Monday, May 2, 2016

Why Your Code Change Proposal Was Disapproved

I am just returning home and getting back into the swing of things.  I spent last week in Louisville, Kentucky serving on the International Fire Code (IFC) Development Committee. One of the main benefits of committee involvement is the opportunity to understand why code changes are being proposed, the history behind these code changes, and the potential impacts that the current and proposed changes may have.

It is the committee's responsibility to hear each proposal and decide to approve the proposal as submitted, approve the proposal with a modification, or disapprove the proposed code change. This cycle the committee heard more than 400 proposals. Of these, nearly 200 were moved for disapproval.  Proposals can be disapproved for a variety of reasons. However, examining my notes from the hearings, there are 6 primary reasons that a code change proposals was disapproved.

1.  Proponent is not available to speak on the proposal.

A code change proposal submitter or proponent is not required to be present.  The purpose of the code change proposal should be clear and evident based on the proponents required 'reason statement'. However, if their are questions regarding the proposal, or something is not understood, it is helpful if there is someone available to answer the committee's questions or concerns.  Statements and responses made by the proponents (or opponents) are instrumental in influencing the committees decision on these proposed code changes.

2.  Poor code language.

The specific wording of code change proposals plays a critical role in its approval or disapproval.  Proposals that are disapproved for 'poor code language' includes wording that falls into one of these categories:
  • Open to misinterpretation
  • Not able to be enforced
  • Uses terminology that is not in the code, not clearly defined, or that conflicts with other terms in the code or referenced standards
  • The wording is confusing to read, hard to understand, or illogical
  • The wrong code or standard is referenced
  • The intent is not understood
  • The proposed code change is being added to the wrong section of the code.

3.  Lack of reliable data and/or facts to substantiate reasoning.

A good code change proposal will be accompanied by hard facts and historical evidence as to its need.  The facts and data should also show how the code change proposal, if approved, will result in the improvements intended.  Those code change proposals that are arbitrarily submitted, and lack sufficient data, are most likely to be disapproved.

4.  Effects of the code change would be too broad.

The proposal, though creating a fix in one area, may create a problem in several other areas.  Those proposals that apply to a large variety of occupancies, industries, processes, or materials may be disapproved, as the effects are so far reaching that the negative or positive consequences cannot be readily distinguished. Successful proposals are structured to effect only the intended concern.  If the proposal is intended to be broad, multiple proposals targeted at each concern should be submitted.

5.  Violates requirements and provisions outlined in CP #28-05.

This is the ICC Council Policy on code development. Of importance to those submitting code change proposals are the sections that outline specific requirements regarding how code change proposals are to be submitted, and the section that describes what types of codes and standards can be referenced.  As a submitter, be sure that you understand these council policies, and that your proposal does not violate these requirements.

6.  New technology that has not been vetted.

With the rapidity of change and technology development that is currently happening in our world, it is impossible to be fully knowledgeable on all things. New technologies, techniques, and processes, may require and benefit from specific code inclusions.  Committee members may not be aware of, or may be seeing, the technology for the first time in your proposal.  If the technology is not understood, the effects of the code change proposal cannot be realized. Education should be critical component of the submitter's reason statement and testimony. A strategy that involves educational outreach in advance of the committee hearings should be considered.

When submitting code changes, or recovering from a 'disapproval', review your written proposal, and presentation strategy for these 6 items.  Use this as a checklist to help you write a winning code change proposal!