When Conditions are Extreme

By Julie Ruth, AAMA
April 15, 2008
COLUMN : Code Arena | Codes & Standards

You have had an aneurysm break in the back of your brain, between your brain and your skull. We are going to send you to the University of Colorado Hospital, where they will treat you." I stared at the Denver airport paramedic who had said this to me, trying to absorb it.

My first thought, of course, was, "I can't go to the hospital; I am going to miss my flight." They did send me to the hospital, where I was treated and beat the odds by not only surviving, but surviving in such a fashion that they tell me I can expect 100 percent recovery. Oh, to be alive in such an age as this.

Following this incident last fall, when the folks on AAMA staff asked me what I thought I would be able to do in 2008, my first response was that I wanted to go to the 2008 International Code Council code development hearings in February. I know-it's a sickness, but the need to attend code hearings is a disease all of us involved in the process recognize. Besides the desire to get out of Chicago in February, I was spurred by the fact that pretty well everything else I do business-wise is based upon these hearings.

Held in Palm Springs, Calif., the ICC meetings featured discussions on numerous code change proposals relating to windows and doors. A summary of the hearings results follows:

The proposal by the Window & Door Manufacturers Association (S141) would have required side-hinged doors to be tested and labeled to AAMA/WDMA/CSA 101/I.S.2/A440 in the same manner as windows and sliding glass doors in both the International Residential Code (one- and two-family dwellings and townhouses) and the International Building Code (all other types of residential, and commercial buildings). The Association of Millwork Distributors opposed the requirement, arguing that it would limit consumer choices because it would prevent pre-hangers from putting together a door using components from different suppliers. AAMA had offered a modification to the proposal that would have limited its scope to doors in areas with a wind design speed greater than 110 mph, and on doors that did not have a large overhang and which served habitable areas. 

Unfortunately AAMA, WDMA and AMD were not able to come to agreement on the proposed modification, including possible further revisions, before the code development hearings. As a result, WDMA ended up asking for and receiving disapproval of its proposal at the hearings. By asking for disapproval rather than withdrawing the proposal, WDMA left the door open for the side-hinged door issue to be brought up again during ICC's final action hearings, scheduled for September.

A few different proposals to change the requirements in the IRC for window installation, including adding reference to ASTM E2112 (RB172) and permitting pan flashing as a method of window flashing (RB201) were denied. A proposal to require all flexible adhered flashing membranes to comply with AAMA 711 (RB199), however, was approved.

During previous ICC code change cycles, a lot of controversy was generated by the introduction of a 24 inch minimum sill height for operable windows that open more than 4 inches and which are located more than 72 inches above the exterior grade or surface below the window. The minimum sill height requirement is designed to help prevent child falls, but there are many who question its effectiveness on that front and note that it creates challenges as far as egress.

The ICC Board of Directors eventually deferred the issue to the ICC code technology committee, which had been developed specifically to address issues that had taken up a lot of time on the hearing floor. The ICC CTC submitted a proposal for this code change cycle (RB173), which added certain exceptions to the 24 inch minimum sill height requirement. Among these was the equipping of the window with a "window opening limiting device" that initially permitted the window to open no more than 4 inches, but which, upon release, would permit the window to be opened further. The intent of this proposal was to allow these devices to be used on emergency escape and rescue openings, which are required to open to a minimum height of 24 inches and a minimum width of 20 inches under the normal operation of the window, without the use of "keys, tools or special knowledge." While it is hoped that this type of proposal may eventually allow the industry to provide a product without limitation on its placement in the wall, unfortunately at this time there were some concerns that the requirements for these window opening limiting devices were vague, and the proposal was disapproved. A proposal by WDMA to remove the minimum sill height requirements (RB174) was also disapproved. Size of doors

A proposal by AAMA (E37) to clarify the size of door requirements in the IRC and IBC as a minimum clear width of 32 inches was approved. Within the IRC the proposal was approved with a minimum clear opening height of 78 inches, as proposed by AAMA. Within the IBC the proposal was modified to require a minimum clear opening height of 80 inches.

The 2000 and 2003 IBC require analysis or test data from a registered design professional for framing that supports glass and deflects more than L/175 under design load, but an exemption exists for products that are labeled to AAMA/WDMA/CSA 101/I.S.2/A440. A proposal to remove this exemption (S142) was disapproved during the hearings. 
There were a number of proposals submitted that dealt with residential fenestration U-factors in the IRC and International Energy Conservation Code (EC14, EC 16-EC21, EC22-EC26, EC54-EC56). The net results of the code development hearings for these groups of proposals are shown in Tables 1 & 2.
On the commercial side, a proposal to permit the use of AAMA 507 for fenestration energy rating in commercial buildings (EC4), was denied. Among concerns expressed by the IECC committee was the fact that the proposal allowed the glazing contractor to sign the required certificate of compliance, and concern that residential window manufacturers might want to use AAMA 507 instead of NFRC labeling for their products. 

A WDMA proposal that would have eliminated reference to metal framing in the prescriptive table for fenestration energy performance in commercial buildings, and would have required U-factors as low as 0.35 for all windows and exterior glass doors other than entrance doors (EC113), was denied. Also failing to find approval was a proposal to remove consideration of projection factor in the determination of maximum SHGC for commercial fenestration (EC115).

Although two proposals to remove reference to ASHRAE 90.1 (EC103 & EC104) were disapproved, a proposal that limited the designer to either using the IECC in its entirety, or ASHRAE 90.1 in its entirety (EC105), was approved. The 2003 and 2006 IECC permit the designer to use the IECC for one building system, such as the exterior building envelop or the HVAC system, and ASHRAE 90.1 for another. Proposals by both AAMA and AEC (EC107 & EC108) that would have permitted calculation of the average U-factor for the exterior envelop and average SHGC for the exterior fenestration as a method of compliance with the IECC, were both also denied.

At the present time, residential energy conservation requirements are contained in both the IRC and IECC. Two proposals to remove this redundancy (RE2 & RE3) by deleting the provisions from one of the codes failed to move forward. AAMA stayed neutral on these two proposals, which sought to remove the residential energy provisions from either the IRC or IECC.

Proposals which would have restored separate values for plastic skylights in commercial construction (EC114), which would have required skylights in 2 percent of the roof area of certain occupancies, when automatic lighting controls and other criteria were met (EC120 & EC121) and which would have permitted skylights in up to 6 percent of the roof area of certain occupancies and exempted them from the SHGC limitations of the prescriptive method, when automatic lighting controls were provided (EC122) were all denied. These proposals would have all made the prescriptive provisions of the IECC more conducive to manufacturers of plastic skylights.  

The update of several standards currently referenced in the IBC, IRC and IECC was approved. Among the newer editions of standards currently referenced that were accepted for the 2009 International Codes were AAMA/WDMA/CSA 101/I.S.2/A440-08, NFRC 100-04, NFRC 200-04 and NFRC 400-04.

While many decisions were made in Palm Springs, none are final. Those who wish to challenge any of the decisions made during the hearings may do so by submitting a public comment to ICC by June 9. Those public comments will then be heard during ICC final action hearings in Minneapolis, Minn., September 17-23. AAMA has conducted its initial review of these results, and will be preparing public comments on some of the proposals, during the next few months.

I have received a lot of different responses to the incident described at the beginning of this month's column. People have told me I have been given a second chance and a wakeup call. I have been told that God's hand was on me, and that God isn't through with me yet. My daughter told me they (presumably my family?) need to find a way to motivate me to take better care of myself.

All of these are rather heavy topics to think about, and I don't really think their full ramifications have hit me yet. But the one thing that has been brought home to me is all the really great people I have been fortunate enough to have in my life. That includes the people I have worked with in the code community, and within the fenestration industry. Thank you to all of you for the e-mails, phone calls, cards, flowers that couldn't be delivered to ICU, help preparing for the code hearings and the AAMA Annual meeting, words of encouragement, etc. that you have provided throughout this entire incident. There are too many people for me to try to thank, and I am afraid if I did I might miss someone. I would like to thank all of you who offered me such great support these past few months. I feel I have been truly blessed to work in such a great industry, and to work with so many great people.

Editor's Note: We're certainly glad to have Julie back to health and back in Window & Door.

Code Arena is brought to you by the American Architectural Manufacturers Association. Julie Ruth may be reached through AAMA at 847/303-5664 or via e-mail at julruth@aol.com.