ICC Updates Fenestration Codes
in Final Action Hearings
by Tara Taffera
The International Code Council (ICC) held its final action
code hearings May 15-23 in Dallas, where issues such as installation,
flashing and window egress, took center stage and were heavily debated.
The approved updates will be released as part of the 2012 version of the
International Codes, available in April 2011, while some of those disapproved
changes may return in the next cycle of change proposals.
Installation and Flashing
The International Code Council heard several proposals having to do with
door and window installation, as well as flashing. The ICC upheld its
original decision regarding RB119, part of the International Residential
According to this section, doors and windows should be installed in accordance
with the fenestration manufacturers written installation instructions.
It also states that penetrations and opening in exterior walls shall be
flashed or sealed in such a manner that will inhibit entry of water into
the wall cavity or penetration of water to the building structural framing
components. Self-adhered membranes used as flashing shall comply with
Jeff Inks, representing the Window and Door Manufacturers Association
(WDMA), submitted a public comment during the final action hearings that,
among other things, would have addressed the following: “For applications
not addressed in the fenestration manufacturer’s written instructions,
in accordance with the flashing manufacturer’s written instructions.”
“We haven’t taken any responsibility away from the window manufacturer,”
said Inks. “All we have done is provide additional options so they are
flashed correctly in situations where manufacturers instructions don’t
adequately cover that in particular applications.”
Julie Ruth, representing the American Architectural Manufacturers Association
(AAMA), also was in favor of bringing forth Inks’ public comments but
ultimately that motion failed.
During the debate over RB 119, many who were opposed to Inks’ proposal
mentioned how RB 145, also submitted by Inks, was a better way to address
this issue. RB145 came up later that day and that proposal, also brought
forward by the WDMA, adds a new definition for pan flashing as: “Corrosion-resistant
flashing at the base of an opening that is integrated into the building
exterior wall to direct water to the exterior and is pre-manufactured,
fabricated, formed or applied at the job site.
That proposal was approved and adds the following text to the IRC:
Flashing at exterior window and door openings shall be installed
in accordance with one or more of the following: The fenestration manufacturer’s
installation and flashing instructions, or for applications not addressed
in the fenestration manufacturer’s instructions, in accordance with
the flashing manufacturer’s instructions. Where flashing instructions
or details are not provided, pan flashing shall be installed at the
sill of exterior window and door openings. Pan flashing shall be sealed
or sloped in such a manner as to direct water to the surface of the
exterior wall finish or to the water resistive barrier for subsequent
drainage. Openings using pan flashing shall also incorporate flashing
or protection at the head and sides.
Window Sill Heights
The issue of sill heights once again was debated. RB 122, Part 1, would
have raised sill heights from 24 to 36 inches.
“I understand the concern about child safety as I have three kids myself,”
said Ruth. “But I’m concerned that when trying to help one part of population
we will hurt another [such as the
“Raising sill heights from 24 to 36 inches will have a very significant
impact,” added Inks. “That’s a huge leap … As a result we will have a
great number of emergency and escape and rescue windows installed with
guards or window opening control devices that haven’t been adequately
justified and could impede egress in an emergency.”
The proposal ultimately was disapproved.
While RB 122, Part I, deals mainly with single-family structures that
are covered by the International Residential Code, RB122, Part 2 would
raise sill heights from 24 to 36 inches in the International Building
Code. That proposal was approved.
Role of Sprinklers in Window Egress
When E-150-09/10, Part II, a proposed change to the International Residential
Code, came up during the hearings, Jeff Shapiro, speaking on behalf of
himself, said, “This is probably the most passionate testimony you will
hear all week on both sides of the issue.”
Shapiro spoke in support of the proposed change which states that: emergency
escape and rescue openings shall not be required in one- and two-family
dwellings and townhouses that are equipped with an approved automatic
sprinkler system. The ICC committee approved this proposal as submitted
last October during the code hearings. The reason was as follows: “The
change adds a reasonable exemption based on approved automatic sprinkler
systems in the dwelling. This creates an incentive to provide a sprinkler
system. Also, this may get some retrofits for additions.”
Another proponent simply pointed out that if a building has sprinklers
then it doesn’t have to meet the window egress requirements.
However, speaking in favor of disapproval, Inks brought up some points
for the committee to consider.
“These sprinklers don’t require maintenance–that is an important issue
that needs to be considered … We don’t know that they will work every
time,” he said.
Inks was joined in support for disapproval by many others in the door
and window industry including Ruth, as well as fire safety officials including
one fire marshal in Colorado who pointed out that windows serve a dual
purpose–they allow fire rescue personnel to enter a building in addition
to allowing people to get out.
“I support incentives for fire sprinklers,” he said. “They will do what
they are intended to do, but people still need to get out.
Another in opposition advised the committee that this is a local trade-off
issue—not a national one.
Ultimately, the motion carried for disapproval.
Window Labeling for Egress
A proposal to label windows installed as an “Emergency Escape and Rescue
Opening” also was debated heavily. Inks and Ruth were successful in urging
the committee to uphold its original action for disapproval.
Other opponents, including one field inspector, pointed out that inspectors
verify with a tape measure so labeling is not needed.
Another said, “We don’t need this. An inspector will be on-site with a
tape measure, etc. If he doesn’t, he’s not doing his job. Let the inspector
do his job. We don’t need these labels on these windows.”
One individual speaking in support of the proposal said, “Everything has
labels right now–why should windows be different? It will also help consumers
know if the window complies with egress requirements.”
Thomas Zaremba, representing himself, rebutted that argument by pointing
out that certain properties such as solar heat gain coefficients, etc.,
can’t be verified in the field, which is why labels are needed. However,
this can be verified easily by taking some measurements in the field,
making the labeling unnecessary, he said.
Rick Davidson of the city of Maple Grove, Minn., a proponent of RB 42-09/10,
told the committee that “window manufacturers had the opportunity to come
back with a solution and came back with nothing.”
“It wasn’t because they didn’t want to do anything,” responded Inks. “It’s
because they found there isn’t a viable option that will not require field
verification of the opening dimensions.”
Skylight Changes: Some Approved and Some Denied
S144-09/10-PART I, submitted by Ruth, was approved as amended by public
comment, and added text to the definition of unit skylights to include
tubular daylighting devices (TDDs).
The public comment from Gary J. Ehrlich, PE, National Association of Home
Builders, though, proposed that TDDs be defined separately as:
“A non-operable fenestration unit primarily designed to transmit
daylight from a roof surface to an interior ceiling via a tubular conduit.
The basic unit consists of an exterior glazed weathering surface, a
light-transmitting tube with a reflective interior surface, and an interior-sealing
device such as a translucent ceiling panel. The unit may be factory
assembled, or field-assembled from a manufactured kit.”
“A tubular daylighting device is typically field-assembled from a manufactured
kit, unlike a unit skylight which is typically shipped as a factory-assembled
unit,” said Ehrlich in support of his proposal. “If the current unit skylight
definition is applied to TDDs, some code users will expect that TDDs be
entirely assembled in the factory.”
In addition, Ruth’s proposal also added text to say that under 1715.6
skylights and sloped glazing, unit skylights shall comply with the requirements
of Section 2405. All other skylights and sloped glazing shall comply with
the requirements of Chapter 24, which lays out structural requirements
Also approved was a revision to S-3-09, proposed by the Window and Door
Manufacturers Association. In section 1503.6, crickets and saddles, it
states that a cricket or saddle shall be installed on the ridge side of
any chimney or penetration greater than 30 inches wide as measured perpendicular
to the slope. The following exception was added, “skylights installed
and flashed in accordance with the manufacturer’s instructions.”
Another proposal, S141-09/10, submitted by William E. Koffel, Koffel Associates
Inc., representing the Glazing Industry Code Committee, was disapproved.
The proposal recommended that products installed in buildings of Group
R not more than three stories above grade plane that are tested and labeled
as conforming to AAMA/WDMA/CSA 101/I.S.2/A440 would not be subject to
the requirements of Sections 2403.2 and 2403.3 of the code, which ensure
safe performance through proper support of glass.
ICC Rejects Side-Hinged Exterior Door Standard
The industry debated the topic of exterior door and window assemblies
once again during the ICC hearings and the Association of Millwork Distributors
(AMD) ultimately was unsuccessful in getting its side-hinged exterior
door standard added to the code.
Jeff Burton, director of codes and standards, representing AMD, proposed
that R612.8 of the International Residential Code be revised as follows:
Exterior windows and door assemblies not included within the scope of
Section R612.6 or Section R612.7 shall be tested in accordance with ASTM
E 330 or AMD side-hinged exterior door standard (SHEDS).
Burton said this would add an additional option to the code that includes
as structural component interchangeability methodology that is prevalent
in the SHED industry but is not address in the building codes or its current
referenced standards. The addition of AMD SHEDS, which was developed in
accordance with the current industry ASTM E330 static pressure test, adds
that needed structural component interchangeability option, according
Both Ruth and Inks were opposed to the proposal, citing the fact that
AMD SHEDS is still in draft form.
Additional reasons for disapproval cited by the two included that they
feel provisions of the standard are inadequate, validation test data has
not been made available for review and use of the proposed referenced
standard would significantly weaken the current requirements of the IRC.
Side-hinged door assemblies also came up later in the code hearings during
discussion of S143-09. John Woestman, representing the Door Safety Council,
proposed to add new text to 1717.5.2. The proposed language was as follows:
Structural performance of exterior side hinged door assemblies shall be
determined in accordance with either ASTM E330 or ANSI A250.13.
He also proposed adding a new standard to chapter 35: ANSI A 250.13-08,
Testing of Severe Windstorm Resistant
Components for Swinging Door Assemblies.
That proposal also was disapproved.
All Codes Not Yet Complete
The next round of the International Code Council’s (ICC) hearings is scheduled
for October 28-November 1, 2010. The hearing will cover “Group B,” which
includes code changes to the International Energy Conservation Code and
the International Residential Code - Energy, among others.
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