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With each edition, the ICC International Codes evolve to address benefits and challenges posed by new materials, technologies, and practices for the design and construction of buildings. The 2024 edition brings updates and new provisions concerning fire safety requirements for foam plastics and exterior wall assemblies containing combustible components, and roof assemblies, many of which contain above-deck foam plastic insulation.

With each edition, the ICC International Codes evolve to address benefits and challenges posed by new materials, technologies, and practices for the design and construction of buildings. The 2024 edition of the International Building Code® (IBC®) is no exception, bringing significant updates and new provisions concerning fire safety requirements for foam plastics and exterior wall assemblies containing combustible components, and roof assemblies, many of which contain above-deck foam plastic insulation. As with any significant updates, knowledge and understanding of these updates are essential for both design professionals and Authorities Having Jurisdiction (AHJ’s) to help ensure the fire safety and code compliance of modern buildings.

The 2024 IBC contains several updates to provisions for exterior wall assemblies containing combustible components. These updates include multiple new provisions and revisions that help code users to determine when vertical and lateral flame propagation testing (i.e., NFPA 285 ) is required, and then prescribe three compliance methods for demonstrating compliance with NFPA 285. Other updates provide specific recognition and requirements for Insulated Metal Panel (IMP) systems, a new NFPA 285 requirement for certain metal-faced veneers using combustible adhesives, and revisions to provisions for certain exterior wall assemblies containing foam plastic insulation. Still further updates have added important information and requirements for roof assemblies and rooftop structures associated with occupied/occupiable roofs.

The 2024 I-Codes also contain sweeping revisions to the duties and powers of the building official provided under the scope and administrative provisions in Chapter 1 that are common across all of the I-Codes.

Authors note: This article is not intended to provide a comprehensive discussion of all changes to the 2024 IBC requirements. It is the code user’s responsibility to review and understand the applicable IBC requirements for their specific project or use as adopted and enforced by the appropriate Authority Having Jurisdiction (AHJ).

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Revisions to section 104.2 provide building officials with clearer and more specific language regarding authority and guidance for determining compliance with the code along with more robust tools to assist with evaluating and approving alternative materials, designs and methods of construction or equipment.

Chapter 1 – Section 104 Duties and Powers of the Building Official

Section 104 is significantly overhauled for all 2024 I-Codes. The changes include a complete reorganization of the section, new tools and options for the building official, and more explicit language regarding code compliance and its determination. Provisions regarding the approval of alternative materials, design and methods of construction and equipment (“alternatives”) are an important compliance path for many exterior wall assemblies, exterior wall coverings, and uses of foam plastic insulation and other polymer-based materials.

Section 104.2 of the 2024 I-Codes now adds language that explicitly grants the building official authority to determine if a building is in compliance, along with additional guidance and tools for doing so. Prior to 2024 such authority was inferred by the general provision providing building official authority to render interpretations of the code and to adopt policies and procedures to clarify the application of code provisions that are in compliance with intent and scope of the code.

“104.2 Determination of compliance. The building official shall have the authority to determine compliance with this code, to render interpretations of this code and to adopt policies and procedures in order to clarify the application of its provisions. Such interpretations, policies and procedures:

1. Shall be in compliance with the intent and purpose of this code.
2. Shall not have the effect of waiving requirements specifically provided for in this code.”

Within Section 104.2 are additional new provisions that provide the building official with additional tools and guidance to assist their compliance determination in the application and enforcement of the code:

• Section 104.2.1 regarding provisions where the code or referenced standard requires equipment, materials, products or services are listed to a specified standard.
• Section 104.2.21402.2 granting the building official authority to obtain technical assistance by requiring the owner or their agent to provide a technical opinion and report at the owner’s cost (Section 104.2.2.1) while also establishing:
• Qualifications for the person or firm providing the technical opinions and reports (Section 104.2.2.2).
• Content of the analysis behind the technical opinions and reports (Section 104.2.2.3).
• Authority for the building official to require tests as evidence of compliance where there is insufficient evidence of compliance available (Section 104.2.2.4).

New Section 104.2.3 rearranges and expands the current provisions governing the building officials’ authority to approve alternative materials, design and methods of construction and equipment. Significant attention was given to this section (formerly Section 104.11) including a new Exception. The exception is provided for performance-based alternatives complying with the International Code Council Performance Code (ICCPC) , however, the exception does not apply to alternatives for either structural materials or structural designs.

The new language of Section 104.2.3 expands the guidance and requirements regarding criteria for establishing equivalence of alternatives. Section 104.2.3.4 on equivalency criteria retains the existing requirement for alternatives to provide no less than equivalent to what the code prescribes in terms of: Quality, Strength, Effectiveness, Durability, and Safety, but replaces Fire Resistance (the defined term) with the more general Fire Safety. Equivalency in Fire Safety encompasses more than just fire resistance as the defined term would suggest.

Section 104.2.3.5 maintains the building official’s authority to require tests as evidence of compliance and substantiation of claims with an added provision regarding the scale of the tests. The new provision requires that tests are, “…of a scale that is sufficient to predict performance of the end use configuration.” This same provision is separately applied to fire tests to demonstrate equivalent fire safety in new Section 104.2.3.5.1 which requires tests are, “…a scale that is sufficient to predict fire safety performance of the end use configuration.”

Section 104.2.3.6 expands the previous provision for Research Reports to make a distinction between “evaluation reports” (Section 104.2.3.6.1) issued by approved agencies and “other reports” (Section 104.2.3.6.2) issued by other qualified persons or organizations acceptable to the building official. The building official is also authorized to require the submittals to be both prepared and stamped by a registered design professional.

Finally, Section 104.2.3.7, another new provision, provides the building official with the authority to require submittal of a peer review (also a new defined term) report along with a request to use alternative materials, designs, or methods of construction or equipment.

Remaining revisions to Section 104 largely center on the keeping of records for approved alternatives, inspections, fees, and tests.

The net result of the revisions to Section 104 provides the building official with more clear and specific language regarding authority and guidance for determining compliance with the code along with more robust tools to assist with evaluating and approving alternative materials, designs and methods of construction or equipment. This is particularly relevant for projects that incorporate advanced materials like foam plastics, insulated metal panels, and other building envelope technologies which may require special consideration due to their unique properties, construction, or functional capabilities.



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The 2024 IBC includes some new defined terms and revisions to existing definitions pertaining to topics of exterior wall assemblies, exterior wall coverings, claddings, and related fire performance and fire safety.

International Building Code® (IBC) Updates:

IBC Chapter 2 – Section 202 Definitions and Terminology

The 2024 IBC includes some new defined terms and revisions to existing definitions pertaining to topics of exterior wall assemblies, exterior wall coverings, claddings, and related fire performance and fire safety. New defined terms (some closely associated with new or revised code provisions) include:

“CONTINUITY HEAD-OF-WALL SYSTEM. An assemblage of specific materials or products that are designed to resist the passage of fire through voids created at the intersection of fire barriers and the underside of roof assemblies that are not fire-resistance rated for a prescribed period of time.”

“INSULATED METAL PANEL (IMP). A factory manufactured panel consisting of metal facings and an insulation core intended for use as a system forming an exterior wall, an exterior wall covering, a roof covering or a roof assembly of a building.”