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What Did PA’s 2021 Code Adoption Change for Fire Protection?
General guidance, not a code determination for any project. Confirm the adopted code and local amendments with the authority having jurisdiction.
Pennsylvania’s 2021 code adoption moved the Uniform Construction Code (UCC) from the 2018 to the 2021 International Codes (I-Codes) on January 1, 2026, which makes National Fire Protection Association (NFPA) 13 (2019) the sprinkler standard referenced by the International Building Code (IBC), replaces the model rule for NFPA 13R sprinklers in Group R-2 buildings with a Pennsylvania roof-height test, and brings in the 2021 International Fire Code (IFC) by reference only, without modification. Accessibility did not move: the 2018 provisions still apply, and Pennsylvania still has no statewide fire code for existing buildings.
The update was decided by the UCC Review and Advisory Council (RAC) and adopted by the Pennsylvania Department of Labor and Industry (L&I) as final-omitted Regulation #12-125, amending 34 Pa. Code Chapters 401 and 403. This article lists the fire protection items the Council changed or kept, compares the 2018 and 2021 code sets as adopted, explains which edition a project uses and sets out the dates. Each item below comes from the Council’s report in the Independent Regulatory Review Commission (IRRC) file for the rule or from the Pennsylvania Construction Code Act, Act 45 of 1999.
At a Glance: Pennsylvania’s 2021 Code Adoption
- Jurisdiction: the Commonwealth of Pennsylvania; the UCC applies statewide and is enforced by municipalities that elected to enforce it, by their third-party agencies, or by L&I.
- Local code and edition: the UCC, 34 Pa. Code Chapters 401 and 403, on the 2021 I-Codes since January 1, 2026 (as of November 2026), including the 2021 IBC, International Residential Code (IRC), International Existing Building Code (IEBC) and IFC; accessibility stays on the 2018 IBC Chapter 11 provisions.
- Agency (AHJ): the authority having jurisdiction (AHJ) is the municipal building code official or certified third-party agency; L&I reviews commercial work in municipalities that opted out and all state-owned buildings.
- Filing or permit name: a UCC building permit application under 34 Pa. Code 403.42 and 403.42a, with fire protection shop drawings approved before installation (403.42a(f)(3)); in Philadelphia, a Fire Suppression Systems Permit filed in eCLIPSE.
- Key difference from the model code: Pennsylvania modifies IBC Section 903.3.1.2 (NFPA 13R), adopts only listed sections of IBC Chapter 30 (including fire service access and occupant evacuation elevators), keeps earlier text for IBC Sections 426.1, 704.2 and 704.4.1, and keeps the 2018 accessibility provisions.
- Review time range (as of November 2026): 30 business days for a commercial permit application (34 Pa. Code 403.43(a)) and 15 business days for residential, or 5 with a design professional’s certification (403.63(a)); these clocks sit in Chapter 403, not in the I-Codes.
What Did Pennsylvania Adopt, and When?
The RAC reported its decisions on the 2021 I-Codes to the Secretary of Labor and Industry on September 14, 2024. Under Act 45 section 304(a)(1), L&I must adopt the Council’s decisions without change through final-omitted regulations. IRRC approved Regulation #12-125 (IRRC #3455) on October 16, 2025, the rule was published as final in the Pennsylvania Bulletin on November 8, 2025, and it took effect on January 1, 2026.
The Council’s report lists 11 adopted codes: the 2021 IBC, IRC, IEBC, IFC, International Mechanical Code, International Fuel Gas Code, International Plumbing Code, International Energy Conservation Code, International Swimming Pool and Spa Code, International Wildland-Urban Interface Code and the International Code Council (ICC) Performance Code. The codes in force before January 1, 2026 were the 2018 I-Codes, effective under the UCC since February 14, 2022.
Two parts of the IBC were outside the Council’s review. IBC Chapter 1 (administration) is excluded under Act 45, so permits, plan review and inspections still follow the administrative provisions of 34 Pa. Code Chapter 403. IBC Chapter 11 (accessibility) is also excluded, and the 2021 accessibility provisions remain under the permanent injunction the Commonwealth Court issued on October 26, 2022.
What the 2021 Codes Changed for Fire Protection in Pennsylvania
The Council adopted IBC Chapter 9 (Fire Protection and Life Safety Systems) with a single modification, to Section 903.3.1.2. The rest of Chapter 9 applies as the 2021 model text. The items below are the fire protection changes and carry-overs that the Council’s report names, plus the change in referenced standard edition that comes with the 2021 IBC.
Sprinkler standard edition: NFPA 13 (2019)
The 2021 IBC references NFPA 13 (2019), so sprinkler systems permitted under the 2021 codes are designed to that edition. NFPA 13 (2019) places plans and calculations in Chapter 27 and system acceptance in Chapter 28. Shop drawings, hydraulic calculation cover sheets and specifications carried over from a 2018-code project need their edition and chapter references checked before filing under the 2021 codes.
Philadelphia’s Code Bulletin B-2501 lists the referenced standards the City applies with the 2021 codes, including NFPA 72 (2019) for fire alarm systems and NFPA 70 (2020), the National Electrical Code (NEC). Outside Philadelphia, the reviewing code official confirms the referenced edition for each standard on the permit.
NFPA 13R in Group R buildings: Pennsylvania’s modified Section 903.3.1.2
The 2021 model IBC allows an NFPA 13R system in a Group R building only where the building is 4 stories or fewer above grade plane and the highest floor is 30 ft or less above the lowest level of fire department vehicle access, with podium stories counted from grade plane. The ICC’s significant changes summary describes that 30 ft test as replacing the 2018 model limit of 60 ft above grade plane. Pennsylvania keeps the 4-story limit, the 30 ft floor-level test for Group R occupancies other than R-2 and the grade plane count for podium buildings built under IBC Sections 510.2 and 510.4.
For Group R-2 occupancies, Pennsylvania’s text replaces the floor-level test with a roof-height test: the roof assembly must be less than 45 ft above the lowest level of fire department vehicle access. Pennsylvania takes that height from the lowest required fire apparatus access road beside the building up to the highest of three points: a pitched roof’s eave, the line where the top roof meets the exterior wall, or the top of a parapet. The lowest story must still be 30 ft or less below the lowest level of fire department vehicle access.
The practical result is that a 4-story R-2 apartment building is checked against its roof and parapet height rather than its top floor level. A design team that set a parapet or roof profile without that measurement in mind can lose the 13R option and need a full NFPA 13 system.
The 2021 IFC, by reference only
The Council adopted the 2021 IFC by reference only and without modification. Under 34 Pa. Code 403.21 the IFC is part of the UCC only to the extent the other adopted codes reference it, so the UCC does not make the IFC a statewide fire code for occupied buildings. Operational permits, fire inspections and maintenance rules apply only where a municipality adopted a fire code by ordinance, a point DGA explains in whether Pennsylvania has a statewide fire code.
Elevators, combustible dust and fire-resistance text
IBC Chapter 30 is adopted only for the sections the Council listed: 3002.1, 3002.2, 3002.4, 3002.7, 3004.2.1, 3004.3.1, 3005.4, 3006, 3007 (fire service access elevators) and 3008 (occupant evacuation elevators). Section 426.1 on combustible dusts keeps the 2018 IBC text. Sections 704.2 (column protection) and 704.4.1 (light-frame construction) keep the 2015 IBC text, and the Section 803.3 heavy timber exemption keeps the modification made in the 2018 adoption. On the residential side, IRC Section R314.4 on smoke alarm interconnection keeps the 2015 IRC text.
DGA confirms which code edition governs a filing, maps 2021 code changes against designs started under the 2018 codes and prepares fire protection code analyses across New York, New Jersey, Pennsylvania, Maryland and Delaware. Project briefs get confirmation and preliminary code feedback within one business day. See where DGA works →
2018 vs 2021 Codes as Adopted in Pennsylvania
The table compares the two UCC code sets on the points that matter to fire protection design and review. The 2018 column describes the codes in force from February 14, 2022 to December 31, 2025; the 2021 column describes the codes in force from January 1, 2026, as of November 2026.
| Topic | 2018 codes (Feb 14, 2022 to Dec 31, 2025) | 2021 codes (from Jan 1, 2026) | Source |
|---|---|---|---|
| Model code family | 2018 I-Codes | 2021 I-Codes, with the Council’s modifications | 34 Pa. Code 403.21; Regulation #12-125 |
| Sprinkler standard referenced by the IBC | Edition referenced in 2018 IBC Chapter 35 | NFPA 13 (2019) | IBC Chapter 35 |
| NFPA 13R height test, Group R other than R-2 | 2018 model text | Highest floor 30 ft or less above fire department vehicle access | IBC 903.3.1.2 as modified |
| NFPA 13R height test, Group R-2 | 2018 model text | Roof assembly less than 45 ft above fire department vehicle access | IBC 903.3.1.2 as modified |
| Podium buildings (IBC 510.2, 510.4) | 2018 model text | Group R stories counted from grade plane | IBC 903.3.1.2 as modified |
| International Fire Code | 2018 IFC, only where other UCC codes reference it | 2021 IFC by reference only, without modification | 34 Pa. Code 403.21; RAC report |
| Fire service access and occupant evacuation elevators | Listed sections of 2018 IBC Chapter 30 only, including 3007 and 3008 | No change: listed sections of 2021 IBC Chapter 30 only, including 3007 and 3008 | 34 Pa. Code 403.21; RAC report |
| Accessibility | 2018 provisions | No change: 2018 provisions (2021 provisions enjoined) | Commonwealth Court order, Oct 26, 2022 |
| Plan review clock, commercial | 30 business days | 30 business days (set in Chapter 403, not the I-Codes) | 34 Pa. Code 403.43(a) |
For commercial sprinkler work, the change in referenced edition reaches every new design filed under the 2021 codes. The Council’s NFPA 13R modification matters mainly to Group R projects of up to 4 stories, where the R-2 roof-height test decides whether a 13R system is allowed.
Figure 1: Referenced NFPA 13 Editions Across the Region
| Jurisdiction | Code base (as of November 2026) | NFPA 13 edition |
|---|---|---|
| Pennsylvania | UCC on the 2021 I-Codes | 2019 |
| New Jersey | UCC on the 2024 I-Codes | 2022 |
| New York State outside New York City | 2025 Uniform Code on the 2024 I-Codes | 2022 |
| New York City | 2022 NYC Construction Codes | 2016, as modified by Appendix Q |
| Maryland | 2021 IBC through the county permit; NFPA 1 (2024) | 2019 through the county permit; NFPA 1 (2024) references 2022 |
| Delaware | Regulation 701 (2026) | 2025 |
Who Reviews Fire Protection Under Pennsylvania’s 2021 Codes, and Which Edition Applies
The adoption did not change who reviews fire protection work. A municipality that elected to enforce the UCC reviews plans through its own certified code officials or a certified third-party agency (34 Pa. Code 403.102), while L&I reviews commercial work in municipalities that opted out of enforcement and all state-owned buildings (403.141). The steps from application to permit are covered in DGA’s guide to how fire protection plan review works under the Pennsylvania UCC.
The edition follows the application. Act 45 section 304(c)(4) lets a permit issue under the code in effect when a design or construction contract was signed, if the permit application is filed within 6 months after new regulations take effect, and a municipality may set a shorter period. For the 2021 update that window opened on January 1, 2026 and has now closed, so a new application filed in November 2026 is reviewed under the 2021 codes and NFPA 13 (2019).
Philadelphia set its own rule in Code Bulletin B-2501, issued October 20, 2025. Applications received before July 1, 2026 could be reviewed under either the 2018 or 2021 editions, with the 2018 edition applying unless the application or plans named the 2021 edition. Applications received on or after July 1, 2026, including trade permits, must use the 2021 editions, and an earlier demolition, foundation or excavation permit does not fix the edition for later filings.
Philadelphia’s Fire Code remains on a 2018 IFC basis, with the 2021 IFC applying only where the 2021 building codes reference it. The City’s April 2026 narrative on its adopting ordinances says some 2021 IFC maintenance provisions fall outside the Construction Code Act and will be adopted by separate ordinance. DGA’s Philadelphia fire protection consulting page describes how DGA works with the City’s Department of Licenses and Inspections.
Key Dates in Pennsylvania’s 2021 Code Adoption
The dates below explain where Pennsylvania’s code sets came from and which one a filing uses. The dates come from the IRRC record, Act 45 and Philadelphia’s Code Bulletin B-2501, as of November 2026.
Figure 2: From the 2018 Codes to Mandatory 2021 Use
| Milestone | Date | Source |
|---|---|---|
| 2018 I-Codes effective under the UCC | February 14, 2022 | 52 Pa.B. 971 |
| 2021 accessibility provisions permanently enjoined | October 26, 2022 | Commonwealth Court; L&I |
| RAC report on the 2021 I-Codes | September 14, 2024 | IRRC #3455 file |
| IRRC approval of Regulation #12-125 | October 16, 2025 | IRRC #3455 |
| Philadelphia Code Bulletin B-2501 issued | October 20, 2025 | Philadelphia Department of Licenses and Inspections |
| Final rule published | November 8, 2025 | Pennsylvania Bulletin |
| 2021 I-Codes effective statewide | January 1, 2026 | Regulation #12-125 |
| 2021 editions mandatory in Philadelphia | July 1, 2026 | Code Bulletin B-2501 |
Pennsylvania is now one I-Code edition behind New Jersey, which moved to the 2024 I-Codes on August 17, 2026, as DGA explains in what New Jersey’s 2024 code adoption changed for fire protection, while Pennsylvania stays on the 2021 set. DGA’s Fire Code Cheat Sheet for NY, NJ, PA, MD and DE lists the adopted editions across the region.
Key Takeaway: Since January 1, 2026, Pennsylvania’s UCC has been on the 2021 I-Codes, which puts sprinkler design on NFPA 13 (2019), applies a Pennsylvania roof-height test of less than 45 ft to NFPA 13R in Group R-2 buildings and brings in the 2021 IFC by reference only. The 6-month transition window for contracts signed earlier has closed, Philadelphia requires the 2021 editions from July 1, 2026, and accessibility stays on the 2018 provisions.
Frequently Asked Questions
Which building code edition does Pennsylvania use now?
The 2021 International Codes. Since January 1, 2026 the UCC has adopted the 2021 IBC, IRC, IEBC, IFC and the other 2021 I-Codes with the changes decided by the Review and Advisory Council, except that accessibility still follows the 2018 provisions.
Can a project still use the 2018 codes?
Conditional: only a project whose design or construction contract was signed before January 1, 2026 and whose permit application was filed within 6 months after that date, or within a shorter period set by the municipality, under Act 45 section 304(c)(4). Philadelphia requires the 2021 editions for applications received on or after July 1, 2026.
Which NFPA 13 edition applies in Pennsylvania?
NFPA 13 (2019), the edition referenced by the 2021 IBC, for projects permitted under the 2021 codes. A project permitted under the 2018 codes during the transition stays on the edition referenced by the 2018 IBC.
Did Pennsylvania adopt the whole 2021 IBC?
No. Chapter 1 administration gives way to 34 Pa. Code Chapter 403, Chapter 11 accessibility stays on the 2018 provisions, Chapter 30 is adopted only for listed sections, Section 903.3.1.2 is modified for NFPA 13R, and Sections 426.1, 704.2 and 704.4.1 keep earlier text.
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This article is general information, not a code determination for any project. Code editions, Council modifications and transition rules change; confirm the edition that applies with the building code official for the municipality where the building sits, or with L&I where L&I reviews the plans.
Filing Fire Protection Work in Pennsylvania?
Send the drawings, the contract date and the municipality. DGA confirms which code edition the filing uses, checks the design against the 2021 changes, including the NFPA 13R height test, and prepares the code analysis for the building code official. Project briefs get confirmation and preliminary code feedback within one business day.