Can One Standard be All Things to All?
by Rosalie Leone
rleone@amdweb.com

Can one standard be all things to all in the fenestration industry or is it like pushing a square peg through a round hole? In the millwork industry, where the side-hinged exterior door industry is concerned, we believe there are sound options. A little history may help bring some things into context before explaining further.

A Quick History Lesson
Many years ago, before model codes and federal regulations, sliding glass doors were all the rage. They were mostly made out of wood or aluminum and annealed glass. But if you ran into the glass door, or bumped it hard, the glass could break pretty easily into dangerous shards that could cause serious bodily harm. So in the 1970s the federal government decided it needed a safer door product in homes across America, and mandated the use of safety glass in doors; this is still in effect today. That was a good thing. The door and window industry welcomed the requirement and it evened out the playing field for all manufacturers. Everyone had to comply with the new law. As time passed, “voluntary” standards began to make a larger impact in the building industry and eventually into regulation. It was an excellent way for companies to show-off the quality of their products by showing compliance to a voluntary standard.

"For those in the door industry, the NAFS is a cumbersome and impractical standard, period. NAFS is a full system-based test standard that requires complete door systems, i.e., each and every different assembly type sold in the marketplace, to undergo not only structural testing (per ASTM E330, mind you) and air leakage testing, but also water penetration testing, durability testing, materials testing, forced-entry resistance testing, cycling performance testing, and vertical loading resistance testing, not to mention water-repellent preservative treatment of millwork used."

In the early 1990s the International Code Council (ICC) was formed to be the keeper of all the building codes, dedicated to developing a single set of comprehensive and coordinated national model construction codes. Its job was and is to help the building safety community and construction industry provide safe, sustainable and affordable construction through the development of codes and standards used in the design, build, and compliance process. This was also a good thing because everyone could then make products to meet the requirements of a single set of codes. Today, there are more than a dozen international codes in place which cover areas from residential and commercial construction to energy conservation and fire safety.

Current Codes
Two such international codes that currently reference the AAMA/WDMA/CSA 101/I.S.2/A440, NAFS, North American Fenestration Standard/Specification for windows, doors, and skylights, are the International Residential Code (IRC) for residential construction and the International Building Code (IBC) for commercial construction. The first version of the NAFS was known as ANSI/AAMA/NWWDA 101/I.S.2.97, Voluntary Specifications for Aluminum, Vinyl (PVC) and Wood Windows and Glass Doors. It was a voluntary standard that specified performance levels for windows, skylights and glass patio doors that was incorporated into the codes. It did not reference side-hinge exterior doors (SHEDs). It addressed the air infiltration, water resistance and structural loading and other problems identified, and it was primarily a windows-related standard. As time went on, this standard increased the number of tests required as new levels of performance were identified to assure buyers the quality of products brought to market. This is all fine for windows, skylights and glass doors. After all, these fenestration openings have quite different usage demands and exposures than SHEDs. The standard developed over time to meet new performance requirements, written to match the product specifications, profiles and usage characteristics of window-related products.

Sometime in 2003-2004, or prior, the American Architectural Manufacturers Association (AAMA) and the Window and Door Manufacturers Association (WDMA) joined forces with the Canadian Standards Association (CSA) and updated the specification to incorporate aspects of CSA’s A440 specification for windows and, low and behold, included provisions for SHED. This became known as the 101/I.S. 2/A440 Specifications for Windows, Doors, and Unit Skylights. Since this time AAMA/WDMA has made a concerted effort to make the NAFS a mandatory standard for all fenestration products. They have attempted to exclude SHEDS from testing to the ASTM E330 test standard in the IRC and IBC. Code change proposals were introduced by these associations in both 2005 and 2008 to exclude the E330 test option for SHEDS. They were promptly opposed and defeated at the ICC hearings by the Association of Millwork Distributors (AMD) and others in the industry who realized the serious implications to the industry if this test option was removed.

"Attempts have been made time and time again to force SHEDs, the square peg, into the round hole of NAFS performance requirements despite the fact that there has been an appropriate option in the codes."

The E330 standard test method sets forth the structural performance of doors, windows and skylights by uniform static air pressure difference, and it has been part of the international codes for many years. This testing protocol assures everyone that products tested to this standard should remain intact and operable following a high wind event. Attempts have been made time and time again to force SHEDs, the square peg, into the round hole of NAFS performance requirements despite the fact that there has been an appropriate option in the codes.

For those in the door industry, the NAFS is a cumbersome and impractical standard, period. NAFS is a full system-based test standard that requires complete door systems, i.e., each and every different assembly type sold in the marketplace, to undergo not only structural testing (per ASTM E330, mind you) and air leakage testing, but also water penetration testing, durability testing, materials testing, forced-entry resistance testing, cycling performance testing, and vertical loading resistance testing, not to mention water-repellent preservative treatment of millwork used. Much of this testing is unnecessary for side-hinged doors and not even explicitly referenced in the IRC or IBC.

Though the NAFS may be viewed by some in the industry as the way to harmonize fenestration standards in North America and provide a comprehensive high-performance standard for a vast array of products, others would beg to differ and argue otherwise, the door industry in particular, and not because harmonization and high performance are a bad thing. And it’s clearly not because reducing costs and forsaking the quality of the product is the name of the game for the door industry.

A Door is Not a Window
Yes, doors and windows seem to go hand-in-hand. Many fenestration manufacturers produce both products—they’re both fenestration products. Perhaps, though, that’s as far as the similarities go. A window is not a swinging door. A circle is not a square though they’re both geometric shapes. There are distinct differences in each of the product’s functionality and purpose. So there should consequently be distinct performance criteria for each of these products as well.

And what forever seems to be misunderstood and/or overlooked is the fact that the door industry itself functions differently than the window industry. It is comprised of not only manufacturers but also smaller distributor and pre-hanger operations that buy their door components from multiple manufacturers and interchange these components in their systems on a regular basis depending on customer needs. Doors are still very much a customized product. Customers have different aesthetic requirements, security requirements, energy-efficiency requirements and structural requirements. The door industry is well aware of these multifaceted needs and continues to step up to the plate to deliver sound quality products. And rightly so; it’s good for business and it’s the right way to do business. Door combinations, various options for glass, a variety of materials and differences in components has allowed the market to produce products that meet the specific architectural, budgetary considerations, and consumer preferences for every component of the door system. The industry is and has been well served with all of these customized choices, not to mention the ability of independent entrepreneurs to build a unique business model that provides jobs in communities across the country.

Costs and Components
If the E330 testing option were not in place, as is the current situation now in the Canadian codes, door pre-hangers in the United States that use door components from multiple suppliers and test their own products, would have no other alternative but to test to NAFS, which involves multiple tests using multiple systems of each door configuration they assemble for the marketplace. More importantly, there are no protocols in NAFS for component substitution. This would be such a significant cost for pre-hangers that the price would be too great to perhaps be able to stay in business, especially in this economy. The alternative would be to start buying complete door systems from door manufacturers that have the resources to conduct testing of their own complete systems. For the consumer, it would mean limited choices in a restrictive marketplace. We need to strike a balance between testing and certification costs, and the value those costs provide to the marketplace. If the door industry is forced to comply to NAFS, every door assembly would have to be tested and certified to the tune of $1,500 to $3,000 per configuration, which would inevitably be passed down to the consumer.

"A window is not a swinging door. A circle is not a square though they’re both geometric shapes. There are distinct differences in each of the product’s functionality and purpose."

So let’s summarize:
• The side-hinged door industry is significantly different than the window industry;

• The method to bring products to market is significantly different;

• The methodology for testing products developed and refined for the window industry over the years would be a significant hurdle for door companies to absorb and comply with;

• Compliance with the current NAFS has the potential to significantly and detrimentally affect the housing market by reducing the number of suppliers and increasing the cost of all products brought to market; and

• Compliance to NAFS will most likely reduce the number of smaller pre-hanging companies due to the financial impact of compliance.

Proactive Approach to Codes
AMD has kept a vigilant eye on code changes here in the United States to ensure that side-hinged exterior doors are not solely bound by NAFS in the codes. AMD will continue to do so during this next code development cycle which will take place in May 2012 and next year.

AMD found it necessary to write a standard that encompasses the concerns of all within our industry, and has taken a proactive position by becoming a performance standards developer for side-hinged doors. AMD’s first standard, the AMD 100, Structural Performance Ratings of Side-Hinged Exterior Door Systems and Procedures for Component Substitution, is close to completion and will be an alternative to NAFS in the near future. The AMD 100 minimizes the amount of testing required in that its sole focus is the structural performance (i.e., design pressure rating) of SHEDs per ASTM E330 and component evaluation procedures for substituting components in rated systems. AMD plans to pursue the development of other performance standards, such as air leakage, in the near future. It is AMD’s goal to develop performance standards for side-hinged doors that are well thought out and that will evolve over time in sync with the door industry.

I’d like to re-emphasize, it’s not because harmonization and high-performance products are a bad thing, and it’s not because cutting costs are the be all and end all. The door industry would have been in bad shape if that were the case. It’s about striking a balance between performance requirements, and manufacturing a quality custom product that is accessible to customers. It’s simply because it’s the right thing to do.

AMD represents numerous segments of all dimensions in the manufacturing and distribution of millwork products. On behalf of the millwork industry, AMD will maintain a close watch and continue to be proactive on code change proposals to the IBC and IRC that would make NAFS the exclusive standard for design pressure rating compliance in the international codes.

As I stated early on, we believe there are sound options where the side-hinged exterior door industry is concerned. NAFS is, unfortunately, not all things to all fenestration products. It’s a nice idea, but simply not realistic or practical for the door industry. Perhaps what’s more realistic is trying to be all things to all people without running the risk of oversight, presumption, and perhaps a bit of elitism.

Rosalie Leone serves as CEO of the Association of Millwork Distributors.

DWM
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