The International Code Council (ICC) held public hearings in Orlando, Fla., in May to consider updates to several ICC codes. Participants in the hearings debated over proposed changes to the 2027 editions of the International Fire Code (IFC), International Building Code (IBC), International Plumbing Code (IPC) and International Mechanical Code.

The ICC Committee on Health Care (CHC) submitted 14 proposals for consideration and provided testimony for 35 other proposed changes.

Key proposals supported by the ICC CHC that were adopted during the first round of code hearings include modified requirements for alcohol-based hand rub (ABHR) storage, control vestibules, hyperbaric chambers and carbon monoxide detection.

Successfully adopted proposals

Alcohol-based hand rubs. During the COVID-19 public health emergency, the use of ABHRs was significantly perpetuated, yet the IFC didn’t specifically address the storage, use or handling of ABHRs. Members of the American Society for Health Care Engineering (ASHE) participated in a working group led by the ICC Fire Code Action Committee to develop four proposals, all of which were adopted, to help clarify these issues within the IFC.  

  • Dispensers located in corridors are to be wall-mounted to help maintain the means of egress.
  • In coordination with the National Fire Protection Association’s NFPA 101®, Life Safety Code®, ABHR dispensers in health care facilities are limited in size to 41 ounces (1.21 liters) in rooms, corridors and areas open to corridors, and 68 ounces (2 liters) in care suites, with an aggregate quantity within a smoke compartment not to exceed 30 gallons.
  • To help alleviate the burden of needing to obtain operational permits from the local fire department when ABHR quantities exceed a certain amount, a proposal was passed stating that  organizations in compliance with the IFC’s requirements for ABHRs do not need to obtain this special permit. 
  • Finally, a proposal was submitted that established maximum allowable quantities for ABHR storage at the following quantities in sprinklered and nonsprinklered locations:

Storage location



Open storage areas

60 gallons

30 gallons

Non-dedicated storage room with 1-hour fire separation

240 gallons

60 gallons

Non-dedicated storage room with 2-hour fire separation

360 gallons

240 gallons

Dedicated storage room

360 gallons

240 gallons

Dedicated storage room with 1-hour fire separation

600 gallons

240 gallons

Dedicated storage room with 2-hour fire separation

720 gallons

240 gallons

Control vestibules. While the use of control vestibules may seem contrary to the life safety principle of maintaining the means of egress free and unobstructed, there are specific areas within health care facilities where it is beneficial to have an interlocked series of doors so that when one door is open it restricts the other doors from opening at the same time. For instance, control vestibules can help to manage airflow into and out of a space, such as in a compounding pharmacy. The control vestibule proposal supported by the ICC CHC passed successfully, allowing these types of door configurations in the means of egress for security, environmental control or clinical needs. 

Hyperbaric chambers. While hyperbaric facilities have been required to meet the requirements of NFPA 99, Health Care Facilities Code, for some time, there has been confusion on whether the existing code requirements also apply to hyperbaric chambers used for non-medical purposes. The ICC CHC worked with a group of interested parties to help clarify that the requirements within the IFC should apply to all hyperbaric chambers.

Carbon monoxide detection. During the 2024 ICC code cycle, changes were made in the IBC and the International Existing Building Code (IEBC) regarding carbon monoxide detection. During the two-year process, improvements were made to the language within the IEBC that were not included in the IBC. When a work group was assigned to align the language within the IBC, it was determined that a rewrite of Section 915 Carbon Monoxide Detection was necessary. The ICC CHC participated throughout the rewrite process. While the rewrite appears to be a significant change, the actual requirements within the rewrite are aligned with the language that was developed during the 2024 code cycle.

Relocatable power taps. The ICC CHC also helps to provide alignment between the ICC codes and federal requirements. One group submitted a proposal to replace relocatable power taps (RPTs) listed UL Standard 1363A with RPTs listed and labeled UL Standard 2930, which directly conflicts with the Centers for Medicare & Medicaid Services (CMS) requirements. CMS only allows UL Standard 1363A or UL Standard 60601-1 listed RPTs to be used in the patient care vicinity. The ICC CHC worked with the proponent to include the UL Standard 2930 listing along with the current CMS requirements. There is concern that this may cause confusion since CMS currently does not specifically allow UL Standard 2930 RPTs. However, it does provide the opportunity for this listing to be considered for inclusion by CMS in the future.

More work ahead

With the changes that ICC has made to its code development process, the ICC CHC still has some work to do on proposals that did not pass. A second round of committee action hearings will be held in Long Beach, Calif., from October 23–31, 2024, during which the ICC CHC will address committee concerns on the below proposals:

Definition of clinical need. It was brought to the ICC CHC’s attention that some surveyors have been questioning door locking arrangements based on the clinical needs of patients. This is due to the fact that no definition of “clinical need” exists. To assist with this, the ICC CHC developed and submitted a definition for clinical need: “A known care or welfare risk to care recipients that necessitates an enhanced level of safety or security.”

While the International Building Code Development Committee had concerns with the security portion of the definition and therefore disapproved the proposal, it agreed that this is an issue that needs to be resolved and strongly encouraged the ICC CHC to continue working on the definition and bring it back to the second code action hearing.

Handwashing station water temperature. The current requirement within the IPC for tempered water is between 85 F and 110 F. This temperature range is the ideal range for the growth of many waterborne pathogens, which is why the ICC CHC is working to modify temperature requirements.

Medical gases. A proposal was submitted to duplicate the compressed gases table found in the IFC and include it in the IBC, Section 427 Medical Gas Systems. While medical gases are compressed gases, the compressed gases table currently found in the IBC conflicts with the current requirements for medical gases within NFPA 99. The ICC CHC will work with the proponent to align the requirements with NFPA 99.

The results of the first round of hearings are available for review through the ICC cdpAccess webpage. As mentioned previously, a second round of committee action hearings to discuss the results of the first hearing will be held in Long Beach, Calif., from October 23-31, 2024. 

Anyone interested in participating in the ICC CHC’s testimony efforts at the hearings or via the committee virtual sessions can reach out to the ICC CHC chair, Jeff O’Neill, AIA, ACHA, CHFM,  at Jeffrey.O’ or to ASHE staff member Jonathan Flannery, MHSA, CHFM, FASHE, FACHE, at

Jonathan Flannery, MHSA, CHFM, FASHE, FACHE, is senior associate director of ASHE regulatory affairs.