DWM - 2007 - October

Volume 8, Issue 9 - October 2007

guest column

Misrepresented
It’s Critical for Manufacturers to Play by Product Label Rules
by Val Brushaber

As most anyone in the door and window industry knows, manufacturers deal with new or changing codes constantly. Keeping up with the changes, although a job unto itself, is just the tip of the iceberg. Ensuring that we can sell our products in this ever-changing world of building codes engenders a whole series of adaptations and responses. For example, new code requirements typically prompt a new certification policy that may prompt a new labeling requirement, which often prompts a new manufacturing process … and so forth. And, as if that isn’t enough to think about, we also have to deal with a handful of manufacturers who mislead builders, building code officials and, worse than that, their end-use customers by creating their own performance labels that do not tell the real story.

What’s Required
Currently, the major building codes (the International Building Code (IBC), International Residential Code (IRC), Florida Building Code, etc.) require windows and sliding doors to bear a third-party label showing compliance that identifies the design pressure (DP) rating of those products in accordance with AAMA/WDMA/CSA 101/I.S.2/A440-05. The 2006 IBC and IRC also require swinging doors to bear a third-party certification label for AAMA/ WDMA/CSA 101/I.S.2/ A440-05 or be tested to determine the structural design pressure in accordance with ASTM E330. Manufacturers who are playing by the rules spend a lot of time and money to be sure that their products are tested and labeled to the required levels so the product can be sold legitimately into the coastal markets.

The problem is that not everybody plays by the rules. There are a handful of manufacturers who are selling in areas where building code officials are not enforcing code requirements or truly do not understand them. Such code officials do not recognize the difference between a third-party label and a manufacturer’s own label, nor the difference between DP rating and structural test pressure. They are looking for an easy-to-locate and easy-to-read number on a label that will match up with the records they have on file.

They may not understand what a third-party label is so they accept any type of a label as long as it bears a number that at least meets what they believe they are looking for. Often the manufacturer prints up their own labels, which may reference the 101/I.S.2/A440-05 standard that can be interpreted, though incorrectly, as an AAMA-certified label. Other labels show a number that many times cannot be backed up with a validated test report. Or, if manufacturers are really creative, they go so far as to print a big, easy-to-read number on the label that gives the impression that the value is representative of the DP rating, when in actuality they are showing the structural test pressure (which, per any edition of the 101 standard, is 1-1⁄2 times the actual DP).

Labels Really do Matter
Why the big deal? Because often coastal jobs require a DP50 or higher to meet the wind loads for their regions. A DP35 window rarely meets the code requirements in the higher wind zones. But take a label and manipulate it by printing the structural test pressure for a DP35 instead of the actual DP rating and the value shows up as 52.5 PSF. And if a code official asks to see a test report, the manufacturer merely directs him to the structural test pressure in the report and it matches the 52.5 PSF, so the building inspector approves the certificate of occupancy. To a code official who has been trained to look for a number on a label, the 52.5 number printed in big, bold letters gives the impression the product is “good to go.” If the code official is not versed in the third-party certification concept, he just approved a window far below the structural requirements for the specific area.

What are some of the differences between doors and windows that add to the confusion? Right now, most codes do not require door products to meet air infiltration or water penetration limits—only structural loading. Dade and Broward Counties in the Florida market do require the full gamut of testing, but they are an exception at this time. For windows, a DP rating is reflective of overall air, water and structural performance. Doors can be rated with an overall DP rating that covers air, water and structural performance; or they can be rated for structural performance only. No wonder building officials get confused! And then throw in the structural test pressure on a label and try to explain that this value is different than a DP rating … now you have some heads spinning.

Educate Others Regarding Misleading LabelsThe best defense to this dilemma is to educate building officials so they become trained to recognize an imposter! We all need to make more people aware of the misleading labels being used. This hurts everyone, but especially a homeowner who believes he bought doors and windows that meet the codes required for his location. It would be a horrible thing to find out that someone was injured because the doors or windows blew out during a hurricane or severe storm.

If you are concerned that someone may be misleading building inspectors and homeowners by putting false or not-so-true information on his performance labels, please contact your local building department. It, in turn, can contact AAMA to get an explanation of the differences. This is a serious matter and everyone is working very hard to reduce or eliminate the instances where it occurs. As a manufacturer, I urge you to set up meetings with your builders, architects and local inspectors to train them on what a third-party label really is and the difference between DP ratings and structural test pressures. Teach them how to read a test report and find the actual DP rating so they cannot be misled.

Val Brushaber of Monarch Holdings Inc. is first vice president of AAMA’s door council.