# Presentation: 490266

## IBC / IFC Chapter 1Self-Assessment OverviewPresented at the DOE/Contractor Fire Protection Safety Workshop

- Perry D’Antonio, ManagerFire Protection & Electrical Engineering Department
- April 18, 2007

**Notes:**
PERRY

## Today’s Agenda

- Key Messages
- Self Assessment Drivers
- I-Code Background
- Team Charter & Assessment Results
- Team Recommendations

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY

## Key Messages

- The health of SNL’s CFPP has significantly improved over the last year
- The Model Building Codes (e.g., IBC, NFPA) have a Chapter 1 Administrative Section that describes how to use and enforce the Code
- SNL self assessment to Ch 1 identified a potential10 CFR 851 gap
- The I-Codes do not conflict with DOE Orders
- Following the I-Codes (Ch 1) can help SNL improve & demonstrate model contract compliance
- SNL’s Built Environment is substantially code-compliant but improvement opportunities exist!

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY
Socialize to communicate changes that would take place throughout the Lab
SSO and DOE Contractors not following Administration Section in total - need to understand how SSO views compliance with Chapter 1
Next Task Team (with SSO participation)
Socialize with Lab Leadership & SSO
Improvement Opportunities
Process streamlining
Customer service
Change control
Documentation
General understanding of R2A2s regarding code compliance

Model Contract: 
H-1 Clause – SSO defines the What, SNL does the how
H-3 Clause – Contractor Assurance System – risk based self-assessments, method for validating assurance process, continuous improvement
H-4 Clause – NNSA Oversight @ system level vs. at transactional level
H-5 Clause – Accountability – not have to rely on NNSA oversight for performance
H-6 Clause – Standards Management – ISO to replace DOE Requirements

## Today’s Agenda

- Key Messages
- Self Assessment Drivers
- I-Code Background
- Team Charter & Assessment Results
- Team Recommendations

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY

## Self-Assessment Drivers

- One year ago CFPP was in “*state of neglect*” per SSO, FY06 2nd Qtr PEP feedback
- 2006 improvements include:
- Responded to all 42 findings from 3 audits & 1 self assess
- Filled critical staffing positions (e.g., Fire Marshal, FPEs)
- Wrote new fire protection policy, program and procedures
- 2007 improvement goals:
- Rely more on self assessment program vs. audits
- Improve formality of operations aligned with model contract
- Earn credibility with SSO
- 10 CFR 851 references the Building Codes
- Initiated Task Team to assess compliance to Administration Sections, Ch 1 of IBC & IFC (“How-to” Manual)

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY
SSO grade went from “F” to strong B – still room for improvement
2006 improvements believed to be sufficient to meet 10 CFR 851 requirements, but there is still room for improvement
Initially 10 CFR 851 gaps tied to closing CAPs from 3 previous assessments; 

!0 CFR 851 reference to building codes raised questions on what this meant – discussion with SNL Fire Marshals indicated needed to understand how SNL processes compared to Administration Section of the I-Codes.

## Driver to Use IBC

- 10 CFR 851 Appendix A Part 2 (b)
- An acceptable fire protection program must include those fire protection criteria and procedures, analyses, hardware, and systems, apparatus and equipment, and personnel that would comprehensively ensure that the objective in paragraph 2(a) of this section is met. ***This includes meeting applicable ***_***building codes***_*** and National Fire Protection Association codes and standards (emphasis added)***
- 10 CFR 851 text in DOE Order 440.1A (1998)

- DOE/Contractor Fire Protection Workshop

**Notes:**
Perry
Rule text increases importance of full compliance with a Building Code.
No other DOE sites have full compliance.  
DOE Complex 1st.
Not in commercial sector.
This is a liability for DOE.

## Driver to Use IBC

- DOE Order 420.1B - ***must...meet or exceed applicable building codes for the region...***
- State of NM and the City of Albuquerque adopt IBC
- State of CA and City of Livermore will be using IBC (January 2008)
- Notes:
- States generally **modify** Model IBC to their use
- DOE O 420.1B requires use of Model with no relief granted to exclude any Chapters

- DOE/Contractor Fire Protection Workshop

**Notes:**
Perry

These other drivers have been there a long time.
What changed? (Nothing really), Issuance of Rule increased visibility.  FPEs have known there was a problem. Not sure what it was or a path forward. 
Hiring of Gordon (outside experience) created synergy with the opinion Marty was forming.  

Compliance/Implementation has always been incomplete.  We need a Program solution. More later.

## Other Drivers

- Public Law 104-113 – mandates Federal agencies use private voluntary standards to the extent feasible (DoD UFC driver)
- Local – SNL Corporate Fire Protection Program (CFPP) adopts model IBC for all SNL sites

- DOE/Contractor Fire Protection Workshop

**Notes:**
Perry

These other drivers have been there a long time.
What changed? (Nothing really), Issuance of Rule increased visibility.  FPEs have known there was a problem. Not sure what it was or a path forward. 
Hiring of Gordon (outside experience) created synergy with the opinion Marty was forming.  

Compliance/Implementation has always been incomplete.  We need a Program solution. More later.

## Today’s Agenda

- Key Messages
- Self Assessment Drivers
- I-Code Background
- Team Charter & Assessment Results
- Team Recommendations

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY

## Fire Protection Requirements

- Model Building Code & it’s required references describe **how** to meet minimum requirements

- Federal & StatutoryRequirements

- State Req’s

- HPR

- ModelBldgCode

- DOEOrders

- HPR is **added** to the min requirements via DOE Orders

- DOE Orders intended to be additive **not replace** the Model Bldg Code

- DOE/Contractor Fire Protection Workshop

## Two U.S. Building Code Sets

- I-Codes (International Code Council, formed in 1994 from the 3 Regional Model Code Groups)
- NFPA 5000 (National Fire Protection Association)
- Both codes have a similar mandatory Administrative Provisions, Chapter 1
- Ch 1 describes how to use and enforce code
- DOE Orders do not grant relief from following Ch 1
- DOE and their Contractors have not uniformly used the Administrative Provisions

- DOE/Contractor Fire Protection Workshop

**Notes:**
MARTY
SNL (and all of DOE) does not use codes correctly.  We fish for to topic at hand and don’t apply the entire code.
NFPA 5000/NFPA 1  Very few states and municipalities are using this. DOE O 420.1B Footnote - “The provisions of the applicable state/regional model building codes take precedence over NFPA 5000”. \
DEAR Clause , Federal Law  SNL Contract Section I #72 – Contractor shall comply with federal, state and local laws unless relief specifically granted.  (REQUIRES the USE OF THE I-CODES).
Note: 10 CFR 851 (pg. 6896): DOE agrees to remove NFPA 5000 from the final rule since several contractors adhere to IBC.

I Code set Most widely adopted and regularly updated. 
Each model code set has a mandatory Administrative Section that is very similar.

Pick One, Stick with it, Apply the whole thing. Do NOT FISH

## I-Code Adoption Map

- Green = I codes adopted statewide
- CA = Adopted but not yet enforced (Jan 2008)
- IBC = 47 States
- IFC = 42 States
- NFPA 5000 adopted 3 municipalities
- Orange = I Codes Adopted at local level

- DOE/Contractor Fire Protection Workshop

**Notes:**
MARTY
Green = I codes adopted statewide
CA = Adopted but not yet enforced (2008)
IBC = 47 States
IFC = 42 States
NFPA 5000 adopted 3 municipalities  
Orange = I Codes Adopted at local level.

## Why I-Code Adoption?

- I-Codes are most widely adopted nationally
- We gain from the existing body of expertise (regular update cycle)
- Efficient
- AEs & Const. contractors already use I-Codes (learning curve is less)
- Stops circular referencing
- Training - ICC has established certification program (ICC On-Line Campus)
- I-Codes are a Complete System
- Ch. 1 is the “how-to” Guide

- DOE/Contractor Fire Protection Workshop

**Notes:**
MARTY 
(e.g., most states, GSA, Veterans, NASA, DOD, Forest Service)

I-Codes are most widely adopted nationally
We gain from the existing body of expertise - NIH Not Invented Here. (200 years of cumulative experience)
I-Codes reference needed NFPA and other needed codes & standards - NO net loss of detail, safety or requirements 
Streamline - AEs & Const. contractors already use I-codes (no retraining for a SNL specific system); 
Note: ~75% of construction safety violations in 2005 attributable to non-compliance to SNL ES&H spec 01065 (message: there is a learning curve if SNL establishes unique requirements set)
ICC has established certification program (ICC On-Line Campus) e.g.:
Inspectors (SNL-NM requirement, CA-not there yet)
Building Officials (SNL-NM Fire Marshal is a CBO)
Fire Code Officials (site Fire Marshal @ SNL)

Regular update cycle (3 year) -References too

- Code Adoption Process Comparison

_**Municipal Model**_

_**DOE Model**_

- DOE/Contractor Fire Protection Workshop

**Notes:**
MARTY
DOE & Municipal processes are parallel.
Building code DOES work for un-common occupancies.
Building code is prescriptive for common occupancies but allows for performance based which is the Traditional approach to nuclear facilities in both DOE and NRC arenas.
No Fishing Allowed – Stay in SCOPE

## IBC Myths (examples)

- Myth: IBC isn’t a consensus-based process
- Fact:
- I-Codes are consensus-based with public input
- eligible technical voters are selected from the 3 prior regional code groups
- protects against special interest groups driving code requirements
- Myth: If we adopt IBC we’ll lose the NFPA Standards
- Fact: 2006 IBC required references includes:
- International Fire Code
- 84 specific NFPA docs referenced
- International Electric Code
- Basically the NEC (NFPA 70 & 70E)
- International Mechanical Code
- 16 specific NFPA docs referenced
- International Plumbing Code
- 4 specific NFPA docs referenced

- DOE/Contractor Fire Protection Workshop

## I-Code Set Works for ALL

- All common occupancies are addressed with ***prescriptive*** text
- Other (e.g., nuclear) occupancies are also addressed
- IFC 102.7 Subjects not regulated by this code
- IFC102.8 Matters not provided for
- IBC104.11 Alternative materials, design and methods of construction and equipment
- I-Codes allow use of DOE Orders and ***performance-based*** analysis (DSA/TSRs, FHA) for nuclear facilities in addition to I-Codes.
- The I-Codes **DO NOT** Conflict with DOE Orders
- Provides **structured approach** to meet 10 CFR 851.24

- DOE/Contractor Fire Protection Workshop

**Notes:**
MARTY
Points:
These sections allow using other documents (DOE orders etc) without discarding the rest of the I-Code set.  Much of it is still applicable.

## Today’s Agenda

- Key Messages
- Self Assessment Drivers
- I-Code Background
- Team Charter & Assessment Results
- Team Recommendations

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY

## Task Team

- Sponsors - Perry D’Antonio, John Garcia
- Team Members
- CA Site Fire Marshal - Marty Gresho, Team Lead
- NM Site Fire Marshal, Gordon Earhart
- System Engineering / Projects
- CA: Craig Taylor
- NM: Dave Bailey
- Inspection – David Gibson
-  Cross-Discipline Engineering Support
- Glen Argabright, Harry Gullett, Roy Hertweck, Gary Hoe, Steve James, Shelley Whitener

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY
Glen Argabright, 10861, (Fire Protection)
Harry Gullett, 10873, (Facilities Ops)
Roy Hertweck, 10853, Planning (Site Level)
Gary Hoe, 10864, (Standards)
Steve James, 10863, Architect (Bldg Level)
Shelley Whitener, 10864, (Maintenance)

## Task Team Charter

- Review the requirements of IBC/IFC Administrative Sections, Chapter 1
- Intelligent application of code intent to take advantage of existing capabilities and processes
- Not intended to make large perturbations without appropriate justification / value
- Deliverables
- Perform gap analysis
- Prepare recommendations for improving CFPP
- Define potential 10 CFR 851 gaps

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY
and compare/contrast them to SNL practices, policies and procedures

## Gap Analysis Methodology

- Team telecon meetings every other Friday for 4 hours, beginning in October
- Walkdown of each section in IBC / IFC Administration Chapter 1
- IBC Focus: construction & modifications
- IFC Focus: operations
- Identified gaps versus existing Program
- Categorized Gaps

- DOE/Contractor Fire Protection Workshop

**Notes:**
DAVID

- Briefly cover this Slide

## Gap Categories & Examples

- Policy (2)
- Formally adopt IBC for all SNL sites
- Organizational Structure (44)
- Emulate a Dept. of Bldg Safety/Fire Prevention that mirrors Ch.1 requirements
- Provide adequate resources & establish Authority, Responsibility and Limitations of Building Official/Fire Official
- Processes & Procedures (150)
- Plan reviews, *permits*, inspections, etc.
- Board of Appeals

- DOE/Contractor Fire Protection Workshop

**Notes:**
DAVID
Pyramid – Visual Illustration of how the Gaps Categories relate to each other.  Redundancy of Gaps (IBC+IFC)...don’t allow number of gaps to bog presentation down. 
Policy (2)
ID IBC as THE Code site-wide.
Organizational Structure (44)
Establish dedicated, independent code enforcement organization per Chap. 1.
Emulate a Dept. of Bldg Safety/Fire Prevention that mirrors Ch.1 requirements.
Establish Authority, responsibility and limitations of Building Official/Fire Official.
Provide adequate resources & authority for successful enforcement operations. 
Procedures / Processes (150)
Board of Appeals, plan reviews, permits, etc.

## Initial Actions - Examples

- Policy
- Reference IBC in ES&H Manual
- Communicate IBC concepts to MOW
- Organizational Structure
- Formalize & communicate delegation of authority for building official/fire code official, etc. into SNL system
- Formalize enforcement role of inspectors and building official/fire code official

- DOE/Contractor Fire Protection Workshop

**Notes:**
DAVID

Identify I-Codes as code set for SNL Sites
Policy
    Concept
	- I-Code is baseline and other codes/orders referenced in to address special conditions not covered by IBC
	-This concept is fundamentally different than what I understood prior to working on this task team
Organizational Structure
	-Expand AP-220 to document formal delegations of authority and enforcement role of Inspectors/Building 	  	 Official/Fire Code Official

## Initial Actions - Examples

- Processes & Procedures
- Establish comprehensive permit program
- Get *knowledgeable code experts* involved
- Permits document compliance
- Formalize enforcement roles & responsibilities
- Existing processes developed w/o IBC
- Validate compliance through inspection
- Utilize existing processes as much as possible (e.g. PHS process, outage process, plan reviews, etc.)

- DOE/Contractor Fire Protection Workshop

**Notes:**
DAVID

Points: Need a total system approach. We have some ES&H permits (e.g., hot work, confined space, excavation, penetration); but have risk regarding hazardous chemical use and storage
Permits provide auditable demonstration of performance in accordance with model contract requirements.
Section H-3 of contract which requires us to perform self assessments.
Existing processes were developed without looking at IBC/IFC.  Need to fix that.
Operational permits is the most likely to provide immediate and positive results.
Latent vs Active risks

## Today’s Agenda

- Key Messages
- Self Assessment Drivers
- I-Code Background
- Team Charter & Assessment Results
- Team Recommendations

- DOE/Contractor Fire Protection Workshop

**Notes:**
PERRY

## Team Recommendations (1 of 3)

- SNL Champion Actions
- If recommended path forward is acceptable, agree to form a team to develop plans for implementing I-Codes
- Procure outside help in early planning stages
- Communicate path forward to SSO & MOW (unified voice & multiple channels)

- DOE/Contractor Fire Protection Workshop

**Notes:**
David
Champion Actions

This briefing would serve as the common message to all MOW and SSO
Refer to IBTS Slides for more details about outside help in early planning stages.

## Team Recommendations (2 of 3)

- Fire Protection Program Manager Actions
- Work with SSO to validate 10 CFR 851 gap
- Commission Implementation Team to address path forward for other gaps
- Communicate IBC approach to SSO & DOE Fire Protection Safety Community
- Develop SNL version of I-Code Admin structure & functions maximizing use of existing processes
- Independence
- Authority
- Unencumbered access (accountable to) to Director Level Champion

- DOE/Contractor Fire Protection Workshop

**Notes:**
DAVID

Perry’s Actions
Gap is that we are not fully implementing Ch 1 Administration Correctly.  
	-the "threshold of concern"  that 10 CFR 851 is intended to addresses is greater than any gap we've identified 	 during our gap analysis 

Perception within the SSO & DOE community that adoption of I-Codes will compromise integrity of DOE complex requirements. 

Emulate Dept. of Bldg. Safety/Fire Prevention

## Team Recommendations (3 of 3)

- (New) Implementation Team(s) Actions
- Develop an implementation plan for IBC Chapter 1 inline with ICC accreditation criteria
- Supplement Team with established consultants for specific tasks (e.g., to develop permit process)
- Provide Training/Qualifications Plan
- Enforcement Agents: Inspectors, Building Officials, etc.
- Develop Implementation Options
- Invent in house
- Out Task - Hire consultant to train us
- Out Source - Surrender to City

- DOE/Contractor Fire Protection Workshop

**Notes:**
David

I-Code Implementation Team Actions

## Summary

- One Potential 10CFR851 Gap – IBC Chapter 1
- Ch 1 will improve our contractor assurance system & reduce the latent risk in our system
- Need Upper Management Champions to pass the word down to the line and help get SSO buy-in
- Long-Term Commitment - Not an overnight fix
- SNL’s Built Environment is substantially code-compliant. But Improvement opportunities exist:
- Process streamlining
- Customer service
- Change control
- Documentation
- General understanding of R2A2s regarding code compliance

- DOE/Contractor Fire Protection Workshop

**Notes:**
DAVID
1 Gap – 
None of the DOE sites are applying Ch 1 in its entirety.
Must pick one set and follow it (start at the top and drill down) to where it addresses the issue du’ jour.
Must NOT look for ANY code or standards requirement that support a desired position related to the issue du jour.  FISHING
We now have Dan Pellegrino, SSO buy-in to IBC

## Questions?

- Perry D’Antonio
- 505-844-7956
- pedanto@sandia.gov

## Backup Slides

## Gap Analysis Results

- IBC Chapter 1
- 112 Code Sections/Requirements
-   74 Identified Gaps
- IFC Chapter 1
- 161 Code Sections/Requirements
-   98 Identified Gaps

- DOE/Contractor Fire Protection Workshop

## Slide 32

| IBC CH 1-ADMINISTRATION | # Sections | # Gaps | IFC CH 1 ADMINISTRATION | # Sections | # Gaps |
| --- | --- | --- | --- | --- | --- |
| 101 General | 12 | 3 | 101 General | 6 | 1 |
| 102 Applicability | 6 | 3 | 102 Applicability | 9 | 5 |
| 103 Dept.of Bldg Safety | 3 | 1 | 103 Dept of Fire Prevention | 5 | 1 |
| 104 Duties & Powers of Building Official | 14 | 9 | 104 General Authority & Responsibilities | 22 | 10 |
| 105 Permits | 14 | 13 | 105 Permits | 86 | 68 |
| 106 Construction Documents | 15 | 6 | 106 Inspections | 4 | 2 |
| 107 Temporary Structures & Use | 4 | 4 | 107 Maintenance | 8 | 1 |
| 108 Fees | 6 | 4 | 108 Board of Appeals | 3 | 3 |
| 109 Inspections | 16 | 13 | 109 Violations | 8 | 2 |
| 110 Certificate of Occupancy | 4 | 4 | 110 Unsafe Buildings | 6 | 3 |
| 111 Service Utilities | 3 | 3 | 111 Stop Work Order | 4 | 2 |
| 112 Board of Appeals | 3 | 3 | TOTALs | 161 | 98 |
| 113 Violations | 4 | 2 | DoD Excluded Sections, includes 101.4.1 Int’l Electric Code, 
101.4.5 Int’l Property Maintenance Code, and 101.4.6 Int’l Fire Code |  |  |
| 114 Stop Work Order | 3 | 1 |  |  |  |
| 115 Unsafe Structures & Equipment | 5 | 5 |  |  |  |
| TOTALs | 112 | 74 |  |  |  |

- DOE/Contractor Fire Protection Workshop

**Notes:**
Point: Each section of the IBC/IFC CH 1 was reviewed and compared to existing SNL policy/processes. All gaps were identified no matter how significant.

## Department of Building Safety

- Plan/Zoning Review

- Design Review

- Construction Permit

- QA Comments

- Certificate of Occupancy

- Code Inspection

- Inspection Punchlist

- Use Permit (TTO)

- Operational Permits

- Contract Close-out

- Fire Marshal / AHJ
- Fire Code Official (Deputy AHJ Customer Funded)
- Inspectors (Deputy AHJ FE)

- SCR / SDR (Deputy AHJ)PM / BMT/ SME
- Standards / Specs
- Inspectors

- Board of Appeals

- Building Official(AHJ – Line Items, IGPP)

- Code Enforcement

- Project Acceptance

**Big Gap**

**Small Gap**

**Department of Building Safety**

- Projects

- DOE/Contractor Fire Protection Workshop

## Associated Benefits

- Contractor Assurance
- Self Regulating
- XFORMATION team
- to 2008 and beyond!
- Credibility w/DOE
- DOE Complex 1st
- ICC has an accreditation process

- DOE/Contractor Fire Protection Workshop