A change to the code development cycle occurred when the International Code Council (ICC) board approved a standing motion from the Committee on the Long-Term Code Development Process to revise the code development cycle to incorporate two committee action hearings for each code group. This change expands the current process from two independent one-year cycles to a single continuous three-year cycle. It takes effect beginning in 2024 for the development of the 2027 international codes.

In the new timeline, the first year will include two committee action hearings for Group A codes; the second Group A hearing will be completed by the time this is printed. Year two (2025) will include two committee action hearings for Group B codes, and year three (2026) will be the joint public comment hearings and online governmental consensus vote for both code groups. (See below for the identification of the I-Codes in Group A and Group B).

The purpose and intent of the International Code Council’s code development process revision is to allow more in-depth scrutiny of code change proposals. The updated process also offers more opportunity for proposed new referenced standards to be developed and finalized on a consistent timeline regardless of the group with which they are associated.

It is thought that the addition of the second committee action hearings in year one and year two will foster a more in-depth vetting of code change proposals, allowing an opportunity for the committee members to review and evaluate the original proposals and consider the submitted responses. It is also thought that this will give more opportunity for proponents to build consensus for their code change proposal and ensure the best version of their intended improvement to the existing codes.

With combined public comment hearings in the third year, voting members can vote on all suggested changes to the next edition of the I-Codes simultaneously. 

The Code Change Process: How a Code Change Happens

1. A proponent determines the need for a code change proposal. Read the code books! Anyone can submit a proposed code change; however, the ICC has a Plumbing, Mechanical, and Fuel Gas Code Action Committee that reviews the current edition of the Plumbing, Mechanical and Fuel Gas Codes and proposes code changes to those codes.

The ICC’s Policy on Code Development, which prescribes the procedure rules used in the continued development and maintenance of the codes. It provides that: “Any interested person, persons or group may submit a code change proposal which will be duly considered when in conformance to these Rules of Procedure.”

2. A proponent develops the language of the proposed code change proposal. If you have a change to a code section or sections you want to propose, you must comply with ICC’s Policy on Code Development regarding the formatting of your proposed change. 

For example, the policy requires that you indicate whether the code change proposal is intended to be an “addition, deletion, or a revision to existing [c]ode text,” and requires that the text of the current code with the proposed changes be presented “with deletions shown struck out with a single line and additions shown underlined with a single line.” 

Furthermore, the council’s policy is to preserve the existing wording of the code section as much as possible, “with only such deletions and additions as necessary to accomplish the desired change.” It requires that each code change proposal be in proper code format and terminology and the proposed text be in mandatory terms. Please refer to ICC CP No. 28-5, revised July 12, 2024, for a complete listing of the form and content requirements.

3. A proponent provides supporting information. The ICC’s Policy on Code Development also requires that: “Each code change proposal shall include sufficient supporting information to indicate how the code change proposal is intended to affect the intent and application of the [c]ode.” 

As such, in addition to crafting the proposed language of the code change, the council’s policy requires that the proponent of a code change proposal also provide a reason statement, technical information and substantiation and a cost impact statement. The cost impact statement is critical, as “[a]ny proposal submitted which does not include the requisite cost impact information shall be considered incomplete and shall not be processed.” 

The policy offers the following with respect to the cost impact requirement:

“17.1 Cost Impact Statement Requirements. The proponent shall indicate one of the following regarding the cost impact of the code change proposal or the net cost impact of the code change proposal and comment submitted: 

“1. The code change proposal’s estimated immediate cost impacts; or 

“2. The change proposal is editorial in nature or a clarification and has no cost impact on the cost of construction. 

“The proponent shall submit information which substantiates such assertion. This information will be considered by the [c]ommittee and will be included in the published code change proposal. Supporting documentation may be provided via a link to a website provided by the proponent and included in the cost substantiation statement. The cost substantiation statement shall include the date the link was created. 

“Any proposal submitted which does not include the requisite cost impact information shall be considered incomplete and shall not be processed. 

“1. The cost estimates provided shall be straightforward, allowing the Code Development Committee (CDC) members and eligible voting members to rapidly assess their relative validity. 

“2. The cost estimates shall (a) have succinct information to allow the average person to understand how it was calculated (methodology), and (b) may provide reference for the publicly available data used (basis for variables). 

“3. The ICC may develop a cost impact guidance document to assist code change and comment submitters in complying effectively with the cost impact requirements.”

4. A proponent submits the code change proposal. The Policy on Code Development requires that “each code change proposal and all substantiating information shall be submitted online via cdpACCESS.” The deadline for submittals is established by the ICC and posted at least 120 days before the deadline.

Upon receipt of the code change proposal, the Secretariat will check the proposal for compliance with the Rules of Procedure, and will determine which committee will have responsibility for voting on the proposal at the committee action hearings. The Secretariat will set the agenda, which will set forth the order in which each proposal will be heard to facilitate the hearing. The Secretariat will prepare the proposals and post them on the ICC website at least 30 days before the first committee action hearing (CAH No. 1). 

If the Secretariat does not publish your code change proposal in the original posting on the ICC website, or in subsequent errata, it will not be considered.

5. A proponent may attend the first committee action hearing. The council’s policy provides: 

“The intent of the First Committee Action Hearing is to permit interested parties to present their views including the cost and benefits on the code change proposals on the published agenda. The [c]ommittee will consider such comments as may be presented in the development of their action on the disposition of such code change proposals.” 

The committee action hearing is an open hearing. Although only the committee members vote on each proposal, anyone interested in a proposed code change can attend the hearing and participate in a floor discussion. The Rules of Procedure expressly prohibit a participant from discussing their position with a committee member outside of the official proceedings. 

The conduct of the hearing follows Robert’s Rules of Order. When a code change proposal is up for discussion, the moderator will ask the proponent of the code change proposal for comments. After the proponent speaks, others who also support the proposal may speak. (Note that the proponent is not required to attend the hearing). 

After the comments supporting the proposal are finished, there will be an opportunity for comments by those in opposition, then an opportunity for rebuttal in support, and a final opportunity for rebuttal in opposition. The committee sets time limits for floor testimony at the hearing and before it begins, and each person testifying on a code change proposal is given equal time. 

Floor testimony at the committee action hearing is limited to verbal presentations; audio-visual presentations are prohibited. However, the Rules of Procedure provide that the technical information and substantiation, required to be submitted with the code change proposal (along with the reason statement and cost impact statement) shall be located in a designated area in the hearing room. 

The material submitted in response to a code change proposal shall be located in the same area but not distributed to the committee at the public hearing. 

Following the floor discussion of each code change proposal, the committee will either approve the code change proposal as submitted, approve the code change proposal as modified with specific modifications, or disapprove the code change proposal. The majority vote dictates the committee’s action.

Following the conclusion of the CAH No. 1, the Secretariat will post the results, including committee action and reason. This allows “any interested person, persons or group” to “submit a comment noting disagreement with the action taken” at CAH No. 1. In addition, the results are posted on the ICC website with sufficient time to review and submit comments; the comments to the results are posted on the ICC website with sufficient time for review before the second committee action hearing (CAH No. 2).

The ICC’s Policy on Code Development, Section 7.0 — Submittal of Comments to the First Committee Action Hearing, is a new section. The section states its intent, as follows:

“7.1 Intent: Any interested person, persons or group may submit a comment noting disagreement with the action taken at the First Committee Action Hearing. The comment process gives attendees at the Second Committee Action Hearing an opportunity to consider specific objections to the results of the First Committee Action Hearing and more thoughtfully prepare for the discussion and comment consideration at the Second Committee Action Hearing.”

6. A proponent may attend the second committee action hearing. The ICC’s Policy on Code Development, Section 8.0 — Second Committee Action Hearing, is a new section. The section states its intent, as follows:

“8.1 Intent: The intent of the Second Committee Action Hearing is to permit interested parties to present their views including cost and benefits on comments received to the action taken by the [c]ommittee at the First Committee Action Hearing. The [c]ommittee will consider such comments as may be presented in the development of their action on the disposition of such code change proposals prior to the public comment portion of the code development process in accordance with Section 9.0.”

The I-Codes and Their Groupings 

The ICC publishes the International Plumbing Code (IPC), the International Mechanical Code (IMC), the International Fuel Gas Code (IFGC), and the International Private Sewage Disposal Code (IPSDC). 

There is an entire family of international codes, including the International Building Code (IBC), International Fire Code (IFC) and International Residential Code (IRC), which includes plumbing, mechanical and fuel gas sections tailored for residential construction. 

Other codes are the International Existing Building Code (IEBC), International Property Maintenance Code (IPMC), International Wildland-Urban Interface Code (IWUIC), International Green Construction Code (IgCC), International Energy Conservation Code (IECC), International Code Council Performance Code for Buildings and Facilities (ICC PC), International Swimming Pool and Spa Code (ISPSC) and International Zoning Code (IZC). 

The international codes are a large body of codes, and because of the logistics of so many code hearings occurring simultaneously, they were split into two groups of codes (Group A and Group B) and given two separate code hearing cycles. 

• Group A International Codes: 

1. The International Building Code Egress Provisions (IBC-E), which include Chapters 10 and 11; 

2. The International Building Code Fire Safety Provisions (IBC-FS), which includes Chapters 7, 8, 9 (partial), 14 and 26 (the majority of IBC Chapter 9 is maintained by the IFC); 

3. The International Fire Code (the majority of IFC Chapter 10 is maintained by IBC-E);

4. The International Fuel Gas Code; 

5. The International Mechanical Code; 

6. The International Plumbing Code; 

7. The International Private Sewage Disposal Code (code changes are heard by the IPC committee (combined IPC and IPSDC committee);

8. The International Residential Code - Mechanical Provisions (IRC-M), Chapters 12-23 (code changes are heard by the IRC-MP committee);

9. The International Residential Code - Plumbing Provisions (IRC-P) Chapters 25-33 (code changes are heard by the IRC-MP committee);

10. The International Swimming Pool and Spa Code (code changes are heard by the ISPSC committee);

11. The International Wildland-Urban Interface Code (code changes are heard by the IFC and IWUIC committees).

• Group B International Codes: 

1. The Administration Chapter or Chapter 1 of the I-Codes, except the IgCC and IRC (note that Chapter 1 in all codes contains the administrative provisions, and proposed code changes to the administrative provisions will all be heard together. When different technical code committees heard these changes, they did not come out consistent. So, the Building Code General Committee will hear all proposed changes to the administrative provisions in Chapter 1 of most of the I-Codes during the Group B code hearings); 

2. The update of currently referenced standards in all the international codes, except the IgCC. 

3. The International Building Code – General Provisions (IBC-G), Chapters 3-6, 12, 13, 27-33; 

4. The International Building Code - Structural Provisions (IBC-S), Chapters 15-25;

5. The International Existing Building Code – Structural Provisions (IEBC); 

6. The International Existing Building Code - Non-structural Provisions (IEBC);

7. The International Green Construction Code (including the administration provisions of Chapter 1 to provide coordination with the other administrative provisions in the I-Codes); 

8. Appendix M of the IgCC (Note that this appendix is included in the IgCC and is not included in ASHRAE Standard 189.1. It is an informative appendix providing an option for residential compliance with the National Green Building Standard (NGBS) also known as ICC 70. The remainder of the IgCC is based on the provisions of ASHRAE Standard 189.1);

9. The International Property Maintenance Code (IPMC). (Note that code changes are heard by the IPMC/ZC, the combined IPMC and IZC code committee); 

10. The International Residential Code - Building Provisions (IRC-B), Chapters 1-10;

11. The International Zoning Code (note that code changes are heard by the combined committee covering the IPMC and the IZC).

Code Group Notes 

• ICC publishes a document, titled, “2024/2025/2026 Group A and B Code Development Committee Responsibilities Matrix,” which is posted on its website. 

The Code Responsibility Matrix identifies responsibilities different from Group A and B codes and committees, which may impact the applicable code change cycle and resulting code change deadline. 

• Be sure to review the brackets [] for the applicable code committees responsible for a given code. As an example, throughout the codes, Chapter 1 has administrative sections that a separate General Committee on Administration hears. In the Building Code – General Provisions, Chapter 4 (IBC-G), numerous sections include the designation [F], which indicates that the provisions of the section are maintained by the IFC committee. 

Similarly, numerous sections in the IEBC include the designation [BS]. These are building code structural provisions which will be heard by the IBC – Structural committee. The designations in the code are identified in the matrix. 

• Be sure to review the brackets [] in Chapter 2 of the applicable code and the matrix to determine which committee will consider proposed changes to the definitions. 

• The 2027 edition of the ICC PC will be updated using the ICC standards process. 

• The 2027 edition of the IECC will be updated using the ICC standards process. 

• The 2027 edition of Chapter 11 of the IRC will be updated using the ICC standards process. `

There are more steps to the process, and I will cover those in a future column. As of this writing, I am sitting in a hotel room in Long Beach, Calif. The ICC has completed its annual meeting, and I have been on the road for the better part of six weeks for work in New York, New Jersey, West Virginia, Pennsylvania, Connecticut, Oklahoma, San Diego and Dallas, attending industry meetings. I will try to summarize what has happened at each industry meeting in an upcoming column.