The Building Code Council work group for economic impact reviewed proposed changes across multiple model codes on Aug. 25, 2025, flagged a set of proposals for additional economic analysis and agreed to circulate a targeted questionnaire to industry and stakeholder lists ahead of a planned CR-102 rule filing.
The work group, chaired by Todd Byerthu (work group member), focused discussion on whether proposed changes would increase or decrease construction and operating costs and which items warranted a more detailed small‑business economic impact statement. "If there's a cost decrease, we should include it in the statements as well and not just sweep it off our plate," Dustin (work group staff) said while describing the spreadsheet the group used to mark probable impacts.
Why it matters: the work group’s findings will feed the CR-102 (preproposal rule) package the Building Code Council intends to file; several items the group flagged could change costs for event venues, small contractors, mobile food businesses and some existing building owners. The group also discussed practical outreach logistics for the small‑business survey, including distribution via the Building Industry Association of Washington and government notification systems.
Most proposals reviewed were characterized in their submission documents as having "no cost" or being clarifying edits. The work group nonetheless highlighted a subset that warrant outreach or additional analysis, including a change to crowd‑manager thresholds in the International Fire Code (IFC), a proposed retroactive sprinkler trigger for bulk tire storage, revisions tied to snow‑load maps, embodied‑carbon and EV‑charging provisions, and several energy‑ and mechanical‑code references. Patrick Hanks, representative of the Building Industry Association of Washington, advised the group to distinguish items that are strictly cost‑benefit analysis matters from those requiring small‑business surveys for compliance or training costs: "If it's increasing the cost of construction, that's CBA related. If it's something that affects the small business economic impact statement — like training, compliance — that's something that will be survey related," Hanks said.
Discussion highlights
- IFC crowd managers: The work group reviewed a state amendment that would revert state language toward the model code’s 500‑person threshold and remove an explicit allowance for a fire code official to require crowd managers at lower attendance levels. Ken (fire official) warned the change removes the fire official’s ability to require crowd managers at lower attendance levels, while others noted lowering the threshold makes crowd managers mandatory in more situations. The committee discussed whether the net effect would increase mandatory costs for some venues and whether that potential labor cost could be disproportionate to certain small businesses. "What has really happened here is that we've deleted the opportunity for the fire code official to say, 'Hey, I think there needs to be a crowd manager,'" Ken said.
- Bulk storage of tires: The group flagged a proposal that changes the trigger language to focus on the actual aggregated volume of stored tires (20,000 cubic feet) rather than a building or room area. Work group members noted that while the revised chapter 903 language may reduce some costs, a new retrofit clause (1103.5.7) could require some existing facilities to install sprinklers, potentially creating costs well above the work group’s $100 minor‑cost threshold. "If you had an existing business and now you have to put a sprinkler system in, that is a significant increase," Ken said.
- Other items flagged: higher‑resolution snow‑load maps that could increase costs in some locations and decrease them in others; embodied‑carbon reporting and whole‑building life‑cycle proposals that could raise supply‑chain or compliance burdens for small firms; EV charging language and temporary structure load reductions; a fire barrier requirement for energy storage systems; and several mechanical and refrigerant standard updates that reviewers expect will be neutral or slightly reduce cost.
Directions and next steps
The group agreed to publish a questionnaire that lists the proposals and invites respondents to rate probable economic impact on a 1–5 scale, indicate affected industries and provide supporting comments. Todd Byerthu and Dustin will consolidate the group’s spreadsheet and the draft questionnaire. Patrick Hanks said two weeks to circulate and collect survey responses could be tight; staff and industry representatives discussed publication channels including the Building Industry Association mailing list, NAICS‑coded outreach, GovDelivery and other notices. The work group tentatively scheduled its next session for a Tuesday afternoon to finalize flagged items and the survey before broader distribution. "If we get something published and we've had at least this high level discussion between the tag chairs and all the interested parties, it's kind of the first step," Dwayne (work group member) said.
Meeting process notes: the work group adopted the meeting agenda and the minutes from the Aug. 18 meeting at the start of the session. No formal votes on code change proposals were taken; the group’s actions were to flag items for further economic outreach, to request staff produce a questionnaire, and to schedule continued review.
The group requested targeted input on which NAICS industries to include for each flagged proposal and agreed to prioritize outreach to construction‑related businesses and, where relevant, event, hospitality and mobile food industries. Staff will return a revised questionnaire and a consolidated list of flagged proposals to the work group at the next meeting.
The work group adjourned after about 1 hour and 36 minutes of discussion and plans to reconvene to finalize the questionnaire and review any additional tag‑level changes before the CR‑102 filing period.