Disclaimer: The answers below are staff opinions only and not official interpretations by the Board of Building Regulations and Standards .


Using this File:  Click on a question below to get the answer.


1.00 Administration

2.00 Definitions

3.00 Building Planning

(Also see Appendix J - Existing Buildings, below)


4.00 Foundations

8.00 Roof-Ceiling Construction

10.00 Chimneys and Fireplaces


  • 12.00 Mechanical Administration

  • To replace a furnace in the basement of an existing building, located in a flood zone, where must the new furnace be located?
  • 14.00 Heating and Cooling Equipment

  • I would like to purchase a new heating system. How do I know if the product complies with the Building Code?
  • Appendix J Existing Dwellings

  • Are fire sprinklers required when renovating and existing dwelling?
  • Additions and replacement windows: Where do I find the code requirements for additions and replacement windows?
  • Sunroom glazing and wall bracing: Must glazing used for sunrooms and three season porches meet the requirements of R301.2.1.2 , Protection of openings?
  • Duct Testing: Is duct leakage testing required on new duct runs in existing building projects?
  • Answers

    1.00 Administration

    Q: Can a building official grant code modifications? One could interpret Section R104.10.2 to give a building official a wide breadth of authority to grant modifications to the code. Can you provide some guidance on how this section applies?

    A. This section should be used by a building official only in situations that do not lessen health, life, fire safety, structural or energy conservation requirements. This section may apply where say the addition of habitable space in an existing basement is proposed. If a small area of the basement is slightly (about 1 inch) below the minimum height of 6' 8" and if hardship is involved to change it, then the building official may use Section R104.10.2 to allow the modification. So for issues associated with tolerances, this section allows the building official to make slight modifications to the code but still stay with its intent.

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    Q. What projects require a building permit?

    A:Most, but not all, projects require a building permit. For guidance see the following table: Work Requiring HIC or CSL July 1, 2009 doc format of inf_bbrs_work_requiring_hic_csl.doc

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  • Q. Permits for pools: Is a permit required for prefabricated pools?

    A.  Per Section R105.2, no, if the water fill-line for the pool per the manufactures specifications is less than 24 inches. And yes, if the water fill-line for the pool is greater than or equal to 24 inches. If a permit is required please note that the barrier requirements of Appendix G, Section AG105 apply. 

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  • Q: What information is typically required on a Building Permit?
  • A: The standard State building permit application form for One- and Two-Family Dwellings can be found at this link BP Application for One and Two Family Dwellings Final pdf format of appl_bp_ application_for_one_or_two_family_dwellin
(52kb). Municipalities may have their own particular forms but their forms must contain at least all the information that the standard State form has.

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  • Q. Lack of maintenance.  What section(s) of the 8th edition can a building official use to cite an owner for lack of building or structure maintenance?


    In the residential volume either of at least two sections concern maintenance including:

    • R102.7.3 Laws Not in Existence,
    • R104.10.2 Matters Not Provided For,

    In the base volume either of at least two sections concern maintenance including:

    • 102.6.1 Laws in Effect,
    • 104.10.2 Matters Not Provided For,

    Fire protection system installation and maintenance requirements are typically found in the building code-referenced Fire Protection Standards.  Maintenance of HVAC equipment is often found in the manufacturer’s instructions or in applicable MA specialized codes.

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  • Q:  Can the requirements of NFPA 101 supersede those of 780 CMR?

    A:  No. NFPA 101 is not a referenced standard in 780 CMR and as such is not listed in Chapter 35. Therefore whenever NFPA 101 is referenced elsewhere for a particular requirement, exception, or other, as is done in the NFPA 13 standards, the reader may ignore the reference. This may be done even if the requirement in NFPA 101 is more stringent than the same or similar requirement in 780 CMR.

    Q: Who enforces the code? Who enforces the State Building Code on behalf of the Commonwealth?

    A. The Commonwealth employs approximately 14 state building inspectors who enforce provisions of the code for state owned and/or operated buildings. Municipal inspectors (employed by each city or town) enforce the code relative to all other buildings in their municipality. 

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  • Q. Permits for weatherization work: Is a building permit required for weatherization work?

    A. Yes, if the building thermal envelope is altered; like insulation blown into wall cavities or insulation installed in the ceiling of a basement or in an attic. No, if the work is maintenance or repair; like caulk or foam applied for air sealing and the building thermal envelope is not altered.  The permit shall be pulled by an individual with a construction supervisor license (CSL) or insulation CSL (ICSL). If the work is being done on a one- or two-family home, an individual with a one- and two-family dwelling CSL may also pull the permit. Note, a homeowner of a one- or two-family dwelling may choose to pull the permit using an exception (see 110.R5.1.3.1) to the CSL requirements.

    Q. HIC and weatherization work: Is a Home Improvement Contractor registration required for weatherization work?

    A. The Department of Public Safety no longer administers this program so inquiries on the question should be directed to www.mass.gov/oca.  Also, M.G.L. c. 142A s.14 addresses certain exceptions to the HIC program. 

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  • Q: As a CSL, do I need a HIC? If I have an unrestricted Construction Supervisor License (CSL) do I need to be registered as a Home Improvement Contractor (HIC) for example to add a deck to a 2-Family owner occupied house?

    A: You need to submit the HIC application form in order to pay into the guaranty fund since the work is on an owner occupied dwelling.  See www.mass.gov/oca for more HIC information.

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    Q:Does an Unrestricted CSL cover the new specialty license categories? I presently have an Unrestricted Construction Supervisor License (CSL). Does that license cover the new CSL specialty license categories?

    A. Yes

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    Q: CSL or HIC?  Do I need a CSL or HIC to work on existing owner occupied houses with 1- to 4-dwelling units?

    A: Click on this link Work Requiring HIC or CSL July 1, 2009 doc format of inf_bbrs_work_requiring_hic_csl.doc
(127kb) for guidance on what work requires a Home Improvement Contractor (HIC) Registration or Construction Supervisor License (CSL) for existing owner occupied 1- to 4-family dwellings.

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    Q: Do the new CSL Specialty Licenses for Roofing and Windows/Siding permit structural work relative to roofing, windows/siding?

    A: No, except as follows:

    • For Roofing: Work may include sheathing repair/replacement of up to 25% of the gross roof area and sistering 25% of the gross number of rafters in the roof.
    • For Windows and Siding: Work may include sheathing repair/replacement of up to 25% of the gross house exterior wall area and replacing damaged framing in window and door rough openings up to four feet wide

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    Q: Do the new CSL Specialty Licenses only cover work formerly covered by a Home Improvement Contractor (HIC) Registration?

    A: The HIC Registration covered work on owner occupied dwellings of up to four units. The new CSL Specialty Licenses allow work on any type of structure up to 35,000 cubic feet, similar to the existing Restricted and Unrestricted CSL's. Note 35,000 cubic feet is roughly equivalent to a 3500 square foot home or business.

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    Q: Do I need the new CSL Specialty Licenses for Solid Fuel Burning Appliance to repair and service such appliances?

    A: No. A license is not required to repair or service the appliance, only. However, a license is required for the installation of the appliance.

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    Q: Does the Building Code have any language on warranties for construction work?

    A: No. Language on warranties implied or otherwise, is not found in the building code. However, warranty language may be part of the contract documents between the contractor and owner (see for example Massachusetts General Law Chapter 142A. REGULATION OF HOME IMPROVEMENT CONTRACTORS, Section 2, Residential contracting agreements; requirements, item number (8): http://www.mass.gov/legis/laws/mgl/142a-2.htm

    Q. Chimney Lining/CSL/Permit: Is a permit and construction supervisor license (CSL) required to install a chimney liner?

    A. Yes. A permit and a license are required to install a chimney liner. The permit applicant must hold an unrestricted, restricted CSL, or a ‘specialty’ CSL in either Solid Fuel Burning Appliance Installation or Masonry.  However, for projects where only oil heating system work is being done, some municipalities may issue a permit to a holder of an oil burner technician license. For a project involving gas fired appliances a plumber/gas fitter license is required for the installation of the liner.

  • Q. Document retention: As the municipal building official, I receive building permits, plans, construction documents or other.  What are the retention requirements for documents submitted in electronic format?

  • A. The Secretary of State sets the requirements for document retention for municipalities which are found in the Municipal Records Retention Manual. This manual contains information including, but not limited to, storage methods and time duration. In particular it contains a bulletin BACKING UP AND ARCHIVING OF ELECTRONIC RECORDS’ with additional information specific to your question.

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    2.00 Definitions

    Q: What is the change for wind borne debris regions? I understand that the BBRS has added some clarity to the definition of Wind Borne Debris Regions. Can you tell me where this can be found?

    A.  The MA definition is found in section R202 of MA Amendments to IRC 2009 .   Per the modified definition, a survey of the building site may be necessary in some cases to determine if a new home is in a wind borne debris region. But in those cases where a structure is clearly within, or outside of, a wind borne debris region a survey is not required.

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    Q: What is the difference between habitable space and living space?

    A: Chapter R2.00 definitions indicate that living space is greater than habitable space.  Section R304 Minimum Room Areas describes how to calculate habitable space for rooms with sloping ceilings.

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    3.00 Building Planning

  • Q. Hurricane prone wind region: When do the design criteria of section R301.2.1.1 apply?

    A. Only in cities or towns where the wind speed is 110 mph or greater, consistent with the requirements of the 7th edition of the code. BBRS approved a code change, which is in process of promulgation, to clarify this. Additionally, the BBRS approved the following official interpretation at its May 2011 meeting:

    “BBRS approved an official interpretation of the 8th edition Residential Code to clarify that the hurricane prone region in MA, as it pertains to this code, is defined as those municipalities with wind speeds of 110 mph.”

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    Q: Can the WFCM be used for building a house in a 110 mph wind zone? I understand if a new home is built in a town in a 110 mph wind zone then the American Forest and Paper Association (AF&PA) Wood Frame Construction Manual can be used to prescriptively design it. I also understand that in some cases the home can be framed per the WFCM 100 mph Guide, if it meets certain requirements including but not limited to aspect ratio, roof height, number of stories, and exposure category (B). I heard that Massachusetts has a modified ( WFCM Guide) checklist that can be used instead of the checklist at the end of the Guide. Is this true and what can you tell me about this modified checklist?

    A:You are correct on the items that you have noted. MA has modified the checklist in several important ways. See www.mass.gov/dps. The MA version allows a roof with a pitch up to and including 8 in 12 to not be "counted" as a story. Further it does not require steel hold downs and straps in many locations if full height sheathing is used as defined in the MA checklist. Further, if the building will have furring strips installed in the ceiling abutting the gable wall then 2 x 4s installed on top of the ceiling joists are not required. There are other changes as well that were not noted here.

    The MA version of the checklist was formulated in recognition of the highly regarded framing methods used in MA for many years and wood framing that has been used in North Carolina over the past 10 to 15 years which has performed well in severe hurricane weather in that state.

  • Q: Are listed, rated shuttering systems allowed as an acceptable method for protecting glazed openings from wind borne debris?

    A: Yes, R301.2.1.2 addresses glazed opening protection for wind borne debris and requires that glazed openings meet the requirements of the Large Missile Test of ASTM E 1996 and of ASTM E 1886.  Note, there is an exception that wood structural panels of a certain thickness and maximum span are also acceptable for such opening protection.

    Where listed shuttering systems are manufactured to meet the requirements of the Large Missile Test of ASTM E 1996 and of ASTM E 1886. The shutter systems should provide the same level of protection as a rated, glazed window system.

  • Q. Wind borne debris – new v exist. bldgs.: My property is in a wind borne debris region. Do window and door openings need to be protected from wind borne debris per Section R301.2.1.2?

    A.  Yes, but only in the construction of a new building. This requirement does not apply for replacement windows or for additions, unless the addition is structurally independent from the main building. This requirement also does not apply to an existing building that undergoes a complete gut renovation. 

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  • Q.Is roofing and siding considered ordinary repair work?

    A. In general, full roof or siding work is not a "repair". A permit is required except for repairs of a relatively small area of a roof or siding. Further, if this siding replacement or re-roofing is not done properly it could impact the "energy conservation system" or "public health" of the building occupants. However on this same subject, there may be cases where a Building Official may not require a permit because of the limited risk to public health, etc. for example, roofing or siding of an accessory structure.

  • Q:Is a removable sash considered an emergency escape/rescue opening?

    A. No. See section R310.1.4 which requires that 'openings be operational from the inside of the room without the use of keys, tools or special knowledge.

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    Q: Do I need landings at all doors? I have a primary egress of 3' at the front of home and 2'-8" at the back. That would make my 2'-8" door to the garage not counted toward egress and therefore a landing would not be required in the garage as long as the door swings into the home. Is that correct?

    A. Please see Section R311.3 Floors and landings at exterior doors.  A landing may not be required if the door is not a required exit door.

  • Q. Means of Egress:Does Section R311.1 require two stairways to the second and /or third floors of a one- or two-family dwelling?

    A. No. The MA requirement that governs this reads: “All dwellings shall be provided with two means of egress as provided in this section. The means of egress shall provide a continuous and unobstructed path of vertical and horizontal egress travel from all portions of the dwelling to the exterior of the dwelling at the required egress doors…”

    This requirement does not necessarily preclude that each means of egress path follow a common stairway on the way to exit from the building. If the requirement was to have two stairways serving the upper floor(s) then words like “separate” and “independent” would have been used.  

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    Q: Can I penetrate a fire rated ceiling with recessed lighting using R302.4.2 membrane penetrations? If installing recessed lighting in the ceiling of the kitchen on the first floor of an up/down two-family dwelling and if each light box is less than 16 square inches can I install six of them (96 square inches total) in this kitchen which has a ceiling area greater than 100 square feet?

    A. No.  Section R302.4.2 does not apply to ceiling penetrations. Therefore you must either use a listed (rated) recessed light or build a fire rated box for each fixture. If a listed light is used then "the penetration shall be installed as tested in the approved fire-resistance-rated assembly". In either case the installation has to ensure that the required fire resistance of the floor/ceiling assembly is not reduced.


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    Q:How is the area of rooms with knee walls calculated?

    A: R304 Minimum Room Areas has some language on how to calculate habitable space with rooms which have sloping ceilings.

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    Q: Can pull-down stairs be installed in the ceiling of a garage to access storage above?

    A: Generally this can be done as long as the opening for the stairs maintains the fire resistance of the ceiling. This can be done in possibly several ways, two of which may be: 1) spray with intumescent* paint the exposed surfaces of the stair system in its retracted position or 2) install a fire rated pull-down stair system.

    (*a material that swells and chars when exposed to flame and that forms an insulating fire-retardant barrier between the flame and material)

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    Q: Does the MA code require the landing on the exterior side of the required exit doors of a home to be no more than 1 ½ inches below the threshold?

    A: No.  An exception to Section R311.3.1 allows a step down as long as the door swings inward.

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    Q: If a basement contains a sleeping room and other habitable space, does an emergency escape and rescue opening in the sleeping room satisfy the requirement for the other habitable space in the basement?

    A: Yes. The second sentence of R310.1 provides guidance on this. Basement sleeping rooms need direct access to an emergency and escape and rescue opening within said sleeping room. However, if a basement had one sleeping room and some habitable space, the  opening within the bedroom would satisfy the requirement for the entire basement.

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    Q: If a basement contains habitable and unfinished space would the emergency escape and rescue opening have to be located in the habitable space portion of the basement?

    A: No. The code requires that each basement sleeping room has access to an exterior window or exterior door directly from them, without traveling through other adjoining or intervening spaces. Other habitable spaces in the basements of dwelling units can have the required exterior windows or exterior doors located anywhere. Since other habitable spaces are not bedrooms or sleeping areas, the fire awareness times and evacuation times should not be as significant. Therefore, the occupants can travel to other portions of the basements to access the exterior windows and exterior doors (including bulkheads per R310.3).

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    Q. Can spray foam insulation be left uncovered in basements?

    A: No, in most cases. Refer to Section R316 Foam Plastic for the provisions that govern the requirements and uses of this product.

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    Q: Can you answer several questions on the MA Checklist and the 110 mph Guide?

    Q1: How should the MA Checklist for the 110 mph Guide be used?

    A1: The 110 mph Guide is a prescriptive method for wood framing a one- or two-story dwelling in a 110 mph wind zone. The MA checklist  can be used in place of the checklist on pages 27 and 28 of the 110 mph Guide. The guide can be viewed or downloaded at http://awc.org/pdf/WFCM_110-B-Guide.pdf.

    Q2: Does the MA Checklist for the 110 mph Guide need to be met in its entirety to comply with the building code?

    A2: Yes. The MA Checklist , along with the 110 mph Guide, is meant to be a prescriptive compliance "package" for framing a one- or two-story dwelling in a 110 mph wind zone.

    Q3: If the 110 mph Guide and MA Checklist requirements are met, does this serve as a prescriptive means of meeting the requirements of the MA State Building Code?

    A3: Yes, and the construction drawings do not need to be certified by a registered engineer or architect unless special design issues are present (design of structural steel beams, etc.)

    Q4: Can the 5% additional full height sheathing requirement apply to wall lines with garage doors?

    A4: Yes.

    Q5: Can APA Narrow Wall Bracing be allowed to satisfy bracing for a garage door in a detached garage for example?

    A5: Yes, refer to the APA-The Engineered Wood Association website on bracing www.apawood.org/bracing then register and view or download Whole House Wall Bracing (PDF 2.2 MB, free download).

    Q6: Are windows allowed in an exterior wall where the stairwell opening is within two feet of this wall?

    A6: Yes, as long as the requirement for full height studs is met (see page 10 of the Guide).

    Q7: For a lateral addition does the aspect ratio, and other restrictions on the use of the 110 mph Guide, pertain to the entire dwelling or just the addition.

    A7: The addition only.

    Q8: Can you add some clarity for sheathing nailing per the 110 mph Guide for both a one- or two-story dwelling?

    A8: The MA Checklist provides an attachment detail for full height sheathing. Based on input the BBRS staff has received from AF&PA, MA builders, and design professionals, an acceptable alternate attachment detail for full-height sheathing is provided for both a one story 1-STORY WSP Nailing pdf format of inf_bbrs_1_story_wsp_nailing.pdf
(164kb) and two-story dwelling 2-STORY WSP Nailing pdf format of inf_bbrs_2_story_wsp_nailing.pdf

    Q9: If building plans, which are approved and stamped by a MA registered engineer or architect, are submitted does the MA Checklist need to be filled out as well?

    A9: No. If the building plans define the wood framing requirements, with no reference to the Guide, then the MA Checklist is not required.

    Q10: A contractor generated building plans using the Guide and MA Checklist and had a component of the building designed and stamped by an engineer. Are these plans allowed?

    A10: Yes. If the general framing requirements comply with the MA Checklist and a component is engineered, then this falls within the intent of the code. Several examples of building components are headers, or floor or roof support beam(s) and girder(s).


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    Q: Are ground snow loads used directly as roof snow loads?

    A: No. For  conventional construction, the residential code provides a prescriptive (using figures and tables) method to determine roof member sizes. The roof snow loads used to develop these tables are derived from ground snow loads.

    Design of non-conventional framing or structures using the Residential code requires a registered professional. The professional must use snow loads found in R301.2(5) and use accepted engineering practice as per R301.1.3, such as ASCE-7 methods.

    For example, using ASCE-7 to find roof snow loadings, the professional must use the ground snow load from the table R301.2(5) and apply appropriate factors to determine the roof snow loadings. Typically, the uniform roof snow loading is less than the uniform ground snow loading.

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  • Q: Roof solar system loads: Is there a prescriptive process for structural approval of small solar systems?

  • A: Yes, please click the following link: Prescriptive process for structural approval of small PV systems. pdf format of FAQ Prescriptive Process Stamped Signed 2-13-13.pdf
file size 4MB
  • Q. Exit definition: The 8th edition states in section R311.1 that exits are to lead ‘to the exterior of the dwelling’. Can you please clarify this?

    A. Exits from a building are to lead to grade and to a public way.

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    Q. Smoke detectors in existing buildings: I am pulling a permit to do a small bump out of a kitchen in a single family home. Do I need to update the smoke detector system in the entire home per section R314.1 of the International Residential Code 2009?

    A:No. Appendix J applies to construction for existing buildings. Further, section AJ102.3 was replaced with a MA amendment which invokes fire protection requirements for certain construction projects, including but not limited to the addition of a sleeping room. These requirements are consistent with BBRS intent, as recorded in meeting minutes, and previous editions of the building code.



    4.00 Foundations

    Q. What frost protection is required for an accessory structure? Can a 20 ft by 20 ft detached garage be built on a shallow footing? 

    A.. Yes if the garage meets the requirements or exceptions found in Section R403.1.4.1.  Note that a building permit needs to be pulled for the construction of a gauge, regardless of its size.  This does not mean though that a 400 square foot structure can be placed on, and unattached to, a slab or concrete blocks since Section 403.1 states "that all exterior walls shall be supported on ...systems to accommodate all loads according to R301 and to transmit the resulting loads to the soil".

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    Q: Where does the Code cover sill plates and fastening?

    A. See Section R5403.1.6

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    Q. Shallow foundations: Can shallow foundations be used with unheated buildings?

    A.  Yes. Section R403.1.4.1 Frost protection, has two exceptions for accessory structures and also allows the construction of a frost protected shallow foundation (FPSF) for an unheated building using the prescriptive requirements of ASCE 32.  Penn State University has a webinar on this topic that may be helpful in understanding the science of FPSF.  See http://www.engr.psu.edu/phrc/training/FPSF_webinar_March_09.pdf..

    8.00 Roof-Ceiling Construction

    Q: How do you choose rafter size under the new Code? I noticed that the snow loads have increased significantly in 7th Edition One- and Two- Family Dwelling Code compared to what they used to be in the 6th edition of the code per Chapter 36. Can you explain this and also provide some guidance on how rafter spans are determined and if the method is different than what was done using the 6th edition ?

    A. For users of the code who want to "prescriptively" choose a rafter for a particular snow load one may go directly to the family of tables (R802.5.1) and chose a rafter design based on Pg (ground snow load), span, spacing, species, and grade. The code allows use of the on-line Span Calculator to choose a rafter design.

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    Q. Where is guidance for roof mounting solar panels?

    A: Section R301.6, Roof Load, provides the required live and snow loads. 

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    Q: Is venting required when insulation is installed between roof rafters?

    A: Yes or No. Yes if you insulate the rafter space with either fiberglass batts or blown cellulose. See Section R806 and the figure below for guidance on the clearances and area of ventilation required.  

    No, ventilation can be omitted from the assembly, if constructed per section R806.4 and the figures below. These alternate methods install an air impermeable insulation to the underside of the roof sheathing (as with the use of expanding spray foam insulation) or to the top of the roof sheathing (as with the use of board foam plastic insulation). Both of these are types of closed-cell foam insulation.


    In both cases, additional cavity insulation can be installed (typically fiberglass batts or blown cellulose) to increase the overall R-value of the assembly; however, the air impermeable insulation (either expanding spray foam or board foam plastic) must account for a minimum of 40% of the total roof R-value (though it can account for more) in order to manage the potential for condensation within the assembly. In addition, if the expanding spray foam insulation of rigid board foam plastic insulation has permeability less than 2 perms/inch, then a vapor retarder may also be omitted from the assembly.

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    Q:I want to install solar PV panels on my roof. How do I know if the rafters can handle the extra weight?

    A: If the panels are attached in about the same plane (within 10 o) of the roof plane and therefore will not capture snow (drifts) then you may use the prescriptive tables for rafter spans, Tables R802.5.1. The dead load (psf) would have to be determined based on the manufacturer's specifications for the panel weight coupled with the weight of the existing roof material. Use of the on-line rafter span tool, which is allowed by the building code, is another method that will produce the same results as the table.

  • Q. Damaged roofing: In the 7th edition there was a requirement that if replacing more than 25% of a roof covering because of damage or other, then the entire roof covering would need to be replaced and meet the code for new construction.  Is this requirement in the 8th edition?

    A. No. However, if an area of a roof is damaged it may be necessary to remove undamaged roof covering back to a valley, ridge, eave, or other division to adequately repair the damaged area.

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    10.00 Chimneys and Fireplaces

    Q: Explain "listing" versus "testing" for these appliances?

    A: Typically these appliances must be listed. In general, 'listed' means that the equipment is included in a list of products published by a product evaluation/testing organization that is recognized by industry and building code officials. If a product is listed then the product was initially tested and found suitable for the intended purpose. Also, the listing organization routinely tests the product to ensure standards are met. Listed products typically come with documentation including the 'testing' standards met, and assembly, installation and operating instructions. For example, a factory built fireplace (R 1004) must be 'listed' by UL or a similar organization and it must be 'tested' to the UL 127 testing standard to meet the code.

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    Q:Can a pellet stove be installed into an unlined masonry chimney?

    A: No. However, a pellet stove, which is a power vented, positive draft appliance may be installed into a clay tile-lined chimney cavity provided that it is a listed appliance, that the manufacturer's installation instructions explicitly allow it and provided the chimney is lined with a clay tile and is in good, serviceable condition. See  NFPA 211  for regulations pertaining to natural draft (non-power vented) appliances.

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    11.00 Energy Efficiency

      Q: Why does RES check 'pass' a building envelope U-factor that may not meet the minimum prescriptive requirements in Table N1102.1?

    A: REScheck allows, to some extent, a trade off of energy efficiency requirements.  For example it may allow (pass )a design which includes a greater ceiling R-value and a lower wall R-value, than those found in Table N1102.1.

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    Q: Is a vapor retarder required with open cell spray foam insulation.

    A: Generally yes. Open cell insulation has a perm rating in excess of 1.0 (perhaps 2 or more) and as such is inconsistent with prescriptive vapor retarder requirements in Section R601.3. So, either (a) a vapor retarder would therefore be required or (b) the open cell spray foam manufacturer or engineer or architect of record or other would have to demonstrate that such is not the case and detrimental to the building.


    Q. Air leakage testing: Is the air leakage testing outlined in Sections 402.4 and 403.2 of the IECC need to be done by a RESNET certified HERS rater?

    A.  No not necessarily. The IECC code does not have specific certification requirements for this testing. An individual with appropriate experience may perform this testing. A RESNET certified HERS rater is required to conduct the testing in buildings where compliance is to DOE Energy Star requirements.


    Q. REScheck: To comply with the code I am using REScheck for a lateral addition.  Does the software require a fourth wall?

    A.  With REScheck and IECC 2009 the user has the option to choose between two compliance methods: total UA or Performance. For lateral additions which are not thermally isolated from the existing building, the total UA is the proper method and a fourth wall will not be required.


    Q:Energy efficiency certificate: The energy code requires that a certificate is posted indicating R-values, HVAC equipment, etc... Is there a form available for this?

    A.  Yes. Building officials from Pittsfield developed a residential energy compliance certificate that is available for use to meet this requirement.


  • Note: Also see Appendix J for ducts in existing buildings.
  • Q: Duct leakage testing: When is a duct system considered to be inside conditioned space?

    A. In order for ductwork to be considered inside conditioned space, all of the ductwork must be inside both the air barrier and the insulation barrier.

    Q: Duct leakage testing: What part of a duct system needs to be tested if part of the system extends outside the conditioned space?

    A: The entire duct system shall be tested even if only part of the duct system is located outside the building envelope.

    Q: Duct leakage testing: How do I calculate the square footage used for determining whether the duct leakage test passes or fails when there are multiple duct systems in the home or when only part of the home is conditioned?

    A: The area used in the calculation of “CFM per 100 square feet” shall be the area of the home directly conditioned by the duct system being tested.

    Q: Duct leakage testing: What procedure can be used to perform duct leakage testing?

    A: The duct leakage testing procedures in Chapter 8 of the Residential Energy Services Network (RESNET) 2006 Mortgage Industry National Home Energy Rating Standards shall be an approved procedure for testing ductwork.

  • Q. Wall insulation: Does R13 wall cavity insulation and R-2 continuous insulation comply with wall insulation requirements?

    A.  Yes, but only when the wall construction meets the requirements of footnote h. in Table 402.1.1 in the International Energy Conservation Code 2009. For example, if the dwelling has typical 2x4 wall construction with structural sheathing throughout, then R13 cavity and R-2 continuous insulation meets the prescriptive code requirement.

  • Q. Wall insulation: Can I assume that batt insulation which fills a 2x6 wall cavity to be equivalent to R-19?

    A.  No. Insulation manufacturers have installation instructions that must be followed to ensure that the specified R value of the batt is met. For example, if insulation is compressed the specified R value may be compromised as can be seen in this literature from one manufacturer Owens Corning Compression Chart in Excel.

  • Q. Roof insulation: Prior to re-roofing I will remove the entire existing roof covering; must I consider installing insulation?

  • A.  If the roof is part of the thermal envelope then yes, because exception 5 of Section 101.4.3 of the International Energy Conservation Code 2009, only applies as follows: ‘Re-roofing for roofs where neither the sheathing nor the insulation is exposed. Roofs without insulation in the cavity and where the sheathing or insulation is exposed during re-roofing shall be insulated either above or below the sheathing’.
  • Q. Gypsum board and insulation: Does gypsum board have to be in contact with the interior surface of the insulation.

    A.  No, not necessarily. If the thermal envelope is properly air sealed then an air cavity between the gypsum board and interior surface of the thermal envelope is acceptable. Examples of this are wall cavities which are partially filled with foam insulation or in ceiling construction with batt insulation and furring strips.  


  • 12.00 Mechanical Administration

    Q: To replace a furnace in the basement of an existing building, located in a flood zone, where must the new furnace be located?

    A: Section R322.1.6 directs the installer to place any new or replacement electrical, heating, ventilation, air conditioning and other service equipment above the base flood elevation or protected so as to prevent water from entering or accumulating with the system. During the permit process this flood elevation should be addressed prior to the permit being issued and during the final inspection.

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    14.00 Heating and Cooling Equipment

    Q:I would like to purchase a new heating appliance. How do I know if the product complies with the Building Code?

    A: In general Chapter 14 applies. If it is a gas appliance visit the 'Approved Plumbing Products Online System' offered by the Division of Professional Licensure http://license.reg.state.ma.us/pubLic/pl_products/pb_product.asp

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    Appendix J  Existing Buildings and Structures

    Q: Are fire sprinklers required when renovating an existing one or two family dwelling?

    A. The basic approach is as follows:

    1. Determine if new construction of the same type of building would require sprinklers. If yes -
    2. Determine if the renovation work provides an opportunity to incorporate fire protection easily.  For example, in a case of complete reconstruction.  If yes, then it is likely cause to have sprinklers installed.
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    Q: Where do I find the code requirements for additions and replacement windows?

    A. In general this table should apply:





    Horizontal Additions

    Chapter 3

    Compliance typically does not impose significant cost or hardship.

    Vertical Additions

    Chapter 3

     or Appendix J

    If extensive renovation to the lower floor(s) is planned and compliance

     to new construction does not impose significant cost or hardship, then

    Chapter 3 should be met. Otherwise use Appendix J.

    Replacement Windows


    Window U-factors should meet the requirements of the International

    Energy Conservation Code but do not need to meet the opening

    protection requirements for wind borne debris.


    Q: Sunroom/three season porch wall bracing, and, glazing in wind borne debris regions: Must glazing used for sunrooms and three season porches meet the requirements of R301.2.1.2 , Protection of openings

  • A:  No, for existing buildings where protected openings were never required per R301.2.1.2.  

    A: No, for new construction where the sunroom or porch is thermally isolated from the building.

    A: Yes, for new construction where the sunroom or porch is not thermally isolated from the building.  

  • Q: Must sunrooms and porches meet the wall bracing requirements of R602.10?

    A: No, a MA exception was added which applies to single story rooms less than 600 sq. ft. in area which are thermally isolated from the main dwelling.

  • Q: Duct Testing: Is duct leakage testing required on new duct runs in existing building projects?

    A: In general, yes.  However, this guidance may not be economically or technically reasonable in certain projects based on feedback from industry experts.  Two examples are provided:

     Example A, Testing not required: Enclosing a small rear deck area.  A small room that may require only short branch runs would not require duct testing on the old system or new branch runs*. Short lengths of new duct can prove problematic to test.

     Example B, Testing required: Finishing an area above a 3 car garage. An area of this size could typically require installing a small main supply, return duct trunk line and multiple branch duct runs. In this case the new work would need to be tested for leakage per the code guidelines*.

    Typically, in example B, the easiest way to do this would be to test the new ductwork BEFORE it is tied to the original duct system of the dwelling and prior to enclosure in soffits or sheetrock, which would block access for repairs.

     * Again and with respect to both examples provided above, all new duct installations require sealing and a thorough visual inspection, by the duct installer and eventually by the building official, prior to installation of any insulation.


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