Vermont Fire and Building Safety Code plan review: NFPA 101, NFPA 1, and the 2021 IBC since November 2025, the energy standards, and the Access Rules

Which Vermont codes apply to a set of drawings?

20 V.S.A. §2730 defines a public building to include a building owned or occupied by a public utility, hospital, school, house of worship, care home, or child care; a building in which two or more persons are employed or entertained; a cooperative or condominium; a building in which people rent accommodations, overnight or longer; a restaurant, store, office, hotel, tent, or place of assembly; and a building owned or occupied by the State, a county, a municipality, or another public entity. Using any part of a building that way makes the whole building public. The definition excludes an owner-occupied single-family residence, a registered family child care home, farm buildings on a working farm, an owner-occupied home with an accessory dwelling unit unless it is rented, and certain outdoor cannabis cultivation buildings; the Division’s ADA page lists only the first three exclusions, so use the statute. Sections 1 and 2 of the 2025 Vermont Fire and Building Safety Code apply it to the construction, alteration, enlargement, repair, equipment, use and occupancy, maintenance, and demolition of those public buildings. The code does not adopt the IRC: its IBC amendments send one- and two-family dwellings and Group R-3 to NFPA 101, so a rented duplex is reviewed under the Life Safety Code, while an owner-occupied single-family home needs no state construction permit, although the energy standards still apply to it and the residential accessibility standards in 20 V.S.A. §2907 apply to new homes other than one an owner builds for the owner’s own occupancy. Towns may adopt building codes under 24 V.S.A. §3101, but those must be consistent with the Commissioner of Public Safety’s rules, Section 11 of the code says the same of any local fire or building code, and the code’s project matrix warns that some communities have adopted rules that exceed the state codes.

Section 2 adopts NFPA 101 (2021), NFPA 1 (2021), the 2021 IBC, and the 2021 IEBC, with the boiler and pressure vessel standards in Section 7, and sets the order for conflicts: an adopted code governs over a code it references, NFPA 101 governs over any other code, NFPA 1 governs over the IBC and the National Board Inspection Code, and where only one code has a requirement, that requirement applies. The project matrix applies the IBC, NFPA 1, and NFPA 101 to new construction, with every IBC chapter except Chapters 8, 10, 11, 13, 27, 28, 29, and 33; for an addition the IBC governs the new construction and the height and area of the existing building plus the addition; for rehabilitation, change of use, and renovation the IEBC covers structural requirements only, and NFPA 101 Chapter 43 and the occupancy chapter govern the rest. The matrix asks for a code analysis with every new or large renovation submittal. Section 12 makes the code effective November 4, 2025, and does not require changes to documents or work that comply with the 2015 code where a construction permit was issued and construction started within 180 days of that date, or the AHJ approved otherwise before plans were submitted; such a building must still meet the 2025 code’s existing-building requirements. The Division’s Codes and Standards page lists the 2015 code as in force to November 5, 2025, a day after that effective date, so confirm which code applied to an application filed in those days. The same page lists the 2025 Electrical Safety Rules on the 2023 NEC, effective November 5, 2025, the 2025 Plumbing Rules on the 2024 IPC, effective November 4, 2025, the 2014 Elevator Safety Rules, and the 2012 Access Rules. All checked November 5, 2026.

The IBC amendments in Section 5 change what a reviewer looks for. They delete IBC Chapter 1 except Section 107 on submittal documents and a few listed sections, and point the IBC’s references elsewhere: the electrical code to the NEC as the Electricians’ Licensing Board adopts it, the IEBC to its structural requirements only, the International Fuel Gas Code to NFPA 54 (2021) with Annex G, the International Mechanical Code to NFPA 1 with NFPA 90A, the International Plumbing Code to the Plumbers Examining Board’s rules, the property maintenance and fire codes to NFPA 1 and NFPA 101, the IECC to the Vermont Building Energy Standards, and the IRC and Group R-3 one- and two-family dwellings to NFPA 101. They replace IBC Chapter 8 (interior finishes) and Chapter 10 (means of egress) with NFPA 101, Chapter 11 with the Vermont Access Rules, Chapter 13 with a CBES certificate that must be posted in any public building other than one- and two-family dwellings and multi-family dwellings of three stories or less before the final occupancy permit, Chapters 27 to 29 with the electrical rules, NFPA 1 with NFPA 90A, and the plumbing rules, and Sections 904 to 918, from alternative extinguishing systems and standpipes to fire pumps, carbon monoxide detection, and responder radio, with NFPA 101 and NFPA 1. A facility with three or more clients receiving care is Group R-4, new Group R occupancies are sprinklered as NFPA 101 and NFPA 1 require, and in buildings of three or more stories and Risk Category III and IV buildings each firestop system needs a label within 2 inches and each fire-resistant joint system labels within 15 feet of each end and at most every 30 feet. Fire walls follow NFPA 1 and NFPA 221 with a minimum three-hour rating, two hours where supervised sprinklers protect both sides, and High Challenge Fire Walls in Risk Category III and IV buildings. Ground snow loads come from the code’s map of Vermont towns, with sites above 2,500 feet approved by the AHJ on a site-specific analysis; the total roof snow load may not be less than 40 psf on roofs sloped 5 degrees or less, or the slope factor times 40 psf on steeper roofs, except on the windward side for unbalanced loading and on partially loaded spans; and foundations must extend at least 5 feet below finished grade unless built to ASCE 32 or on solid rock. The amendment cites the snow load map as Annex VII while the code’s table of contents lists it as Annex V; use the map titled Ground Snow Loads for Vermont by City or Town. New elevator hoistways three or more stories high must be noncombustible or limited-combustible, a stretcher-size car is needed where a passenger elevator is newly installed in a building three or more stories above or below grade plane, and elevator shunt trip is not permitted.

The NFPA 101 and referenced-standard amendments matter as much. New apartment buildings need a supervised sprinkler system unless they have six or fewer dwelling units and each unit has either an exit door directly to the street or yard at ground level or an interior stair serving only that unit, with one-hour separation that extends to the furthest point of exit discharge; a single exit is limited to six or fewer dwelling units per story; new one- and two-family dwellings need a one-hour dwelling unit separation, and the NFPA 101 sprinkler requirement for them is deleted; new day care occupancies are sprinklered unless every client room has a door directly to the exterior at the level of exit discharge; boiler rooms over 500 square feet, or with boilers totaling 1,000,000 Btu per hour or more, need two means of egress; and new outside stairs, ramps, and landings other than the primary entrance must be designed to limit snow, ice, and water by a roof or other approved means. Section 6 bars sprinklers at the top of elevator hoistways, requires new fire department connections to reach the sprinklers regardless of a closed control valve and not to attach to underground piping, and, where an NFPA 13R system serves a building with a single means of egress, requires sprinklers in every part of it, including exterior stairs, balconies, and porches. The NFPA 1 amendments require a licensed professional engineer, or a person the statute exempts, to design an underground private fire service main to NFPA 24 and submit its working plans for a construction permit, limit seismic protection of fire protection systems to essential facilities, and require triangular truss signs on buildings with lightweight truss floors or roofs.

Plan review and permits run through the Division of Fire Safety. Section 8 requires the owner or a designated representative to obtain a construction permit before beginning any construction, addition, alteration, rehabilitation, demolition, or installation of fixed building equipment, unless the AHJ waives it, by filing the application, fee, and construction documents with the Division’s regional office. The documents must be prepared, stamped, and signed by a registered design professional where 26 V.S.A. chapters 3 and 20 require, drawn to scale, and clear enough to show the work will conform; the AHJ may require a registered design professional in responsible charge under IBC Section 107.1 to coordinate submittals by others, and may give preliminary plan review on significant or complex projects. A permit expires if work does not start, or stops, for 12 months. The code’s permit table requires a state construction permit for public building work, rental property and apartment buildings, rented duplexes, single-family homes, and accessory dwelling units, and public tents over 1,200 square feet, but not for work in an owner-occupied single-family home, and notes that a fire alarm, sprinkler, kitchen hood, or elevator installation also needs an electrical permit. The Division’s permits page adds separate fire alarm, sprinkler, fire suppression, exhaust hood, underground piping, and tank applications and a short form for renovations under $200,000, and its plan submittal guidelines list what the drawings should show, from a site plan with distances to nearby buildings and fire department access to occupant loads, rated walls, floors, and ceilings, door and window details, stair details, roof and floor live loads, firestopping and draftstopping, kitchen hood exhaust, interior finish ratings, barrier-free details, and carbon monoxide detector locations, with electrical and plumbing work notices signed by a master electrician or master plumber.

Towns can take over part of that work. Under 20 V.S.A. §2736 the Commissioner may assign enforcement of some or all of the rules, and of the Access Board’s rules, to a municipality with trained officials and sufficient procedures. The Division’s municipal inspection agreements give Bennington, Burlington, Hartford, Montpelier, and South Burlington the code for new and existing public buildings, each with listed exceptions such as state-owned buildings, federally certified health care facilities, or high-rise buildings; Barre, Brattleboro, St. Albans, and Winooski existing public buildings only; and Bellows Falls and Fairfax existing apartment buildings, small lodging houses, and one- and two-family dwellings, with the Commissioner keeping plan review and permitting there.

The energy standards come from separate statutes. 30 V.S.A. §51 applies the RBES to one- and two-family dwellings and multi-family housing three stories or less, and 30 V.S.A. §53 applies the CBES to every other building except farm structures, including all of a mixed-use building of four stories or more. The Department of Public Service’s update page says the rules adopted April 10, 2026 took effect July 14, 2026 and allow compliance with either the 2020 or the 2024 RBES and CBES; for buildings that began construction before that date, the Department calls the choice of standard a question of legal and business risk, and its CBES page quotes a September 17, 2025 executive order giving projects begun on or after July 1, 2024 the same option. The adopted CBES rule says the 2024 CBES is based on the 2020 CBES and the 2018 IECC, with elements of the 2021 IECC and ASHRAE 90.1-2019. Both statutes make a signed certificate posted at the heating or cooling equipment or the electrical panel a condition of the Division’s final occupancy permit for a public building and of a town certificate of occupancy; for the CBES, the primary designer certifies the design and the general contractor, construction manager, or owner certifies the construction, each with an affidavit. The RBES page allows the REScheck path under the 2024 RBES only for homes tested at 0.15 CFM50 per square foot of building shell or tighter with a balanced ventilation system that complies with Section R304.

Accessibility follows 20 V.S.A. §2902 and the Vermont Access Rules, effective April 1, 2012 and amended November 15, 2013, which adopt the 2010 ADA Standards with Vermont amendments, cover the religious buildings and private clubs the ADA exempts, and are enforced by the Department of Public Safety under §2906, with variances heard by the Access Board. Alterations must make altered elements accessible to the maximum extent feasible, and the path of travel to an altered primary function area up to 20 percent of the alteration cost. Section 2903 exempts residential buildings of three living units or less and, unless federal law requires otherwise, frees dwelling units of three stories or less and two- or three-story retail establishments of 15,000 square feet or less from elevator requirements, while the Access Rules limit that retail exemption to two-story retail of 15,000 square feet or less and three-story retail under 3,000 square feet per story; check the stricter test. The code’s project matrix names the “2012 ADA Standards for Accessible Design” where the Access Rules adopt the 2010 ADA Standards, so design to the Access Rules and confirm with the Division. Permit routing is on the Vermont page, and the model codes have their own guides: NFPA 101, NFPA 1, IBC, IEBC, and IECC.

Gather the code analysis, the permit route, and the Vermont standards

Collect the cover sheet and code analysis with the NFPA 101 and IBC occupancy classifications, each code and edition cited, and the construction type; the life safety plan with egress, occupant loads, travel distances, rated assemblies, and sprinkler and alarm coverage; the site plan with building dimensions, distances to nearby buildings, fire department access, and hydrants; floor plans of every level, new and existing, with door and window details, stair details, and interior finish ratings; wall, floor, and ceiling sections with fire ratings and the firestop and joint system listings; structural general notes with the ground and roof snow loads, roof and floor live loads, frost depth, and foundation concrete strength; the heating equipment, ventilation, and kitchen hood information; the electrical, fire alarm, sprinkler, and carbon monoxide detection plans; barrier-free details; the RBES or CBES compliance documents; and the specifications.

Add the town and the scope of any municipal inspection agreement, the owner and use, including rented units or care clients, the construction valuation, whether the building is historic or the project needs Act 250 approval, where the RBES stretch code applies, the dates the construction permit was or will be issued and construction started, the RBES or CBES edition chosen, and the separate sprinkler, fire alarm, suppression, hood, and underground piping permit applications. Download the code and the Access, Plumbing, and Electrical Safety Rules from the Division’s Codes and Standards page and the energy standards from the Department of Public Service.

Trace the Vermont code and standards through the set

Life safety sheets continue in the NFPA 101 guide, the NFPA 1 guide, and the means of egress guide, sprinkler and fire main documents in the NFPA 13, NFPA 13R, and NFPA 24 guides and the fire sprinkler checklist, alarm documents in the NFPA 72 guide, fire walls and firestop labels in the NFPA 221, IBC Chapter 7, and firestop testing guides, fuel gas and ventilation in the NFPA 54 and NFPA 90A guides, snow loads in the ASCE 7 guide, plumbing and electrical notes in the IPC and NFPA 70 guides, elevators in the ASME A17.1 guide, accessible details in the 2010 ADA Standards guide and the accessibility checklist, and the full set in the architectural drawing checklist. Other New England state codes are in the New Hampshire guide, the Maine guide, and the Connecticut guide.

Example: a three-story apartment building filed only with the town

Hypothetical example. A developer plans a new three-story apartment building with six units per floor and a single exterior exit stair, in a Vermont town that has no municipal inspection agreement. The code analysis cites IBC Chapter 10 for egress and the 2021 International Fire Code for fire protection, the sprinkler notes call for an NFPA 13R system and leave the exterior stair and balconies unsprinklered, the structural notes take the ground snow load from the ASCE 7 hazard tool, the energy notes cite the 2021 IECC, and the permit plan lists only the town’s zoning permit.

The code analysis cites IBC Chapter 10 and the International Fire Code, which the 2025 Vermont Fire and Building Safety Code replaces with the means of egress provisions of NFPA 101 and with NFPA 1, both 2021 editions. Where an NFPA 13R system serves a building with a single means of egress, Section 6 of the code requires sprinklers in every part of it, including exterior stairs and balconies. The ground snow load must come from the code’s map of Vermont towns, with a roof snow load of at least 40 psf on low-slope roofs, and a residential building of three stories or less follows the RBES in its 2020 or 2024 edition, not the IECC. A rental apartment building is a public building under 20 V.S.A. §2730, so a Division of Fire Safety construction permit, with separate sprinkler and fire alarm applications, is needed before work begins, and the Vermont Access Rules apply. Confirm the egress and fire code basis, the sprinkler coverage, the snow loads, the energy standard, and the permit route.

The architect rewrites the code analysis on the NFPA 101 and NFPA 1 basis, the sprinkler designer extends coverage to the exterior stair and balconies, the structural engineer revises the snow loads from the town map, the energy consultant moves the compliance documents to the RBES and plans the certificate, and the team files the construction permit application with the Division’s regional office before construction starts. The finding is a citation and permit-route conflict; the Division of Fire Safety decides compliance.

Review a Vermont set with Groundbook

Upload the current drawings and specifications to Groundbook, and state the edition, amendments, and review scope in your instructions. The Vermont Fire and Building Safety Code, the Access Rules, and the Plumbing and Electrical Safety Rules are free PDFs on the Division of Fire Safety’s Codes and Standards page, the statutes are on the Legislature’s site, and the Department of Public Service links free view-only copies of the RBES and CBES. Upload the Vermont rules and any town ordinance as code files, with NFPA 101, NFPA 1, the 2021 IBC and IEBC, the RBES or CBES edition the project uses, and the NFPA standards the code references from copies you are licensed to use where the license permits uploading them. See how Groundbook works with local and licensed codes.

Compare the cover sheet, code analysis, life safety plan, and every discipline’s general notes with the architectural, accessibility, structural, mechanical, fuel gas, plumbing, electrical, fire protection, and energy documents. Flag NFPA 101 or NFPA 1 editions other than 2021, IBC or IEBC editions other than 2021, references to the IFC, IMC, IFGC, IPMC, IRC, or IBC Chapters 8 and 10 that the supplied Vermont amendments replace, new apartment buildings, day care occupancies, or NFPA 13R single-exit buildings without the sprinkler coverage the amendments require, ground or roof snow loads and frost depths that do not match the supplied code, and energy documents that cite the IECC instead of the RBES or CBES. Use the supplied Vermont rules and model codes and cite both sources.

Groundbook compares the set with reference documents you upload, including licensed codes and standards you hold, and links each potential finding to the note or sheet and to the Vermont rule, statute, or model code. It has no built-in library of licensed codes, runs no calculations, and does not design anything. It does not decide whether a building is a public building, whether a town’s inspection agreement covers it, or which energy standard edition applies; each finding is a question for the responsible design professional.

Document review does not certify compliance, issue a construction permit or an energy certificate, or replace the design professional, the Division of Fire Safety’s plan reviewers and inspectors, a municipal inspector under an inspection agreement, the Access Board, or the Department of Public Service.