NGA’s fire, safety, and structural Code Consultants Thom Zaremba and Nick Resetar of Roetzel & Andress represented the glass and glazing industry by participating in the International Code Council Group B hearings in Louisville, Kentucky, beginning Sept. 14. Below are the results of proposals relevant to glazing.
The Group B half of the Code Development Cycle for the 2024 editions of the International Building, International Existing Building, International Fire and International Residential Building Codes (IBC, IEBC, IFC and IRB, respectively, and I-Codes collectively) are now closed to any further Technical Committee or stakeholder input. The “On-line Governmental Consensus Vote,” or OGCV, opens on October 10, 2022, and closes on October 24, 2022. It will give the Governmental Voting Members of the International Code Council throughout the Country that weren’t able to attend the Public Comment Hearings in Louisville, KY last month, an opportunity to cast their votes.
Since the OGCV rarely changes outcomes and many of the proposed changes discussed here were included on the “Consent Agenda,” and are now final because no Public Comment challenging them was submitted, we’re going to bring you to speed on proposed changes important to the glazing industry processed during the 2022 Group B Code Development Cycle.
ADM13-22 and ADM14-22
We were instrumental in defeating two proposed changes to Section 104 of the IBC. As background, if a specific means or method of construction or a specific product does not meet the literal requirements of the Code, the “Authority Having Jurisdiction,” or AHJ, is permitted to consider and allow, if appropriate, “alternative means, methods and products” if they provide equivalent performance and safety.
The defeated proposals were Public Comments that would have modified ADM13 and ADM14 to allow the AHJ to approve alternative means, methods or products EVEN if their use is specifically PROHIBITED by the Code. These changes would have permitted AHJs to allow builders to use inferior means or methods of construction and materials specifically prohibited by the Code. This could have allowed products inferior to glass to be used in the construction of buildings. While the disapproval of these proposals remains subject to final determination by the OGCV, we don’t believe that vote will change the decision to disapprove them.
G8-22
This GICC proposal to modify Section 403.2 of the IBC was unanimously approved by the Technical Committee and, since no Public Comment was submitted challenging it, the Technical Committee approval is final, and this change will be incorporated into the 2024 edition of the IBC.
This change applies to the use of 2-hour fire-resistance rated glazing used to enclose interior exit stairways in high rise buildings. It puts fire-resistance rated glazing on par with other materials, such as concrete and masonry, used to enclose these interior exit stairways. Specifically, it provides that “glass walls complying with the safety glazing impact requirements of CPSC 16 CFR 1201, Cat. II or ANSI Z97.1, Class A shall be deemed to comply with the requirements of [ASTM C1629/C1629M as specified in] Section 403.2.2.1 and 403.2.2.2.”
EB11-22
In short, this proposal would have required gas appliances to be tested for proper combustion whenever any windows or doors are replaced or, storm windows are installed, in a home. While this proposal, submitted by the Propane Gas Industry, may have some technical merit, its ambiguity, lack of substantiating evidence and lack of enforceability compelled us to successfully oppose and defeat it, subject to the OGCV.
S102-22
This proposal to modify Section 1607 of the IBC was originally drafted to fix the problem of “slack” developing in cable infill systems used in guards. The Technical Committee disapproved the proposal, but unfortunately asked the Proponent to submit a Public Comment expanding the proposal to ALL infill materials. The Proponent submitted a Public Comment as requested, but, applying it to glass guards resulted in several conflicts with GICC authored glass guard requirements in Section 2407 of the IBC. As a result, subject to the OGCV, we successfully defeated this proposal, but have also committed to work with the Proponent to develop a fix for slack in cable infill systems that will not adversely affect the use of glass in guards.
S128-22
This proposal attempted to change several Sections of the IBC to mandate that Environmental Product Declarations (EPDs) for a variety of construction materials, including glass, be included as a part of the plans and drawings submitted to approve new building construction. For a number of reasons, including the fact that EPDs do not support or improve the concept of safe building construction embodied in the IBC, on behalf of the glass industry, we joined a variety of industries, including masonry, concrete, wood and steel, in successfully opposing and defeating this proposal, subject to the OGCV.
S229-22
This is a GICC/NGA safety glazing proposal. It proposed that IBC Section 2406.1 be changed to read: “All glass in glazed areas, including glass mirrors, single panes of glass, laminated glass and all panes in multi-pane glass assemblies in hazardous locations as defined in 2406.4 shall comply with Sections 2406.1.1 through 2406.1.4.”
The proposal was submitted because it was discovered that some triple glazed units manufactured for use in hazardous locations, used safety glazing in the inboard and outboard lights, but not in the center lights. This proposal clarifies that, in the absence of a specific exception, all glass panes used in hazardous locations must be safety glazing, whether they are single, double, triple, quadruple or other types of glazed assemblies.
This proposal was unanimously approved by the Technical Committee and was not challenged by a Public Comment. As a result, the Technical Committee’s recommendation is final, and this change will be incorporated into the 2024 edition of the IBC.
S231-22
This proposal sought to modify exception 3 to Section 2406.4.3 of the IBC. That exception exempts outboard panes in multi-pane window assemblies from the safety glazing requirements applicable to hazardous locations if it is located 25’ or more above grade.
Historically, the 25’ above grade trigger for this exception was justified on the basis that a human impact breaking through a window 25’ or more above grade would result in a fatal fall and, therefore, safety glazing on the outboard pane was unnecessary. However, it is well established that safety glazing standards are used to minimize cutting and piercing injuries resulting from human impact with glazing materials. They are not used to prevent people from falling out of buildings through windows. Further, when we asked building code officials about this proposal, we learned that they found the 25’ trigger difficult to justify or enforce in the field. They cited transom lights as an example where safety glazing is not required because, at 8’ or so above floor level, they are generally out of the reach of human impact.
Consequently, we supported making these changes to Exception 3 to Section 2406.4.3 to the IBC: “Outboard panes in insulating glass units or multiple glazing [shall not require safety glazing] where the bottom exposed edge of the glass is 8 feet (2438 mm) or more above any grade or walking surface adjacent to the glass exterior.”
This modification was unanimously adopted by the Technical Committee and was not challenged by a Public Comment. As a result, the Technical Committee’s recommendation is final, and these changes to Exception 3 will be incorporated into the 2024 edition of the IBC.
S234-22
This proposal suggested that IBC Section 2409.1 be modified to require those choosing not to design glass floors/ceilings to the requirements of ASTM 2751, to submit their proposed designs to the AHJ as an alternate method or means of construction, rather than leave it to the AHJ to evaluate their proposed designs under Chapter 16 of the IBC.
This proposal appropriately shifts responsibility for justifying the design of non-ASTM 2751 complying glass floors/ceilings from the AHJ to the designer and was unanimously approved by the Technical Committee. Since no Public Comment was submitted, the Committee’s recommendation is final, and these changes will be incorporated into the 2024 edition of the IBC.
S235-22
This proposed change to IBC Section 2407.1.1 was submitted by GICC and NGA and was modified with their support from the floor at the Public Comment hearings.
As modified, this proposal rewrites the rule mandating that glass in glass guards be designed using a “factor of safety of four.” The following text of the rewrite is intended to provide an objective basis for designers to meet the “safety factor of four” rule applicable to the glass elements used in guards: “Glass handrails and guards and their support systems shall be designed to withstand the loads specified in Section 1607.9. Calculated stresses in glass elements of handrails and guards due to these loads shall be limited to a maximum of 3,000 psi (20.7 MPa) for heat strengthened glass and 6,000 psi (41.4 MPa) for fully tempered glass.”
This rewrite of Section 2407.1.1 was unanimously adopted by the Technical Committee and no Public Comment challenging it was submitted. As a result, the Technical Committee’s recommendation is final, and these changes to the “safety factor of four” rule governing the use of glass in guards will be incorporated into the 2024 edition of the IBC.