Volume 11, Issue 5 - June 2010


It’s Official
ICC Updates Fenestration Codes
in Final Action Hearings

by Tara Taffera

The International Code Council (ICC) held its final action code hearings May 15-23 in Dallas, where issues such as installation, flashing and window egress, took center stage and were heavily debated. The approved updates will be released as part of the 2012 version of the International Codes, available in April 2011, while some of those disapproved changes may return in the next cycle of change proposals.

Installation and Flashing
The International Code Council heard several proposals having to do with door and window installation, as well as flashing. The ICC upheld its original decision regarding RB119, part of the International Residential Code (IRC).

According to this section, doors and windows should be installed in accordance with the fenestration manufacturers written installation instructions. It also states that penetrations and opening in exterior walls shall be flashed or sealed in such a manner that will inhibit entry of water into the wall cavity or penetration of water to the building structural framing components. Self-adhered membranes used as flashing shall comply with AAMA 711.

Jeff Inks, representing the Window and Door Manufacturers Association (WDMA), submitted a public comment during the final action hearings that, among other things, would have addressed the following: “For applications not addressed in the fenestration manufacturer’s written instructions, in accordance with the flashing manufacturer’s written instructions.”

“We haven’t taken any responsibility away from the window manufacturer,” said Inks. “All we have done is provide additional options so they are flashed correctly in situations where manufacturers instructions don’t adequately cover that in particular applications.”

Julie Ruth, representing the American Architectural Manufacturers Association (AAMA), also was in favor of bringing forth Inks’ public comments but ultimately that motion failed.

During the debate over RB 119, many who were opposed to Inks’ proposal mentioned how RB 145, also submitted by Inks, was a better way to address this issue. RB145 came up later that day and that proposal, also brought forward by the WDMA, adds a new definition for pan flashing as: “Corrosion-resistant flashing at the base of an opening that is integrated into the building exterior wall to direct water to the exterior and is pre-manufactured, fabricated, formed or applied at the job site.

That proposal was approved and adds the following text to the IRC:

Flashing at exterior window and door openings shall be installed in accordance with one or more of the following: The fenestration manufacturer’s installation and flashing instructions, or for applications not addressed in the fenestration manufacturer’s instructions, in accordance with the flashing manufacturer’s instructions. Where flashing instructions or details are not provided, pan flashing shall be installed at the sill of exterior window and door openings. Pan flashing shall be sealed or sloped in such a manner as to direct water to the surface of the exterior wall finish or to the water resistive barrier for subsequent drainage. Openings using pan flashing shall also incorporate flashing or protection at the head and sides.

Window Sill Heights
The issue of sill heights once again was debated. RB 122, Part 1, would have raised sill heights from 24 to 36 inches.

“I understand the concern about child safety as I have three kids myself,” said Ruth. “But I’m concerned that when trying to help one part of population we will hurt another [such as the

“Raising sill heights from 24 to 36 inches will have a very significant impact,” added Inks. “That’s a huge leap … As a result we will have a great number of emergency and escape and rescue windows installed with guards or window opening control devices that haven’t been adequately justified and could impede egress in an emergency.”

The proposal ultimately was disapproved.

While RB 122, Part I, deals mainly with single-family structures that are covered by the International Residential Code, RB122, Part 2 would raise sill heights from 24 to 36 inches in the International Building Code. That proposal was approved.

Role of Sprinklers in Window Egress
When E-150-09/10, Part II, a proposed change to the International Residential Code, came up during the hearings, Jeff Shapiro, speaking on behalf of himself, said, “This is probably the most passionate testimony you will hear all week on both sides of the issue.”

Shapiro spoke in support of the proposed change which states that: emergency escape and rescue openings shall not be required in one- and two-family dwellings and townhouses that are equipped with an approved automatic sprinkler system. The ICC committee approved this proposal as submitted last October during the code hearings. The reason was as follows: “The change adds a reasonable exemption based on approved automatic sprinkler systems in the dwelling. This creates an incentive to provide a sprinkler system. Also, this may get some retrofits for additions.”

Another proponent simply pointed out that if a building has sprinklers then it doesn’t have to meet the window egress requirements.

However, speaking in favor of disapproval, Inks brought up some points for the committee to consider.

“These sprinklers don’t require maintenance–that is an important issue that needs to be considered … We don’t know that they will work every time,” he said.

Inks was joined in support for disapproval by many others in the door and window industry including Ruth, as well as fire safety officials including one fire marshal in Colorado who pointed out that windows serve a dual purpose–they allow fire rescue personnel to enter a building in addition to allowing people to get out.

“I support incentives for fire sprinklers,” he said. “They will do what they are intended to do, but people still need to get out.

Another in opposition advised the committee that this is a local trade-off issue—not a national one.

Ultimately, the motion carried for disapproval.

Window Labeling for Egress
A proposal to label windows installed as an “Emergency Escape and Rescue Opening” also was debated heavily. Inks and Ruth were successful in urging the committee to uphold its original action for disapproval.

Other opponents, including one field inspector, pointed out that inspectors verify with a tape measure so labeling is not needed.

Another said, “We don’t need this. An inspector will be on-site with a tape measure, etc. If he doesn’t, he’s not doing his job. Let the inspector do his job. We don’t need these labels on these windows.”

One individual speaking in support of the proposal said, “Everything has labels right now–why should windows be different? It will also help consumers know if the window complies with egress requirements.”

Thomas Zaremba, representing himself, rebutted that argument by pointing out that certain properties such as solar heat gain coefficients, etc., can’t be verified in the field, which is why labels are needed. However, this can be verified easily by taking some measurements in the field, making the labeling unnecessary, he said.

Rick Davidson of the city of Maple Grove, Minn., a proponent of RB 42-09/10, told the committee that “window manufacturers had the opportunity to come back with a solution and came back with nothing.”

“It wasn’t because they didn’t want to do anything,” responded Inks. “It’s because they found there isn’t a viable option that will not require field verification of the opening dimensions.”

Skylight Changes: Some Approved and Some Denied
S144-09/10-PART I, submitted by Ruth, was approved as amended by public comment, and added text to the definition of unit skylights to include tubular daylighting devices (TDDs).

The public comment from Gary J. Ehrlich, PE, National Association of Home Builders, though, proposed that TDDs be defined separately as:

“A non-operable fenestration unit primarily designed to transmit daylight from a roof surface to an interior ceiling via a tubular conduit. The basic unit consists of an exterior glazed weathering surface, a light-transmitting tube with a reflective interior surface, and an interior-sealing device such as a translucent ceiling panel. The unit may be factory assembled, or field-assembled from a manufactured kit.”

“A tubular daylighting device is typically field-assembled from a manufactured kit, unlike a unit skylight which is typically shipped as a factory-assembled unit,” said Ehrlich in support of his proposal. “If the current unit skylight definition is applied to TDDs, some code users will expect that TDDs be entirely assembled in the factory.”

In addition, Ruth’s proposal also added text to say that under 1715.6 skylights and sloped glazing, unit skylights shall comply with the requirements of Section 2405. All other skylights and sloped glazing shall comply with the requirements of Chapter 24, which lays out structural requirements for skylights.

Also approved was a revision to S-3-09, proposed by the Window and Door Manufacturers Association. In section 1503.6, crickets and saddles, it states that a cricket or saddle shall be installed on the ridge side of any chimney or penetration greater than 30 inches wide as measured perpendicular to the slope. The following exception was added, “skylights installed and flashed in accordance with the manufacturer’s instructions.”

Another proposal, S141-09/10, submitted by William E. Koffel, Koffel Associates Inc., representing the Glazing Industry Code Committee, was disapproved. The proposal recommended that products installed in buildings of Group R not more than three stories above grade plane that are tested and labeled as conforming to AAMA/WDMA/CSA 101/I.S.2/A440 would not be subject to the requirements of Sections 2403.2 and 2403.3 of the code, which ensure safe performance through proper support of glass.

ICC Rejects Side-Hinged Exterior Door Standard
The industry debated the topic of exterior door and window assemblies once again during the ICC hearings and the Association of Millwork Distributors (AMD) ultimately was unsuccessful in getting its side-hinged exterior door standard added to the code.

Jeff Burton, director of codes and standards, representing AMD, proposed that R612.8 of the International Residential Code be revised as follows: Exterior windows and door assemblies not included within the scope of Section R612.6 or Section R612.7 shall be tested in accordance with ASTM E 330 or AMD side-hinged exterior door standard (SHEDS).

Burton said this would add an additional option to the code that includes as structural component interchangeability methodology that is prevalent in the SHED industry but is not address in the building codes or its current referenced standards. The addition of AMD SHEDS, which was developed in accordance with the current industry ASTM E330 static pressure test, adds that needed structural component interchangeability option, according to Burton.

Both Ruth and Inks were opposed to the proposal, citing the fact that AMD SHEDS is still in draft form.

Additional reasons for disapproval cited by the two included that they feel provisions of the standard are inadequate, validation test data has not been made available for review and use of the proposed referenced standard would significantly weaken the current requirements of the IRC.

Side-hinged door assemblies also came up later in the code hearings during discussion of S143-09. John Woestman, representing the Door Safety Council, proposed to add new text to 1717.5.2. The proposed language was as follows:

Structural performance of exterior side hinged door assemblies shall be determined in accordance with either ASTM E330 or ANSI A250.13.

He also proposed adding a new standard to chapter 35: ANSI A 250.13-08, Testing of Severe Windstorm Resistant
Components for Swinging Door Assemblies.

That proposal also was disapproved.

All Codes Not Yet Complete
The next round of the International Code Council’s (ICC) hearings is scheduled for October 28-November 1, 2010. The hearing will cover “Group B,” which includes code changes to the International Energy Conservation Code and the International Residential Code - Energy, among others.


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