Nationwide Fire Protection Legislative Update: September 2026

Fire protection codes and regulations are changing across the country, and staying informed isn't optional for contractors, distributors, inspectors, and other fire protection professionals.

This September, major updates include new PFAS requirements for firefighting PPE in Illinois and Montana's proposed transition to the 2024 International Fire Code (IFC).

Here are the biggest updates fire protection companies should have on their radar.

Illinois: New PFAS Requirements for Firefighting PPE

Illinois has enacted Public Act 104-0221, also known as the Deputy Chief Pete Bendinelli PFAS PPE Act. The law creates new requirements surrounding per- and polyfluoroalkyl substances (PFAS) in firefighting protective equipment.

Beginning January 1, 2026, sellers of firefighting personal protective clothing containing PFAS must provide purchasers with written notice explaining that PFAS are present and why they were added.

Both the seller and purchaser must keep that documentation for at least 3 years. If requested by the Illinois Environmental Protection Agency, sellers must provide the notice and associated sales documentation within 60 days.

But that's only the first phase.

Beginning January 1, 2027, Illinois prohibits the manufacture, knowing sale, distribution, or distribution for use of firefighting personal protective clothing containing intentionally added PFAS.

Then, beginning January 1, 2030, similar restrictions extend to auxiliary firefighting PPE, including certain respiratory protection, hearing protection, communication, and fall-protection products.

Action Steps for Fire Protection Companies

If you sell, distribute, or purchase firefighting PPE in Illinois:

• Review current inventory for PFAS-containing products.
• Confirm manufacturers can provide required product documentation.
• Create a system for retaining required records for at least 3 years.
• Start preparing purchasing strategies for the 2027 and 2030 deadlines.

Illinois: Broader PFAS Restrictions Are Also Expanding

Illinois also enacted HB2516 as Public Act 104-0231, expanding the state's regulation of intentionally added PFAS in certain consumer products.

Although this law isn't primarily directed at fire protection equipment, it reinforces a larger trend: PFAS regulation is expanding beyond firefighting foam and into additional products and materials.

For fire protection distributors, this makes manufacturer communication and product documentation increasingly important.

Action Step

Start asking suppliers about PFAS content now. Knowing what's in your inventory can help your company respond faster as state requirements evolve.

Montana: Proposed Adoption of the 2024 International Fire Code

Montana is also moving through a major fire-code update.

The Montana Department of Justice has proposed transitioning from the 2021 IFC to the 2024 IFC, with Montana-specific amendments. The proposal is intended to align the state's rules with the current IFC while maintaining consistency with Montana's Building Code.

What Fire Protection Requirements Could Change in Montana?

The proposed rules contain numerous Montana-specific modifications.

One example involves qualifying rural event venues. Under certain conditions, the building official could allow these buildings to operate without a fire sprinkler system, but alternative protections would be required.

Those requirements can include:

• Fire alarms installed according to NFPA 72
• Type I hood fire suppression for commercial kitchens (Kitchen Suppression Systems)
• Fire extinguishers at each exit
• Illuminated exit signs
• Emergency lighting

Potter PE-HSWC Fire Alarm 170003

Badger Standard 10-MB-8H - 10 lb.

Victory Ultra Thin Emergency Exit Sign

Victory Dual Head Emergency Light

Montana also addresses sprinkler requirements for Group R occupancies based on factors such as guest count, dwelling units, and building height.

Interestingly, Montana's proposal does not simply adopt every newer referenced standard. For airport fueling, the state proposes retaining NFPA 407-12 rather than the 2022 edition because officials determined that retrofitting smaller airports to meet an additional overflow-detection requirement would be economically difficult.

Action Steps for Montana Fire Protection Companies

Companies operating in Montana should:

• Review the proposed 2024 IFC amendments. Don't assume Montana will follow the model IFC word-for-word.
• Identify affected customers. Restaurants, event venues, lodging properties, and other commercial facilities may have specific requirements.
• Train technicians and sales teams. Make sure employees understand which code edition and amendments apply before recommending equipment.
• Check your AHJ. Local jurisdictions may have additional or more restrictive requirements. Montana's proposal specifically allows local governments to adopt certain additional IFC provisions or stricter standards.

Stay Ahead of Fire Protection Code Changes

The biggest takeaway from September's updates is simple: don't assume last year's requirements are still today's requirements.

PFAS regulations, IFC adoption, NFPA references, and state-specific amendments can directly affect what fire protection companies sell, install, inspect, and recommend.

This article is for informational purposes only and is not legal or code-compliance advice. Always confirm current requirements with the applicable authority having jurisdiction (AHJ).