Every day as fire protection engineers, we deal with fire safety codes and standards. They guide our work, but they are not guarantees of safety. Codes and standards are consensus documents, updated on a three-year cycle, which can make them out of step with new hazards the moment they are published.
As fire protection engineers, our professional, ethical, and legal duty is to protect the public. That means recognizing when code minimums fall short and being willing to advocate for safer, smarter solutions.
When Code Compliance Isn’t Enough
I have seen firsthand that code compliance does not equal safety. Buildings that meet the criteria for code compliance can still be destroyed by fire. For example:
- Retail Distribution Center, Plainfield, IN: This 1.2 million sq. ft. mega warehouse was fully “compliant” yet burned to the ground. This resulted in $500 million in property loss and significant environmental damage.
- Recycling Facility: I was on the ground fighting this fire. Despite being “up to code,” the facility was a total loss.
- Residential Apartment Building: I was directly involved in fighting the fire at this multifamily residential building. Again, compliance did not translate to resilience or safety.
- Fort Worth, TX Apartments: A fire at a modern Fort Worth apartment complex, built in 2020 to current codes, displaced over 800 residents and resulted in significant structural damage. Lawsuits have been filed against the building owners.
The Limitations of Codes and Standards
So, if these buildings were all “up to code” why did they fail so catastrophically? The answer lies in the fundamental limitations of codes and standards, which are often reactive and represent a bare minimum for safety.
Several factors make these codes an insufficient “cookbook” for engineers:
- The Lag in Safety Codes: Codes and standards are generally reactive, not proactive. They are typically updated on a three-to-five-year revision cycle, often in response to major fire disasters or new research. This means they can struggle to keep pace with new technologies and fire hazards. For example, the widespread use of lithium-ion batteries in homes and electric vehicles presents a unique fire hazard that earlier codes did not anticipate and may not fully address.
- Codes as Minimums: A building that’s code compliant might not have a sufficient level of safety because codes typically represent the minimum requirements for construction. While they establish a threshold for compliance, a building that just meets these minimums may not be fully adequate to protect life and property in all scenarios.
- Higher Standard: The National Society of Professional Engineers has stated that code compliance is no longer a reliable standard of care. As licensed design professionals, engineers are held to a higher standard and are expected to understand the limitations of codes and advise clients when minimum compliance may not be sufficient.
A Case in Point: Parking Garages & EVs
Take modern parking garages. Many jurisdictions still classify them as Ordinary Hazard Group 1 per older editions of the NFPA 13 standard. But with today’s vehicle construction and the presence of electric vehicles this creates unique and more intense fire hazards, meaning that the hazard classification is outdated. EV battery fires burn hotter, last significantly longer, and are difficult to extinguish with traditional water-based suppression systems. This presents a major challenge to the fire protection systems designed for yesterday’s vehicles, proving that the code minimum simply doesn’t cut it
Alternate Methods: A Path to Safer Designs
Both the International Code Council (ICC) and National Fire Protection Association (NFPA) codes include Alternate Methods provisions that allow engineers to use newer standards if they provide equal or greater protection. This means:
- We don’t have to settle for outdated editions referenced in the code, which is important because jurisdictions often lag behind in adopting the most current standards.
- We can design to the most current NFPA standards, provided there’s no direct conflict.
When using this approach, a designer must apply a chosen edition in its entirety, without “cherry-picking” specific sections. The engineer must also document their rationale and coordinate with Authorities Having Jurisdiction (AHJs) to secure their non-objection. This process is often simple and ensures that projects are aligned with today’s hazards rather than being limited by yesterday’s rules.
Dollar Decisions vs. Safety Decisions
Clients make dollar decisions. Engineers must own the safety decisions. I’ve only been challenged a handful of times on why I recommended more than the minimum. The answer is simple: because it’s in your best interest.
If you are dealing with a client who wants to use an older, less expensive code, engineers should:
- Advocate for the Best Solution: Always recommend the best fire protection solution, which may involve using updated standards.
- Explain: A conservative well-reasoned approach, rather than designing to the bare minimum, helps prevent major losses. Well-reasoned fire protection designs are rarely regretted. Thin, “code-only” designs can fail fast — and fail hard. Make sure clients understand this.
- Documentation: If the owner insists on minimum compliance, I document that directive in writing. That way, everyone is clear about the risk being accepted.
- Don’t Overlook the Insurers: Organizations like FM Global update their guidance continuously, based on full-scale fire testing. They’re not constrained by municipal adoption cycles. When we put their requirements side-by-side with code minimums and the latest NFPA editions in a comparison matrix, the differences can be striking. That matrix helps clients and AHJs see the trade-offs clearly and supports better decisions.
Codes and standards are essential, but in some situations, they are not enough. As professional engineers, our responsibility is to look beyond the minimums and deliver solutions that protect people, property, and business continuity.
That’s the standard of care I practice and the one our industry needs to embrace.