Staff Analysis

ISSUE: DS 2013-029. The petitioner, Gary Dennis, Product Manager for Innovative Insulation, Inc. www.radiantbarrier.com seeks a Declaratory Statement on Rule 61G20-3 as it pertains to their product.

Background: According to the manufacturer their products are radiant barrier and reflective insulation. A radiant barrier insulation system is a layer of metalized film facing an airspace and is installed in the envelope of a building to reflect radiant heat energy instead of trying to absorb it. Reflective insulation products consist of one or two layers of material laminated between layers of metalized film to provide excellent thermal resistance.

Section 61G20-3.001 of the Product Approval Rule, reads as follows:

61G20-3.001 Scope.

(1) Products in the following categories as defined by subcategories of subsection 61G20-3.002(31), F.A.C., shall be available for approval by the Commission pursuant to Rule 61G20-3.090, F.A.C., for use in the state:

(a) Panel Walls;

(b) Exterior Doors;

(c) Roofing Products;

(d) Skylights;

(e) Windows;

(f) Shutters; and

(g) Structural Components.

(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.

Section 61G20-3.002 of the Product Approval Rule, reads as follows:

61G20-3.002 Definitions.

(33) Subcategory of product or construction system means a specific functionality:

(a) For exterior door:

1. Exterior door assemblies: roll-up, sectional, sliding, swinging, automatic; pre-engineered roof access hatches; and products introduced as a result of new technology;

2. Exterior door components and products introduced as a result of new technology;

(b) For windows: awning, casement, dual action, double hung, single hung, fixed, horizontal slider, projected, pass through, mullions, and products introduced as a result of new technology;

(c) For panel walls: siding, soffits, exterior insulation finish system (EIFS), storefronts, curtain walls, wall louver, glass block, and products introduced as a result of new technology;

(d) For roofing products: built up roofing, modified bitumen roof system, single ply roof systems, spray applied polyurethane roof system, roofing fasteners, roofing insulation, asphalt shingles, wood shingles and shakes, roofing slate, roof tile adhesives, cements-adhesives-coatings, liquid applied roof systems, underlayments, metal roofing, roofing tiles, waterproofing, roofing accessories that are an integral part of the roofing system and products introduced as a result of new technology;

(e) For shutters: accordion, Bahama, storm panels, fabric storm panel, colonial, roll-up, pre-engineered equipment, protection, and products introduced as a result of new technology;

(f) For skylights: skylight, and products introduced as a result of new technology; and

(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.

Staff Recommendations: Based on the above facts and circumstances, staff provides the following recommendations:

Question: Do radiant barrier and reflective insulations products fall under the scope of the Florida Rule 61G20-3 and therefore require approval from the Florida Building commission to be sold for construction in your state?

Answer: No, based on the rules 61G20-3.001 Scope and 61G20-3.002 Definitions, “Radiant Barrier and Reflective Insulation” is not a structural product thus does not fall within the scope of the State Product Approval rule. However, the product in question is subject to approval by the local authority having jurisdiction.