Issue: DCA10-DEC-217.  The petitioner seeks a declaratory statement requesting clarification of whether the Florida Building Code allows the Manufacturer through engineering practice to submit additional information that will allow the substitution of anchors and installation into different substrates for a product submitted using the Certification Method and using AAMA 506-06.

The petitioner is requesting on behalf of the American Architectural Manufacturers Association [AAMA], which is a Product Certification Agency and a Product Validation Entity, Approved by the Florida Building Commission.

The petitioner request that the Commission issue a Declaratory Statement to answer the following question:
Does the Florida Building Code allow the Manufacturer through engineering practice to submit additional information that will allow the substitution of anchors and installation into different substrates for a product submitted using the Certification Method and using AAMA 506-06?

Background: 

1.	AAMA 506-06 (Voluntary Specifications for Hurricane Impact and Cycle Testing of Fenestration 	Products)reads in part:
	Section: 7.0 TEST SPECIMEN PREPARATION
7.1 Test specimen shall be mounted using anchors and anchor spacing for which approval is desired. To qualify more than one anchor type, at least one of the test samples must be tested with that anchor and its appropriate framing material (i.e. wood, masonry, etc.)." (underline added for clarity)

NOTE: The 2010 FBC adopts AAMA-08, which allows the substitution of anchors and different substrates to be engineered according to accepted engineering practices. The section is as follows:
	8.0 Qualification of Alternate Constructions:
		8.3 The Anchorage details (size, spacing, or substrate) shall be permitted to qualify by 			submittal of calculations according to accepted engineering practice.

2. 	"Section 1714.5.4.1 Anchoring requirements. Window and door assemblies shall be anchored in accordance 	with the published manufacturer's recommendations to achieve the design pressure specified. Substitute 	anchoring systems used for substrates not specified by the fenestration manufacturer shall provide equal or 	greater anchoring performance as demonstrated by accepted engineering practice." (underline added for 	clarity) 

3.	"Section 102.4 Referenced codes and standards. The codes and standards referenced in this code shall be 	considered part of the requirements of this code to the prescribed extent of each such reference. Where 	differences occur between provisions of this code and referenced codes and standards, the provisions of this 	code shall apply." (underline added for clarity)

Staff Recommendations: Staff provides the following for consideration.

Question: Does the Florida Building Code allow the Manufacturer through engineering practice to submit additional information that will allow the substitution of anchors and installation into different substrates for a product submitted using the Certification Method and using AAMA 506-06.

Answer: Yes, Section 1714.5.4.1 of the Florida Building Code, Building, allows substitute anchoring systems for different substrates using rational engineering analysis "accepted engineering practice".

Petition for Declaratory Statement before the Florida Building Commission

November 2, 2010

FLORIDA BUILDING COMMISSION
FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS
2555 SHUMARD OAK BLVD.
TALLAHASSEE, FLORIDA, 32399-2100
ATTENTION: MS. PAULA FORD, AGENCY CLERK

RE: Sections 1714.5.4.1, 102.4 and AAMA 506-06, Voluntary Specifications for Hurricane Impact and Cycle Testing of Fenestration Products found in Chapter 35 of the 2007 Florida Building Code.

Mr. Mo Madani, CBO, EIT
Planning Manager
Department of Community Affairs

On behalf of the American Architectural Manufacturers Association [AAMA], a Product Certification Agency and a Product Validation Entity, Approved by the Florida Building Commission.

AAMA realizes that some products are being Evaluated outside the scope of AAMA 506-06 and therefore a clarification and interpretation is requested for language found in Section 1714.5.4.1 and Section 102.4 as it pertains to AAMA 506-06, Voluntary Specifications for Hurricane Impact and Cycle Testing of Fenestration Products.

Assertions:

When an AAMA Certified manufacturer has a product tested to AAMA 506-06 for submission to the Florida Product Approval System, and AAMA 506-06 specifically states that the product must be tested in the substrate used for installation will the manufacturer be allowed to provide an Evaluation that is outside the scope of AAMA
506-06? {note that AAMA-08 will allow the substitution of anchors and different substrates to be engineered}.

AAMA 506-06 reads in part:
Florida Building Code-Building Chapter 35:

"AAMA 506-06, Voluntary Specifications for Hurricane Impact and Cycle Testing of Fenestration Products.

Section:
7.0 TEST SPECIMEN PREPARATION
7.1 Test specimen shall be mounted using anchors and anchor spacing for which approval is desired. To qualify more than one anchor type, at least one of the test samples must be tested with that anchor and its appropriate framing material (i.e. wood, masonry, etc.)." (underline added for clarity)

Additionally the Florida Building Code-Building reads in part:

In the 2007 FBC-Building, Section 1714.5.4.1 states:

"Section 1714.5.4.1 Anchoring requirements. Window and door assemblies shall be anchored in accordance with the published manufacturer's recommendations to achieve the design pressure specified. Substitute anchoring systems used for substrates not specified by the fenestration manufacturer shall provide equal or greater anchoring performance as demonstrated by accepted engineering practice." (underline added for clarity) 

This leads to the question: Would the manufacturer have to comply with the standard [which appears to be more restrictive] or would the manufacturer be allowed to comply with the code through "engineering practice?"

In Addition the Florida Building Code-Building reads in part:

In Chapter 1 of the FBC-Building, Section 102.4 states:

"Section 102.4 Referenced codes and standards. The codes and standards referenced in this code shall be considered part of the requirements of this code to the prescribed extent of each such reference. Where differences occur between provisions of this code and referenced codes and standards, the provisions of this code shall apply." (underline added for clarity)

This could lead to an assumption that the manufacturer could submit engineering for the installation of the product into different substrates (as referenced in 1714.5.4.1) which would appear to be less restrictive than the standard. 

Therefore AAMA respectfully submits that the Florida Building Commission consider this request for a Declaratory Statement to clarify this issue. 

Question: Does the Florida Building Code allow the Manufacturer through engineering practice to submit additional information that will allow the substitution of anchors and installation into different substrates for a product submitted using the Certification Method and using AAMA 506-06?

Dwight S. Wilkes
SE Regional Codes and Standards
Consultant for AAMA
[American Architicual Manufactures Association]
632 Casa Fuerta Lane
St. Augustine, Florida, 32080-7107
(904) 501-5528
OiTecllc@Gmail.com