Volume 7, Issue 10 - November 2006

ICC Code Hearings

Cut Your Losses 
Door and Window Industry Wins Some and Loses Some at Recent ICC Hearings

When the International Code Council (ICC) code development committee hearings were held in Orlando, Fla., in late September, the door and window industry was successful in some areas but not in others. The industry is expected to continue to work hard to fight for the interests of its members as the hearing process continues.

The Window and Door Manufacturers Association (WDMA) was present at the hearings and offered proposals (see sidebar, page 47), as were other associations such as the National Fenestration Rating Council (NFRC) (see story, page 20). The American Architectural Manufacturers Association (AAMA) played a large role as well. In fact, Julie Ruth, AAMA codes consultant, participated in the ICC hearings, and gave a report at the recent AAMA meeting held in Las Vegas (for more on that meeting, see page 64). 

According to Ruth, AAMA took positions on 80 of the proposals, three of which it submitted on behalf of AAMA. Two of those were approved resulting in a 66 percent success rate.

She said that while round one of the hearings occurred in September, the association is now busy preparing public comment on the next round, which are due on January 24, 2007.

Additionally, DWM editors attended the code hearings via the online webcast. 

Following are some of the proposals that were of interest to manufacturers and the resulting vote. 

  • EC93–06/07 and EC94-06/07 were heard together, both changes to Table 502.3 proposed by Garrett Stone, of Brickfield Burchette Ritts & Stone, P.C., representing Cardinal Glass Industries. Both proposals failed to modify the commercial fenestration solar heat gain coefficient (SHGC) requirements by projection factor to reflect a uniform method of determining such requirements, but some said this change would give a competitive advantage to Cardinal Glass. Both proposals failed; EC-93 failed 10-3; EC-94 failed 8-6.

  • E162–06/07. The following proposal (1026.6) to add new text was disapproved:

    Emergency escape ladders. Emergency escape and rescue openings located above the first story in Group R-3 occupancies shall be provided with an approved permanently mounted emergency escape ladder.

    Mike Fischer, of the Kellen Company, representing the WDMA was one of the supporters of this proposal but it was ultimately disapproved 13-1 (see related article, page 8). 

  • On September 28, the following proposal was submitted for the International Residential Code but was ultimately disapproved 10-1. Julie Ruth, representing AAMA and Mike Fischer, representing the WDMA, were some of the supporters of the proposal.

    N1101.8 Certificate was the proposal, that suggests a permanent certificate shall be posted on or in the electrical distribution panel. The certificate shall not cover or obstruct the visibility of the circuit directory label, service disconnect label or other required labels. The certificate shall be completed by the builder or registered design professional, and shall list the predominant R-values of insulation installed in or on ceiling/roof, walls, foundation (slab, basement wall, crawlspace wall and/or floor) and ducts outside conditioned spaces; U-values for fenestration; and, where requirements apply, the solar heat gain coefficient (SHGC) of fenestration. Where there is more than one value for each component, the certificate shall list the value covering the largest area. The certificate shall also list the type and efficiency of heating, cooling and service water heating equipment.

  • RB36–06/07. Joseph R. Hetzel, P.E. of the Door and Access Systems Manufacturers Association proposed a change to R301.2.1 (wind limitations) because, he reasoned, that clarification is needed for the code user regarding provisions governing wind effects on garage doors, particularly wind loads.

WDMA supported the revision. The National Association of Home Builders (NAHB) spoke in opposition because the table is limiting of garage door sizes and the language is questionable Mike Fisher, representing himself, said this is a huge improvement for the industry, and added that he used to sell garage doors.

The proposal was disapproved in a vote of 8-3, because some say this is over-kill and a hurricane-prone region problem, and it doesn’t pass the test of affordability.

Straight from the Hearing Floor
by Mike Fischer

In other action taken at the ICC hearings, several proposals of interest to the industry were considered. Here is a recap of the highlights:

  • Action: Disapproved. EC 9 submitted by GANA et al would allow testing of commercial fenestration in accordance with AAMA 507 and remove the generally accepted reliance upon the NFRC certification program. (For the NFRC view, see page 20. For the GANA view, see page 20).

  • Action: Disapproved. Follow-up: WDMA will work with AAMA via public comment. EC 90 submitted by AAMA provides tradeoffs for increased allowed area and higher U-factors for commercial sloped glazing under the prescriptive fenestration table, when the building is equipped with automatic daylighting controls. The proposal provided a material-neutral approach to the daylighting issue and was supported by WDMA. 

  • Action: Disapproved. Follow-up: WDMA will work on revisions via public comment. EC 91 submitted by WDMA would provide material-neutral prescriptive performance values for vertical fenestration used in commercial occupancies. The concept of material neutrality garnered support, but issues with curtainwall and storefront values drew opposition.

  • Action: Disapproved in favor of EC 95. Follow-up: WDMA will work on revisions with AAMA via public comment. EC 92 submitted by WDMA would provide material-neutral prescriptive performance values for sloped glazing and skylights used in commercial occupancies. WDMA worked with AAMA on a floor modification to revise the proposed values, but the proposal was deemed to be a reduction in stringency and the committee considered a separate proposal submitted by Cardinal Glass. 

  • Action: Approved as Modified. Follow-up: WDMA will work on the concept in EC 92 via public comment. EC 95 submitted by Cardinal Glass would provide material-neutral prescriptive performance values for skylights used in commercial occupancies, but more stringent values than in EC 92. The committee modified the proposal and revised solar heat gain requirements. 

  • Action: Approved as Modified. Follow-up: WDMA will submit revised text via the public comment period. RB 244 submitted by WDMA modifies requirements for installation requirements for flashing at exterior doors and windows. The proposal was modified to provide a pointer within the IRC structural provisions to flashing requirements found elsewhere in the code. The proposal was modified by the IRC committee to retain the provision requiring that window manufacturers be responsible for flashing instructions.

  • Action: Disapproved. Follow-up: WDMA will work with AAMA to submit revised text via the public comment period. RB 245 submitted by WDMA would have placed a threshold height maximum of 7 ¾ inches for exterior doors not serving as a required exit. The proposal was offered due to the continued debate over requirements for landing, floor and stair riser heights. These requirements often conflict with door threshold designs, particularly in areas subject to high wind loads and accompanying water penetration values.

Michael Fischer of the Kellen Company serves as director of codes and regulatory compliance for the Window and Door Manufacturers Association.

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