Volume 9, Issue 10 - November 2008

Codes are Now Complete
Recent Approvals, Disapprovals at the ICC Final Action Hearings
by Ellen Rogers, Tara Taffera and Drew Vass

While pre-hangers were saved again from additional testing of doors, some modifications were made to the International Energy Conservation Code (IECC), among others. Here is DWM’s in-depth coverage of the International Code Council’s final action hearings, which were held in September in Minneapolis.

EC26 Sparks Debate; Approved as Modified Proposal EC26 of the IECC generated an abundance of interest and dragged out debate for nearly half an hour during the code hearings. Discussions especially slowed amid public comment number four. A back-and-forth session among attendees included debate over a possible conflict between impact-resistant requirements and energy codes.

As submitted, EC26 would have effectively changed the glazed fenestration solar heat gain coefficient (SHGC) from 0.37 in climate zones one and two to 0.35, and from 0.40 to 0.35 in zone three. Committee action, which was ultimately approved, however, called for a 0.30 requirement across all zones.

The committee stated previously that it believed a 0.30 maximum SHGC rating for fenestration in these zones was reasonable. It further reported that it believed an ample number of products are available to achieve this value. The committee suggested that its move to go from 0.35 to 0.30 reflected a more aggressive value that would be consistent with the level of stringency that present energy conservation concerns call for.

The committee heard debate previously from industry representatives stating that 0.35 was more reasonable than the suggested 0.30 from a product availability point of view, but it ultimately decided to stick with its 0.30.

Public comment number one, provided by Julie Ruth of JRuth Code Consulting, who represented the American Architectural Manufacturers’ Association (AAMA), requested approval as submitted and stated: “As originally submitted, EC26 established a maximum SHGC of 0.35 in Climate Zones one, two and three for residential glazed fenestration in the IECC. This would have been a 12.5-percent reduction in the SHGC. This provided for some reduction in solar heat gain, and hence anticipated cooling load, in the building, while still allowing a certain amount of daylighting through the fenestration products.”

Comment one suggested that lowering the SHGC from 0.40 to 0.35 in the IECC would be a reasonable compromise that should result in some net energy savings. Others felt 0.35 wasn’t in sync with current needs.

Public comment number two expressed concerns over having the same requirements for zones one, two and three. Issued by Ron Nickson of the National Multi Housing Council, comment two suggested adjusting zones one and two to a 0.35 requirement, while setting a 0.40 requirement for zone 3. Nickson cited full building simulations as a tool for determining requirements. Some individuals expressed concerns about the data used, but Nickson rebutted those concerns by explaining only one source currently was available.

Public comment number four, supplied by Thomas S. Zaremba, representing Pilkington North America, and Tom Mewbourne, representing AGC Flat Glass North America Inc., proposed modification to the committee’s action to afford greater flexibility in the design and use of hurricane-resistant glass that complies with section 1609.1.2 of the International Building Code. Opposing arguments zeroed in on possible conflicts between IRC and IECC requirements and further focused on the need for EC26 to concentrate on energy conservation needs, not public safety. Michael Fischer, code consultant for the Window and Door Manufacturers Association (WDMA), voiced concerns in this area as well.

“I think you’ve been sold a bill of goods today that we need impact resistance,” Fischer stated. “People will die this year from house fires, because they’re using space heaters and can’t afford to pay their energy bills ... let’s not bring public safety into this.”

Proponents of public comment number four cited a conflict between the use of single-pane,
impact-resistant products and proposed energy requirements.

“If you’re a designer and you’re going to design a piece of glass in a hurricane-prone area, number one you’re going to try to minimize the amount of glass,” argued Zaremba.

“Most of the glass involved in breakage in a hurricane is going to be annealed glass ... it breaks into shards and it can kill you. That’s the cause for single panes of glass.”

EC18 Approved as Modified by Public Comment One Code change proposal EC18 parts one and two were approved as modified by public comments one, respectively. Proposed by Craig Conner, Building Quality, representing himself, as submitted EC18 part one would have lowered fenestration U-factor ratings, as found in table 402.1.1 insulation and fenestration requirements by component, from 0.75 in climate zone two and 0.65 in zone three, both to 0.55. The same changes were proposed for table 402.1.3 equivalent U-factors. EC18 originally was disapproved by committee action. Part two originally proposed changing table N1102.1 insulation and fenestration requirements by component, fenestration U-factor ratings to 0.55 in both zones two and three. Part two applied the same changes to table N1102.1.2 and was previously approved as modified adjusting only zone two to 0.65 in tables N1102.1 and N1102.1.2.

Arguments for and against EC18 parts one and two centered around product material usage and aligning hurricane protection and energy conservation needs.

“EC18 is a much better option for addressing energy efficiency along with hurricane safety issues,” said Thomas Culp, representing the Aluminum Extruders Council (AEC) in a previous session.

EC22: Part One Disapproved; Part Two Approved as Modified by Public Comment Two After drawing much debate during the International Code Council (ICC) code hearings, EC22 part one was disapproved as previously recommended by the code committee.

Part two, however, was approved as modified by public comment two.

Part one called for changing glazed fenestration SHGC requirements in zones one and two from 0.37 to 0.30 and zone three from 0.40 to 0.30 as well. Original and primary reasons included the impact low SHGC windows have by reducing cooling energy use and increasing heating energy use. The committee’s basis for recommending disapproval was in anticipation of more aggressive values in EC24 and EC26. The committee also motioned for disapproval of EC22 part two.

Suggested changes in part two included adjusting SHGC ratings for insulation and fenestration requirements by component to 0.30 in zones one through three.

Public comment two called for softening those requirements to 0.35, which was ultimately approved as submitted.

S141—Proponent: Mike Fischer, representing the WDMA. The ICC upheld its original unanimous decision made in February regarding code proposal S141 (International Building Code-Structural), which addressed the side-hinged exterior door standard. The proposal, submitted by the WDMA, attempted to remove the current exemption for side-hinged exterior doors from nationwide testing of the AAMA/WDMA/CSA A440 test standard.

If approved, the proposal would have added testing and labeling requirements for side-hinged door assemblies that are included within the scope of AAMA/WDMA/CSA 101/I.S.2/A440.

The proposal was again disapproved at the final action hearings. While Fischer spoke on behalf of the WDMA, there were far more people speaking in favor of upholding the committee’s original decision.

This included Jeff Burton, director of codes and standards for the Association of Millwork Distributors’ (AMD), and Larry Ray, representing pre-hanger GHDC Inc. in Tupelo, Miss.

All who spoke reminded members to “uphold the committee’s original unanimous decision in February.”

“This [passage of this proposal] would cause utter chaos in the industry,” said Ray. “Many [prehangers] would not survive.”

According to Fischer, all exterior components in a structure face the same exposure to weather. “This proposal is a logical extension to apply the same requirements to side-hinged doors (within the scope of 101/I.S.2/A440) that are currently applied to windows and sliding doors. It is inconsistent for the code to require side-hinged door installation and flashing to prevent water infiltration while the door itself is exempted from any water testing requirements. Expanding the requirements for testing and labeling to 101/I.S.2/A440 to side-hinged doors addresses this inconsistency in the code.”

“Although my heart goes out to those states with hurricane winds, we don’t have these in Minnesota, but in the individual states that have these problems, there are state codes to address this issue,” said one pre-hanger located in Minnesota.

A representative from Simpson Door reiterated the fact that it is to up to the states to address this issue. “There are codes in place in hurricane- prone regions to address this issue,” he said.

He also noted that exterior sidehinged doors are all tested to NFRC 100 and 200 standards.

“I feel lonely up here,” said Fischer, when it was his turn to speak in favor of the proposal. Another individual also supported the proposal and said, “Those who are opposed to this are saying that it is up to the states, but this is the International Building Code. It’s for the entire country.”

EC14—Proponent: Thom Zaremba, representing the Advanced Building Coalition (ABC).

Discussions went past 2 a.m. when this proposal was debated on September 22, but in the end the ABC defeated the Energy Efficient Codes Coalition’s (EECC) IECC E14 proposal and its companion appendix.

Zaremba represented the ABC, which consists of the Association of Industrial Metalized Coaters & Laminators - Window Film Committee; the International Window Film Association; The AEC; APA; Nu-Wool Co. Inc.; Pilkington North America Inc.; AGC Flat Glass North America Inc.; Icynene Inc.; Craig Conner, Building Quality; and Birch Point Consulting. The group’s objective is  to promote a significant, cost-effective increase in building energy efficiency and sustainability.

The EECC’s website says EC14 was proposed to “boost the energy efficiency of the 2009 IECC by 30 percent over the current model code.” EC 14 has been dubbed by EECC as “The 30 Percent Solution.”

EC14 proposed changing fenestration U-factors for climate zones one through four. Opponents said this would create inconsistencies with the International Residential Code (IRC).

According to hearing documents, the ABC opposed EC14, as it represented an “effort on the part of its proponents to actually introduce inconsistencies into the ICC family of codes … while we strongly support a cost-effective increase in the building energy codes, the proposed ‘solution’ in EC14 is flawed.” Comments from ABC in the documents said, “as part of a strategy to eliminate the energy provisions from the IRC, the proponents of EC14 did not submit a single corresponding change to Chapter 11 of the IRC. Both the IRC and IECC are widely used, and deviations between the two codes will create confusion and enforcement complications.

S83—Proponent: John Woestman, representing the Door Safety  Council. If passed this would have allowed side-hinged door assemblies to meet the impact testing requirements of ANSI/SDI A250.13.

The WDMA opposed this proposal.

RB174—Proponent: Michael Fischer, representing the WDMA.

According to the proposal, window fall prevention devices and window guards, where provided, shall comply with the requirements of ASTM F 2090. The 2006 International Residential Code (IRC) and International Building Code (IBC) contain a newly adopted requirement for minimum sill heights in windows located more than 72 inches above grade as a means to prevent child falls through open windows. During the consideration of this proposal over several code cycles, WDMA expressed dismay with the lack of technical substantiation that demonstrated any positive impact of this requirement on the number of child window falls.

In fact, WDMA’s opposition was due in large part to concerns about the unintended consequences such a requirement could have on fire safety.

When speaking before the committee during the hearing, Fischer said we shouldn’t “experiment with our children.”

He also pointed out that minimum sill heights don’t help reduce child window falls.

“The only jurisdiction in the United States with a sill height requirement is Denver and falls are heightened in that area,” he said. But those in support of the committee’s original decision urged thecommittee to not take the sill height requirement out of the code, and ultimately they were successful as the committee’s original decision was upheld.

S142—Proponent: William E. Koffel, representing the Glazing Industry Code Committee. The proposal called for exterior windows and sliding doors to be tested and labeled as conforming to AAMA/WDMA/CSA101/I.S.2/A440. As was the case with S141, the committee’s original decision in February was upheld and this proposal was denied.

According to the proposal, “the purpose is to remove the exemption that fenestration products labeled to AAMA/WDMA/CSA 101/I.S.2/A440 do not have to meet the requirements of sections 2403.2 and 2403.3, which ensure safe performance through proper support of glass. Specifically, section 2403.3 would have required that the deflection of framing members supporting glass may not exceed L/175 of the glass edge length (or ¾ inch, whichever is less) when subjected to the design load. Chapter 24 of the IBC relies on glass design curves that are contained in ASTM E 1300. This ASTM standard recognizes the importance of limiting  edge deflection of the glass and alsorecommends a limitation of L/175 of the glass edge length. Prior to the IBC, the legacy codes required deflection limitations of L/175 of the span for glass holding members. It was not until the IBC was published that this exemption was allowed.”

S143—Proponent: John Woestman, representing the Door Safety Council. This proposal would have  added the ANSI Standard ANSI/SDI A250.13-XX Testing and Rating of SevereWindstorm Resistant Components for Swinging Door Assemblies to Chapter 35 of the IBC.

At the time of the February hearings this standard was not complete, but it is complete now, so Woestman encouraged its addition in the code as it would, “allow a componentbased approach and allow interchangeability of components.”

This proposal helps resolve performance and code compliance issues when doors are assembled from components from multiple sources and include interchangeable elements, according to Woestman. Gary Erlich of the National Association of Home Builders opposed the proposal in February but is now in favor of it as the standard is complete. The committee’s February vote was no and in Minneapolis the motion failed by one vote.

RE2—Proponents: Thomas Zaremba and Thomas Culp. This proposal would have placed the residential provisions of the energy code in one place, rather than having potentially different requirements in the IRC and the IECC. The committee’s original vote of disapproval was upheld.

EC25—Proponent: Vicki Lovell, representing the Association of Industrial Metallized Coaters and Laminators. The proposal would have allowed for overhangs to allow the user of the code another design option. It would permit modification and configuration of the structure to achieve a lower SHGC.

Many in the industry spoke in favor of this measure, including Julie Ruth representing AAMA, Thomas Culp representing the AEC and Thomas Zaremba representing Pilkington North America.

“Our glass manufacturer members would love to encourage the use of low-E, but how can we tell a homeowner who wants an overhang that they have to use low-E glass instead?” said Culp.

“Shading reduces solar gain, so why as a designer wouldn’t you want to do that?” asked Zaremba. “For one thing you wouldn’t get credit for it in the energy code, but with this proposal you would.”

He added, “We make glass but we’re in support of this as it’s a smart design alternative.”

There were those opposed to the proposal, including Mike Fischer, representing the WDMA, who said that there are inherent problems in the proposal. Garrett Stone, representing Cardinal Glass Industries, also spoke in opposition. He said in essence that we shouldn’t take a known SHGC and put it against all these other factors involved with overhangs.

“This is not the right approach,” agreed Jeff Harris of the Alliance to Save Energy. “In fact, it could increase heat load in the late afternoon and reduce comfort.”

In the rebuttal, Zaremba said that many opposed to the proposal are making it out to be more than it is. “This is not the rocket science that some are trying to make it out to be. Overhangs just make sense,” he said.

EC4—Proponents: Craig Conner, Building Quality; Julie Ruth, JRuth Code Consulting, representing AAMA; Rand Baldwin, AEC; Margaret Webb, representing the Insulating Glass Manufacturers Association; and Greg Carney, representing the Glass Association of North America.

If approved, EC4 would have allowed for the use of AAMA 507 for rating curtainwall and storefronts as an alternative to NFRC 100 and 200.

According to hearing documents, the committee voted to disapprove the proposal, as it did not include third-party oversight requirements for manufacturers doing the determination of the fenestration ratings. The committee also said the standard was unclear regarding who should be qualified to do the fenestration rating calculations.


DWM

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