Many Wins for Industry at Recent Hearings

Julie Ruth
July 7, 2010
COLUMN : Code Arena | Codes & Standards

After the May International Code Council Group A+ final action hearings, an AAMA member remarked to me, “I can’t remember the last time we had such a high rate of success at a code hearing.”

I could. It was before energy conservation codes became as prominent as they are now.

Codes were less a source of division within our industry. We were able to focus more on what we agreed upon on the hearing floor, and less on our differences. We often spoke with one voice, and when we speak with one voice, ICC tends to listen to us.

Now I am not saying anyone should give up their right to express their opinion. As we all know, functioning societal relationships depend upon the ability for all parties involved to be able to express their views. This is as true within an industry or organization as it is within a democracy or family. But when we can discuss the issues that divide us within our own industry and resolve them, and then bring that resolution to other agencies, including ICC, we get better results.  And I think for all of us, what is good for the industry is good for us.

So I am asking all of us, as an industry, to resolve our disagreements before we step up to the microphone at the ICC hearings. Bringing our disagreements to ICC is ineffective and a waste of time, money and other resources.  I will now step down from my soapbox and give you a summary of the Group A+ final action hearings that occurred in Dallas in May.

Sill heights and WOCDs
The required height of operable window sills that are more than 72 inches above exterior grade in residential occupancies that are built under the 2012 International Building Code will be 36 inches or more above the interior floor. This requirement will not apply if the window cannot be opened more than 4 inches under normal operation, or is equipped with a window guard or window opening control device (WOCD) that complies with ASTM F2090, or, for dwelling units that are more than 75 feet above grade, window guards that comply with ASTM F2006.

The window opening control device is to limit the initial opening of the window to no more than 4 inches, but then release with no more than 15 pounds force to permit the window to be opened to a greater size. This could be the size required to meet emergency escape and rescue opening requirements, if applicable, for that particular window. This requirement would apply to multifamily buildings such as apartment buildings, and one- and two-family homes and townhouses if they are being built under the IBC rather than the International Residential Code. It is anticipated the primary impact of this change will be operable windows provided in apartment buildings.

The minimum sill height required for one- and two-family dwellings and townhouses built under the 2012 IRC will remain at 24 inches instead of being increased to 36 inches. This requirement also would not apply if the window does not open more than 4 inches, or if it is equipped with a window guard or WOCD that complies with ASTM F2090.

The discrepancy in height between the two codes (36 inches for the IBC, 24 inches for the IRC) was probably the industry's biggest disappointment in the otherwise fairly successful code hearings. Acceptance of the use of WOCDs as an alternate to the minimum sill height, on the other hand, will provide window manufacturers and home builders alike with more options with regards to compliance with this new set of requirements. AAMA members have been actively participating in the revision of ASTM F2090 to clarify its testing requirements, and we will be seeking the update of that referenced standard to the recently issued 2010 edition during the Group B- hearings later this year.

Exterior door ratings
AAMA was successful in defeating three proposals that would have permitted component-based rating of exterior door assemblies. Two of these proposals relied upon ANSI A250.13 for rating of the individual components, while one relied upon the Association of Millwork Distributor’s Side Hinged Exterior Door standard (SHEDs) for rating of a completed door assembly based upon testing of individual components in that assembly.

Although the concept of component-based rating of door assemblies is one that AAMA itself has pursued actively over the past few years, it is one that is proving to be complex. Testing conducted by the AAMA door council has found the methods proposed for consideration by ICC during this cycle were overly simplistic and did not adequately address all the nuances that needed to be addressed.

The definition of tubular daylighting devices that currently exists in AAMA/WDMA/CSA 101/I.S.2/A440 will appear in the 2012 IRC and 2012 IBC, along with clarification that these devices are to be tested and labeled in accordance with that standard. At the present time, unit skylights are required to be tested and labeled in accordance with the same standard in both the IRC and IBC. Unit skylights will also be exempt from a requirement of the IRC and IBC for saddle or cricket flashing of large roof openings. It is more appropriate for the installer of these skylights to instead rely upon the installation instructions of the skylight manufacturers, as currently occurs for windows.

Proposals that would have required all skylights to be protected by a guard or screen that is capable of resisting a 200 pound load, or for the skylight itself or screen protecting it to be able to resist an 800 ft-lb impact load representative of a falling body part, were disapproved. Also disapproved was a proposal that would have required all plastic dome skylights to be subject to a Class B burning brand test, regardless of the materials used for the dome or framing.

Window installation
Although the 2012 IRC will continue to rely upon the fenestration manufacturers' instructions as the primary source of information for the flashing and installation of windows, other options will be permitted for applications not covered in the fenestration manufacturers' instructions. These options include flashing to a manufacturer's instructions, a registered design professional’s specified method, pan flashing, or other methods approved by the code official.

Framing deflection
Additional testing and analysis for fenestration products whose framing deflects more than L/175 will continue to not be required in the 2012 IBC for AAMA/WDMA/CSA 101/I.S.2/A440 labeled products.

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