The 2025 Building Code of New York State (BCNYS) includes a targeted but impactful change for educational facilities. Under new BCNYS § 917.2, a formal Mass Notification System (MNS) Risk Analysis — conducted in accordance with NFPA 72 — is now a mandatory prerequisite for new school construction at scale. If you're filing permit documents for a qualifying project and this summary is missing, expect a technical objection.
IMPORTANT: BCNYS vs. NYC Building Code
The BCNYS is the statewide building code, administered for school projects by NYSED's Office of Facilities Planning. New York City has its own separate code — the NYCBC — administered by the DOB/FDNY. For NYC school construction, projects often fall under both jurisdictions. Always confirm the governing code authority with your project team and local jurisdiction before filing.
What Exactly Changed in Section 917.2
The NYSED Office of Facilities Planning issued its Notable 2025 Code Changes list on December 15, 2025. The Mass Notification change is Item #1 under BCNYS, and it reads clearly:
"For new buildings containing Group E occupancies with an occupant load of 500 or more, a mass notification risk analysis shall be conducted in accordance with NFPA 72. A results summary of this analysis shall be included with the design documents when submitted for building permit."
— BCNYS § 917.2, Notable 2025 Code Changes, NYSED OFP (12/15/2025)
The key shift: this is no longer advisory. The Risk Analysis summary is a required document in your permit submission package — not an internal engineering note. Its absence is a deficiency, not a minor omission.
Before vs. After: The 2020-to-2025 Shift
| Element | 2020 BCNYS | 2025 BCNYS |
|---|---|---|
| Risk Analysis requirement | No explicit requirement | Mandatory per NFPA 72 |
| Who triggers it | Not defined | Group E, 500+ occupants, new construction |
| Filing requirement | No summary required | Summary included with design documents |
| Code reference | N/A | BCNYS § 917.2 + NFPA 72 |
| Applicable project type | — | New Construction only |
Who Is Affected and When
This requirement applies strictly to new construction. It is triggered when all three conditions are met simultaneously:
- The building is new construction (not additions or alterations on their own)
- It contains a Group E (Educational) occupancy
- The occupant load is 500 or more
Projects that are additions to existing schools, or Level 2/3 alterations, do not directly trigger § 917.2 — though those alteration types carry separate obligations elsewhere in the 2025 EBCNYS worth reviewing.
NFPA 72: The Standard Behind the Analysis
The code doesn't define the Risk Analysis methodology itself — it defers to NFPA 72 (National Fire Alarm and Signaling Code), which provides the framework. Under NFPA 72, a Mass Notification Risk Analysis formally evaluates the facility's communication needs based on occupancy profile, layout, threat scenarios, and notification zone design. The results inform decisions like audibility levels, intelligibility requirements, and the sequencing of emergency messages.
The engineer of record is responsible for conducting and signing off on this analysis. As an expediter, your job is to confirm that a results summary — signed by the RDP — is physically included in the permit package before submission.
Let Automation Handle Your FDNY Filing Paperwork
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Access the Filing Tools →What This Means for Your Submission Package
For expediters preparing permit submissions for qualifying Group E projects, the checklist now includes a new mandatory item. When reviewing your TM-1 and design document package, ask:
- Has the engineer provided a Mass Notification Risk Analysis results summary?
- Is the summary explicitly cross-referenced in the design documents submitted for permit?
- Does the system narrative in your TM-1 reflect the MNS zones and design logic confirmed by the analysis?
- Is the occupant load on the DOB/FDNY records consistent with the threshold of 500+?
Missing the summary at submission is a primary cause for technical objections and delays on these project types. It cannot be resolved with a minor resubmission — the engineer needs to produce and sign the document first.
Other Notable 2025 Code Changes That Affect Your Filings
Section 917.2 isn't the only change from the NYSED December 2025 list that fire alarm contractors and expediters should track. Other items from the same document with direct filing impact include:
- BCNYS § 903.2.9 — Automatic sprinkler requirements for EV bus storage garages with lithium-ion vehicles (new construction + additions ≥500 sf)
- BCNYS § 3006.3 Item 5 — Smoke protective curtain now explicitly required at elevator hoistway door openings (also triggers for Level 2 Alterations)
- FCNYS § 915 — Expanded carbon monoxide detection requirements for Group E occupancies with 30+ occupants, with visible alarm at a staffed location
- FCNYS § 16 / EBCNYS § 510.2908 — New in-building Emergency Responder Communications Enhancement Systems (ERCES) requirements for new and Level 3 alteration projects