO Membership except as
directed by the WABO Executive Committeeo Identify ourselves as representing WABO TCD on all
proposalso WABO TCD focuses on ICC codes and Washington State
codes
Nuts & Bolts of Code Changes
Code change proposals have 2 partso Revision to code texto Reason supporting change
Keeping track of your code change issues
WABO Discussions—TCD discussion forum (WABO website)
Lee keeps ideas in a 3-ring binder and on website forum
Maureen keeps a list in her computer
Formatting code change language
Underline words you want to add to the code
Strike through words you want to remove from the code
Reason statements Reason should be based on data when available
o Is there a study that supports your proposed change? Be Clear
o OK to use diagrams and photos if it will make your reason clearero Longer reason statement isn’t always more persuasive
Be Conciseo Keep it short unless it’s a complex issue that has not been discussed
before Focus on what’s persuasive
o “That’s the way we do it” isn’t persuasiveo Anticipate opponents’ arguments, but don’t focus on them, and you
don’t have to mention them Tell the truth
o Don’t distort datao Don’t overstate your case
ICC Code DevelopmentGood “Starter” Issues
Fixing obvious errorso Fixing cross-references might be dealt
with “editorially” – staff discretion -- but they usually ask you to prepare a code change proposal
Resolving conflicts within or between codes Fixing confusing language
o Be careful of unintended consequences (changing intent of original provision)
Example of starter issue
Another starter issue
ICC Code DevelopmentMore “Advanced” Issues
Eliminating unenforceable code requirements Complex issues
o Complexity can be technical or political o Support with data or good reasoning
Examples: o Political issue, like residential fire sprinklerso Adding new requirements, like CO alarmso Confusing or complicated issues, like State
Res Code provisions on protection of cantilevered floors
ICC Code DevelopmentWhat makes for a successful proposal?
Technical merito Consistent with IBC philosophy (not “because that’s
how it was in UBC” or “this is from the Washington State Code”)
Well-written and supported Simple to understand (Committee has limited
time to review loads of proposals)o Deal with one issueo Not too longo Note: if complex issue, try to break it into smaller
proposals• Breaking it up may lead to “chicken and egg” problem,
esp. if parts go to different committees.
Wrap up: WABO TCD wants you (to give us your code
change ideas)! You can make a positive difference in your
community. Let us know if you need help with your code
changes. TCD keeps a meeting schedule on the WABO
website.
Thanks for your participation today and in the future!