Window Safety and Sill Heights
Proposed Changes Won’t Solve Safety Issues

by Michael Fischer

n 1999, 560 children aged ten and under died in non-arson related residential fires in the United States, according to statistics by the National Fire Protection Association (NFPA). In 2001, there were 383,500 residential fires in the United States, resulting in 3,110 deaths—more than 500 from children ages five and under. In fact, during the five-year period between 1994 and 1998, children five and under represented 9 percent of the population, but accounted for 17 percent of the U.S. residential fire deaths. In 2001, more than 41,395 U.S. firefighters were injured while at fires, and, in 2002, 97 died while on duty.

According to the U.S. Consumer Product Safety Commission (CPSC), approximately 12 children ages ten years and under die annually as a result of injuries incurred in falls from windows. Many of these occur when children are playing on furniture, especially beds, placed near windows. A review of child fall data from reports from the Chicago Housing Authority shows furniture placement as a key factor in a majority of those incidents. 

Statistics from the CPSC and the NFPA indicate a huge disparity between the death rate for children from residential fires and from window falls. Therefore, any attempt to improve window safety performance to reduce child window falls must not come to the detriment of the emergency escape and rescue features of residential construction. Without regard to all of the safety issues, more harm than good may be done. 

In spite of the need to keep a balanced approach to these safety issues, the International Code Council code committees voted recently to require a 24-inch sill height minimum for windows located more than six feet above grade. They chose to do so: 
• Despite the fact that no data was presented showing how a 24-inch sill height would reduce child falls; 
• Despite the potential adverse effect on emergency escape and rescue during home fires that already result in approximately 50 times the number of deaths to children ages ten and under; 
• Despite the fact that no data was presented showing sill height as a contributing factor in child window falls, and despite the fact that none of the safety organizations, both public and private, providing safety education in the United States recommend changes in window sill height minimums; and 
• Despite the fact that the numbers of child fall deaths are decreasing.

How is it that in a growing population living in more residences than ever before, the actual number of child fall deaths is decreasing? The incidence of window falls by children is an important safety concern in the United States. Because of the need to reduce the number of falls and deaths from windows, the industry has worked hard to provide education to parents and promote awareness on the part of safety advocate groups. Those efforts are working. Between 1994 and 2001, according to the CPSC, annual child fall deaths dropped from 18 to an annual estimate of 12. If the existing programs are improving fall safety, then any effort at modifying the built environment must not have an adverse effect on the greater issue of fire safety.

Life Safety as Lifesavers 
There are many other factors contributing to child falls from windows. Economic factors for example, may place limits on the size of sleeping rooms. Smaller rooms may mean a greater likelihood that beds and other furniture items will be placed near windows, potentially increasing the chance of window falls. In some cases, increasing sill heights add to the likelihood that a bed would be placed adjacent to that window, due to a perception that higher windows create “furnishable” wall space. The issues are complicated. That is why any change to architectural considerations must be approached carefully, in an effort to avoid the potentially adverse overall effects on life safety.

The Window and Door Manufacturers Association (WDMA) has been at the forefront of window safety issues for years, including child fall prevention, safety glazing requirements and emergency escape and rescue features. While the ICC code committees approved the mandatory minimum sill height proposal during last fall’s hearings in Nashville, the proposal is still subject to final action hearings to be held in May 2004 in Overland Park, Kan. The WDMA filed a public comment seeking to overturn the committee actions on the sill height proposal and intends to work diligently to ensure a balanced approach to window safety. 

The Window Industry Safety Task Force met again in Chicago at the National Safety Council this past October to discuss the potential implications of the ICC actions if approved by the code body. Some of the issues discussed during that meeting were earmarked for follow-up action. These included the need to revisit the available safety data, attempt to gather more specific and up-to-date information about window safety issues for fall and fire events, as well as a review of the effectiveness of window safety educational programs. The task group will be making recommendations for future activities designed to improve overall window safety. 

The WDMA has been and will continue to be an active participant in the window safety debate to help ensure that all safety considerations are discussed. As an important advocate for safety of the built environment, we will act diligently to do our part to help ensure the safest use of our products possible.