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August  2004

The Rate Debate

The Case Against Self-Certification
by Jim Benney

Since its inception, the National Fenestration Rating Council (NFRC) has been linked closely with state and national code enforcement. In fact, it can honestly be said that the NFRC was founded in large part to serve the needs of those who develop and enforce building codes.

Since then, NFRC’s role in the code arena has grown broader and deeper. The last time we redesigned our temporary energy performance label, we made changes with building officials in mind. Our most recent survey of building officials, conducted in 2000, found that more than half relied on NFRC labels to determine if fenestration products met code. We can only assume that even more do so today, as NFRC certification references and requirements have spread to more states.

Despite NFRC’s terrific progress, there is still a challenging road ahead. Even today, there are manufacturers attempting to “self-certify” and place non-NFRC labels on their products.

NFRC Heads South for SHGC
NFRC’s rating procedures began with U-factor. As enforcement of U-factor requirements expanded in the north and east, the use of NFRC’s labels followed suit. However, NFRC labeling and certification did not grow as fast in the southern region of the country because strengthening U-factor performance is not perceived as being as important as important in warm weather states. The biggest issue in these states is, of course, air-conditioning loads, not heating bills.

California again led the way in recognizing the role that fenestration products played in admitting solar heat into buildings. Title 24 specified limited solar heat gain for glazed products in those climate zones with significant cooling requirements; and relied upon NFRC 200 as a reference for establishing those limits. 

The major breakthrough came in 1998, when the first edition of the International Energy Conservation Code (IECC) established a prescriptive limit on the amount of solar heat gain through windows, patio doors and skylights for the first time. As with U-factor, the IECC relied on NFRC standards to ensure a uniform application of the ratings. The code also relied on NFRC labels to assure a means of enforcing the energy codes in cooling codes.

Replacements, Remodeling and Commercial
The 1998 IECC also brought other major national changes. For the first time, the code established prescriptive requirements, both U-factor and SHGC, for residential replacement windows. California has now followed a similar path for its 2005 standards.

As a result of all these changes, the code comprehensively covers the entire window market for the first time. The net effect of these requirements, along with those solidly in place for new construction, is to necessitate NFRC-rated products for most applications.

The bottom line: as codes increasingly reference and require NFRC ratings for a wider spectrum of products, the importance of NFRC certification grows.

Self-certification threatens to roll back these advances. This practice places the entire burden of enforcement on building inspectors and the building code agency, even though they have no way to know if the manufacturer truly performed the required tests and simulations in accordance with NFRC standards and at accredited laboratories. A desire to self-certify ignores the painful history of the window industry, which led to the development of NFRC and independent, accredited laboratories in the first place. Self-certification takes us back to the 1970s and 1980s when manufacturer claims and stated performance values were NOT credible and NFRC strongly opposes the practice. NFRC has worked (and will continue to work) closely with the building code organizations to educate them on the need to look for NFRC labels. We simply don’t want to throw away all the progress we have made. 

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