Code/Concerns, DWM 2004

September 2004

Code/Concerns

It Takes a Village–and Association
Consensus–in Code-Driven Times

by michael fischer

When the International Code Council (ICC) decided to move from annual code cycles to 18-month cycles, the building industry generally greeted the news as a positive step. Having more time to prepare proposals and respond to code actions was, after all, a favorable move.

One of the consequences of the change in cycle timing, however, is the fact that there will be just one supplemental code cycle between each edition of the International Codes. That fact, makes it increasingly important for industry groups to reach consensus. The current cycle (2004/2005 ICC code development cycle) with submittals in August, is no exception. Code proposals will be reviewed by ICC staff for technical substantiation, in accordance with the ICC by-laws, and then published in December 2004. Those proposals will be considered during code committee hearings to be held in February of 2005, and final action hearings slated for September 2005.

Working Together
Representatives from code committees and staff members for the leading fenestration industry trade associations, including the Window and Door Manufacturer’s Association (WDMA), the National Sunroom Association (NSA), the Fenestration Manufacturer’s Association (FMA) and the American Architectural Manufacturer’s Association (AAMA), worked through the summer to agree on common positions concerning many issues facing the industry. Some of the more important issues that are to be considered during the upcoming code cycle include:

Energy Code. The International Energy Conservation Code (IECC) was modified recently with substantial changes to the prescriptive methods used for determining envelope requirements. These changes, proposed by the U.S. Department of Energy (DOE), included the elimination of window-to-wall ratios when using the prescriptive performance compliance method. In spite of the overwhelming support of the DOE proposals by the fenestration industry, there is still some work to be done to fix some glitches in the prescriptive U-Factor values assigned, particularly in some commercial applications with lower glazing areas.

Window Safety. The final action hearing assemblies upheld committee actions that placed a minimum window sill height for residential occupancies as a way to reduce or prevent child falls. WDMA is particularly concerned about these actions and will continue to press for educational efforts—proven as the best means to reduce child window falls—without sacrificing fire safety. The unintended consequence of the ICC action will likely be a reduction in the actual size of egress openings that may very well lead to more fire deaths in the future. WDMA will maintain its efforts and involvement in the window safety task force.

Window Installation. A code proposal mandating installation instructions for every window was approved by the ICC committees in last fall’s code committee hearings. A public comment to clarify those requirements, and remove the manufacturer’s responsibility for installation instructions when a window is placed in a wall system for which it was not intended, and not appropriate, was not approved. WDMA, AAMA and FMA will continue to work to find solutions.

Entry Door Requirements. There has been some confusion regarding the applicability of the joint industry standards, 101/I.S.2 97 and 101/I.S.2/NAFS-02 to entry door systems. The industry associations have completed joint position statements as well as code proposals to define the scope of those documents.
One of the by-products of the consolidation of the three existing model codes into the I-Codes is the actual organization of the requirements for windows, doors and skylights in the International Building Code (IBC) and the International Residential Code (IRC). Reorganiza-tion of those requirements may add clarity to the language, and help to streamline interpretation and enforcement of these provisions. Whether or not this concept is accepted during the current cycle, it will continue to be part of the fenestration industry’s agenda.