Codes and CRE: How they are Developed, Adopted, and Applied to CRE

July 26, 2021 | By: Owen Kavanagh

Codes are paramount to buildings and architecture. They guide and mandate what can and cannot be done when building, designing, and drafting architecture. But where do they come from? Codes are developed over many years, then adopted by states and localities, and finally applied to building projects in local jurisdictions.



The International Code Council (ICC) is one of a few groups developing codes. Their I-Codes (International Codes) have been adopted in all 50 states and forms the basis of many countries’ building codes, such as Mexico, Saudi Arabia, and Colombia.

I-Codes cover all aspects of a building, from energy conservation and swimming pools to plumbing and zoning. These codes are thorough and nuanced, many codes appear rigid and absolute, but almost all of them rely on code official’s interpretations for application.

The ICC develops code on a 3-year cycle and makes changes based on amendments made during the previous adoption cycle. These changes are made through an open and transparent process over a minimum of 120 days. The ICC Voting Members meet and discuss proposed changes in an open forum. Any member of the public can submit a code change for the International Code Council’s review as an interested party and begin the development process.


Code changes are posted at least 30 days ahead of a hearing, giving ample time for the public to review. This hearing is open to the public at no charge and can be viewed online as a stream or later as a video. The hearing begins with a floor discussion during which the proposal is considered. This hearing allows for the code committee to both vet the change and groups putting it forward.

Interested parties may present their case on the proposed code change, and once it is discussed, the code development committee gives their recommendation on the code to the ICC. ICC Members in attendance may challenge this as part of an Assembly Action. If there is no challenge and the assembly passes or denies the proposed change, the results of the hearing are posted to the ICC website 60 days ahead of the final action.

At this point, interested parties may submit comments on the code changes online to the code development committee. These comments are collected and posted publicly 30 days before final action.

The final part of development is a final action hearing, where eligible voters cast their votes on the proposed code change. These voters consist of designated governmental and honorary members, and the hearing is open to the public both in person and online. In the final action hearing, a code change is allowed or denied, and if it is allowed, it will appear in the next ICC edition on a 3-year cycle.


Codes are adopted and amended at a state level every few years, then local jurisdictions apply the codes within their spheres of influence. Adopted codes cannot be less stringent when used by local jurisdictions, only stricter. States adopt codes on different cycles. Florida adopts changes every 3 years, Georgia adopts on a 6-year cycle, and many states, such as Texas, Alabama, and Tennessee, have a mixture of codes from different years.

States amend codes before adoption to better fit their local areas, and these amendments are an integral part of the adoption and development process. For example, Georgia follows the ICC codes in most areas, but for chapter 10 of the International Building Code (IBC), they have adopted NFPA 101, the National Fire Protection Association’s Life Safety Code.

This amendment was part of a deal between the State Fire Marshal and the group in charge of the code adoption, the Department of Community Affairs (DCA), and illustrates the process through which States change codes as they adopt them. Once a code is adopted to a state, a local jurisdiction like a city or county applies the codes to building projects in their areas.


Codes are applied early in the building process. Architects send their drawings to code officials for approval and comments. The drawing is approved or denied, and if denied the architect or firm revises the plan based on comments from the code official. Code officials have a wide berth when it comes to interpreting codes, and the many nuances in codes matter immensely for their application.

“Codes are open to interpretation,” explained Mark Schroeder of IA Interior Architects. “In most cases, if a code official disagrees with a particular interpretation of the code from the Architect, they will listen to the Architect’s interpretation to gain an understanding of why they are interpreting it the way they are.”

Even changing the inflection on an “and” between codes cycles can have enormous effects, and the interpretation of codes by officials can bring in business or dissuade it. Code officials are highly trained and receive nearly continuous education on the codes they enforce. Even with this, code enforcement can cause a cascade of difficulties on projects, as you must always apply the most current adopted code to a project.

This may sound like no big deal, but old buildings were built under different specifications and codes but require applications of new codes never expected when the building went up. This can lead to headaches for architects retrofitting an older building.

“If the architect is prepared with a good argument and a solid methodology to walk the code official through the how’s and why’s of their interpretation, the architect stands a very good chance of swaying the opinion of the code official,” Schroeder stated. “Remember, code officials are people too and are always trying to improve upon their knowledge base.”

Codes are a daily reminder of how far we have come. They help keep people safe and secure, and they are built on the backs of years of amendments, development, and at times tragedy. There are many drives to change and enhance codes, but their adoption and application remain a cornerstone of humanity’s progress in architecture and safety.


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  • Insight and Guidance from Mark Schroeder, Technical Director at IA Interior Architects
  • The ICC Code Development Process, By Bruce Johnson, Director of Fire Service Activities, International Code Council – Government Relation
  • The International Code Council, org 

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