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Volume 6   Issue 8               September  2005

Code Concerns

ICC Hearings: Diagnosis—Critical
by Michael Fischer

It is now time for the International Code Council’s (ICC) 2005 Final Action Hearings slated for September 28 through October 2 in Detroit. Testimony and voting on the hundreds of public comments at the gathering will eventually result in the publication of the 2006 International Codes. 

The recently-formed Joint Code Committee (JCC) of the American Architectural Manufacturers Asso-ciation (AAMA) and the Window and Door Manufacturers Association (WDMA) will work on behalf of the door, window and skylight industry to represent the associations’ membership at the hearings by monitoring and representing the industry before the ICC governmental voting members. Formed this year in the midst of the current code cycle, the JCC will coordinate preparation for the hearings and provide direction to staff of both organizations to ensure that the member interests are best served.

The Key Proposals
There are many key issues on the table in Detroit. Some of the most significant include:

• Standards references: The new harmonized 101/I.S.2/A440 fenestration standard was introduced to the ICC during the committee hearings in Cincinnati last February. Unfortunately, not every committee adopted the updated reference in the same manner. The JCC position that the I-Codes should contain a single reference to the joint fenestration standards for windows, doors and skylights means that industry advocates will be working towards that goal during the public comment testimony. 

• Exterior window and door installation: The JCC worked hard to reach a satisfactory compromise with the key stakeholders representing the flashing and envelope industries, building code officials and homebuilders. The public comment filed by WDMA attempts to complete that task. If successful, the action will result in clear direction regarding the appropriate use of flashing as well as a requirement to follow manufacturer’s installation instructions. 

• Window safety: Several public comments regarding the problem of child falls and the issue of window sill height restrictions have been filed. During the ICC committee hearings, conflicting actions were taken by separate committees as well as a result of an assembly motion. The IRC Building and Energy Code Committee passed a resolution asking the ICC Board to create an ad hoc committee to investigate the issue of child falls, sill height requirements and emergency escape and rescue provisions. WDMA supports the recommendation of the IRC B/E committee. 

• Energy: Thirty-nine separate comments will be heard by the ICC assembly in Detroit. Besides the standards reference mentioned above, many other energy proposals affecting the window industry will be included. Some of the issues to be determined include definitions, prescriptive skylight U-Factor and Solar Heat Gain Coefficient (SHGC) requirements, limits to trade-off values for fenestration products, sunroom provision limitations and the applicability of “above-code” programs as a means of identifying energy code compliance. 

• Urban-Wildland Interface: A proposal requiring testing of exterior glazing to NFPA 257-00 in certain zones was approved during the committee hearings; a public comment filed by the National Association of Homebuilders seeks to disapprove the proposal. 

• International Fire Code: Several comments affecting the architectural door industry were submitted for final action consideration, including one from the Door Safety Council (DSC). The DSC comment seeks to clarify language regarding the use of security devices that may impair means of egress under certain conditions. 

Needless to say these hearings will be an important and momentous milestone for the industry, particularly with the advocacy of the JCC. It will be interesting to see what October brings with the completion of the 2004/2005 code development cycle and the publication of the 2006 I-Codes. 

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


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