Volume 47, Issue 3 - April 2008— Only Online--EXPANDED
S141 Voted Down—For Now
Officials Speak Out at the 2008 ICC Hearings
by Samantha Carpenter editor of Shelter magazine.
The International Residential Code (IRC) committee voted unanimously 9-0 at the recent International Code Council hearings to disapprove the code amendment S141 (see related articles on this standard in the November/December 2007 issue of Shelter on page 50 and in the January/February 2008 issue of Shelter on page 16).
The amendment was submitted by the Window and Door Manufacturers Association (WDMA), and it attempted to remove the current exemption for side-hinged exterior doors from nationwide testing of the AAMA/WDMA/CSA A440 test standard.
The reasoning for the proposed amendment by the WDMA in the code document read:
“This proposal adds testing and labeling requirements for side-hinged door assemblies that are included within the scope of AAMA/WDMA/CSA 101/I.S.2/A440. Starting with the 2000 IRC (and International Building Code), exterior windows and exterior sliding doors have been required to be tested and labeled as conforming to AAMA/WDMA/CSA 101/I.S.2/A440 (or to the 1997 or 2002 versions of this standard) requiring window and sliding door assemblies to meet air infiltration, water infiltration, structural, operational, and forced entry performance requirements. This proposal adds side-hinged doors to the list of exterior fenestration products which will be required to meet air infiltration, water infiltration, operational, and forced entry performance requirements in addition to structural performance requirements currently required by the IBC and IRC. This proposal also revises the language describing labeling requirements in IRC Section R613.4 to be consistent with the IBC. It is important to note that storm doors and site-built door systems are not within the scope of AAMA/WDMA/CSA 101/I.S.2/A440, as listed in this industry consensus standard, and would not be affected by this proposal. This proposal will increase complexity and cost of manufacturing side-hinged door assemblies because it requires side-hinged door assemblies to be tested, and labeled, to performance requirements previously not required.”
Additional Work Needed
The “This Week @ WDMA” newsletter noted, “WDMA, in presenting the proposal, acknowledged that additional work was needed in dealing with some certification issues but asked the IRC committee to weigh in on the subject.”
Tom Myers, a building official from Center City, Colo., and a member of the IRC code committee, testified during deliberations against the proposal, but urged stakeholders to resolve their certification issues, according to the newsletter.
“I have to admit there is a certain amount of hypocrisy to require detailed flashing instruction for exterior door openings, and then exempting the door assemblies themselves from water penetration requirements,” Myers said.
Mike Fischer of the Kellen Co., who serves as director of codes and regulatory compliance for the WDMA, testified in support of the WDMA proposal, stating that in the absence of performance requirements in the code, state legislators may take matters into their own hands. Fischer spoke about state legislation that was passed in 2003 in California, and recent activity in Florida related to water management and labeling of exterior fenestration products.
“If we don’t bring these standards forward and advocate for quality products meeting the latest standards, state officials will do it for us,” Fischer said. “California SB 800 is a prime example of how a right-to-cure bill can contain more stringent standards than those in the model codes.”
Against the Proposal
The Association of Millwork Distributors’ (AMD) director of codes and standards, Jeff Burton, spoke against the code amendment. “I firmly stated that the proposal was not needed and further provided scientific evidence from three sources that exterior side-hinged doors proved no significant failures or water infiltration problems during the recent hurricane seasons,” Burton said. He cited three studies to back up his claims: “Rainwater Management Performance of Newly Constructed Residential Building Enclosures During August and September 2004” by Dr. Joe Lstiburek of the Building Science Corp., the Home Builders Association of Metro Orlando and the Florida Home Builders Association; “The Benefits of Modern Wind Resistant Building Codes on Hurricane Claim Frequency and Severity—A Summary Report” by Dr. Timothy Reinhold from The Institute for Business and Home Safety; and the “Post-2004 Hurricane Field Survey – an Evaluation of the Relative Performance of the Standard Building Code and the Florida Building Code” by Dr. Kurt Gurley of the University of Florida and funded by the State of Florida. Burton was a contributor on the latter two studies.
AMD president Larry Ray, representing pre-hanger GHDC Inc. in Tupelo, Miss., also spoke against the proposed amendment and discussed the economic problems that S141 could cause if implemented. He noted that the proposed standard tends to favor providers of complete door systems that have resources to develop, test and provide an integrated system, and if passed, would put pre-hangers that typically source their components from multiple suppliers at a disadvantage. In addition, he said that the costs would prevent distributors that don’t carry certified door units from a major manufacturer from selling exterior doors.
Richard Sorrell, representing Barnett Millwork in Mobile, Ala., addressed the Code Council as a homebuilder and a door pre-hanger. “[Sorrell’s] comments and reflections seem to greatly affect the four homebuilders on the Council,” Burton said. “Richard’s pragmatic statement that, as a seller of side-hinged exterior doors, ‘I couldn’t sell doors, if they leaked, no one would buy them …’ drove his points home.”
Also speaking against the standard was Dave De Block, a technical consultant representing ODL. According to Burton, De Block addressed the Council about current testing and reiterated that the standard was more fitted to windows and not doors. AMD member John Quinn of Simpson Door also reviewed numerous current requirements from states such as Texas and Florida. “He reviewed portions of the standards and pointed out that no provisions are made for the substitution or interchange of rated components within a door unit, unlike other standards currently in use, such as tests for fire rating,” Burton explained.
Also present in opposition of S141 was a representative from the National Association of Home Builders.
“The five speakers were well prepared in opposition to the provisions of S141 … All were well-prepared with a different viewpoint on the matter. Equally important to showing up with well-prepared speakers were the letters written by our members in opposition to S141,” AMD president Larry Ray says. “AMD perhaps had one of its finest hours as an advocate for [its] membership.”
But where does the standard go from here now that the proposed standard was voted down? Fischer says the ICC will hold Final Action Hearings for the current code cycle this September in Minneapolis. “WDMA will likely submit a public comment on S141, placing it on the agenda. The results of that will determine the provisions of the 2009 I-Codes,” Fischer says.
He says that the WDMA Hallmark Certification and Exterior Standards Committees will meet in March to discuss the status of testing and certification programs for side-hinged entry doors.
“WDMA will work with stakeholders, including AMD, to define the best way to approach testing of entry doors for compliance with water penetration requirements found in the joint standards,” Fischer says. “The end-user has an expectation that entry door systems will resist water penetration, and it is important that the parties come together to satisfy that desire. WDMA believes that appropriate and reasonable solutions to certification issues are possible and will work to continue the dialogue.”
AMD officials will report to their members on the IBC actions and future advocacy with a Codes and Standards website video on AMDWEB.com.
“Among the membership of AMD are more than 3,000 independent door pre-hangers across this country,” Ray says. “These pre-hangers are the primary source for exterior side-hinged doors for the majority of lumber dealers, home centers, builders and remodelers in this nation. Many of these pre-hangers would not have been able to bear the financial burden of door system testing implied by S141. AMD will continue to raise a united voice on behalf of our members and those in the millwork distribution business.”
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