The Common Building Code
Build once above the strictest safety requirement anywhere you operate, and compute only the non-safety remainder per market
Nothing in this paper constitutes an offer to sell, or a solicitation of an offer to buy, any interest in a Woodfine direct-hold solution; any offering is made only by the applicable Private Placement Memorandum. Statements marked "planned," "intended," "targeted," "may," or "expected" are forward-looking and subject to change. Full disclosures appear at the end of this paper.
Working Paper WCP-008 · v0.1.0 · CC BY 4.0
Our thesis is that a developer who intends to build the same building in many countries should set one design standard, built to exceed the strictest safety requirement found in any of them, and then treat every market's remaining differences as a short list to be computed rather than a design to be redone. We call the result the Common Building Code. It is assembled in three layers: a Class-A specification as the baseline, a national code framework as the next layer, and the genuinely local differences on top of both.
The reason this works is not cleverness on our part. It is a fact about what building codes contain. A building code is overwhelmingly about safety — fire, escape, structure, and access — and comparatively little about anything else. Our own working assessment, from reviewing the codes across the markets we intend to enter, is that in most cases about ninety-nine per cent of a code's content is safety-driven. That is our estimate rather than a published measurement, and we flag it as such, but the direction of it is not in serious doubt to anyone who has read one. If the baseline design already clears the strictest safety requirement in the set, then the baseline has absorbed nearly the whole code, and what is left to handle market by market is the narrow, non-safety remainder: permitting procedure, documentation, local zoning particulars, the administrative texture of building in a particular place.
The hedge belongs here rather than at the end. This holds in the great majority of cases, not universally. Rarely — not never — a local code will contain a safety requirement the Class-A specification does not already encompass, and the arrangement has to cope with that rather than deny it. Section five is about exactly that case.
1. The thesis
Building once to exceed the highest safety bar found anywhere in our markets absorbs nearly all of what a code contains, because nearly all of what a code contains is safety. The remainder is narrow, non-safety, and computable.
The claim is worth separating from a weaker one it resembles. The weaker claim is that standardisation saves money, which is true of almost anything built repeatedly and is not interesting. The claim here is about where the variation actually lives. If a developer believes that building codes differ substantially from country to country in ways that reach the design of the building, then entering a new country genuinely requires a new design, and the cost of the tenth country is much like the cost of the first. If the variation is mostly not in the design but in the paperwork and the procedure around it, then the cost curve is entirely different, and the interesting question becomes which of those two pictures is accurate.
Our position is the second picture, with a specific mechanism behind it. Safety requirements differ in their numbers and their wording across jurisdictions, but they do not differ in kind. Every code in every market we intend to build in is concerned with the same handful of things: that the building stands up under load, that a fire is contained long enough for people to leave, that there is a route out and it is wide enough and reachable in time, and that a person using a wheelchair can get in and use the building. Because they differ in degree rather than in kind, they can be cleared by exceeding the most demanding version of each, once. Procedural and administrative requirements are the opposite: they differ in kind, from place to place, and no amount of over-building clears them. They have to be handled, and they are what remains.
2. The problem, in the reader's terms
Consider how a law firm handles a contract it will sign in twenty countries.
The naive approach is to have a lawyer in each country draft the contract from scratch against local law. This produces twenty correct contracts and costs twenty fees, and worse, it produces twenty different contracts, which means twenty different sets of obligations to track and no ability to say anything general about what the company has agreed to.
The approach a well-run firm actually takes is to draft one master agreement, written to the strictest standard in the set, and then attach a short jurisdiction-specific rider to each copy covering the handful of places local law demands something particular — a statutory notice period, a mandatory governing-language clause, a local filing. The master agreement is the expensive part and is paid for once. The riders are short, they are reviewed by local counsel, and the tenth one costs a fraction of the first. Nobody considers this cutting corners; it is simply how a competent organisation operates across borders.
Building design is ordinarily done the first way. A developer entering a new market commissions a local architect to design a building for that market, reviewed against that market's code from a blank page. The result is a correct building and a full design fee, and nothing learned in the last market transfers except in the loosest sense. Repeat that nine times and a developer has nine buildings, nine design fees, and nine sets of operating characteristics that cannot be compared with one another.
What we are proposing is the second way, applied to a building instead of a contract. One design, drawn once above the strictest safety standard in the set; a short, published list of local differences per market; and a local architect whose job is to redraw the approved design for the local permit and stamp it, rather than to design a building. That redrawing is real work and we do not pretend otherwise — but it is the rider, not the master agreement.
3. What a building code actually contains
A reader who has never had cause to open one will benefit from a short, honest account of what is in a building code, because the whole argument turns on it.
A modern building code is a long technical document, usually running to hundreds of pages, adopted into law by a state, province, or country, that sets the minimum requirements a building must meet to be lawfully occupied. In the United States the dominant document is the International Building Code, written by a non-governmental body and adopted, usually with amendments, by individual states. In Canada it is the National Building Code, drafted federally and adopted by the provinces. In Europe the picture is layered differently: structural design is largely governed by a common set of European standards, with each country publishing its own national parameters within them, while fire and occupancy rules remain national.
Open any of them and the same subjects fill almost all of the pages. How the building is classified by what it is used for and how many people are in it. How the structure must perform under dead load, live load, wind, snow, and — where relevant — earthquake. How the building is divided into fire compartments and how long each separating wall and floor must resist fire. How many exits there must be, how wide, how far apart, and how far a person may have to travel to reach one. How the stairs are enclosed and pressurised. How the sprinklers, alarms, and smoke control work. How a person with limited mobility enters, moves through, and uses the building. What the guardrails, the stair risers, the door hardware, and the glazing must do so that ordinary use does not injure anyone.
Every item in that list is a safety requirement. Between them they are the substance of the document. The non-safety content is real but comparatively slight: energy performance, some accessibility provisions that go beyond safety into amenity, and — mostly outside the code proper, in the zoning ordinance and the permitting process — how tall the building may be, how far it must sit from the property line, how much parking it must provide, what it must look like, which drawings must be submitted, who must stamp them, and how long the authority has to respond.
That division is the whole basis of what follows. Scholars of the built environment have long observed that codes and standards are the quiet language in which places are actually made, and that their content is rarely examined by the people most affected by it [ben-joseph-2005-code-of-the-city]. We examined it because we had to decide whether to design nine buildings or one.
4. What a Class-A Building is
The word "Class-A" is used constantly in commercial property and almost never defined. It is worth defining here, because it is the load-bearing term in our baseline.
Commercial office buildings are informally graded by the market — A, B, and C — on a combination of age, finish, building systems, location, and the quality of tenant the building attracts. The grading is market convention, not a legal classification, and it is applied locally: a Class-A building in a small market may be considerably less building than a Class-B one in a major city. That local relativity is precisely what makes the term unhelpful as a specification, and precisely what we are avoiding.
When we say Class-A, we mean something specific and absolute rather than local: the criteria and codes met by buildings built in the central business districts of major international cities — San Francisco, New York, London, Paris, Berlin. The observation underneath is that genuine Class-A buildings in those cities are strikingly alike. Walk into one in New York, Mexico City, Vancouver, Amsterdam, or Berlin and the differences are small. The variation people notice in the term comes from buildings marketed as Class-A that are not — buildings with a Class-A façade and building systems specified only to the local minimum.
So a Class-A specification, used this way, is an absolute standard imported into markets that do not ordinarily see one. It is the baseline because, in our assessment, a building specified to it sits above what any of our markets requires in almost every respect a code speaks to. That is the mechanism by which the baseline absorbs the code: not by studying every code and satisfying each, but by starting above the top of the range.
Three specific regulatory standards are engineered directly into the baseline's geometry rather than met afterward: a European standard for lighting of indoor workplaces, which governs how deep a floor can be before daylight fails to reach a desk; a Swiss standard for ventilation, which sets fresh air per occupant and therefore the depth of the ceiling space; and the circulation provisions of the German workplace ordinance, which set how wide a corridor must be for the number of people using it [en-12464-1] [arbstaettv]. Each of these is adopted as the standard in place of whatever the local requirement happens to be, on the same logic as the Class-A specification itself: take the more demanding instrument and apply it in every market. Adopting them this way is the same move as adopting the Class-A specification, applied at the level of a dimension rather than a finish.
5. The three layers, and the one that is narrow
The assembly is straightforward once the baseline is understood.
The first layer is the Class-A specification. The prototype design is drawn to it once. Emergency travel distances, exit widths, stair enclosures, elevator provision, and corridor circulation are worked out at this layer to a standard intended to hold across every jurisdiction in scope, rather than being solved per market.
The second layer is a national code framework. The International Building Code is a good base and is used as one — laid over the Class-A specification to catch anything structured differently in codified form than a market convention expresses it [ibc-icc]. The equivalent national instruments in the other markets in scope are read the same way [nbc-2020].
The third layer is the local remainder. This is what is actually computed market by market: the places where a particular jurisdiction's requirement differs from the two layers below it. In practice this has been mostly non-safety in character — permitting procedure, submission and stamping requirements, zoning particulars, the local authority's own conventions — because the safety content was absorbed at the first layer. Where the differences cluster, the response is not a new design but a sub-prototype: a defined variant of the same building, organised around where codes do not overlap rather than around national borders, since the clusters rarely follow borders neatly.
Two consequences are worth drawing out.
The first is that the leasing geometry — the arrangement of rooms, corridors, and divisible spaces that a tenant actually occupies — is untouched by any of this. Because code content is overwhelmingly safety content, and safety is resolved in the building's core and structure, the system that plans the leasable space answers a question the safety layer never reaches. It is a space-planning question, not a code question, and so it was never exposed to jurisdictional variation in the first place. That is why the same leasing system travels across markets unchanged, and it is a consequence of this paper's argument rather than a separate claim.
The second is that the baseline can, and does, go beyond code in places where code is silent but use is not. The clearest instance is washroom provision inside a tenancy. Local codes often do not require a leasehold to have its own washroom, and by the letter of the code a medical or dental practice with a waiting room full of visitors all day could be built without one. The shared washrooms on that floor would then be occupied continuously by one tenant's visitors, which is unfair to every other tenant on the floor. So the baseline sets the requirement by how the space is used and how much daily foot traffic it generates, scaled to the size of the leasehold, rather than by whichever code minimum happens to apply where the building sits. This is the Common Building Code doing something a code does not: making the amenity a tenant receives depend on what they do, not on where the parcel is.
6. Where this does not reach
The honest limit is not the one a reader might expect. It is not that safety requirements escape the baseline — safety is exactly what the baseline is built to absorb, and it is the part we are most confident about. The limit is narrower and it is about time.
A baseline is built to exceed the strictest safety requirement found in the markets in scope as at the date it was last revised. A jurisdiction that adopts a genuinely novel safety requirement afterward is, by definition, not covered by it. This is not hypothetical: codes change, and they change in the direction of more requirement rather than less. Seismic provisions, façade fire performance, and embodied-carbon rules have all moved substantially in the last decade in at least one of the markets in scope.
What follows is a standing obligation rather than a one-time cost. The baseline needs periodic review, and it needs a review each time a new market is entered, with the specific question being whether anything in that market's code is novel rather than merely stricter. We are not claiming this arrangement eliminates local code review permanently. We are claiming it changes local review from a design exercise into a checking exercise — and that the two have very different costs and very different failure modes.
There is a second limit that belongs in the same breath and is more prosaic. A local architect still redraws the approved design for the local permit, stamps it, and carries it through the authority's process. That is real, unavoidable professional work in every jurisdiction, and nothing here removes it. What it removes is the design decision, not the professional.
What this changes for the reader
The change is in how an investor should expect the cost of expansion to behave.
A developer whose design work is redone per market has a cost structure in which the tenth market resembles the first. A developer whose design work is paid once and whose per-market work is a checking exercise and a permit redraw has a cost structure in which the tenth market is materially cheaper and faster than the first. Those are different businesses, and which one a developer is running is not obvious from the outside.
The check available to a reader is specific. Ask whether the developer's building is the same building in each market or a different one. Ask what, precisely, is redrawn per market and by whom. Ask whether there is a published list of local differences, or whether "we adapt to local requirements" is doing the work of an answer. A developer who has genuinely standardised can produce the list. One who has not will describe a process instead.
The trade-offs are real and belong here rather than in a footnote. Building above the strictest requirement everywhere means building above the requirement almost everywhere — a deliberate over-specification, paid for in every market, in exchange for not designing in any of them. A fixed baseline also means walking away from sites the baseline does not fit, rather than adapting the baseline to the site. And the whole argument rests on our own assessment of how much of a code is safety content. If that assessment is materially wrong in some market — if a jurisdiction's non-safety requirements reach the design more deeply than we expect — then the remainder in that market is not narrow, and the economics there look more like the conventional case.
An open invitation
The questions here belong to people who practise code and construction law in the markets we intend to build in, and we would rather work them with those people than around them.
To building-code officials and code consultants across Canada, the United States, Mexico, the United Kingdom, Spain, Italy, Poland, and the Nordic countries: the load-bearing assumption is that a specification set above the strictest requirement in the set clears local safety requirements in all but rare cases. We would genuinely like that tested rather than assumed. The most useful thing anyone could tell us is a concrete counter-example — a real local safety requirement that a central-business-district Class-A specification would not already satisfy, and which would therefore reach the design.
To construction lawyers working across borders: our expectation is that the remainder is mostly procedural, and procedure is your field rather than ours. Where does procedural variation actually bite hardest, and is there a jurisdiction where it reaches design decisions in a way that would break the three-layer arrangement?
To anyone who maintains a standard against a moving regulatory target: the limit we identify — that a baseline covers what existed when it was last revised — is not unique to us, and other industries have solved the review-cadence problem better than a developer entering their first markets is likely to. How often, on what trigger, and assessed by whom?
And to researchers in comparative building regulation: our ninety-nine per cent figure is an internal working assessment, not a measurement, and we have said so. If a real measurement exists, or could be made, we would rather cite it than our own estimate.
Conclusion
Build once, above the strictest safety requirement found anywhere you intend to operate, and compute only the non-safety remainder as a short published list per market. That is the Common Building Code, and the reason it works is a fact about codes rather than a claim about us: a code is mostly safety, safety differs in degree rather than in kind, and what differs in kind is mostly procedure. The arrangement does not eliminate local review, it does not survive a jurisdiction adopting a genuinely new safety requirement without a revision, and it costs a deliberate over-specification in every market. What it buys is that the design is paid for once, and that entering a further market is a checking exercise rather than a design exercise. That is the difference we are building toward.
References
Ben-Joseph, E. 2005. The Code of the City: Standards and the Hidden Language of Place Making. MIT Press.
European Committee for Standardization. EN 12464-1 — Light and lighting: lighting of work places, part 1, indoor work places. Issued by CEN; distributed through national standards bodies.
Federal Ministry of Justice (Germany). Verordnung über Arbeitsstätten (Arbeitsstättenverordnung — ArbStättV), §12 (Verkehrswege). https://www.gesetze-im-internet.de/arbst_ttv_2004/BJNR217910004.html
International Code Council. International Building Code. https://www.iccsafe.org/
National Research Council Canada. National Building Code of Canada 2020. https://nrc.canada.ca/en/certifications-evaluations-standards/codes-canada/codes-canada-publications/national-building-code-canada-2020
Contributors
Prepared by Woodfine Management Corp.
How this paper was produced
This paper is grounded in the operating and development work the preparing staff do themselves, and in what they have learned from the people they work with routinely: the graphic designers, web developers, and software developers and engineers who build the platform alongside them, and the architects and structural, building-services, and civil engineers they develop buildings with. No outside professional reviewed or approved this paper, and nothing in it is professional advice. It was drafted and edited with AI assistance under editorial direction, and the analysis and conclusions are Woodfine's own.
Disclosures
Woodfine Capital Projects Inc. ("Woodfine") is the author of record and is the developer and promoter of the building standard described in this paper; Woodfine Management Corp. employs the staff and retains the consultants who prepare this material and conduct the code review it describes. Woodfine has a direct commercial interest in the approach argued for here. This work was funded internally; no external research funding was received. Nothing in this paper constitutes an offer to sell, or a solicitation of an offer to buy, any interest in a Woodfine direct-hold solution; any offering is made only by the applicable Private Placement Memorandum, which prospective investors should review with their own professional advisors. Nothing here is a legal opinion on the building code of any jurisdiction, and nothing here should be relied on in place of advice from a qualified local architect, engineer, or code consultant. Some statements above describe planned or intended future work; language such as "planned," "intended," "targeted," "may," and "expected" marks this forward-looking content, which is subject to change and does not constitute a commitment regarding future performance. No Woodfine Building has been constructed as at the date of this paper, and no building described here has been submitted for permit in any jurisdiction.
Data and reproducibility
The building codes and standards this paper reasons about are public instruments. Two of them — the American and Canadian national codes — are published by their issuing bodies and readable by anyone, in the Canadian case free of charge. The German workplace ordinance is published in full and free of charge by the German federal justice ministry. The European lighting and Swiss ventilation standards are sold rather than given away by their issuing bodies, which is ordinary practice for European standards and means a reader who wants to check our use of them must buy them. A reader with those documents can verify every characterisation this paper makes of what a code contains.
One figure here is ours rather than anyone else's, and should be read accordingly: the estimate that in most cases about ninety-nine per cent of a building code's content is safety-driven is our own working assessment from reading the codes in the markets we intend to enter. It is not a published measurement, we are not aware of one, and we have not attempted a formal content analysis to produce one. The figure is load-bearing for this paper's argument, which is why we would rather state its status plainly than let it read as established. No independent party has reviewed the baseline specification described here, assessed it against any jurisdiction's code, or confirmed the claims made for it.
Woodfine Capital Projects™ is a trademark of Woodfine Capital Projects Inc.