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Council declines emergency finding for 2024 IMC petition, directs staff to include A2L language in CR102
Summary
The council denied an emergency petition for the 2024 International Mechanical Code language but voted to include the A2L refrigerant proposal in the CR102 filing for the 2024 code so it will receive public comment during the 2024 code package rulemaking.
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The Washington State Building Code Council on Oct. 17 declined to find an emergency basis for a petition that would update proposed 2024 International Mechanical Code (IMC) language related to A2L refrigerants, but the council directed staff to include updated petition language in the CR102 filing for the 2024 IMC so the change will go out for public comment.
Council staff and counsel explained that an emergency finding for a code that has not yet been adopted is difficult to justify administratively and could create confusing implementation dates. Staff recommended handling the matter through the CR102 comment process after the CR101/CR102 filing for the 2024 package. Proponents and several council members said they preferred a transparent path that would let the community comment on the updated text.
After discussion, Councilmember Kjell Anderson moved that the council not find an emergency for the 2024 petition; that motion was seconded and carried. The council then voted (motion by Councilmember Jay Arnold, seconded by Tom Handy) to include the A2L petition language in the CR102 filing for the 2024 IMC. The verbal vote on the CR102 motion was recorded as unanimously in favor in the meeting transcript, and staff said they would amend the CR102 to include the proposed language.
Why it matters: Staff and council members said adopting the update through the 2024 code package (CR102) gives the public the fullest opportunity to review changes and for the council to consider any late adjustments to ASHRAE addenda. At the same time, the council acknowledged the practical challenge: jurisdictions and industry want consistent language between the currently effective 2021 code (now updated by emergency amendment) and the upcoming 2024 code.
What to expect: Council staff will include the updated A2L proposal in the 2024 CR102 filing for the IMC, publish it for public comment, and then the council will consider comments during the next rulemaking steps. The petition proponent was informed that public comments, expedited rulemaking, or an emergency petition remain possible pathways if needed.
Attribution: Quotations and votes come from the Oct. 17 meeting transcript.

