Business Impact AnalysisLast week, the Ohio Board of Building Standards posted a 434-page business impact analysis containing all of the comments submitted with regard to the proposed code change on classroom barricade devices.  My comments to the board included a comparison of the recommendations made in the July 2015 OBBS Final Report vs. the proposed code language.  There are numerous conflicts between what the OBBS recommended and the changes that could soon become part of the Ohio code.  The OBBS response to my comments was basically the same as their response to the other comments, including those submitted by the AIA, NFPA, PASS, and close to 20 others:

“Lori Greene submitted written comments included in the attached Exhibit C.  Ms. Greene’s comments compared the draft rules with the Board’s Classroom Barricade Forum Report issued by the Board on July 24, 2015.  The Board’s Code Committee reviewed the comments and information submitted by Ms. Greene and determined not to make a change as a result of the comment.  While the Board does not disagree with Ms. Greene’s analysis, any changes that would be made based on the comments or the Board’s report would be inconsistent with the mandate established by the Ohio General Assembly in Revised Code § 3781.106.  See response to Question 11 and the Board’s July 24, 2015 Classroom Barricade Forum Report attached as Exhibit D.”

The response to Question 11 referenced above basically says that the law passed in Ohio last summer defines many of the prescriptive requirements regarding the use of classroom barricade devices, therefore, the OBBS had no other option but to include these requirements in the code.  This information is on pages 8 and 9 of the business impact statement.  The OBBS understands the concerns and potential problems with the use of these devices, but legislators with little or no experience in code development or codes in general are now writing the codes.  If this practice continues, it will undermine the established code development process and impact life safety of building occupants.

The revised code change proposals are available on this page of the site (in the second section down, called Division of Industrial Compliance / Ohio Board of Building Standards Ohio Building Code).  The Ohio BBS is taking comments on the proposed amendments until January 8, 2016. You may submit your comments via email or U.S. Mail at Ohio Board of Building Standards, 6606 Tussing Rd, Reynoldsburg, Ohio 43068, Attn: Regina Hanshaw.

So now what?  I’m open to any and all ideas to help the legislators understand the issues in hopes that the law will be changed.

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