Staff
Analysis for Declaratory Statement Request
DS2015-022
Issue: DS2015-022. Petitioner
seeks a Declaratory Statement on status of state rejected Novum Point Supported
Glass canopy panels product approval application # 17478 which is deemed by
staff to be outside scope of Rule
61G20-3.001. The Petitioner requests
clarification to the following question:
Is
a skylight product ineligible for a Florida Product Approval solely because it
is not part of the building envelope?
Background:
Situation:
The request focuses on a particular Point Supported Glass canopy panels, offered by Novum Structures. The petitioner applied for Florida Product
approval #FL3885 in January of 2005 for a point supported glass [PSGJ panel
skylight system for use on canopies and other similar cladding applications
that do not enclose
a space.
They decided to apply for a renewal of their product approval [under #17478J
for 4 minor reasons provided in the Appendix section of the letter. The product
itself has not changed in anyway.
Petitioner’s explanation:
The reason we indicate that our product is not to be
used as part of the building envelope is that it is not designed for, nor been
tested for, large or small missile impacts. Per Section 1626 of the 2010 FBC
the envelope of a building needs to be impact resistant to avoid internal
pressure changes to a building due to penetrations in the envelope during a high
wind event. Further, in section 1626.1, exception "a" specifically
excludes "canopies" from requiring ballistic testing.
We were told back in 2005 that we could forego the missile testing and perform
only the
uniform load pressure testing and that this would
make our product eligible for a product
approval for use in non-envelope areas such as canopies. This is what we did and we
received
product approval and have been installing PSG panels
on canopies in Florida since 2005.
The application was rejected by the department who
said the product is outside the scope of Rule 61G20-3.001. We believe the reason we were given that
direction and product approval in 2005 was because in the 2010 FBC section
1625.1 and 1625.2 it indicates [paraphrasing) "any construction where
there is insufficient evidence of compliance with the code, the building
official may require load testing" and the load
testing needed is defined there. As there is no
nationally recognized design standard which provides
clear analytical calculation methods,
Point Supported Glass is the type of product that
would likely fall into this category of
requiring testing.
We are only asking to renew the approval of a product
that has been thoroughly tested and
used successfully in the field for many years.
Note: The product in
question was first approved in October 11, 2006. This application has not been updated since
its original approval, which was specific to the 2001 FBC.
Rule 61G20-3 PRODUCT APPROVAL
61G20-3.001
Scope. (Current
Rule)
(1) Products in the following categories
as defined by subcategories of subsection 61G20-3.002(33), F.A.C., shall be
available for approval by the Commission pursuant to Rule 61G20-3.007, F.A.C.,
for use in the state:
(a) Panel Walls;
(b) Exterior Doors;
(c) Roofing Products;
(d) Skylights;
(e) Windows;
(f) Shutters;
(g) Structural Components; and
(h) Impact Protective Systems.
(2) This
rule applies to approval of products and systems, which comprise the building
envelope and structural frame, for compliance with the structural requirements
of the Florida Building Code.
Rulemaking
Authority 553.842(1) FS. Law Implemented 553.842(5) FS. History–New 11-22-06, Formerly 9B-72.005, 9N-3.001, Amended
4-1-14.
61G20-3.002
Definitions.
31) Structural component means any part or assembly of buildings
that comprises the main wind force resisting system and components or cladding.
(g) For structural components: truss plates, wood
connectors, anchors, exterior coolers-freezers, insulation form systems,
engineered lumber, pre-engineered air conditioner stands, structural wall
components, and roof deck, and products introduced as a result of new
technology.
Rule
9B-72 as existed before November 11, 2006
(28)
Structural component means any part or assembly of a
building or structure used or intended to support or shelter any use or occupancy, and which affects the
safety of such building or structure or which supports any dead or designed
live load and the removal of which part, material or assembly could cause, or
be expected to cause, all or any portion to collapse or to fail, or both.
ASCE 7
– 2010 (Minimum Design Loads for Buildings and other Structures)
Section 1.2 Denfinition:
Buildings: Structures, usually enclosed
by walls and a roof, constructed to provide support or shelter for an intended
occupancy.
Main Wind-Force Resisting System: An asseblage of structural elements assigned
to provide support and stability for overall structure. The system generally received wind loading
from more than one surface.
2010 FloridaBuilding Code, Building 202, Definitions
BUILDING. Any structure used or
intended for supporting or sheltering any use or occupancy.
2010 Florida Building Code, Energy conservation,
202 Definitions
BUILDING THERMAL ENVELOPE. The basement walls, exterior walls, floor,
roof, and any other building element that enclose conditioned space. This
boundary also includes the boundary between conditioned space and any exempt or
unconditioned space.
Webster’s Third New International Dictionary
BUILDING
A constructed edifice designed
to stand more or less permanently, covering a space of land, covered by a roof
and more or less completely enclosed by walls, and serving as a dwelling,
storehouse, factrory, shelter for animals, or other useful structure –
distinguished from structures not designed for occupancy (as fences or
monuments) and from structures not intended for use in one place
----
2012 NFPA1 fire code
3.3.250 Structural element
The columns and girders, beams, trusses, joists,
braced frames, moment- resistant frames, and vertical and lateral resisting
elements, and other framing memebers that are designed to carry any portion of
the dead or live load and lateral forces, that are essential to the stability
of the building or structure.(5000,2012)
2010 FloridaBuilding Code, Building 202, Definitions
CANOPY. Any fixed roof-like
structure, not movable like an awning, and which is cantilevered in whole or in
part self-supporting, but having no side walls or curtains other than valances
not more than 18 inches (457 mm) deep. Lean-to canopies, fixed umbrellas and similar structures are included in this
classification. Structures having side walls or valances more than 18 inches
(457 mm) deep shall be classified as a tent as set forth herein.
2010 FloridaBuilding
Code, Building Section 1626
High-Velocity Hurricane Zones—
Impact Tests For Wind-Borne
Debris
1626.1
All
parts or
systems of a building or structure envelope such as, but not limited to, exterior
walls, roof, outside doors, skylights, glazing and glass block shall meet
impact test criteria or be protected with an external protection device that
meets the impact test criteria. Test procedures to determine resistance to wind-borne debris
of wall cladding, outside doors, skylights, glazing, glass block, shutters and
any other external protection devices shall be performed in accordance with
this section.
Exception: The following structures or
portion of structures shall not be required to meet the provisions of this
Section:
a.
Roof assemblies for screen rooms,
porches, canopies, etc; attached to a building that do not breach the exterior
wall or building envelope and have no enclosed sides other than screen.
2010 FloridaBuilding
Code, Building Section 1625
1625.1 Application.
Whenever there is
insufficient evidence of compliance with the provisions of this code or
evidence that any material or any construction does not conform to the
requirements of this code, or in order to substantiate claims for alternate
materials or methods of construction, the
building official may require testing by an approved agency, at the expense
of the owner or his agent, as proof of compliance. Testing methods shall be as
specified by this code for the specific material.
Florida Statutes
553.8425 Local product
approval.—
(1) For local product approval,
products or systems of construction shall demonstrate compliance with the
structural windload requirements of the Florida Building Code through one of
the following methods:
(a) A certification mark,
listing, or label from a commission-approved certification agency indicating
that the product complies with the code;
(b) A test report from a
commission-approved testing laboratory indicating that the product tested
complies with the code;
(c) A product-evaluation
report based upon testing, comparative or rational analysis, or a combination
thereof, from a commission-approved product evaluation entity which indicates
that the product evaluated complies with the code;
(d) A product-evaluation
report or certification based upon testing or comparative or rational analysis,
or a combination thereof, developed and signed and sealed by a Florida
professional engineer or Florida registered architect, which indicates that the
product complies with the code;
(e) A statewide product
approval issued by the Florida Building Commission; or
(f) Designation of
compliance with a prescriptive, material standard adopted by the commission by
rule under s. 553.842(15).
(2) For product-evaluation
reports that indicate compliance with the code based upon a test report from an
approved testing laboratory and rational or comparative analysis by a Florida
registered architect or Florida professional engineer, the testing laboratory
or the evaluating architect or engineer must certify independence from the
product manufacturer.
(3) Local building
officials may accept modifications to approved products or their installations
if sufficient evidence is submitted to the local building official to
demonstrate compliance with the code or the intent of the code, including such
evidence as certifications from a Florida registered architect or Florida
professional engineer.
(4) Products demonstrating
compliance shall be manufactured under a quality assurance program audited by
an approved quality assurance entity.
(5) Products bearing a
certification mark, label, or listing by an approved certification agency
require no further documentation to establish compliance with the code.
(6) Upon review of the
compliance documentation, and a finding that the product complies with the
code, the authority having jurisdiction or a local building official shall deem
the product approved for use in accordance with its approval and limitation of
use.
(7) Approval shall be
valid until such time as the product changes and decreases in performance; the
standards of the code change, requiring increased performance; or the approval
is otherwise suspended or revoked. Changes to the code do not void the approval
of products previously installed in existing buildings if such products met
building code requirements at the time the product was installed.
History.—s. 19, ch. 2005-147; s. 66, ch. 2006-1.
Staff
Analysis:
Question: Is a skylight product
ineligible for a Florida Product Approval solely because it is not part of the
building envelope?
Answer/Option
#. 1: Yes, as per Rule 61G20-3.001, the product in question would fall outside
the scope of the state product approval program. However, the said product must
meet the requirements of the Florida Building Code and is subject to approval
by the local authority having jurisdiction.
Answer/Option
#2: No, as long as the applications/limits of use of the product in question
are limited to those applications where the said product is directly attached
or applied to the building envelop. Standalone (open structure) applications of
the product in question fall outside the scope of the state product approval
program. However, Standalone (open
structure) applications must meet the requirements of the Florida Building Code
and are subject to approval by the local authority having jurisdiction.