Volume 39, Issue 2, February  2004

A New Course
Once Solely Focused on the Residential Arena

by Alan B. Goldberg

Until recently, the National Fenestration Rating Council (NFRC) has focused its efforts toward the residential market. Now, it has embarked upon a new course, with an entrance into the non-residential arena. Some in the industry welcome this expansion, while others do not.

What is NFRC?
For 12 years, the NFRC, a non-profit organization formed by the window industry and other stakeholders (including the Department of Energy [DOE], state energy offices, energy service providers, builders and architects), has provided standards on the measurement and reporting of thermal properties of fenestration systems. According to its executive director, Jim Benney, there was no uniform means of measurement prior to the group’s formation. He says thermal values were reported as U-factors, R-values, center-of-glass, whole product, by calculations or various test methods, leading to a credibility gap between the industry and customers due to discrepancies in reporting information. 

In 1991, the NFRC published its first standard—for determining the thermal transmission of fenestration products. Others that followed related to solar heat gain, visible transmission, optical properties, air leakage and condensation resistance.

But NFRC services go beyond publishing standards. The organization also administers an independent, third-party certification and labeling program and an accreditation program for simulating and testing laboratories. Through these laboratories, NFRC says it can offer assurance that the thermal performance ratings are accurate and consistent.

A Move to Non-Residential 
Eighteen months ago, an NFRC non-residential subcommittee reviewed the current rating system and decided there was a need for new ratings, a new program and with it, a need to support the curtainwall industry and its interaction with architects and other parties in the commercial market.

“This expansion and involvement of those who would be affected by new products and energy ratings represents a very exciting turning point in the history of this organization,” said Benney. He explained that the situation in the commercial market is different from residential, where NFRC has seen many positive results from its involvement. One of the reasons, he explained, is the way the architectural community historically has operated. Specifically, the architect or specifier has relied on specifications provided by the manufacturer for meeting performance or aesthetic requirements. 

“It is this reliance on manufacturer specifications that must be challenged,” Benney said. “There are two main reasons: manufacturers’ specifications can change as products change, resulting in a lack of repeatability over time, and manufacturers’ specifications are developed in the absence of consensus and may not represent all the products that are available.”

Comparing these specifications to standards, Benney said “bias” is the key difference. “Standards form the technical basis for agreements (both legal and contractual) because they represent what is mutually acceptable to both parties without bias. This is in stark contrast to a manufacturer’s specification, where typical product descriptions and performance are defined by what the supplier produces or sells,” Benney said. He said that for this reason proprietary test methods rarely are accepted in specifications. 

Another advantage of standard performance specifications is repeatable use. Benney offered the following hypothetical (but typical) example of a building specification that could create problems with compliance due to requirements being open to interpretation:

“System 1208 by Curtainwall Co. Inc. or equivalent with 1-inch insulating glass utilizing Clear Lite (from XYZ Glass Inc.) or equivalent. System U-factor must meet or exceed U=0.75 or solar heat gain coefficient ( SHGC) of 0.40 inches.”

He describes three potential problems with this type of specification when it is being reviewed by a local code official:

• The extent to which a curtainwall system is thermally improved will vary from one system to another. The U-factors (or thermal transmission) in each system can differ by as much as 10 percent or more;

• The absence of a standard for determining the U-factor or SHGC leaves the option for using any number of tests or calculations, making it very difficult to validate that the system conforms to a code requirement; and 

• The requirement for SHGC means that the entire fenestration system (frame and glass) must be 0.40. Glass ratings are not adequate and framing systems can affect SHGC ratings by 10 percent or more. 

Benney suggests the following addition to a specification to avoid confusion or misinterpretation: 
“Product ratings must be determined in accordance with NFRC 100 and NFRC 200 by an independent, accredited lab and labeled and certified by the curtainwall manufacturer, glazing contractor or other responsible party.” 
Mention of an independent, accredited lab eliminates the possibility of any bias with product ratings.

Site-Built Certification and Rating Program
With the establishment of a certification and rating program for site-built products, Benney feels key performance information can be determined and appropriate building systems and controls specified. NFRC has published a ten-step process, which begins with the specification of NFRC-certified performance ratings. The program entails working closely with NFRC and an accredited simulation laboratory and testing laboratory, and signing a license agreement authorizing the use of the NFRC name on certified products. Ultimately, the certified product is identified with an NFRC label certificate, also posted at the site that includes all of the system’s performance characteristics. 

Benney said that, as part of the state’s revised standards and energy codes, California has begun to require NFRC label certificates for site-built and site-assembled fenestration systems on commercial buildings. Both U-factor and SHGC ratings must be determined in accordance with NFRC’ s published procedure (formerly 100-SB, now NFRC 100-Part B). The result, according to Benney, is that glazing contractors will work with the organization’s independent certification and inspection agents who will provide label certificates where NFRC ratings are required. Curtainwall suppliers will also follow the same standard, making use of NFRC’s accredited testing and simulation laboratories.

“In 2001, California enacted an energy performance code for commercial buildings. It is often said that what happens in California today happens in the rest of the country tomorrow,” said Frank Fisher, general manager, Arcadia Windows Division. “To better serve the needs of the commercial fenestration industry, NFRC has stepped up and is looking at all aspects of how we rate commercial fenestration products.”

The state of Washington has required that fenestration systems meet NFRC standards for some time. 

“The 1994 Washington State Energy Code specified the NFRC rating and certification system for all fenestration products installed in all spaces, residential and non-residential, while also providing a limited set of default values for un-rated products,” said John Hogan, an architect and senior code development analyst with the city of Seattle and also a former NFRC board member.

Hogan continued, “For energy code compliance in non-residential buildings in Seattle, we enforce NFRC labeling and certification by looking for the NFRC labels on factory-assembled fenestration products that might be installed in small commercial buildings and requesting the NFRC label certificates on high-rise buildings with site-built curtainwall systems.”

According to Benney, the state of Massachusetts has been enforcing NFRC requirements for residential and commercial buildings as well.

“With label requirements and NFRC referenced in both ASHRAE 90.1-1999 and the 2000 IECC (International Energy Conservation Code), it is anticipated that more states and jurisdictions will mandate both NFRC labels and certificates. Florida has adopted the IECC and other states, including Arizona, Georgia, Maryland, North Carolina, New York, Pennsylvania, South Carolina and Utah will soon follow,” said Benney. 

The Opposition 
But not everyone sees NFRC’s involvement so positively.

“I must say, regulations in general are a concern for us,” said Steve Green, director of sales and marketing for Tubelite. “As a smaller company, we find regulations to be, more often than not, frustrating and overbearing. The NFRC’s procedures, as they relate to the residential market, are quite onerous to those of us in the commercial market, more specifically in the aluminum window market. Through the diligent efforts of some of the major aluminum window manufacturers, it is our hope that ultimately we will not be burdened by cumbersome, costly and difficult regulations,” he added. 

Greg McKenna, engineering services supervisor for Kawneer Co. Inc., has similar views.

“I’d been working with NFRC for more than 12 years when the organization first started the process of developing a rating system for commercial products. Despite efforts from the commercial side to create a program to meet the needs of the market, the result was the current site-built program, which hasn’t worked well,” McKenna said. “More recently, they [NFRC] have been working on the establishment of a testing and certification program for non-residential products, which is a departure from their original thinking. I am not overly optimistic about a quick adoption (by the NFRC membership) of this new direction. Hopefully, this will evolve into something that is useful for our industry.” 

Raj Goyal, director of business development, Graham Architectural Products, has also been vocal in his opposition of the NFRC’s entrance into the non-residential realm.

“We understand that the minimum energy performance criteria must be established for commercial fenestration. If it were not done, the market might continue to use single-glazed glass,” Goyal said. “The overall requirement by the DOE is to reduce energy consumption in buildings by utilizing state-of-the-art fenestration products that save energy. DOE has mandated NFRC as the only entity to create test procedures and labeling for the products. There is no question that energy ratings have to be done. We fully support that, but there is more than one way to establish them.”

Goyal explained, for example, that the American Architectural Manufacturers Association and other organizations have been involved in these issues for a longer period of time and have established test procedures. 

“NFRC insists that their way is the only way and we take issue with that. The prescriptive ratings, as they are now proposed, would put every aluminum window and curtainwall manufacturer out of business,” said Goyal. “We [certain manufacturers of non-residential products and Lawrence Berkeley National Laboratory] have proposed a performance-based criteria for total energy usage, which we believe, is a more practical option.”

He continued, “Let’s be realistic—a program has to be good for the manufacturer, user, the government and the developer to make it practical and usable. Otherwise, it will be no different than the government pushing for fuel economy while consumers buy sport utility vehicles. The DOE has agreed to review our proposal. Hopefully, we can come to some agreement.” 

Goyal said review of this proposal has moved to the fast track and DOE is anxious to get feedback from manufacturers. Once DOE agrees that the performance-based approach is practical and acceptable, it will be turned over to NFRC to develop ratings and procedures accordingly. 

“I believe we are within two years of seeing a proposed program that is acceptable,” said Goyal. 


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