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November/December 2004

ABC - 123
Code/Concerns 

Window Safety Still a Hot Topic
by Carl Wagus

The upcoming International Code Council (ICC) cycle will feature continued debate regarding child falls from windows and the role of these fenestration products as egress openings. 

The ICC approved a measure recently requiring a minimum sill height of 24 inches for residential windows more than 72 inches above grade. The proposal, intended to solve child falls from windows, may have a negative effect on fire safety. The Window and Door Manufacturers Association (WDMA) has submitted a proposal to remove the requirement. WDMA intends to show the committees how a mandatory sill height requirement will likely have little effect on child falls. Instead, WDMA has concerns that it could have the opposite effect—and lead to more of these incidents. 

Many advocates, including the Consumer Product Safety Com-mission (CPSC) and the American Academy of Pediatrics (AAP), caution caregivers to keep furniture away from windows. WDMA’s concern is that a minimum sill height set at 24 inches increases the likelihood of furniture placement beneath windows.

New Joint Efforts
WDMA, along with other stakeholders, including the National Safety Council (NSC), National Association of Homebuilders and the American Architectural Manu-facturers Association have participated in the Window Industry Task Force created to focus on how best to reduce child window falls. That task force resulted from the 1994 CPSC roundtable on child window falls. 

Now, industry efforts to focus on safety will expand to include a re-examination of the fire issue. The NSC has agreed to host an ad hoc committee to explore all aspects of window safety. The committee will review child window falls, emergency escape and rescue, and revisit minimum egress size dimensions developed in the 1970s. 

The role windows play in fire escape or rescue situations cannot be underestimated. In fact, the ICBO 1991 Commentary to the Uniform Building Code included the following: “The very essence of the requirement for emergency escape windows is that a person must be able to effectively escape or be rescued in a short period of time because in all probability the fire will have spread to the point where all other exit routes are blocked. Thus, time cannot be wasted to figure out means of opening rescue windows or obtaining egress through them. Any impediment to escape or rescue caused by security devices, inadequate window size, difficult operating mechanisms, etc., is not permitted by the code.” 

WDMA is concerned that the balance between fire and child fall safety will be lost if the approved provisions are adopted. Educational campaigns and the use of accessory devices like window guards and smoke detectors have met with success. Recent data from the CPSC show an overwhelmingly positive trend:
• Child Fall Safety: Average annual deaths ages 0-9 reduced by 55 percent from 1990 to 2000; Per capita deaths in ages 0-9 reduced by two-thirds from 1990-2000.
• Fire Safety: Average annual deaths all ages reduced by one-third from 1990 to 2000; Average annual deaths ages 0-9 reduced by half from 1990 to 2000.

Something Must be Done
Addressing child window falls—but not at the expense of fire safety—is an important consideration for the window industry. WDMA is concerned that a minimum sill height requirement will result in smaller-sized egress windows because of architectural limitations including standard eight-foot ceilings. If that holds true, the average size of egress windows installed in new construction will be reduced to the bare minimum, holding serious consequences for fire safety.

WDMA hopes the NSC ad hoc committee will result in a serious review of all of the issues at risk. With stakeholders from all sides of all the issues working together, the hope is that a more permanent solution can be identified. 

Michael Fischer serves as director of codes and regulatory compliance for the WDMA in Des Plaines, Ill.

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