Falls, Fires and Opening
Balancing All Three is Not Easy
by Chuck Anderson
The risk of young children falling from windows is real.
Safe Kids Worldwide reports that, on average, 18 children ages 10 and
under die annually from falls from windows. The problem has engendered
efforts to instill safety measures in the building codes. But this worthy
mission must be reconciled with the dual role of window openings requiring
emergency escape and rescue provisions. It has been a difficult balancing
act to codify.
Setting Sill Heights
One approach has been to call for a minimum sill height. Another has been
to require a window guard or a device that limits how far a window can
be opened, yet still permit operation as an emergency exit. (Note that
screens do not qualify as guards, as they were never designed to restrain
the weight of a child.)
The 2006 International Building Code (IBC) for commercial structures and
the International Residential Code (IRC) called for a minimum sill height
of 24 inches above the floor for operable residential windows located
more than 6 feet above grade. An alternate to this provision was to limit
the window opening to no more than 4 inches. But such a requirement was
seen as compromising egress for fire safety, so many state jurisdictions
that otherwise adopted the 2006 I-codes elected not to adopt the sill
Consequently, the International Code Council (ICC) Code Technology Committee
(CTC) went back to the drawing board and introduced a new change proposal
(RB173) into the last (2007/2008) code revision cycle. That proposal expanded
upon the 24-inch minimum sill height requirement by introducing exceptions
to allow for emergency egress. However, the industry criticized the proposal
as vague and posing significant compliance problems, and it was disapproved
by the ICC at its February 2008 hearings. In response, the CTC submitted
three public comments to modify the proposal, a move that ensured its
reconsideration at the September 2008 final action hearings.
These public comments were adopted in part and the amended requirement
was published as Section R613.2 of the International Residential Code
(IRC), released January 1, 2009, for one- or two-family dwellings and
town homes of fewer than three stories. It requires the 24-inch minimum
sill height for windows more than 6 feet above grade, but provides an
exception for windows that are equipped with “self-acting” opening control
devices that restrict the initial opening of the window to no more than
The Role of Window Opening Devices
These devices must incorporate an intuitively operated and clearly identified
release mechanism that permits further operation to provide a net clear
opening compliant with Section R310.1.1 governing windows used for emergency
escape and rescue. The IRC further requires that the opening control device
not require more than 15 foot-pounds of force to operate and that it remains
operable in “all types of weather” (which is a controversially vague requirement).
Exceptions also are made for windows equipped with fall prevention devices
and window guards that comply with ASTM F2090-08, Standard Specification
for Window Fall Prevention Devices with Emergency Escape (Egress) Release
The issue still is not fully decided. For example, the current (2009/2010)
cycle of code change hearings could raise the 24-inch minimum sill height
requirement up to 36 inches. This proposal was the subject of one of the
CTC’s public comments to the final action hearings of 2008 and has also
received the support of fire protection officials. But this proposal poses
serious problems inherent in fitting a double-hung window into an 8-foot
wall and still allowing for a rough-opening header, a 3-foot sill and
adequate egress opening.
The CTC is reviewing that issue, as well as looking into ways to integrate
the requirements into the IBC successfully since the same provision was
disapproved for this commercial code. Because the use of opening control
devices is intended to counter the necessity of minimum sill heights—especially
36 inches—all stakeholders should remain vigilant regarding the latest
code proposals and stand ready to prove the efficacy of these devices
in both fall prevention and fire safety.
Chuck Anderson, PE, serves as codes and industry affairs manager
for the American Architectural Manufacturers Association in Schaumburg,
Ill. He may be reached at email@example.com. Mr. Anderson’s opinions
are solely his own and do not necessarily reflect those of this magazine.
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