• Welcome to The Building Code Forum

    Your premier resource for building code knowledge.

    This forum remains free to the public thanks to the generous support of our Sawhorse Members and Corporate Sponsors. Their contributions help keep this community thriving and accessible.

    Want enhanced access to expert discussions and exclusive features? Learn more about the benefits here.

    Ready to upgrade? Log in and upgrade now.

Pennsylvania Construction Codes Debacle: A Call for Reform of the PA UCC

jar546

jar546

CBO
Joined
Oct 16, 2009
Messages
13,198
Location
Not where I really want to be
The Pennsylvania Uniform Construction Code (PA UCC) has become a bureaucratic maze, riddled with inconsistencies and inefficiencies that create confusion for code officials, contractors, and designers alike. The convoluted system overseen by the Pennsylvania Department of Labor and Industry and the Review and Advisory Council (RAC) has fragmented the International Code Council (ICC) model codes, leaving users to navigate a mess of outdated references, scattered amendments, and multiple codebooks just to piece together compliance requirements.

A System in Disarray​

Unlike states such as Florida, which has adopted a clear and comprehensive Florida Building Code (FBC) by integrating its modifications into a unified state-specific document, Pennsylvania still relies on a patchwork approach. Pennsylvania’s code adoption process is an exercise in frustration. The state picks and chooses sections from different editions of the ICC codes while maintaining outdated language in critical areas. For example, IRC section R602.10, which governs bracing requirements, remains locked in the 2006 edition despite Pennsylvania having since adopted more recent versions of the IRC.

The recently published 2021-UCC-Code-Adoption-Final-Report highlights just how convoluted this process has become. The RAC’s adoption of the 2021 International Codes includes dozens of modifications, exclusions, and carryovers from previous code cycles. For instance, Pennsylvania chose to adopt the 2021 International Residential Code (IRC) but still retained portions of the 2015 and even 2006 IRC in critical areas. This forces professionals to reference outdated language that no longer aligns with best practices or modern construction standards. Additionally, the 2021 International Building Code (IBC) was adopted with modifications that exclude crucial sections such as Chapter 1 (Scope and Administration), creating further inconsistency and uncertainty in enforcement.

Adding to the confusion, Pennsylvania does not recognize Chapter 1 of the IRC or IBC, replacing it with state statute 34 Pa. Code § 403. However, some inspectors mistakenly believe that Chapter 1 of all ICC codes is not adopted at all, which is incorrect. Chapter 1 is crucial for properly enforcing the International Energy Conservation Code (IECC), International Plumbing Code (IPC), and other I-Codes, as these rely on the administrative provisions found in Chapter 1. This misconception creates enforcement issues, leaving code officials unsure of their authority and regulatory framework, further undermining uniform application.

The Case for a Pennsylvania Building Code (PBC)​

The logical solution is for Pennsylvania to abandon this piecemeal approach and develop a comprehensive Pennsylvania Building Code (PBC), akin to Florida’s FBC. By working directly with the ICC to produce a fully integrated set of codes specific to Pennsylvania, the state could:
  • Eliminate Confusion – A single, consolidated codebook would provide clarity by embedding all state amendments directly within the text, rather than requiring users to cross-reference multiple sources.
  • Ensure Uniform Enforcement – Standardized code provisions across municipalities would promote consistency in plan reviews, inspections, and compliance.
  • Streamline Training and Education – Code officials, contractors, and design professionals would no longer need to decipher conflicting requirements from different code cycles, improving efficiency and reducing training costs.
  • Improve Code Adoption Efficiency – Rather than the RAC dragging out the review process with incremental and sometimes arbitrary changes, a streamlined, state-specific code adoption model would allow for more predictable updates.

Legislators Must Act​

The responsibility for fixing this mess lies with Pennsylvania’s legislators. The RAC and the Department of Labor and Industry have demonstrated that their current methodology is fundamentally flawed. The 2021-UCC-Code-Adoption-Final-Report itself is evidence of this dysfunction—rather than creating a clear and modernized code; it lists an overwhelming number of exclusions and modifications that make compliance a guessing game.

If Pennsylvania is serious about improving its construction code enforcement, reducing regulatory confusion, and fostering a more efficient and consistent building industry, it must follow the lead of states like Florida and create a PBC that fully integrates ICC modifications into a single, authoritative document.

It’s time for lawmakers to get off their hands and mandate that Pennsylvania work with the ICC to develop a state-specific set of building codes that eliminates the fragmented, outdated, and convoluted system currently in place. Pennsylvania builders, code officials, and residents deserve better.
 

Attachments

One thing good about this is that builders won't argue with the inspector because it is almost imposable for them to understand the PA codes. They don't know it's the same for the inspectors too.
 
Deletion of chapter 1 in the IBC, IRC, and other model ICC publications is pretty common, PA does not have that market cornered.

NJ has done it from their first adoption of the 2000 IBC and continue to do it still today.

https://codes.iccsafe.org/content/NJBC2021P1/chapter-1-scope-and-administration

I believe the frustration lies in that PA has done and continues to do such a poor job of providing a clear and followable path, and continues to not correct the patchwork of poor modifications at adoption when only focused on a point and not the method of getting there.

That is what happens when they are only interested in the cliff notes and not the novel.
 
They need to get ICC to print a version of the codes with the state amendments, like Virginia and many other states do. It looks like a lot of the state revisions are just reprinting entire paragraphs when one word is added or changed.
 
The even more embarrassing aspect of IBC adoption is PA is that they are trying to adopt a 2021 code in the summer of 2025, and still can't enforce it because they haven't submitted the required regulatory language for approval. The enforcement date is now "TBD", and at this point I don't expect it to happen this year.
 
dasman66 said:
The even more embarrassing aspect of IBC adoption is PA is that they are trying to adopt a 2021 code in the summer of 2025, and still can't enforce it because they haven't submitted the required regulatory language for approval. The enforcement date is now "TBD", and at this point I don't expect it to happen this year.
Click to expand...
The UCC started off well-intentioned, was then bastardized from top to bottom, and continues to be an embarrassment to the state. There are more unnecessary statutes altering the code, which makes matters worse.
 
jar546 said:
The UCC started off well-intentioned, was then bastardized from top to bottom, and continues to be an embarrassment to the state. There are more unnecessary statutes altering the code, which makes matters worse.
Click to expand...
How did it get so bad? I feel like you can't accidentally stumble into this situation.
 
steveray said:
Politics....The same way everything gets screwed up...
Click to expand...
I mean, fair, but what was the logic of this system originally? Like, I'm sure they had some idea what they were attempting to accomplish with this system. Even the stupidest, most corrupt politician has a reason for doing what they do. Clearly this system was meant to benefit someone.

Is it just for the sake of chaos? Are they trying to be more confusing to an outsider than California? Because, I'll be honest, I think they succeeded here.
 
For example...here is our 1964 Statute for demolition:

Sec. 29-406. (Formerly Sec. 19-403g). Permit for demolition of particular structure. Exemption. Waiting period. (a) No person shall demolish any building, structure or part thereof without obtaining a permit for the particular demolition undertaking from the building official of the town, city or borough wherein such building or part thereof is located. No person shall be eligible to receive a permit under this section unless such person furnishes to the building official: (1) Written notice of financial responsibility in the form of a certificate of insurance specifying demolition purposes and providing liability coverage for bodily injury of at least one hundred thousand dollars per person with an aggregate of at least three hundred thousand dollars, and for property damage of at least fifty thousand dollars per accident with an aggregate of at least one hundred thousand dollars; (2) written notice in the form of a certificate of notice executed by all public utilities having service connections within the premises proposed to be demolished, stating that such utilities have severed such connections and service; (3) written notice that such person is the holder of a current valid license issued under the provisions of section 29-402, or is exempted from such license requirement as provided in subsection (c) of said section; and (4) a written declaration by such person that the town or city and its agents shall be saved harmless from any claim or claims arising out of the negligence of the applicant or the applicant's agents or employees in the course of the demolition operations. No permit shall be issued under this section unless signed by the owner and the demolition contractor. Each such permit shall contain a printed intention on the part of the signers to comply with the provisions of this part.

By some sort of stupid law....I can't let someone tear down part of their house without the utilities being disconnected...And a demo license when we don't even have a building license...
 
And here is the one that says I can't issue a permit without water company approval which I have never been able to get:

Sec. 19a-37d. Changes to public water supply systems. Required notifications to water company and local building inspector. Authority of local director of public health to implement mitigation measures. (a) Any person engaged in the installation of an irrigation system or other physical connection between the distribution system of a public water supply system and any other water system shall notify the water company servicing the property or building of such installation and shall be subject to all applicable rules and regulations of such water company. For purposes of this section, “water company” has the same meaning as provided in section 25-32a.

(b) When a permit application is filed with the local building inspector of any municipality concerning any project that includes a change of use or installation of fixtures or facilities in a building that may affect the performance of, or require the installation of, a reduced pressure principle backflow preventer, a double check valve assembly or a pressure vacuum breaker, the local building inspector shall provide written notice of the application to the water company serving the building not later than seven days after the date the application is filed. Upon receipt of such written notice, the water company shall cause to be performed an evaluation of cross-connection protection by a person who has met the requirements prescribed in the regulations of Connecticut state agencies and such water company shall notify the local building inspector regarding its determination. The local building inspector shall not issue a permit or certificate of occupancy until any cross-connection issue has been corrected.
 
Incredible...
steveray said:
And here is the one that says I can't issue a permit without water company approval which I have never been able to get:
Click to expand...
Pretty sure CA has something similar. Every single project I work on, if I so much as touch a plumbing fixture, the water district reviews the plans. Difference is, they actually review the plans (or pretend to, like the Fire Department, and just sign off on everything - I've never seen a comment from them).
steveray said:
(2) written notice in the form of a certificate of notice executed by all public utilities having service connections within the premises proposed to be demolished, stating that such utilities have severed such connections and service;
Click to expand...
Wait, so, if someone wants to demo a bedroom for whatever reason, the utilities must be disconnected and service stopped for the building?
 
arwat23 said:
Incredible...

Pretty sure CA has something similar. Every single project I work on, if I so much as touch a plumbing fixture, the water district reviews the plans. Difference is, they actually review the plans (or pretend to, like the Fire Department, and just sign off on everything - I've never seen a comment from them).

Wait, so, if someone wants to demo a bedroom for whatever reason, the utilities must be disconnected and service stopped for the building?
Click to expand...
No one does it, but by the stupid law....yes
 
Let's look at the very first Act that was enacted within months of the UCC taking effect in 2004.

Pennsylvania Act 92 of 2004 – What It Means for Building Officials​


Act 92 amended the Pennsylvania Construction Code Act (PCCA), which is Pennsylvania’s statewide building code law. The PCCA adopts and enforces the Uniform Construction Code (UCC), which is based on the International Codes. Act 92 changed definitions, exemptions, and enforcement rules, and clarified what municipalities can and cannot regulate.

If you are used to the I-Codes in other states, think of this as Pennsylvania’s legal “overlay” that modifies when and how the codes apply.

1. Expanded and Clarified Definitions​


Act 92 defines key terms that decide whether the UCC applies:
  • Addition – Increasing floor area or height of a building.
  • Alteration – Construction or renovation to an existing structure that is not a repair or addition.
  • Repair – Rebuilding or renewing part of a building to maintain it.
  • Agricultural building – Storage of farm products or housing animals. Includes milk houses and certain religious sect carriage houses.
    • Does NOT include habitable space, product processing areas, or any place open to the public.
  • Recreational cabin – Must be strictly for recreation, not a residence, commercial use, workplace, mailing address, or tax residence. Cannot be over two stories. Must have smoke alarms, CO alarms, and a fire extinguisher.
  • Residential building – 1- and 2-family dwellings and certain small multi-single-family dwellings (≤3 stories) with separate egress.
  • Utility & miscellaneous use structures – Accessory buildings ≤1,000 sq ft (sheds, small detached garages, greenhouses), not including pools or spas.

2. When the UCC Does NOT Apply (Statewide Exemptions)​

Act 92 created several exemptions that completely remove a project from UCC enforcement unless a local ordinance requires otherwise. The UCC does not apply to:
  1. Projects already in design/permitting before the UCC took effect.
  2. Small accessory structures to 1-family homes (≤1,000 sq ft).
  3. Agricultural buildings.
  4. Alterations to residential buildings that do not change structural elements or means of egress.
  5. Repairs to residential buildings.
  6. Recreational cabins that meet all definition and affidavit/insurance requirements.
Important: If a recreational cabin is sold, the seller must disclose the exemption in the sales agreement and deed. If they fail to, the buyer can void the sale.

3. Special Rules for Certain Areas and Projects​

  • Allegheny County (County of the Second Class) – Municipalities here do not enforce plumbing provisions of the UCC. The county enforces plumbing through its own code, which must meet UCC minimum standards.
  • Smoke Alarms in Existing Homes – The UCC does not require hardwired interconnected alarms when altering, repairing, or adding to existing 1- or 2-family dwellings. Instead, battery-operated alarms are required.

4. Municipal Power to Go Beyond the UCC​

Municipalities can adopt ordinances that:
  • Exceed UCC minimum administrative provisions.
  • Add requirements for alterations or repairs to residential buildings.
  • Impose stricter standards for small utility/miscellaneous structures.
However, these ordinances must be adopted following proper legal procedures.

5. Inspector Training and Waivers​

  • The state defines inspection categories (e.g., building, electrical, plumbing, energy).
  • A certified code administrator may act in place of a lumber grading agency for certain IBC provisions.
  • Waivers from initial training/certification can be granted for equivalent past training or experience, but continuing education is still required.

6. Other Exemptions​

  • Manufactured homes with a federal compliance label and industrialized housing under state law are exempt.
  • Religious beliefs exemption – Members of recognized religious sects may be exempt from certain electrical provisions if they file an affidavit. Applies to dwellings and one-room schoolhouses. On sale/lease, the building must be brought into compliance unless the new owner files the same affidavit.
  • Natural cut trees – State code does not regulate them, but municipalities may restrict placement by ordinance.

Practical Takeaways for Building Officials​

  • Many small residential projects, repairs, and agricultural structures are completely outside the UCC unless your municipality has adopted stricter local ordinances under §503.
  • Recreational cabin exemptions are narrow. If a structure is ever used as a residence or for work, it loses the exemption.
  • Allegheny County plumbing enforcement is county-level only.
  • Always check whether a project truly meets the definition of an exempt category before waiving UCC requirements. Misclassification could expose the municipality to liability.
 
How Act 92 Changed Single-Family Permit Authority in Pennsylvania

Section 104(b)(4) and (5) of the Pennsylvania Construction Code Act (PCCA), as amended by Act 92 in 2004, lists exemptions where the Uniform Construction Code (UCC) does not apply.

Two key exemptions for residential work are:
  • (4) Any agricultural building.
  • (5) Alterations to residential buildings that do not make structural changes or changes to means of egress, except as might be required by ordinances in effect under Section 303(b)(1) or adopted under Section 503.
If your municipality did not have a building code ordinance in place before the PCCA took effect in 1999, your ability to require permits for single-family home work is limited.

Without a pre-1999 ordinance:
  • You cannot require a UCC permit for residential alterations that do not affect structure or egress.
  • You cannot require a permit for most residential repairs.
  • Enforcement is limited to what the UCC covers now — primarily new homes, additions, major structural alterations, and work affecting means of egress.
With a pre-1999 ordinance:
  • If your municipality had a building code and permit requirement before April 8, 2004, and kept it in effect through UCC adoption, you can continue to enforce those same permit requirements under Section 303(b)(1).
  • You can still require permits for residential alterations and repairs, even when the UCC would normally exempt them.
  • Expanding beyond that now requires adopting a new ordinance under Section 503.
Key point:
  • Pre-1999 code municipalities have broader authority to require permits for single-family work, including minor alterations, siding, roofing, window replacements, etc.
  • Post-1999 municipalities are bound by the UCC’s limited scope unless they formally adopt stricter local requirements under Section 503.
  • Once a pre-1999 ordinance is repealed, it cannot simply be revived without going through Section 503.
 
You must log in or register to reply here.
Back
Top