Massachusetts recently adopted a new version of 527 CMR, The Massachusetts Comprehensive Fire Safety Code, incorporating the 2021 edition of NFPA 1 along with Massachusetts-specific amendments. These updates came into effect on December 9, 2022.

The adoption of the 2021 edition of NFPA 1 holds particular significance for laboratory buildings. Under the revised Massachusetts Fire Safety Code, Section 26.1.6.1.1 now mandates that building management companies maintain specific documentation. This includes current and accurate Hazardous Materials Inventory Statements (HMIS), Hazardous Material Compliance Strategy Reports (Building 414 Reports), and Tenant Laboratory Registration Compliance Reports (Tenant 414 Reports).

While such requirements were already in place in certain areas like Boston and more recently in Watertown, the updated Code now extends these obligations statewide. However, enforcement will be at the discretion of the local Authority Having Jurisdiction (AHJ) or the respective Fire Department.

Enforcement procedures for the updated Code are anticipated to vary across different cities and towns. Drawing from the models seen in Boston and Watertown, requirements in other Massachusetts municipalities are likely to involve the preparation of:

Building 414 Reports: These reports delineate criteria from Massachusetts Building Code (780 CMR) Section 414.1.3, establish a control area strategy, and clearly define hazardous material limitations for the relevant permit-associated space. Detailed information should include maximum allowable quantities (MAQ) of hazardous materials per control area and mandated fire protection features.

Tenant 414 Reports: Meeting the criteria of Massachusetts Fire Code (527 CMR) Chapters 26 and 60, these reports confirm hazardous materials compliance with the Fire Code and the building’s 414 Report. They should provide a comprehensive evaluation of laboratory operations, processes, and space-specific fire protection systems.

Hazardous Material Inventory Statements (HMIS): These necessitate the preparation of a thorough chemical inventory. Depending on the locality, each hazardous chemical entry may include its name and CAS number, physical state, International Building Code Hazard Classification, NFPA 30 classification for flammable and combustible liquids, NFPA 704 rating, and volume in storage and use (open and closed systems). Additionally, a summary report per control area is required, providing MAQ analysis to ensure specific area compliance.

In Massachusetts, local fire departments typically mandate that all documentation be either prepared by or reviewed by an approved and qualified third-party fire protection engineering firm.