Volume 8, Issue 2 - February 2007


ICC Kicks off Window Safety Study
Sill Code Requirement Raises Confusion
by Michael Fischer

The International Code Council (ICC) Code Technology Committee (CTC) has begun work on initiatives aimed at reducing the incidence of child falls from windows. 

The CTC appointed a study group recently to focus on window safety. The group, a five-member committee comprised of a cross-section of code and industry representatives, held its first meeting via conference call last month to set the scope of data collection and research activities and devise a work plan. 

This initiative comes on the heels of state code adoptions of the 2006 edition of the ICC International Residential Code (IRC). The 2006 IRC contains language restricting the location of operable residential windows when installed 72 inches or more above the adjacent surface by implementing a minimum sill height of 24 inches. Exceptions to that requirement include windows with a limited opening of four inches, and windows equipped with window guards that comply with standards for window fall prevention devices developed by the American Society for Testing and Materials (ASTM). 

Several states have begun to implement the minimum sill height requirement and confusion has reigned thus far, with homebuilders and code officials scrambling to apply the requirements. Inconsistencies in the interpretation of the exceptions for opening limitations, for example, have created a difficult landscape for builders. 

During the ICC code development debate on the window sill height requirement, window industry representatives expressed concerns about potential negative consequences of the proposal. Opponents of the minimum sill height stated that higher window sills could lead to a greater likelihood that furniture would be placed beneath windows. Window safety advocates and research groups including the U.S. Consumer Product Safety Commission (CPSC) have long noted the link between furniture and child window falls, and have advised caregivers to keep beds, desks and other pieces away from windows.

Another concern expressed by minimum sill height opponents was the likelihood that such a rule would result in smaller emergency escape and rescue windows, driving the average window size to the bare minimum allowed by code requirements aimed at providing escape during residential fires.

Window industry advocates urged caution to ICC code development stakeholders, believing that no code requirement (especially one with such a potential effect on the use of windows for emergency and escape and rescue) should be implemented without careful study. The National Safety Council (NSC), a longtime advocate of window safety education, agreed. In fact, NSC representative Alan Hoskins, sent specific correspondence to the ICC to that point, suggesting that the ICC not enact such a rule without a full study of all of the likely outcomes and factors.

Education is the Way

Meanwhile, educational programs and awareness campaigns continue and have helped reduce the numbers of window falls over the past several decades. As part of these efforts, the Window and Door Manufacturers Association (WDMA) has worked with the American Architectural Manufacturers Association (AAMA) and other industry representatives to increase awareness of the need for caregivers and parents to take proactive measures to prevent child window falls in the home.

WDMA messages include a recommendation that nothing can take the place of close parental supervision and a reminder that a parent is best able to influence the environment in which their children live and play. Proponents of minimum sill height requirements disagreed with that approach, claiming that parents are not able to fulfill that role and that only raising the window sill height will prevent child falls.

Despite the position taken by sill height proponents that parental supervision is not the best way to prevent falls, the code requirement contains an exception for windows that include an installed window guard. Ironically, the proper use of such a device necessitates the education of parents and only parents will be able to ensure the guard is correctly in place when children are present. Supporting testimony during development of the sill height requirement decried parental responsibility and the need to supervise young children. However, the code requirement leaves the window guard exception in the hands of those same parents ó even though they could not be trusted to keep the window closed around young children. 

WDMA believes that a balanced approach to all window safety factors is the best way to improve child safety and that awareness campaigns and educational programs do indeed have a well-documented history of success in reducing child falls from windows. These falls and residential fire deaths have decreased in the past several decades as a result of such awareness programs and the use of smoke detectors and window guards. WDMA maintains that the appropriate use of window guards that comply with the ASTM standards does play an important role, especially in multi-family high-rise construction. 

Inconsistencies Arise

Now that the 2006 IRC is being adopted, some of the same inconsistencies noted above are being questioned. While many states striken the minimum sill height requirement during adoption, those which have included it are struggling with various enforcement issues. Meanwhile, the ICC CTC will be studying the issue, albeit several years late. The CTC will be tasked with a review of the code proposal history and will necessarily consider all of the safety issues that come into play. Hopefully the CTC recommendation to the ICC will be based on a careful study of all pertinent factors and not on an emotional response to a difficult problem that requires responsible consideration. Sometimes the cure is worse than the disease. In this case, however, we canít be very certain that the cure is actually even that. 

Michael Fischer of the Kellen Company serves as director of codes and regulatory compliance for the Window and Door Manufacturers Association. He may be reached at MFischer@wdma.com.


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