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August  2004

AAMA Analysis

Skylight Manufacturers Get a 
Helping Hand with NFRC Re-certification
by Larry Livermore

Who would guess that something as simple as the angle at which a product is tested could pose a serious challenge for a group of manufacturers? Skylight manufacturers found that out first hand recently, but turned the issue into an object lesson in the value of working together.

The National Fenestration Rating Council’s NFRC-100:1997 standard provided for U-factor testing of skylight products oriented in a vertical position. While everyone knows that skylights are used on a sloped surface rather than a vertical one, this was the extent of testing and simulating capabilities at the time.

By 2001, new capabilities allowed for more realistic rating of skylight U-factor performance by testing them positioned at a 20-degree slope. Not unexpectedly, this increased the reported U-factor by as much as 19 percent. While not exactly stellar news, skylight manufacturers recognized this as a more appropriate representation of the real world. Testing at the 20-degree slope was thus made a requirement of the updated NFRC-100:2001. A straightforward transition, it would seem.

Transition Poses Certification Troubles
However, transitions often pose difficulties. NFRC Certification Authorization Reports (CARs)–the document issued after products are tested and simulation calculations are performed permitting manufacturers to apply the NFRC label to their products–are good for four years. Products must be re-certified at the end of that period or face the loss of NFRC certification–a real handicap in today’s energy-conscious marketplace. Such re-certification is not trivial in terms of testing and simulation costs, amounting to tens of thousands of dollars. This is an accepted rule of the road for product certification.

But, here’s the dilemma. Certification to the new 2001 standard was not available for such re-certification until April 1, 2003. Any manufacturer that certified its skylights before that date had to use the previous (1997) procedure. Theoretically, such a certification should have been valid as late as March 31, 2007. But, during the last three years of that four-year period, other manufacturers would be certifying to the new standard and facing an apparent 19-percent performance penalty in the marketplace. Confusion would reign among buyers and code officials as well.

So, NFRC ruled that all products had to be re-certified to the new procedure at the uniform deadline of April 1, 2004, regardless of the date on their certificates. Logical, yes–but some manufacturers were caught with their relatively new certifications expiring in as little as one year, and found themselves facing the substantial expense of re-certification as much as three years sooner than expected.

A few manufacturers pleaded their cases to NFRC and, this past March, the NFRC extended the deadline by six months to October 1, 2004. But this did not resolve the issue completely of costly re-testing well before the certification expiration.

Organizations Unite
Working together as a single voice, AAMA and its skylight council worked together with the NFRC to propose a simple and clever compromise that would benefit all involved. The groups worked to make the 1997-tested and 2001-tested products distinguishable in the marketplace and keep manufacturers from spending thousands of dollars in re-testing.

In a response letter from NFRC to all skylight manufacturers, James Benney, NFRC executive director, stated that skylight manufacturers could continue utilizing their existing CARs for 1997 ratings until they expire. In order to clarify for the marketplace which version of the NFRC 100 was used to obtain the certification, all skylight products labeled with 1997 ratings must have “RES97 rated at 90 degrees” on the one-size label by October 1, 2004. All new ratings or re-certifications completed after April 1, 2004, must comply with 2001 NFRC procedures that rate skylights at 20 degrees.

This adjustment would apply only for the remainder of the four-year certification period for existing CARs, after which the manufacturers would–as always–have to re-certify to the new standard. In roughly three years, everyone would be back on the same page. The NFRC does, however, encourage skylight manufacturers to move to the 2001 ratings as soon as possible.

This approach was seen as representing a “win-win” option for all concerned.

Steve Richter, president of Crystalite Inc. and a member of AAMA, was particularly pleased with the decision. 
“This situation illustrates the importance of being a member of an industry organization such as AAMA. Without AAMA membership support, it is doubtful that the individual skylight manufacturers across the country could have affected this compromise, which saved potentially thousands of dollars to those manufacturers that would have to re-test products prior to the sunset date of their four-year certification cycle.”

Once again, this is an opportunity where AAMA members working together collaborated with the NFRC to develop a process that was fair to the skylight manufacturers and the fenestration industry as a whole.

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