Comments to International Code Council (ICC) Code Change Proposals
Public comments have been made by members of the real estate industry and code-conscious individuals in response to ICC actions taken earlier this year. The following comments have been identified as of interest to BOMA members by BOMA International Codes staff. If you would like to view the full monograph of the code change proposals and their public comments, click here. All of the comments listed below beginning with ‘G’ can be found under ‘IBC – General Grp B CAH2.pdf,’ and those beginning with ‘S’ can be found under ‘IBC – Structural Grp B CAH2.pdf.’
ICC has two Committee Action Hearings (CAHs) each year of the 3-year code development process. We are currently in the midst of the 2027 code development cycle, meaning this version of the I-Codes will be published in 2027. CAH #1 of this year took place in April and May of 2025. CAH #2 will take place October 22-30, 2025. BOMA members’ responses will be used to form BOMA International’s testimony, action, and support or criticism of certain code change proposals this October.
The purpose of this document is to provide transparency on how the building code development process works and how BOMA International is involved. Moreover, codes staff hope to receive feedback from BOMA members on which of the issues below, if any, concern them. As always, please direct any and all questions, concerns, and/or inquiries to Manager of Advocacy & Codes and Staff Liaison to the Codes Committee, Steve Dimino at sdimino@boma.org.
 
 
Proposal G34-25

• Proponent: Jeff Grove, Chair, representing Building Code Action Committee (BCAC)
• Description: This proposal clarifies that rooms or spaces used for assembly purposes that are less than 750 square feet in area, or with an occupant load of less than 50, and are accessory to another occupancy, are to be classified as Group B or as part of the main occupancy. The change aims to prevent misinterpretation and reduce an unnecessary limit on the size of conference rooms in small office buildings.
• Previous Action: The committee disapproved of the proposal but acknowledged it was a "good clean up to help avoid misinterpretation." The committee suggested that "shall" be replaced with "shall be permitted" and noted opposition due to the exclusion of the "accessory" aspect.
• Recommendation: Codes staff recommends opposing this comment because it would unnecessarily increase the number of sprinkler heads required for certain occupancy levels, needlessly increasing the cost of construction.

 
Proposal G35-25

• Proponent: Ali Fattah, City of San Diego Development Services Department
• Description: The proposal intends to reduce confusion by avoiding the classification of an assembly area as a Group B occupancy. It recommends a live load of 60 psf for small assembly areas, fixed seats, and dining areas. The proponent argued that this is more appropriate and can lead to cost reduction in construction.
• Previous Action: The committee disapproved of the proposal, citing that it would create confusion by placing the proposal within the fixed seating section. They also recommended that the proponent create a separate entry in the load table and coordinate with the ASCE 7 standard.
• Recommendation: Codes staff recommends merely monitoring this comment, as it is not seen as particularly controversial. However, we generally support this comment because of the accommodation it offers for small restaurants.

 
Proposal G38-25

• Proponent: Greg Johnson, Johnson & Associates Consulting Services
• Description: This proposal introduces a new occupancy classification, Group D, specifically for data centers. The goal is to provide a classification appropriate for the unique hazards of data centers, which currently fall into different categories (B, F-2, S-1, S-2).
• Previous Action: The committee disapproved the proposal for a new Group D. Instead, they modified the proposal to classify data centers under the existing F-1 (Moderate-hazard factory industrial) classification, which they deemed more appropriate for data processing functions. The committee suggested that additional requirements could be addressed in Chapter 4 of the IBC.
• Recommendation: Codes staff recommend supporting this comment, as it would result in data centers being newly classified as F-3 Occupancy. Data centers are becoming more prevalent and crucial to the U.S. economy. Because of their unique function and risks, they deserve their own classification.

 
Proposal G96-25

• Proponent: Jeffrey Shapiro, representing Lake Travis Fire Rescue

• Description: This proposal suggests increasing the allowable height of Group R-3 buildings to four stories when an NFPA 13D automatic fire sprinkler system is installed. The proponent argues that the current IRC and IBC limits are inconsistent with the performance of modern sprinkler systems. This change could also influence multi-story mixed-use buildings with a residential component above a commercial office space.
• Previous Action: The committee approved the proposal, noting that NFPA 13D systems are allowed in four-story dwelling units and this change would decrease construction costs, making housing more affordable.
• Recommendation: Codes staff recommends monitoring this comment but generally supporting it as well. While mixed-use buildings are in the minority of BOMA properties, this measure would still reduce construction costs, which is viewed as positive.

 
 
Proposal G101-25

• Proponent: David Renn, representing the Code Change Committee of the ICC Colorado Chapter
• Description: This proposal suggests adding specific construction requirements for equipment platforms, which are currently not addressed in the code. It would require these platforms to be noncombustible materials in Type I and II construction and to be fire-resistance-rated if they provide bracing for a building's columns or bearing walls. This could affect commercial office buildings with large mechanical or utility platforms.
• Previous Action: The committee disapproved of the proposal, stating that the existing code already addresses these issues and that the proposed language could be confusing.
• Recommendation: Codes staff recommend monitoring this comment. While this comment is seen as negative, the previous proposal was defeated 13-0, so this comment is not expected to gain any traction.

 
Proposal G104-25

• Proponent: Greg Johnson, Johnson & Associates Consulting Services
• Description: This proposal sought to add a new Group D occupancy classification to Table 506.2, which specifies allowable floor area factors. The values proposed matched those for Group S-1, intending to align with current construction practices for data centers.
• Previous Action: The committee disapproved of the proposal, citing their previous action to disapprove of the creation of a new Group D occupancy. The committee found the proposal unnecessary given their decision to classify data centers as F-1 occupancies.
• Recommendation: Codes staff recommend supporting this comment. As was the case with G38-25, this code change would classify data centers as F-3 occupancies.

 
Proposal G113-25

• Proponent: Greg Johnson, Johnson & Associates Consulting Services
• Description: This proposal aimed to include the new Group D occupancy in Table 508.4, which outlines required occupancy separations. The values were set to match the existing F-1 occupancy, and a footnote was added to reference incidental uses.
• Previous Action: The committee disapproved this proposal, again based on their previous actions regarding the proposed Group D occupancy.
• Recommendation: Codes staff recommend supporting this comment. As was the case with G38-25 and G104-25, this code change would classify data centers as F-3 occupancies.

 
Proposal G116-25

• Proponent: Bill McHugh, representing National Fireproofing Contractors Association
• Description: This proposal suggests increasing the fire-resistance rating for parking garages located beneath Group R occupancies from 2 hours to 4 hours. It also proposes that the structural members supporting these garages should have a 4-hour fire-resistance rating. While this proposal specifically addresses Group R, a mixed-use building could have a Group B occupancy above a garage, making this relevant.
• Previous Action: The committee disapproved the proposal, citing a lack of data to support the increased fire-resistance rating and noting that the proposal does not consider the role of sprinkler systems in mitigating risk.
• Recommendation: Codes staff recommend opposing this comment. The current two-hour fire resistance is plenty safe, and there is no need to increase it to three hours.

 
Proposal G117-25

• Proponent: Gabriel Levy, representing the Code Change Committee of the ICC Colorado Chapter
• Description: This proposal aims to clarify the requirements for horizontal building separations, particularly for buildings with a Type IA podium below a wood-framed structure. The proposed changes would prohibit "unconcealed vertical openings" through the horizontal assembly, ensuring fire and smoke separation between the different building sections. This could affect mixed-use commercial and residential buildings.
• Previous Action: The committee disapproved the proposal, with the proponent requesting more time to edit the language for clarity. The committee noted that horizontal assemblies already address this topic, making the changes potentially unnecessary.
• Recommendation: Codes staff recommend monitoring this comment because it would constrict building construction capabilities. This proposal was previously defeated 13-0, so it does not appear to have much support at all.

 
Proposal G120-25

• Proponent: Richard Walke, representing the National Fireproofing Contractors Association
• Description: This proposal would require a fire-resistance rating for occupiable roofs that is equal to or greater than the floor assembly below. This is meant to protect occupants and the building from fire originating on the roof. This could be relevant for commercial buildings with rooftop amenities.
• Previous Action: The committee disapproved the proposal, citing a lack of technical data to support the need for increased protection. They also suggested that the cost increase would be substantial and that the proposal did not adequately address occupiable roof areas that are only partially occupied.
• Recommendation: Codes staff recommend opposing this comment because it would require increasing the fire resistance rating on rooftops where there are small gatherings. It is commonplace now to have office buildings with a small assembly space on their rooftops, and this comment would create an unnecessary hurdle for the building owners.

 
Proposal G124-25

• Proponent: Charles Anderson, representing the City of Minneapolis
• Description: This proposal aims to revise Table 601, which details fire-resistance ratings for building elements. The change would require all exterior walls in Type III construction to have a minimum 1-hour fire-resistance rating, which the proponent argues aligns with the original intent of Type III construction. This is relevant to Group B buildings as many are constructed using Type III.
• Previous Action: The committee disapproved the proposal, stating that it would make Type IIIA buildings too similar to Type VA buildings without sufficient justification and that the proposal focused too heavily on Group R occupancies.
• Recommendation: Codes staff recommend merely monitoring this comment. This comment does not appear to have any chance of passing, so there is no need to actively oppose it.

 
Proposal G130-25

• Proponent: David Tyree, representing the American Wood Council
• Description: This proposal would add concrete or gypsum concrete topping as an option for protecting combustible surfaces in concealed spaces within Type IV-HT construction. This could be relevant to certain Group B buildings that use mass timber construction.
• Previous Action: The committee disapproved the proposal, requesting further clarification on what is being protected within the concealed space. They also raised concerns about the potential for "ponding" of moisture between the topping and the combustible material.
• Recommendation: Codes staff recommend supporting this comment. This comment seems to address the Committee’s previous concerns, and it is not expected to be a controversial matter at the hearing.

 
Proposal G133-25

• Proponent: John Mengedoht, representing NBBJ
• Description: This proposal would permit combustible exterior soffit materials in Type I and Type II construction, provided they meet Class A fire safety criteria. The proponent noted that many code officials already permit this due to the similarity with interior finishes.
• Previous Action: The committee disapproved of the proposal. The committee noted that the material properties were not similar to other items on the list and raised concerns about combustibles within enclosed spaces. They also stated that while the proposal helps fill a gap in the code, the language needed refinement.
• Recommendation: Codes staff recommend monitoring this comment. Noncombustible materials would include steel and concrete, and the comment would possibly make roof repairs and reroofing less expensive.

 
Proposal S65-25

• Proponent: John Taecker, representing Taecker Codes & Technical Services
• Description: This proposal would add requirements for the seismic and wind design of distributed wind energy systems. While not directly related to occupancy, the structural integrity of these systems is a concern in any building where they are installed, including commercial office buildings.
• Previous Action: The committee approved the proposal, finding it a reasonable approach to address an emerging technology with minimal impact on cost and safety.
• Recommendation: Codes staff recommend monitoring this comment. Any BOMA members who have or are considering having wind turbines on their roofs, please contact Steve Dimino at sdimino@boma.org to ensure that your interests are properly represented at the hearing.

 
Proposal S153-25

• Proponent: Christopher Brunette, Colorado Division of Fire Prevention & Control
• Description: This proposal would allow the use of salvage sawn lumber in both structural and non-structural applications. The proposal outlines specific criteria for using salvage lumber, including freedom from decay and insect damage, and requires proof loading or visual inspection depending on whether the lumber has an existing grade mark.
• Previous Action: The committee disapproved the proposal, citing that relying solely on testing is unreasonable and not a one-size-fits-all solution. Concerns were raised about the limited availability of testing labs, and challenges in obtaining approval from building officials. The committee also stated that the proposal contained a significant amount of subjective language that needs revision.
• Recommendation: Codes staff recommend disapproving of this comment. The language in the comment is unenforceable, and the comment is very unlikely to receive support at the hearing.