OCTOBER 10, 2014

ATTENTION AMD MEMBERS!

RE: LATEST DRAFT OF THE 2014 FLORIDA BUILDING CODE AND REQUIREMENTS FOR SIDE-HINGED          
      EXTERIOR DOORS

Recently, the Draft 5th Edition of the Florida Building Code was posted to the International Code Council’s website. Significant modifications have been made to the sections of the commercial (Building) code that set forth structural performance requirements for windows and doors (See Chapter 17, Sections 1710.5.1 and 1710.5.2). Of particular concern right now to AMD and others in the door industry is the fact that language has been removed that expressly states that side-hinged exterior doors (SHEDs) have the option to comply to Section 1710.5.2 which allows testing to ASTM E330 for non-HVHZ (non-High Velocity Hurricane Zone) products.

Section 1710.5.2 exists for windows and doors that are not covered by 1710.5.1. However, since SHEDs are not specifically referenced in either of these sections now, it unclear as to where they are to fall in these requirements. Which “door assemblies” are covered by 1710.5.1 and which “door assemblies” are covered by 1710.5.2? Do SHEDs still have the option to comply with one or the other of these sections as they do in Florida’s residential code?

AMD’s Industry Standards and Certification Committee (ISCC) and Codes and Standards, Strategy Committee (CSSC), and AMD Director of Codes and Standards are currently working with other industry stakeholders to address this issue. AMD is requesting that the Florida Building Commission take action and provide a resolution prior to final code adoption. We strongly urge our members doing business in Florida to contact the Florida Building Commission on this issue----don’t wait!

The Fenestration Manufacturers Association (FMA) supports AMD’s concerns and recently published an article in their October newsletter which explains this issue in more detail; it is re-printed below, courtesy of FMA.

Please contact Jessica Ferris, Director of Codes and Standards, with any additional questions or concerns you may have.  


October 2014
Article Provided Courtesy of Fenestration Manufacturers Association

WILL SIDE-HINGED EXTERIOR DOORS NEED TO BE TESTED AND LABELED PER AAMA/WDMA/CSA/101/I.S.2/A440 (NAFS) STANDARD IN THE 2014 FLORIDA BUILDING CODE, 5th EDITION?

The draft version of the 5th Edition of the 2014 Florida Building Code has amended the section affecting Exterior Window and Door Assemblies (new Section references are codified at S.1715.5.1 and Section 1715.5.2). At first blush it appears that side-hinged exterior doors will require that they be tested to AAMA /WDMA/CSA/101/I.S.2/A440 (NAFS) referenced standards or to TAS 202. Labeling requirements listed in Section 1710.5.1 would also be required.

Now for one of the more generous terms in the English language, the word “OR” appears in Section 1710.5 and directs the reader to Section 1710.5.1 or Section 1710.5.2 as an alternative.

Section 1715.5.2 suggests another option to demonstrate compliance and that is to provide testing to ASTM E 330, Standard Test Method for Structural Performance of Exterior Windows, Doors, Skylights, and Curtain Walls by Uniform Static Pressure Difference with no labeling requirement.

No supplemental label requirements would be required as in Section 1710.5.1, FBC if using section 1710.5.2.

It has been discussed at length over the past several months by concerned parties that the language in Sections 1710.5.1 is unclear as to whether an alternative route exists for side-hinge door manufacturers to opt for testing to ASTM E 330, as provided for in Section 1710.5.2, and not be required to meet supplemental label requirements.

Reviewing Section R612.5 in the Florida Residential Code, it provides similar language as Section 1710.5.1, Florida Building Code. Reading this section it becomes clear that side-hinge doors are provided the option of complying with R612.5 which limits testing to ASTM E 330 with no labeling requirement.

The Florida Building Commission will hold a public hearing prior to the formal adoption of the 5th Edition of the 2014 Florida Building Code. The date has not been set at this time. A request for clarification could be made at this time by the general public. However, the most expedient route according to the Florida Building Commission staff is to file a Request for a Declaratory Statement after code adoption.

FMA/WDMA in conjunction with the Association of Millwork Distributors (AMD) supports requesting the Florida Building Commission to discuss this issue and provide a resolution prior to the final code adoption hearing. That is, no Declaratory Statement after the fact.

Questions to be addressed:

  • Section 1710.5.1, what takes you to Section 1710.5.2 for code compliance? It is our view that a product manufacturer of these categories of products are free to choose one or the other path, and if the choice of 1710.5.2 does not include the same labeling requirements as 1710.5.1.
  • Do the labeling requirements of Section 1710.5.1 apply when products comply with 1710.5.2? It is our view that if you take the 1710.5.2 path, label requirements of 1710.5.1 are not applicable.
  • The 2012 IBC language is quite different than the Version 5 of the 2014 Florida Building Code. Based on the rules that were established for the code development process, what Florida specific need was demonstrated for this change, other than the addition of the HVHZ standard (TAS202) and the labeling requirements?
  • The FBC (Building) and FBC (Residential) codes have somewhat different language for window and door assemblies. We argue that the intent was to keep the language effectively equivalent. In the base codes (2012 IRC and the IBC) there is no difference. We question a demonstrated need resulting in these differences.

FMA New Briefs – October 2014