Insights topic · 62 articles
Approvals by Jurisdiction
How fire protection plans are filed and approved in NYC, New York State, New Jersey, Pennsylvania, Maryland, Delaware and on GSA leases.
Fire protection approvals work differently in each state and city. New York City splits review between the Department of Buildings and the FDNY. New Jersey uses a fire protection subcode official under its Uniform Construction Code. Pennsylvania leaves most review to municipalities and third-party agencies. Maryland and Delaware enforce NFPA-based fire codes through state and local fire marshals. The guides below explain each process and what reviewers look for, including federal leases.
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How Does AHJ Review Work in NYC, NJ and Philadelphia?
AHJ review is the plan examination a building or fire official performs on a fire protection submittal before a permit is issued. What reviewers at NYC DOB and FDNY, New…
Questions this topic answers
What it is
| Question | Code basis | Last reviewed |
|---|---|---|
| What Is a NYC Letter of No Objection? | NYC Administrative Code Title 28: 28-101.4.3, 28-101.5, 28-102.4, 28-102.4.1, 28-117.1, 28-118.3.1, 28-118.3.2, 28-118.3.4, 28-118.3.5; 2022 NYC Building Code 903.2 and 907.2; DOB LNO/LOV application form (revision 7/24); DOB Code Notes on the LNO (2017); DOB Buildings Bulletins 2015-026 and 2023-012 (rescinding 2009-025); FDNY Local Law 195 FAQ (2019) | |
| What Is a Prior Approval Under the NJ UCC? | N.J.A.C. 5:23-1.4 and 1.6(a); N.J.A.C. 5:23-2.15(a)5 and (f)4ii(1); N.J.A.C. 5:23-2.16(a)3 and (j); N.J.S.A. 4:24-39 et seq.; DCA Bulletins 79-1, 91-2, 96-3 and 97-1; NJ UCC on the 2024 I-Codes, effective Aug 17, 2026 | |
| What Is NYC Professional Certification and Its Risks? | NYC Administrative Code Title 28: 28-101.5, 28-104.2.1, 28-104.2.7, 28-104.2.10, 28-105.10; 1 RCNY 21-01 and 21-02; 3 RCNY 104-02 (amended 2023) | |
| What Is UFC 3-600-01 and When Does It Apply? | UFC 3-600-01, Fire Protection Engineering for Facilities (requirements described from the 2016 edition with Change 6, May 6, 2021; current edition on WBDG); UFC 1-200-01, DoD Building Code (2022 with Change 4, Dec 17, 2024); USACE ECB 2026-13 (June 18, 2026); UFS 1-300-01 (Jan 14, 2026); NFPA 101; NFPA 1; 2026 PBS Core Building Standards (GSA contrast only) | |
| What Does WSSC Require for Fire Service Connections? | 2024 WSSC Plumbing and Fuel Gas Code (2024 IPC basis, effective Dec 1, 2025; Amendment 1 effective Feb 2, 2026), Sections 109.4, 109.5, 506.11, 506.12, 508.2; WSSC Development Services Code; WSSC SU/MSU Design Checklist (rev. Nov 15, 2022); NFPA 13 (2019) via the 2021 IBC county permit; NFPA 13 (2022) 4.5.1.1 via NFPA 1 (2024); NFPA 24 | |
| What Is a Life Hazard Use Registration in New Jersey? | Uniform Fire Safety Act, N.J.S.A. 52:27D-196(e) and 197(a); N.J.A.C. 5:70-2.4 to 2.4D, 2.5, 2.6, 2.7, 2.9 and 2.12 (Uniform Fire Code); State Fire Prevention Code on the 2018 IFC (N.J.A.C. 5:70-3.1); Fire Safety Code (N.J.A.C. 5:70-4) | |
| What Is a TR1 Special Inspection for Sprinklers? | 2022 NYC Building Code Ch. 17 (1704.1, 1705.17, 1705.29, 1705.30); NYC Administrative Code Title 28, Arts. 104, 115, 116; 1 RCNY 101-06; 2022 NYC Fire Code 901.6.3; NFPA 13 and 14 (2016) as modified by BC Appendix Q | |
| Is GSA P100 Still Required for Fire Protection? | PBS P100 Facilities Standards (2024, rescinded Feb 24, 2025), Ch. 1 and 7; PBS Interim Core Building Standards (Feb 24, 2025); 2026 PBS Core Building Standards (memo Sept 21, 2026), App. A Sec. 1, 3 and 7; 40 U.S.C. 3312; 15 U.S.C. 2227; 41 CFR 102-71.30 and 102-71.35 (formerly Part 102-80, Subpart C); GSA Order PBS 5921.1 (2020); GSA Lease L100 (May 2026) 3.09 to 3.11; GSA Form 12000 | |
| Which FDNY Certificates of Fitness Does a Building Need? | 2022 NYC Fire Code FC 113, FC 112, FC 901.6.2.1, FC 901.6.3, FC 901.7.2, FC 903.5, FC 905.1.1, FC 608.7, FC 3308.1; FDNY Certificates of Fitness list (as of November 2026) | |
| What Is Expedited or Third-Party Plan Review? | NYC Administrative Code 28-104.2.1; 1 RCNY 21-01, 21-02; 3 RCNY 104-02; N.J.A.C. 5:23-4.12 to 4.16; 34 Pa. Code 401.1, 403.63(a), 403.102(g), 403.103(b); Philadelphia L&I Fire Suppression Systems Permit (accelerated review); Prince George's County DPIE Third-Party Plan Review Program manual (Nov 2025); Baltimore City Fire Department third-party plan review; 19 NYCRR Parts 1203 and 1205; 1 DE Admin. Code 701 (2026) section 1.5.1.2 | |
| What Is an AHJ and How Do You Find Yours? | NFPA official definitions (Ch. 3, Sec. 3.2; NFPA 1, 13, 101); NFPA 13 (2022) 4.5.1.1; IBC and IFC Sections 104 and 202; N.J.A.C. 5:23-3.4, 3.17, 4.24 and 5:70; 34 Pa. Code 403.102, 403.103, 403.141; NY Executive Law 381 and 19 NYCRR Parts 1203, 1204; NYC Local Law 195 of 2018; COMAR 09.12.51 and 29.06.01.03, .04; 16 Del.C. 6612 and DSFPR Regulation 701 (2026); GSA PBS 5921.1; 40 U.S.C. 3312 | |
| What Is the NJ Rehabilitation Subcode? | N.J.A.C. 5:23-6 Rehabilitation Subcode (as amended by R.2026 d.087, effective Aug 17, 2026); N.J.A.C. 5:23-2.10; N.J.A.C. 5:23A; 2024 IEBC Chapters 6 and 13 | |
| What Is the NJ Fire Protection Subcode and Who Enforces It? | N.J.A.C. 5:23-3.17 and 5:23-3.4 (fire protection subcode); N.J.A.C. 5:23-4.4, 4.24 (officials, DCA plan review); N.J.A.C. 5:23-5.3 (licensing); NJ UCC on the 2024 IBC, effective Aug 17, 2026; NFPA 13 (2022), NFPA 72 (2022); N.J.A.C. 5:70 Uniform Fire Code (2018 IFC basis) | |
| What Is GSA Form 12000? A Part B Guide for Lessors | GSA Form 12000 (Rev. 5/2011); Public Law 102-522; 41 CFR Part 102-80; GSA Leasing Desk Guide Appendix D (2015); NFPA 101 | Oct 2026 |
When it is required
| Question | Code basis |
|---|---|
| What Fire Protection Does a Federal or GSA Building Need? | GSA Global Lease Template L100 (May 2026) 3.09 to 3.11; GSA Form 12000 (Rev. 5/2011); RLP Template R100 (May 2026) 3.01.K; 2026 PBS Core Building Standards, Appendix A Sections 1 and 7; 15 U.S.C. 2227; 40 U.S.C. 3312; GSA Order PBS 5921.1 (2020); UFC 1-200-01 and UFC 3-600-01 (editions per contract); NYS, NYC, NJ, PA, MD and DE codes as of November 2026 |
| What Fire Protection Does a GSA Lease Require? | GSA Global Lease Template L100 (May 2026) 3.09, 3.10, 3.11, 3.13; RLP Template R100 (May 2026) 2.07, 3.01.K; GSA Form 12000 (Rev. 5/2011); 15 U.S.C. 2227; 41 CFR 102-71.35; PBS 5921.1 (2020); NFPA 13, 25, 72 and 101 |
How the process works
| Question | Code basis | Last reviewed |
|---|---|---|
| How Does AHJ Review Work in NYC, NJ and Philadelphia? | NYC Building Code Ch. 9 and Ch. 35 (2022); N.J.A.C. 5:23 and 5:70; The Philadelphia Code Title 4; NFPA 13, 20, 72, 291 | Oct 2026 |
| How Do Federal Agencies Review Leased-Space Fire Protection? | GSA Leasing Desk Guide Appendix D (May 2015) Sections 1, 2, 4, 11; GSA Global Lease Template L100 (May 2026) 1.06, 1.13, 3.08 note, 3.09 to 3.11; RLP Template R100 (May 2026) 2.07, 3.01.K; GSA Form 12000 (Rev. 5/2011); GSA Template 3517B General Clauses: GSAR 552.270-8, 552.270-10, 552.270-29; PBS 5921.1 (2020) 1.6.2, 1.7.2, 3.3.2.2, 3.3.7.2, 3.3.7.4, 5.2.5.3; NFPA 25 and 72 | |
| How Do You Appeal or Get a Variance Under the PA UCC? | PA UCC (2021 I-Codes, effective Jan 1, 2026); 34 Pa. Code 403.43, 403.44, 403.121, 403.122, 403.141, 403.142; Act 45 of 1999 section 501(c); 2 Pa.C.S. 752; 42 Pa.C.S. 933(a)(2) and 5571(b); Philadelphia Board of Building Standards and Board of Safety and Fire Prevention procedures | |
| How Do You Apply for a Variation in New Jersey? | N.J.A.C. 5:23-2.9 to 2.13 (UCC variations); N.J.A.C. 5:23-3.7 (alternative materials, equipment and methods); N.J.A.C. 5:23-4.24 (DCA plan review); N.J.A.C. 5:23A-1.2, 1.3, 2.1 to 2.3 (construction boards of appeals); N.J.A.C. 5:70-2.14 (Uniform Fire Code variances); DCA form F160 (rev. 5/2003) | |
| How Do You Get a Code Variance in New York State? | 19 NYCRR Part 1205 (1205.1, 1205.3 to 1205.6); Executive Law 381(1)(f); DOS Variance Fee Schedule (Nov 2022); 19 NYCRR 1203.3(h); 2025 NYS Uniform Code; Energy Law 11-106 | |
| How Long Does Fire Protection Plan Review Take by State? | N.J.A.C. 5:23-2.16(a), 5:23-4.24, 5:23A-2.1; 34 Pa. Code 403.43, 403.63; NYC Administrative Code 28-104.2.7; 2022 NYC Fire Code FC 105.2.4, FC 105.4.4; 19 NYCRR Parts 1203 and 1205; COMAR 29.06.04; 1 Del. Admin. Code 701 (2026); 40 U.S.C. 3312; NFPA 13 (2022) 4.5.1.1 | |
| How Do You Get a Place of Assembly Certificate in NYC? | NYC Administrative Code Title 28, Article 117 (28-117.1, 28-117.1.1), 28-104.2.3, 28-104.2.7, Article 109; 2022 NYC Building Code Chapter 10 (Table 1004.1.3); 2022 NYC Fire Code Sections 105.6 and 407.4; DOB NOW: Build place of assembly filing; FDNY Public Assembly Permit | |
| How Does a NYC TCO or CO Get Fire Protection Sign-Offs? | NYC Administrative Code Title 28, Articles 109, 116 and 118; 2022 NYC Building Code 1705.17, 1705.18, 1705.29, 1705.30; 2022 NYC Fire Code 901.6, 903.5, 3314.2; 1 RCNY 101-06; DOB Certificate of Occupancy Worksheet (Rev. 8/25); FDNY FA-26 (Rev. 02/25) | |
| How Does FDNY TM-1 Fire Alarm Filing Work? | Local Law 195 of 2018; 2022 NYC Building Code 907.1, 907.1.1 and Appendix Q (NFPA 72, 2016); 3 RCNY 104-02 and 105-01 (amended eff. May 1, 2023); FDNY TM-1 (7-7-25), B-45, FA-26 | |
| Does FDNY Issue a Sprinkler Letter of Completion? | NYC Construction Codes (2022) and DOB rules on sign-off and Letters of Completion; NYC Fire Code (2022); NFPA 13 hydrostatic test; NFPA 25 | Oct 2026 |
How the options compare
| Question | Code basis |
|---|---|
| Federal or Local Fire Code: Which Governs a Federal Site? | 40 U.S.C. 3312; 15 U.S.C. 2227; 41 CFR 102-71.35 and 102-71.45; GSA Order PBS 5921.1 (2020) 1.6.2, 1.7.1, 1.7.2; 2026 PBS Core Building Standards; GSA Lease L100 and RLP R100 (May 2026); UFC 3-600-01; UFC 1-200-01 |
| Who Reviews Fire Protection Plans in Pennsylvania? | 34 Pa. Code Ch. 401 (401.1, 401.2a, 401.3, 401.6); 34 Pa. Code Ch. 403 (403.21, 403.42a, 403.43, 403.63, 403.102, 403.103, 403.121, 403.122, 403.141, 403.142); Act 45 of 1999 section 105(b); PA UCC on the 2021 I-Codes (Jan 1, 2026) |
| NJ UCC or Uniform Fire Code: Which Applies to a Project? | N.J.A.C. 5:23 (UCC, 2024 I-Codes, effective Aug 17, 2026); N.J.A.C. 5:70 (Uniform Fire Code, 2018 IFC; 5:70-2.1, 2.5, 2.6, 2.7, 2.19, 3.1, Subchapter 4); N.J.A.C. 5:23A; N.J.S.A. 52:27D-192 |
| DOB or FDNY: Who Approves What in New York City? | Local Law 195 of 2018; NYC Administrative Code Title 28 (Articles 109, 116, 118); 2022 NYC Building Code (BC 901.2, 907.1.1, 1705.18, 1705.29, 1705.30); 2022 NYC Fire Code (FC 105.6, 608, 901.4.1, 901.6, 909.1.1, 912.6); 3 RCNY 104-02, 3 RCNY 608-01 |
| Maryland’s Two Codes: Building Code or NFPA 1 and 101? | Maryland Building Performance Standards, COMAR 09.12.51 (2021 IBC, IRC, IECC; amendments effective May 29, 2023); State Fire Prevention Code, COMAR 29.06.01 (NFPA 1 and NFPA 101, 2024 editions, effective June 23, 2025; amendments at .07 and .08); Public Safety Article 6-206; NFPA 13 (2019 via the 2021 IBC; 2022 via NFPA 1 2024) |
By state and city
| Question | Code basis | Last reviewed |
|---|---|---|
| How Do Pittsburgh Fire Protection Approvals Work? | Pennsylvania UCC (Act 45 of 1999; 34 Pa. Code Ch. 403) on the 2021 I-Codes, effective Jan 1, 2026; Pittsburgh Code Ch. 1002 (UCC amendments) and Ch. 1004 (IPMC); IFC as enforced by PLI in buildings in use; NFPA 13 (2019); PLI EP-2025-01 and P-2022-01 | |
| What Is Maryland’s Sprinkler Law for New Homes? | COMAR 09.12.51 (2021 IRC Section R313; .04C(6) P2904.1 deletion); Public Safety Article 12-504(a)(1)(iii) and (a)(3), 6-305(a)(3); NFPA 13D; IRC P2904 | |
| Does the Pennsylvania Fire and Panic Act Still Apply? | Fire and Panic Act (Act of April 27, 1927, P.L.465, No.299), sections 1, 3.6, 13 to 15 as in force; Pennsylvania Construction Code Act (Act 45 of 1999) sections 103, 902, 1101 to 1103; 34 Pa. Code 403.1(d), 403.42, 403.43, 403.101, 403.141; 34 Pa. Code Chapter 49 (Fire and Panic regulations, 1984); UCC on the 2021 I-Codes (effective January 1, 2026) | |
| What Does NYC Require for Construction Site Fire Safety? | 2022 NYC Fire Code Ch. 33 (FC 3301 to 3319, incl. 3308, 3313, 3314) and FC 104, 105.6, 111; 2022 NYC Building Code Ch. 33 (BC 3301.13, 3303.3, 3303.7, 3303.8, 3303.12, 3310); NYC Administrative Code 28-104.2.7; Local Law 147 of 2021; 2024 IFC Ch. 33 (model comparison) | |
| Does NYC Local Law 97 Affect Fire Protection Systems? | NYC Local Law 97 of 2019 (Administrative Code Article 320; 1 RCNY 103-14); 2022 NYC Fire Code FC 105.2.4, 105.6, 601.4.1, 603, 606 and 608; 2022 NYC Building Code 903.2, 907.1.1, 907.2 and 1705.17; Administrative Code 28-104.2.7; 1 RCNY 101-19 (effective Oct 26, 2025); 3 RCNY 608-01; NYC Existing Building Code (Local Law 33 of 2026, effective July 17, 2027) | |
| How Do Fire Protection Approvals Work in Wilmington, DE? | 16 Del.C. 6612(c); Regulation 701, 2026 DSFPR (NFPA 1 and 101 2024, NFPA 13 and 72 2025); Wilmington City Code Ch. 4 Sec. 4-26 (2018 IBC, Ord. 4690) and Ch. 12 | |
| Who Approves Fire Protection in Westchester and Long Island? | 2025 NYS Uniform Code (2024 I-Codes base, effective Dec 31, 2025); 19 NYCRR Parts 1203 and 1205; Executive Law 379(1), (2), (3) and (5), 381(2), 383(1)(c); DOS Legal Memorandum LG07; Education Law 7209; Nassau County Charter 1704 to 1706; Nassau County Fire Prevention Ordinance (Ord. 28-2016 as amended; Articles XXII and XXIV; Sections 1.4.1, 2.0.2, 2.1.3, 2.6.4); Suffolk County Code Ch. 471, Art. III; Town of Islip Code Ch. 19, Art. XXVII; Town of Huntington Fire Prevention Code; NFPA 13 (2022) | |
| NYC Fire Code or Building Code Chapter 9: Which Governs? | 2022 NYC Building Code Chapter 9 (BC 901.1, 901.2, 901.3, 901.5, 901.9, 903.2, 903.5, 905.3.1, 907.1, 907.1.1) and Appendix Q (NFPA 13, 14, 20 and 72, 2016, as modified); 2022 NYC Fire Code Chapters 1 and 9 (FC 102.1 to 102.6.1.1, 104.1, 105.2.4, 901.1, 901.4.1, 901.6, 901.7, 903.2, Table 903.2.13, 905.12.1, 907.20.2, 909.1.1.3, 912.6) and Appendix B; NYC Administrative Code Title 28 (28-101.4.3, 28-101.5, 28-102.4, 28-102.4.1, 28-103.1, 28-103.1.1, 28-104.1.1, 28-104.2.7); Local Laws 33 and 42 of 2026; 2021 IFC Chapter 9 (model comparison) | |
| What Are Philadelphia’s Own Sprinkler and Fire Alarm Laws? | Philadelphia Fire Code (Title 4 Subcode F, 2018 IFC basis): F-901.6.4, F-901.6.4.9, F-901.11.1, F-701.6.1, F-1103.5.6, F-1103.5.8, F-1103.6, F-1103.7.7; Philadelphia Building Code (2021 IBC) B-903.2.11.7; L&I fire protection certifications (as of November 2026) | |
| What Are New Jersey’s Sprinkler Retrofit Laws? | N.J.A.C. 5:70-4 (Fire Safety Code); N.J.A.C. 5:70-1.5, 2.5, 2.12, 2.14, 3.1(d); N.J.A.C. 5:10 (Hotel and Multiple Dwelling rules); N.J.A.C. 5:23 (UCC, 2024 I-Codes, effective Aug 17, 2026); N.J.A.C. 5:23A; 2024 IBC 403.3, 903.2, 905 | |
| Which Building Code Applies in Each Delaware County? | Delaware State Fire Prevention Regulations 2026 (Regulation 701, sections 1.5.1.2, 3.1, 3.2); NFPA 1 and NFPA 101 (2024); NFPA 13 and NFPA 72 (2025); New Castle County Code Ch. 6 (2021 IBC); Kent County 2018 IBC with amendments; Sussex County Ordinance 2851 (2021 IBC and IRC); Wilmington Ordinance 4690 (2018 IBC); City of New Castle Ordinance 561 (2024 IBC); 9 Del.C. Ch. 25; 16 Del.C. 6612(c), 7601, 7602 | |
| When Does the Maryland State Fire Marshal Review Plans? | Md. Public Safety Article 6-206 and 6-305; COMAR 29.06.01 (State Fire Prevention Code: NFPA 1 and NFPA 101, 2024, effective June 23, 2025); COMAR 29.06.04 (fees); COMAR 09.12.51 (MBPS, 2021 IBC) | |
| How Do Baltimore City and County Approve Fire Protection? | Building, Fire, and Related Codes of Baltimore City (2024 Edition, Ord. 24-341): 2021 IBC (Part II), 2021 IFC as Baltimore City Fire Code (Part VIII); Baltimore County 2021 IBC (Bill 49-24); Baltimore County Fire Prevention Code, NFPA 1 and NFPA 101 (2024) (Bill 73-26); COMAR 09.12.51; COMAR 29.06.01; NFPA 13 (2019) | |
| How Do Montgomery and Prince George’s Approve Fire Plans? | Montgomery County Executive Regulations 13-24 (2021 IBC) and 14-24 (NFPA 1 and NFPA 101, 2021; NFPA 13 and NFPA 72, 2019), effective Dec 10, 2024; Prince George's County Code Subtitles 4 and 11 (2021 IBC; NFPA 1 and NFPA 101, 2021; NFPA 13 and NFPA 72, 2019), effective Mar 1, 2026; COMAR 09.12.51 (MBPS, 2021 IBC); COMAR 29.06.01 (SFPC, NFPA 1 and NFPA 101, 2024); Md. Public Safety Article 6-206 | |
| What Did PA’s 2021 Code Adoption Change for Fire Protection? | PA UCC, 34 Pa. Code Ch. 401 and 403 (Regulation #12-125, IRRC #3455), 2021 I-Codes effective Jan 1, 2026; RAC report Sept 14, 2024 (IBC 903.3.1.2 modified, IFC by reference, Ch. 30 limited, 426.1, 704.2, 704.4.1); Act 45 of 1999 s. 304(c)(4); NFPA 13 (2019); Philadelphia Code Bulletin B-2501 | |
| How Do NYC Alteration Types Affect Fire Protection Filings? | NYC Administrative Code Title 28 (28-101.4.3, 28-101.5, 28-104.6, 28-116.2.4, 28-118.3); 2022 NYC Building Code Chapter 9 and Sections 1705.29, 1705.30; 2022 NYC Fire Code Section 105; Local Law 195 of 2018; Local Laws 33 and 42 of 2026 (NYC Existing Building Code); DOB NOW: Build job types | |
| Which NYC Retroactive Fire Laws Apply to a Building? | NYC Administrative Code Title 28 Article 315 (28-315.1 to 28-315.11), 28-104.2.7 and 28-116.4; 2022 NYC Fire Code FC 102, FC 107; 2022 NYC Building Code 903.2.2.2, 903.6, 905.11, 908.13, 915.1.2.1; 1 RCNY 915-01; Local Laws 5 of 1973, 16 of 1984, 10 of 1999, 26 of 2004, 157 of 2016, 102 of 2025; 2021 IFC Chapter 11 (model comparison) | |
| What Does NYC Local Law 5 Still Require of Office Towers? | NYC Local Law 5 of 1973; 1968 NYC Building Code retroactive requirements (Administrative Code 28-102.4.1); Local Law 26 of 2004 (27-929.1, Buildings Bulletin 2017-017); 2022 NYC Fire Code FC 401.4, FC 404.2.1; NYC Existing Building Code 302.8 | |
| What Changed in Delaware’s 2026 Fire Prevention Regulations? | Delaware State Fire Prevention Regulations, 2026 edition (1 DE Admin. Code 701 and 701A); NFPA 1 and NFPA 101 (2024); NFPA 13, 20 and 72 (2025); NFPA 25 (2023); compared with the 2021 edition | |
| How Does Delaware State Fire Marshal Plan Review Work? | 1 Del. Admin. Code 701 and 701A (Delaware State Fire Prevention Regulations, 2026 edition): NFPA 1 and 101 (2024), NFPA 13 (2025), NFPA 20 (2025), NFPA 72 (2025), NFPA 25 (2023); Regulation 703; 16 Del.C. 6612; COMAR 29.06.01 (Maryland comparison) | |
| How Does Fire Protection Plan Review Work in Maryland? | Maryland Building Performance Standards, COMAR 09.12.51 (2021 IBC, IRC, IECC); State Fire Prevention Code, COMAR 29.06.01 (NFPA 1 and NFPA 101, 2024); COMAR 29.06.04 (OSFM fees); Public Safety Article 6-206 and 12-504; NFPA 13 (2019) via the 2021 IBC | |
| Does Pennsylvania Have a Statewide Fire Code? | PA UCC, 34 Pa. Code Chapter 403 (2021 I-Codes, effective Jan 1, 2026): 403.1, 403.21, 403.42, 403.42a, 403.43, 403.63, 403.102, 403.141; Act 45 of 1999 (sections 104, 304); 2021 IFC by reference only; municipal fire codes: Philadelphia Fire Code (2018 IFC), Bethlehem Art. 1501 (2018 IFC), Reading Ch. 180 Part 14 (2021 IFC), Lower Merion Ch. 78; 2021 IEBC; NFPA 13 (2019) | |
| What Did NJ’s 2024 Code Adoption Change for Fire Protection? | N.J.A.C. 5:23-3.14, 3.16, 3.17 as amended by R.2026 d.086 (eff. Aug 17, 2026); 2024 IBC; 2023 NEC; NFPA 13 (2022); NFPA 72 (2022); N.J.A.C. 5:23-2.15, 2.16, 4.24; N.J.A.C. 5:70-3.1 (2018 IFC) | |
| How Does Fire Protection Plan Review Work Under the NJ UCC? | N.J.A.C. 5:23-2 (2.15, 2.16, 2.23), 5:23-3.4 and 3.17, 5:23-4.24, 5:23-5.3; N.J.A.C. 5:23A; 2024 I-Codes as adopted by R.2026 d.086 (effective Aug 17, 2026); NFPA 13 (2022); DCA forms F100, F140 (rev. 12/25), F160, F270 | |
| What Does the NYC Existing Building Code Change? | NYC Existing Building Code (Local Law 33 of 2026, effective July 17, 2027); Local Law 42 of 2026; NYC Administrative Code Title 28 (28-101.4, 28-101.4.3, 28-101.4.5, 28-101.5, 28-104.2.3, 28-104.2.4, 28-104.2.7, 28-104.2.8); 2022 NYC Building Code Chapter 9; 1968 Building Code; 2021 IEBC (model comparison) | |
| How Does Fire Protection Plan Review Work at NYC DOB? | NYC Administrative Code Title 28 Ch. 1 (28-104.2, 28-104.2.1, 28-104.2.3, 28-104.2.7, 28-104.6); 1 RCNY 21-01; 2022 NYC Building Code Ch. 9, BC 1705.29 and 1705.30, Appendix Q (NFPA 13 and 14, 2016); Local Law 195 of 2018 | |
| How Do Philadelphia Fire Protection Approvals Work? | Philadelphia Code Title 4 (Building Code on 2021 IBC; Fire Code, Subcode F, on 2018 IFC); L&I Code Bulletin B-2501; NFPA 13 (2019) and NFPA 72 (2019); PA UCC, 34 Pa. Code Chapter 403 (2021 I-Codes) | |
| How Does Fire Protection Plan Review Work Under the PA UCC? | Pennsylvania Construction Code Act (Act 45 of 1999); 34 Pa. Code Ch. 403 (403.21, 403.42, 403.42a, 403.43, 403.45, 403.46, 403.102, 403.103, 403.121, 403.122, 403.141); 2021 I-Codes (effective Jan 1, 2026); 2018 accessibility provisions; NFPA 13 (2019) | |
| How Are Fire Protection Plans Approved in New York State? | 2025 Uniform Code of New York State (2024 I-Codes base, effective Dec 31, 2025); 19 NYCRR Parts 1201, 1202, 1203, 1204, 1205; Executive Law 379, 381, 383; Education Law 7209; NFPA 13 (2022); NYC Administrative Code 28-104.2.7 (comparison) | |
| What Did NYC Local Law 26 Require for Office Sprinklers? | NYC Local Law 26 of 2004; Buildings Bulletin 2011-016; 1968 NYC Building Code occupancy groups; NYC Fire Code (2022) for records | Oct 2026 |
Problems and how to fix them
| Question | Code basis |
|---|---|
| How Do You Respond to an FDNY Plan Exam Objection? | 2022 NYC Fire Code FC 104.8, 104.9, 105.2.3, 105.2.4, 105.4; 2022 NYC Building Code BC 907 with NFPA 72 (2016) as modified by Appendix Q; Local Law 195 of 2018; FDNY TM-1 (7-7-25); NYC Charter Section 666 |
Fire protection approvals are the permits, plan examinations, inspections, witnessed tests and closeout documents that an authority having jurisdiction (AHJ) issues before a sprinkler, standpipe, fire pump, fire alarm or special hazard system can be installed and placed in service. Every project in New York, New Jersey, Pennsylvania, Maryland and Delaware goes through some version of that sequence, but the office that reviews the plans, the code edition it reviews against, the form it wants and the clock it runs on change at every state line, and in New York City they change between two agencies on the same project.
This guide is for owners, developers, architects and construction managers who need to know, before a project starts, who approves what and how long the path is likely to take. It explains the three layers every approval has, compares the six jurisdictions DGA Fire Protection Engineering works in plus federal projects, and gives each jurisdiction its own section with links to the DGA guides that answer the narrower questions.
At a Glance: Fire Protection Approvals by Jurisdiction
- What this topic covers: how fire protection plans are filed, examined, permitted, inspected, tested and closed out by building officials, fire officials, water purveyors and federal agencies in New York State, New York City, New Jersey, Pennsylvania, Maryland and Delaware, including variances and appeals when the prescriptive code does not fit.
- Governing codes and editions (as of November 2026): New York State 2025 Uniform Code, based on the 2024 International Codes (I-Codes), administered under Title 19 of the New York Codes, Rules and Regulations (19 NYCRR) Part 1203; New York City 2022 Construction Codes (Administrative Code Title 28) and 2022 Fire Code; New Jersey Uniform Construction Code (UCC), New Jersey Administrative Code (N.J.A.C.) 5:23, on the 2024 I-Codes since August 17, 2026, with the Uniform Fire Code, N.J.A.C. 5:70, on a 2018 International Fire Code (IFC) basis; Pennsylvania UCC, 34 Pa. Code Chapter 403, on the 2021 I-Codes since January 1, 2026, with no statewide fire code; Maryland Building Performance Standards on the 2021 International Building Code (IBC), Code of Maryland Regulations (COMAR) 09.12.51, and State Fire Prevention Code, National Fire Protection Association (NFPA) 1 and NFPA 101 (2024), COMAR 29.06.01; Delaware State Fire Prevention Regulations, Regulation 701 (2026 edition), with NFPA 1 and 101 (2024) and NFPA 13 (2025), and the IBC adopted county by county; federal buildings under the General Services Administration (GSA) Public Buildings Service (PBS) Core Building Standards, which replaced the rescinded P100, and federal leases under the GSA lease and GSA Form 12000.
- Who it applies to: any owner or tenant installing, altering or placing a fire protection system in service, and the architects, engineers, contractors and expediters who file for them.
- The 3 decisions that drive cost: which code edition and which office the submittal is written for (a wrong guess means a resubmission); whether the design relies on an alternative, variation or variance that needs its own approval track; and how early the water purveyor, insurer and fire official are brought in alongside the building official.
- Where to start: identify every AHJ with a say on the project (there are usually at least two), confirm the adopted edition in each, then plan the filing sequence around the slowest review.
- Related services and tools: DGA's code consulting and Fire Department of the City of New York (FDNY) approvals services, the Fire Code Cheat Sheet for adopted editions and the Timeline Estimator for planning ranges (all linked under Working with DGA below).
How Fire Protection Approvals Work: Three Layers
Every fire protection approval in the region has three layers, and a submittal has to get each one right. The first is the adopted code: the code and edition a jurisdiction has written into law, which is the edition the design is reviewed against regardless of what is newest. The second is the reviewing office: the building official, fire official, state agency or federal engineer with the power to examine the plans and inspect the work. The third is the filing and sign-off: the application or portal that starts the review and the closeout document that ends it.
The sequence through those layers is the same in every jurisdiction even though the names change. The design team fixes the code basis, prepares sealed drawings and calculations, and files them with the office that has jurisdiction over that work type. A plan examiner issues objections or comments, the designer answers them, and the office issues a permit or plan approval.
After the permit, the installer builds, the inspector checks rough-in and concealed work, and the AHJ witnesses the acceptance tests the adopted standards require. The jurisdictions differ in who holds each step: in New York City the sprinkler permit sits with the Department of Buildings (DOB) while the fire alarm plan sits with FDNY, and in most of Delaware the State Fire Marshal reviews the fire protection plans in a submittal separate from the county building permit. DGA's guide to how AHJ review works in NYC, NJ and Philadelphia shows what reviewers there expect in a submittal.
From Code Basis to Certificate of Occupancy
Who the AHJ Is in Each Jurisdiction
An authority having jurisdiction is the office or official with the legal power to enforce a code on a project and to accept or reject the work done under it. Most fire protection projects have at least two: the building official who issues the permit and the certificate of occupancy, and a fire official, fire marshal or state reviewer who reviews the fire protection systems, witnesses tests or enforces the fire code once the building is in use. DGA's guide to what an AHJ is and how to find the right one covers the definition and the search.
Two other authorities are easy to forget until they stop a project. The water purveyor decides whether a fire service connection, backflow preventer and meter arrangement are acceptable, and its flow data sets the design basis. The insurer is not a public authority, but a carrier recommendation written into a lease or loan has the same effect on the design, and FM Global data sheets often ask for more than the code minimum.
The table names the building reviewer, the fire protection reviewer, the filing system and the path for alternatives in each jurisdiction. Each row is expanded in its own section below.
Who Reviews Fire Protection Work, as of November 2026
| Jurisdiction | Building reviewer | Fire protection reviewer | Filing system | Alternative or variance path |
|---|---|---|---|---|
| New York City | DOB | DOB for the Sprinkler (SP) and Standpipe (SD) work types; FDNY for fire alarm, fire protection plans and non-water suppression (Local Law 195 of 2018) | DOB NOW: Build; FDNY TM-1 through FDNY Business | DOB Construction Code Determination (CCD1); FDNY fire alarm variance on the TM-4 |
| New York State (outside NYC) | City, town or village code enforcement official under 19 NYCRR Part 1203; the county or the Department of State (DOS) where a municipality opted out | The same official; a county fire marshal where one reviews, as in Nassau County | Municipal building permit application | Petition to DOS under 19 NYCRR Part 1205, decided by DOS staff or a regional board of review |
| New Jersey | Municipal construction official | Fire protection subcode official in the construction office; the Department of Community Affairs (DCA) for listed projects and for Class 1 and 2 structures the local office is not classified to review | Construction permit on forms F100 and F140 | Variation from the construction official (N.J.A.C. 5:23-2.10); appeal to the construction board of appeals |
| Pennsylvania | Municipal code official or its certified third-party agency; the Pennsylvania Department of Labor and Industry (L&I) for commercial work in opt-out municipalities and for state-owned buildings | The same UCC reviewer; a local fire code official only where a municipality adopted a fire code | UCC building permit application; eCLIPSE in Philadelphia | Appeal, variance or extension petition to the municipal board of appeals (34 Pa. Code 403.122); the Industrial Board for L&I decisions |
| Maryland | County or municipal permit office | A designated local fire official, such as Montgomery County's permitting department or the Baltimore City Fire Department; otherwise, and for State-owned property, the Office of the State Fire Marshal (OSFM) | County permit; the Fire Marshal Plan Review form for OSFM review | Building code: the building official; fire code: alternatives approved by the State Fire Marshal or designee (COMAR 29.06.01.04B) |
| Delaware | County building official, or a city such as Wilmington | Delaware Office of the State Fire Marshal (SFM); a city fire marshal that reviews in its place, such as Wilmington's | SFM site, building and system applications, on paper; county or city building permit | Alternative requested from the SFM (Regulation 701 section 1.7); variances and appeals to the State Fire Prevention Commission |
| Federal (GSA) | GSA regional fire protection engineer for GSA-owned buildings; the local building official for leased buildings | GSA regional fire protection engineer; for leases, the GSA fire protection engineer who reviews the Form 12000 package | Design review submittals; GSA Form 12000 with a lease offer | Equivalent level of safety accepted by GSA's fire protection engineer |
New York City: DOB and FDNY
New York City writes its own construction and fire codes on an I-Code base and splits fire protection approvals between two agencies. The Department of Buildings (DOB) examines and permits sprinkler and standpipe work under the 2022 NYC Building Code, with NFPA 13 and 14 (2016) as modified by its Appendix Q, filed in DOB NOW: Build as the SP and SD work types. The Fire Department of the City of New York (FDNY) examines fire alarm plans filed on its TM-1 application through FDNY Business, a job that moved from DOB under Local Law 195 of 2018 for filings made on or after June 2, 2019. DGA's comparison of which approvals belong to DOB and which to FDNY sets out the full split, including fire protection plans and non-water suppression.
DOB and FDNY: Who Approves What in New York City
- Sprinkler (SP) and standpipe (SD) plan examination and permits in DOB NOW: Build
- 2022 Building Code Chapter 9 with NFPA 13 and 14 (2016) as modified by Appendix Q
- 40 calendar days to approve complete, code-compliant documents (Administrative Code 28-104.2.7)
- Special inspections under Building Code Sections 1705.29 and 1705.30, certified on the Technical Report form (TR1)
- Sign-off of each SP and SD permit; Letter of Completion or certificate of occupancy for the job
- Fire alarm plan examination on the TM-1 for filings since June 2, 2019 (Local Law 195 of 2018)
- Building Code Section 907 with NFPA 72 (2016) as modified by Appendix Q, the 2022 Fire Code and FDNY rules
- 40 calendar days to act on each submission (Fire Code Sections 105.2.4 and 105.4)
- Inspection of the installed alarm; Letter of Approval when it passes, Notice of Defect when it fails
- Fire Code enforcement for every system once the building is occupied
Both agencies run review clocks set in code, as of November 2026. Administrative Code 28-104.2.7 gives DOB 40 calendar days to approve complete, code-compliant construction documents, extendable once by 20 days for good cause, and 2022 NYC Fire Code (FC) Section 105.2.4, which FC 105.4 applies to fire alarm documents, gives FDNY 40 calendar days from each submission, resubmissions included, to approve or to deny with written grounds, extendable once by 40 days for good cause. FC 105.2.3 treats an FDNY application as abandoned 180 calendar days after filing unless it is diligently pursued, and FDNY's application page says resubmission is free within six months of the Letter of Deficiency. The steps are set out in DGA's guides to fire protection plan review at NYC DOB, FDNY TM-1 fire alarm filing and responding to an FDNY plan exam objection.
On an existing building, the DOB NOW job type decides how the work is filed and closed. An Alteration-CO changes the certificate of occupancy (CO), an Alteration closes with a Letter of Completion, and a Limited Alteration Application (LAA) lets a licensed contractor file small sprinkler and standpipe jobs within the limits of Administrative Code 28-101.5, as DGA's guide to NYC alteration types and fire protection filings explains. Alteration applications filed on and after July 17, 2027 fall under the NYC Existing Building Code, enacted as Local Law 33 of 2026, which ends the owner's option to alter a prior code building under the 1968 code.
Closeout runs through both agencies. Each SP and SD permit is signed off after a passed final inspection or a certified final technical report, and the required sprinkler and standpipe special inspections are certified on the job's TR1, as DGA's guide to TR1 special inspections for sprinklers explains. The closing letter for sprinkler work comes from DOB, as DGA's article on whether FDNY issues a sprinkler Letter of Completion explains, while FDNY inspects the installed alarm, issues a Letter of Approval when it passes and lists failed items on a Notice of Defect, formerly the Letter of Defect, covered in how an FDNY Letter of Defect is cleared. A temporary certificate of occupancy (TCO) or final CO waits on those letters and sign-offs, as the guide to NYC TCO and CO fire protection sign-offs lays out.
Once a building is open, FDNY enforces the Fire Code for every system, whichever agency approved the installation, and DGA's article on whether the NYC Fire Code or Building Code Chapter 9 governs explains the split between design and operation. Owners need the right FDNY certificate of fitness holders for each system, and older buildings may owe work under retroactive laws such as Local Law 5 of 1973 and Local Law 26 of 2004, which DGA's checklist of NYC retroactive fire laws sorts by building type.
More New York City guides:
- How to get a Place of Assembly Certificate of Operation in NYC
- What a NYC Letter of No Objection confirms for a building with no CO
- What the NYC sprinkler five-year inspection involves
- How Local Law 97 projects affect fire protection systems
- What NYC requires for construction site fire safety
New York State Outside New York City
Outside the five boroughs, fire protection plans are approved by the code enforcement official of the city, town or village as part of the building permit, under the 2025 Uniform Code and the minimum program rules in 19 NYCRR Part 1203. The 2025 Uniform Code took effect December 31, 2025 with no transition period after that date, is based on the 2024 I-Codes and, through the 2024 IBC, references NFPA 13 (2022) for sprinklers. Where a municipality has opted out of enforcement under Executive Law Section 381, the county or the Department of State (DOS) enforces instead, and the State enforces for its own agencies' buildings under Part 1204.
Part 1203 requires every local program to issue permits and inspect fire protection systems, but it sets no number of days for plan review, as of November 2026. When an official fails to act within a reasonable time, the remedy is an appeal to DOS under 19 NYCRR 1205.3(a)(2). The construction documents must show, with the seal and signature, that a New York licensed architect or engineer prepared them (1203.3(a)(3)(ix)). DGA's guide to how fire protection plans are approved in New York State walks through the permit, and the article on who approves fire protection in Westchester and Long Island covers the county layer, including the Nassau County Fire Marshal's review of system drawings.
Relief from the Uniform Code comes from the State, not the local official. A variance is petitioned to DOS under 19 NYCRR Part 1205, which decides routine and alternative compliance cases itself and sends the rest to one of six regional boards of review that decide within 60 days of a complete petition unless there is good cause, as DGA's guide to getting a code variance in New York State explains.
New Jersey: The UCC, the Fire Protection Subcode and the Uniform Fire Code
New Jersey enforces the Uniform Construction Code through municipal construction offices, and the fire protection work on every permit falls under the fire protection subcode, N.J.A.C. 5:23-3.17, with its scope set by the responsibility tables in 5:23-3.4. A licensed fire protection subcode official in the construction office enforces it, as DGA's guide to the NJ fire protection subcode and who enforces it explains. The Department of Community Affairs (DCA) Bureau of Construction Project Review takes the plan review instead for listed project types and for Class 1 and 2 structures the local office is not classified to review (5:23-4.24).
The application is the F100 permit jacket with the F140 Fire Protection Subcode Technical Section and sealed plans, and the construction official must grant or deny it within 20 business days and act on resubmitted plans within 7 (5:23-2.16(a)). A missed deadline counts as a denial that can be appealed, not as an approval, and no permit issues until every required prior approval under the NJ UCC, such as zoning, is in place. The filing steps are in DGA's guide to fire protection plan review under the NJ UCC.
The UCC moved to the 2024 I-Codes on August 17, 2026, which puts sprinkler and fire alarm design on NFPA 13 (2022) and NFPA 72 (2022), and a complete application submitted through February 17, 2027 may still be reviewed under the prior codes, as covered in what NJ's 2024 code adoption changed for fire protection. Work in existing buildings follows the NJ Rehabilitation Subcode, where the category of work decides which sprinkler and alarm rules apply, and relief from a UCC provision is a variation applied for on DCA form F160.
Once the building is in use, the Uniform Fire Code takes over, enforced by the local fire official on a 2018 IFC basis, so a project designed under the 2024 IBC is inspected under a fire code on a 2018 IFC basis once it opens. The Uniform Fire Code carries life hazard use registration for listed uses and the New Jersey sprinkler retrofit laws in its Fire Safety Code, and DGA's comparison of the NJ UCC and the Uniform Fire Code shows which one applies to a given project.
New Jersey's Two Codes: The Work and the Building in Use
- New construction, additions, alterations and changes of use, including sprinkler, standpipe and fire alarm installation
- 2024 I-Codes since August 17, 2026; NFPA 13 and 72 (2022)
- Construction official and fire protection subcode official; DCA review for listed projects
- Forms F100 and F140; decision within 20 business days
- Variation on form F160; certificate of occupancy or approval at the end
- Buildings in use: maintenance, fire inspections and permits for listed activities
- 2018 IFC basis
- Local fire official, with DCA's Division of Fire Safety
- Life hazard use registration (5:70-2.6) and fire permits (5:70-2.7)
- Retrofit rules in the Fire Safety Code (5:70-4), installed under a UCC permit
Pennsylvania: The UCC, Who Reviews and No Statewide Fire Code
Pennsylvania's Uniform Construction Code moved to the 2021 I-Codes on January 1, 2026, and fire protection plans for a commercial building are reviewed as part of the building permit. The building code official must grant or deny a commercial application within 30 business days of filing, extendable by written agreement (34 Pa. Code 403.43(a)), as DGA's guide to fire protection plan review under the PA UCC explains. Sprinkler design under the 2021 IBC references NFPA 13 (2019), one of the changes covered in what PA's 2021 code adoption changed for fire protection.
Who reviews depends on how the municipality chose to enforce the UCC. In municipalities that enforce it, the reviewer is the municipal code office or a certified third-party agency it retains; where a municipality opted out, the Pennsylvania Department of Labor and Industry (L&I) reviews commercial work, and L&I reviews every state-owned building. L&I's Municipal Elections and Contact List shows each municipality's choice, and DGA's comparison of who reviews fire protection plans in Pennsylvania sets out each path.
Who Reviews Fire Protection Plans in Pennsylvania?
Pennsylvania has no statewide fire code. The UCC brings in the IFC only to the extent the other adopted codes reference it (34 Pa. Code 403.21), so operational permits, fire inspections and maintenance rules apply only where a municipality has adopted a fire code by ordinance, as DGA's article on whether Pennsylvania has a statewide fire code explains. The older Pennsylvania Fire and Panic Act no longer governs design or permits, though it still matters as a record for buildings approved before 2004.
Philadelphia and Pittsburgh run their own city departments. Philadelphia's Department of Licenses and Inspections (Philadelphia L&I) reviews sprinkler, standpipe and fire pump work under a Fire Suppression Systems Permit filed in eCLIPSE, against Title 4 codes built on the 2021 IBC and the 2018 IFC, as covered in how Philadelphia fire protection approvals work. The city's high-rise retrofit and yearly certification rules are in Philadelphia's own sprinkler and fire alarm laws, and Pittsburgh's Department of Permits, Licenses and Inspections issues suppression and fire alarm permits through OneStopPGH, as described in how Pittsburgh fire protection approvals work.
A code official's decision is challenged by petitioning the municipal board of appeals for an appeal, variance or extension under 34 Pa. Code 403.122, or the Industrial Board when L&I made the decision. A municipal board must hear the matter within 60 days of the request, and DGA's guide to appeals and variances under the PA UCC covers the grounds and the evidence.
Maryland: Two Codes, County Review and the State Fire Marshal
Maryland applies two state codes to one building. The Maryland Building Performance Standards (COMAR 09.12.51) adopt the 2021 IBC with Maryland amendments effective May 29, 2023 and are enforced through the county or municipal building permit, while the State Fire Prevention Code (COMAR 29.06.01) adopts NFPA 1 and NFPA 101 (2024), effective June 23, 2025, and is enforced by the State Fire Marshal or a designated local fire official. Neither code says it overrides the other, so each item is designed to the stricter limit, as DGA's comparison of Maryland's building code and NFPA 1 and 101 explains.
In Maryland, the county building permit reviews sprinklers to NFPA 13 (2019) through the 2021 IBC, while the State Fire Prevention Code (NFPA 1, 2024) references NFPA 13 (2022). The building code also carries Maryland amendments; for example, COMAR 09.12.51.04B(17) lowers from 1,000 to 300 the Group A occupant load at which activation of the fire alarm must initiate a signal through an emergency voice/alarm communication system (IBC Section 907.2.1.1). On the fire code side, Maryland deletes NFPA 1 Section 1.12 (Records and Reports) and makes the Section 1.13 permits discretionary under each AHJ's own policies (COMAR 29.06.01.08), so the State issues no NFPA 1 operational permits as a matter of course.
Review starts at the county or city permit office. Where a local fire official is designated, that office reviews the fire protection plans; elsewhere, and for all State-owned property, the Engineering Services Section of the Office of the State Fire Marshal (OSFM) does, as DGA explains in how fire protection plan review works in Maryland and when the Maryland State Fire Marshal reviews plans.
The largest jurisdictions run their own review. Montgomery County's Department of Permitting Services issues separate Fire Protection System and Fire Alarm System permits filed through ePlans, under a county fire code on NFPA 1 and NFPA 101 (2021), one edition behind the State code. Prince George's County's Department of Permitting, Inspections and Enforcement requires fire protection shop drawings to pass a third-party reviewer the owner hires before it issues the permit, as covered in how Montgomery and Prince George's approve fire plans.
Baltimore City sits outside the State Fire Prevention Code except for buildings under Public Safety Article Title 6, Subtitle 4, and the Baltimore City Fire Department reviews fire protection plans under the city's own fire code, the 2021 IFC. Baltimore County applies NFPA 1 and NFPA 101 (2024), and DGA's guide to how Baltimore City and County approve fire protection covers both.
In most of Montgomery and Prince George's counties, WSSC Water (the Washington Suburban Sanitary Commission) approves the fire service connection separately from the county permit, as DGA's article on what WSSC requires for fire service connections explains. New one- and two-family dwellings and townhouses must be sprinklered under International Residential Code Section R313 as adopted in the Building Performance Standards, covered in Maryland's sprinkler law for new homes.
Delaware: State Fire Marshal Review and County Building Codes
Delaware splits a project between two reviews. The Delaware Office of the State Fire Marshal (SFM) reviews the site plan, the building plans and each fire protection system before construction under the Delaware State Fire Prevention Regulations (Regulation 701, 2026 edition), while the county or city issues the building permit under its own building code. Submittals go on paper to the New Castle, Kent or Sussex division, and the SFM witnesses the hydrostatic test and performs the acceptance test before the building is occupied, as DGA's guide to Delaware State Fire Marshal plan review explains.
The 2026 edition took effect January 1, 2026 and adopts NFPA 1 and NFPA 101 (2024), NFPA 13, 20 and 72 (2025) and NFPA 25 (2023), with permit and plan submittal rules moved into a new Regulation 701A, as covered in what changed in Delaware's 2026 fire prevention regulations. Regulation 701 deletes NFPA 1 (2024) Chapter 1 except Section 1.13, rewrites 1.13.1 to point to the Delaware regulations and deletes 1.13.2 to 1.13.8 (sections 3.2.1.1 to 3.2.1.3), so Delaware issues its own licenses and permits instead of NFPA 1 permits.
Delaware has no statewide building code: as of November 2026, New Castle and Sussex counties enforce the 2021 IBC, Kent County and Wilmington the 2018 IBC, and towns with their own building departments can set their own edition, as shown in which building code applies in each Delaware county. Inside Wilmington, the city Fire Marshal's Office reviews fire protection plans in place of the SFM, because Regulation 701 leaves plan review to city fire marshals that hold exclusive jurisdiction under Title 16, Section 6612(c) of the Delaware Code, as covered in how fire protection approvals work in Wilmington. Alternatives of equivalent safety are requested from the SFM under Regulation 701 section 1.7, and variances and appeals go to the State Fire Prevention Commission.
Federal and GSA Projects
Federal work runs on its own track, and ownership decides which rules apply. A building on federal property follows the codes and criteria its agency adopts, with the agency deciding compliance, while a privately owned building with a federal tenant stays under the state and local codes with the lease requirements added on top, as DGA's comparison of federal and local fire codes on a federal site explains. Under 40 U.S.C. 3312, local officials may review a federal agency's plans on request for up to 30 days, inspect during construction and recommend changes, but they cannot bring an action, impose a fine or collect fees.
GSA rescinded the P100 Facilities Standards on February 24, 2025, and GSA-owned and lease-construction projects awarded on or after October 1, 2026 follow the 2026 PBS Core Building Standards: the I-Codes, NFPA 101 for egress and listed NFPA standards, reviewed by GSA's regional fire protection engineers, who act as the AHJ under GSA order PBS 5921.1. DGA's article on whether GSA P100 is still required covers the transition, and the sector guide to fire protection for federal and GSA buildings sets out each ownership case.
Space GSA leases in an existing building answers to the lease. The current GSA lease template (L100, May 2026) requires a building-wide fire alarm when any Government space is on the 3rd floor or higher, sprinklers up to the highest Government floor when any space is on the 6th floor or higher, and a fully sprinklered building when that space comes with 35,000 ANSI/BOMA Occupant Area (ABOA) square feet or more of Government occupancy, as DGA's guide to GSA lease fire protection requirements explains. The offeror documents the building on GSA Form 12000, with Part B prepared by a licensed fire protection engineer when the space is on the 6th floor or higher (DGA's GSA Form 12000 Part B guide), and the review steps from offer to acceptance are in how federal agencies review leased-space fire protection.
Military facilities follow the Department of Defense (DoD) Unified Facilities Criteria (UFC) instead of state and local fire codes: UFC 1-200-01 as the DoD building code and UFC 3-600-01 for fire protection. DGA's guide to what UFC 3-600-01 is and when it applies covers scope and review.
Fire Protection Plan Review Times and Faster Paths
Three jurisdictions in the region write a plan review deadline into law, as of November 2026. New Jersey's construction official must grant or deny an application within 20 business days and act on resubmitted plans within 7 (N.J.A.C. 5:23-2.16(a)), and Pennsylvania's building code official must grant or deny a commercial application within 30 business days of filing (34 Pa. Code 403.43(a)).
New York City runs two clocks: DOB has 40 calendar days for complete, code-compliant construction documents, extendable once by 20 (Administrative Code 28-104.2.7), and FDNY has 40 calendar days from each submission, extendable once by 40 (FC 105.2.4). The other three jurisdictions leave the pace to the reviewing office: New York State's Part 1203 sets no review period, Maryland has no statewide clock and OSFM publishes no review time, though Prince George's County says most commercial permit applications are reviewed within 4 weeks, and the Delaware SFM publishes no review time while Regulation 701 sets none. Each clock covers one decision, not the whole approval, so the number of resubmission rounds often decides the real schedule, as DGA's comparison of fire protection plan review times by state shows.
Plan Review Clocks by Jurisdiction, as of November 2026
- 20New Jersey: business days to grant or denyN.J.A.C. 5:23-2.16(a); 7 on resubmission
- 30Pennsylvania: business days, commercial work34 Pa. Code 403.43(a)
- 40NYC DOB: calendar days, one 20-day extensionAdministrative Code 28-104.2.7
- 40FDNY: calendar days per submission, one 40-day extensionFC 105.2.4 and 105.4
- NoNew York State, Maryland and Delaware: no statewide clock19 NYCRR Part 1203; OSFM and SFM publish none
Three avoidable mistakes restart review, and none of them is a design error. The first is the wrong edition, such as a sprinkler design run to NFPA 13 (2022) for a Maryland county permit that reviews to the 2019 edition, or a New Jersey set drawn to the prior codes and filed after the grace period ends on February 17, 2027. The second is the wrong office, such as a New York City fire alarm filed in DOB NOW, a Delaware sprinkler plan sent to the county but not to the SFM, or a Pennsylvania commercial permit filed with an opt-out municipality instead of L&I. The third is an alternative method buried in the drawings instead of filed first on its own track, whether an IBC 104.11 alternative or a New York City CCD1, a New Jersey variation or a variance petition.
Faster paths exist, but each one is set by the jurisdiction and the AHJ keeps final authority. New York City lets a registered design professional file by professional certification, so DOB accepts the documents with less than full examination but can audit them later (Administrative Code 28-104.2.1), and Philadelphia L&I offers accelerated review of fire suppression permits for new construction in 5 business days. Prince George's County and Baltimore City use owner-paid third-party reviewers, as DGA's guide to expedited and third-party plan review explains.
Code Editions by State, as of November 2026
The editions below are the ones each AHJ reviews against as of November 2026. New Jersey's move to the 2024 I-Codes on August 17, 2026 and Pennsylvania's move to the 2021 I-Codes on January 1, 2026 are the most recent changes, and the NYC Existing Building Code takes effect July 17, 2027. Local amendments are not shown, and the Fire Code Cheat Sheet linked below adds effective dates and transition rules.
| Jurisdiction | Adopted code and edition | NFPA 13 edition | AHJ | Filing name |
|---|---|---|---|---|
| New York State (outside NYC) | 2025 Uniform Code (Building, Fire and Existing Building Codes of New York State on the 2024 I-Codes), effective December 31, 2025; administration under 19 NYCRR Part 1203 | 2022 | City, town or village code enforcement official; the county or DOS where a municipality opted out | Building permit application (municipal form) |
| New York City | 2022 NYC Construction Codes (Administrative Code Title 28) and 2022 NYC Fire Code; NYC Existing Building Code effective July 17, 2027 | 2016, as modified by Appendix Q | DOB for sprinkler and standpipe; FDNY for fire alarm | DOB NOW: Build, SP and SD work types; FDNY TM-1 through FDNY Business |
| New Jersey | UCC, N.J.A.C. 5:23, on the 2024 I-Codes, effective August 17, 2026, with a grace period for complete applications submitted through February 17, 2027; Uniform Fire Code, N.J.A.C. 5:70, on a 2018 IFC basis | 2022 | Construction official and fire protection subcode official; local fire official under N.J.A.C. 5:70 | Construction permit, forms F100 and F140 |
| Pennsylvania | UCC, 34 Pa. Code Chapter 403, on the 2021 I-Codes, effective January 1, 2026; no statewide fire code; Philadelphia Code Title 4 in the city | 2019 | Municipal code official or third-party agency; L&I in opt-out municipalities and for state-owned buildings; Philadelphia L&I | UCC building permit application; Fire Suppression Systems Permit in eCLIPSE in Philadelphia |
| Maryland | Maryland Building Performance Standards, 2021 IBC (COMAR 09.12.51); State Fire Prevention Code, NFPA 1 and NFPA 101 (2024) (COMAR 29.06.01) | 2019 through the county permit; NFPA 1 (2024) references 2022 | County or municipal permit office; designated local fire official or OSFM | County building permit with fire protection plan review |
| Delaware | State Fire Prevention Regulations, Regulation 701 (2026), NFPA 1 and 101 (2024), NFPA 13, 20 and 72 (2025); IBC 2021 in New Castle and Sussex counties, 2018 in Kent County and Wilmington | 2025 | SFM, or a city fire marshal such as Wilmington's; county or city building official | SFM site, building and system applications, plus the building permit |
| Federal (GSA) | 2026 PBS Core Building Standards for GSA-owned and lease-construction projects awarded on or after October 1, 2026 (P100 rescinded February 24, 2025); GSA lease for leased space; UFC 1-200-01 and UFC 3-600-01 for DoD | Set by the standard or the lease | GSA regional fire protection engineer; the local AHJ for leased buildings | Design review submittals; GSA Form 12000 (Part A or Part B) |
Key Concepts
| Term | One-sentence definition |
|---|---|
| Authority having jurisdiction (AHJ) | The office or official with the legal power to enforce a code on a project and to accept or reject the work, usually a building official plus a fire official on a fire protection project. |
| Code official | The local official who issues the building permit and the certificate of occupancy, called the code enforcement official in New York State, the construction official in New Jersey and the building code official in Pennsylvania. |
| Fire official | The fire marshal or fire code official who enforces the fire code in buildings in use and, in some jurisdictions, also reviews fire protection plans and witnesses tests. |
| Subcode | In New Jersey, one technical part of the Uniform Construction Code, such as the fire protection subcode (N.J.A.C. 5:23-3.17), enforced by its own licensed subcode official. |
| Plan review | The AHJ's examination of sealed construction documents for code compliance before a permit issues, ending in an approval or written objections the applicant must answer. |
| Permit | The written authorization to install or alter a system, issued after plan approval and closed by the inspections and sign-off that follow. |
| Special inspection | An inspection the code requires for listed work, done by a qualified inspector the owner engages rather than by the AHJ, such as the sprinkler special inspection certified on a New York City TR1. |
| Acceptance test | The test of a completed system that the installer performs and the AHJ witnesses before the system is placed in service, such as a hydrostatic test, a fire pump test or a fire alarm functional test. |
| Sign-off | The AHJ's closeout of a permit after a passed final inspection or a certified final report, which New York City DOB requires for every work type before a Letter of Completion or certificate of occupancy issues. |
| Certificate of occupancy (CO) | The document the building official issues when a building or space may lawfully be occupied, which waits for the fire protection sign-offs; a TCO allows occupancy for a limited period. |
| Variance | A formal permission to depart from a code requirement, granted under each jurisdiction's own test by a body such as the New York Department of State, a Pennsylvania board of appeals or the Delaware State Fire Prevention Commission. |
| Variation | New Jersey's term for relief from a UCC provision, applied for in writing to the construction official on form F160 under N.J.A.C. 5:23-2.10. |
Working with DGA on This
DGA's code consulting work on approvals starts before the drawings: confirming the adopted edition in each jurisdiction, identifying every AHJ with a say, deciding whether an alternative method needs its own filing and sequencing the submittals so the slowest review starts first. On New York City projects the FDNY approvals service carries the TM-1, witnessed tests and closeout letters through the Fire Department. The code consulting service page is listed under Related Reading below.
DGA manages fire protection plan review, variances and approvals 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 →
Two tools support the planning step. The Fire Code Cheat Sheet for NY, NJ, PA, MD and DE lists the building and fire codes in force in each jurisdiction with their editions, effective dates, transition rules and reviewers. The Fire Protection Project Timeline Estimator answers four questions with a two-phase planning range: engineering and hydraulic calculations, then the expected AHJ filing and plan review cycle.
Key Takeaway: Every fire protection approval has three layers, the adopted code, the reviewing office and the filing and sign-off, and all three change at every state line and, in New York City, between DOB and FDNY. As of November 2026, New Jersey, Pennsylvania and New York City set plan review deadlines by law, while New York State, Maryland and Delaware leave the pace to the reviewing office. Projects lose time to the wrong edition, the wrong office and alternatives that were not filed on their own track; identifying every AHJ and its adopted code before drawing prevents all three.
Frequently Asked Questions
Does a fire protection project need approval from both a building department and a fire department?
Conditional: in New York City, Maryland and Delaware, usually yes, because a fire agency reviews plans or witnesses tests separately from the building permit. In New York State, New Jersey and Pennsylvania the building official usually holds the permit and the fire official's role depends on the municipality, though New Jersey routes the sprinkler, standpipe and alarm work on every permit through the fire protection subcode official.
Who approves fire alarm plans in New York City?
FDNY. Since June 2, 2019, under Local Law 195 of 2018, fire alarm plans are filed with the Fire Department on the TM-1 application through FDNY Business rather than with DOB, which still permits sprinkler and standpipe work in DOB NOW: Build.
How long does fire protection plan review take?
Conditional: as of November 2026, New Jersey must act within 20 business days (N.J.A.C. 5:23-2.16(a)), Pennsylvania within 30 business days on commercial applications (34 Pa. Code 403.43(a)), New York City DOB within 40 calendar days on complete construction documents (Administrative Code 28-104.2.7) and FDNY within 40 calendar days of each submission (FC 105.2.4). New York State sets no review deadline, and Maryland and Delaware publish none at state level, so timing there depends on the office and its queue.
Which code edition applies to a project in New Jersey after August 2026?
The 2024 I-Codes. New Jersey's Uniform Construction Code moved to the 2024 International Codes on August 17, 2026, with a six-month grace period in which a complete application submitted through February 17, 2027 may still be reviewed under the prior codes, while the Uniform Fire Code for existing buildings under N.J.A.C. 5:70 stays on a 2018 IFC basis.
Can a design that does not meet the prescriptive code still be approved?
Yes. Every jurisdiction in the region has a path for alternatives: a CCD1 determination at New York City DOB, a variation under N.J.A.C. 5:23-2.10 in New Jersey, a variance from the municipal board of appeals in Pennsylvania, a variance petition to the Department of State under 19 NYCRR Part 1205 in New York State, and an alternative approved by the building official or the fire marshal in Maryland and Delaware. The alternative has to be filed on its own track, not buried in the drawings.
Is the GSA P100 still in effect?
No. GSA rescinded the P100 Facilities Standards on February 24, 2025, and GSA-owned and lease-construction projects awarded on or after October 1, 2026 follow the 2026 PBS Core Building Standards. Space GSA leases in an existing building follows the lease's fire protection paragraphs and the local code, documented on GSA Form 12000.
Do Maryland and Delaware issue NFPA 1 operational permits?
No, not as a matter of course. Maryland deletes NFPA 1 Section 1.12 (Records and Reports) and makes the Section 1.13 permits discretionary under each AHJ's own policies (COMAR 29.06.01.08), and Delaware's Regulation 701 deletes NFPA 1 Chapter 1 except Section 1.13, which it rewrites to point to the Delaware regulations, so Delaware issues its own licenses and permits instead.
This guide is general information, not a substitute for a project-specific code analysis. Code editions, local amendments and reviewer practice change; confirm the adopted code and the authority having jurisdiction for each project.
Starting a Project in a New Jurisdiction?
Send the location, the systems involved and the target opening date. DGA identifies every authority with a say, confirms the adopted editions and lays out the filing sequence before the first sheet is drawn. Project briefs get confirmation and preliminary code feedback within one business day.
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Need an engineer on this?
DGA Fire Protection Engineering works on these questions every week for owners, architects and contractors in New York, New Jersey, Pennsylvania, Maryland and Delaware.
