TN State Fire Marshal Codes Adoption – Update January 2025

Update January 28, 2025: the State Fire Marshal’s Office filed rules with the Secretary of State that update the State’s minimum codes and other regulations. The rule filing can be found here: 01-17-25.pdf. It will become effective April 17, 2025. In accordance with TN Department of Commerce and Insurance Rule 0780-02-03-.11, plans for construction that are required to have State Fire Marshal’s Office approval may be submitted under the previous codes for 120 days after April 17, 2025, which is August 15, 2025.

Highlights of the changes are:

  • Inclusion of rules for Mobile Food Units
  • Discontinuance of NFPA 101 Life Safety Code for state buildings, schools, and other buildings requiring initial inspection from the State Fire Marshal’s Office
  • Modifications to requirements for storm shelters
  • Adoption of Appendix AM of IRC for family home day cares
  • Modification of ASCE 7 edition adopted by reference in IBC
  • Modification of requirements for flammable gases
  • Modification of requirements for emergency radio coverage systems
  • Modifications to IECC related to automatic receptacle control, energy monitoring systems, commissioning, and code edition related to occupancy
  • Modifications to IEBC related to storm shelters and repairs to damaged structures
  • Inclusion of rules for audits of Exempt Jurisdictions
  • Modification of requirements for exempt jurisdictions that reduce requirements of their adopted codes

Register now for a Virtual Education Training Session on February 6 and 7 to learn more about the transition to the 2021 codes!

Update November 15, 2024: The 2021 codes will not be adopted this month. However, the State Fire Marshal’s office worked diligently to find a solution for the design community while waiting on the final adoption of the proposed 2021 codes. At this time, the current projection is the Government Operations Committee will review and approve the recommended adoption in Feb/March and the codes will be effective 90 days following that approval.  The following information has been released for those wanting to move forward with the proposed 2021 codes:

Pursuant to the adopted codes, the State Fire Marshal’s Office has the authority to grant modifications for individual cases where strict compliance with the code is impractical, upon written request by the owner/representative, if the modification does not lessen health, accessibility, life and fire safety, or structural requirements so long as the modification is in compliance with the intent and purpose of the code. The request to comply with the 2021 IBC would be considered a modification allowed under this provision.

If you would like more information on how to proceed, please contact Chris Bainbridge, Director of Codes Enforcement, at the State Fire Marshal’s office.

We will continue to update members on the status of the final 2021 codes adoption. AIA TN’s GR team and leadership continues to advocate that it is essential to stay current with evolving building standards to ensure that Tennessee’s buildings remain safe, functional, and resilient in the face of evolving challenges and risks. The proposed 2021 edition of the IBC incorporates significant advancements in building technology, construction practices, and safety standards that have emerged since the publication of the 2012 edition.

Update October 14, 2024: Due to unforeseen circumstances, the adoption of the 2021 codes has been delayed, creating a significant hurdle for architects and the broader construction community. Our team has been in close communication with key officials within the State Fire Marshal’s office and the Governor’s Administration, emphasizing the need for prompt implementation as anticipated in November 2024. We are committed to advocating for a swift resolution, recognizing that timely adoption is essential. Once we hear more information, we will update members.

In the meantime, if you have any questions, please contact Chris Bainbridge, Director of Codes Enforcement at the Tn State Fire Marshal’s office.

Update as of March 14, 2023: Rules to update the state minimum codes from 2012 to 2021 have been filed with the Secretary of State’s office and a Rulemaking Hearing has been scheduled for April 29, 2024. The AIA TN State Minimum Codes working group supports all the changes. See the details below for your information.

View the Proposed Rules w/Redline Version Here: 03-05-24.pdf (tnsosfiles.com)

The Rulemaking hearing will be held at 10am/CT on April 29 in Conference Room 1B at Tennessee Department of Commerce and Insurance, Davy Crockett Tower, 500 James Robertson Parkway, Nashville, TN 37243

Below are Proposed Changes to State Minimum Codes from 2012 to 2021 and will have the earliest possible effective date of November, 2024 with a 120-day grace period after that:

  1. IBC 2012 to IBC 2021 with exceptions
  2. IFGC 2012 to IFGC 2021
  3. IMC 2012 to IMC 2021
  4. IPC 2012 to IPC 2021
  5. IPMC 2012 to IPMC 2021 with exceptions
  6. IEBC 2012 to IEBC 2021 with exceptions
  7. IFC 2012 to IFC 2021 with exceptions
  8. IECC 2012 to IECC 2021 with exceptions

Additional changes are to Alternatives & Conflicts, Local Ordinances, and Audits of Local Codes in Enforcement Agencies.

Note: The LSC is not part of this new adoption except for certain new Residential Board and Care Small Facilities described in the Rules and references to locking of classroom doors in Educational and College/University buildings.

Update on information below as of August 2023: Draft Rules are currently being reviewed. Once the Rules are finalized and filed with the Attorney General’s office, the State Fire Marshal’s office will update the Stakeholder’s working group. The goal is to file the the rules in time for an effective date of July 1, 2024 with a provision for utilizing the previous codes for 120 day after the new codes are effective.

In June 2022, the Tennessee State Fire Marshal’s Office (TNSFMO) called a first meeting for Stakeholders to update the Building and Fire Codes adopted and enforced by their office.

AIA Tennessee (AIA TN) appointed two representatives to serve on the stakeholders group that also includes members of other professional organizations such as engineers, building officials, fire officials, other State agencies, the ICC and trade groups.

The first meeting was an orientation to the mission of the group and introduction to the first draft of the updated rules draft. TNSFMO is currently on the 2012 version of the International Building Code (IBC) and 2012 NFPA 101 Life Safety Code (LSC). After some discussion, TNSFMO staff and most stakeholders felt the 2021 version of the IBC was the most logical edition to move to since it is the most current and looking at the 2018 edition would already be four years old. Significant changes between the 2012 and 2021 editions were provided for review. The LSC is not proposed to be part of this new adoption.

After review of the draft, a second meeting was held in October and the draft was reviewed line by line with input from committee members. The revised draft was then sent to all stakeholders who were requested to review and return any comments for a final draft.

AIA TN created a working committee consisting of members from each local component to review, prepare comment to submit to the TNSFMO. A final draft has been received from the TNSFMO and the working committee is comfortable with the final revision. The next step is for the SFMO to schedule a public hearing for input from the general public. Once the rules are finalized, the document is submitted through the various State channels including the Attorney General’s office for final implementation.

AIA TN Representatives to Stakeholder Group are Bill Steffenhagen and Bob Franklin.

AIA TN Working Group members are Daniel Huitt, Jr., Marietta Haywood, Faris Eid, Matt Lyle, Linda Marzialo and Valentina Cochran