NAHB's Decision Making Process Disregards Harm Caused to Truss Industry
Originally published by: SBCRI-SBCA Investigative Report #1 — October 28, 2015
The following article was produced and published by the source linked to above, who is solely responsible for its content. SBC Magazine is publishing this story to raise awareness of information publicly available online and does not verify the accuracy of the author’s claims. As a consequence, SBC cannot vouch for the validity of any facts, claims or opinions made in the article.
Editor's Note: Here are five key summary points to provide context for the article below:
1. Excerpts from publicly distributed email correspondence from Mr. Steve Orlowski, former Program Manager for Construction, Codes & Standards for the National Association of Homebuilders (NAHB) are being shared to make it clear to the marketplace the extent to which politics, not science-based facts, resulted in R501.3 being drafted and adopted into the International Code Council’s (ICC) 2012 International Residential Code (IRC).
2. A competitive advantage for 2x10s was crafted by NAHB in collaboration with Bob Glowinski, Kuma Sumathipala, Brad Douglas and Ken Bland of the American Wood Council (AWC).
3. It has been known since 1992 that 2x10s burn faster than tradition suggests. More recent UL and SBCA ASTM E119 standardized testing show floor assemblies constructed of 2x10s last approximately 10 minutes or less. UL emphatically states that all floors should be protected.
4. Currently, the fire service and IRC R501.3 expect a minimum of a 15 minute membrane rating, where tradition expects a minimum of 20 minutes (i.e. the '20 minute rule'). UL suggests that the proper number is 26 minutes of performance using ASTM E119 testing.
5. The NAHB (and AWC) decision making process was described by NAHB as follows:
a. Limit the application of under floor protection to only the specific products that were a concern to the fire service (i.e. unilaterally sacrifice trusses, I-joists and steel joist as viable products without any science to back it up.),
b. Place several exceptions in the provisions to limit the application of the provisions (i.e. no crawl spaces), and
c. Take the argument away from the fire service that sprinklers need to be mandated to protect the fire service.
Below are excerpts from publicly distributed email correspondence between Mr. Steve Orlowski, Program Manager for Construction, Codes & Standards for the National Association of Homebuilders (NAHB) and other members of the homebuilding community (for complete context, the entirety of Orlowski’s correspondence can be found here, along with NAHB's talking points on light-frame construction referenced in those emails).
This correspondence is being shared to make it clear to the marketplace the extent to which politics, not science-based facts, resulted in R501.3 being drafted and adopted into the International Code Council’s (ICC) 2012 International Residential Code (IRC). As can be read below in Orlowski’s words, he, along with Kuma Sumithapala, Ken Bland, Brad Douglas and Bob Glowinski of the American Wood Council (AWC), negotiated the language of R501.3 to slow down or prevent mandatory sprinklers from being included in the IRC. It also provided a competitive advantage to 2x10s.
In an attempt to work with the fire service, NAHB was a proponent of the following public comment that combines the basic elements of current construction practice and proven performance of materials already in use in many of today’s homes. Based on the vast amount research and study that the fire service has produced in relationship to wood trusses and engineered floor joist, the major concern is that there are some engineered wood products on the market that do not perform as well under fire conditions that conventional wood framing with nominal lumber provided. The major two concerns that the fire service points out is that these engineered products that do not have the same mass as nominal lumber, burns at a faster rate resulting in earlier structural failure, which significantly impacts the ability for first responders to perform search and rescue when they arrive on the scene. It also shortens the amount of time given to the occupant to escape in the event of a fire emergency. This proposal outlines when protection is required on the underside of the joist and provides for exceptions that either offset the risks to areas where the chance of fires originating are extremely low or will reduce the risk of injury to the fire service should structural collapse occur.
Below is a explanation (in red) behind the reasoning for each exception…
4. Wood floor assemblies using dimension lumber or structural composite lumber equal to or greater than 2-inch by 10-inch nominal dimension, or other approved floor assemblies demonstrating equivalent fire performance.
This was by far the most difficult items to reach an agreement on with the fire service, but in the end the CC&S members and staff were able to convince the fire service that if their real concern is the introduction of light-weight engineered framing products then there should be an exception for nominal lumber. The reason behind this push by CC&S came from the fire services own account that their concern was over the introduction of light-weight engineered products did not give them the same time afforded by conventional framing when fighting interior fires.
From: Orlowski, Steve [mailto:firstname.lastname@example.org]
Sent: Friday, June 04, 2010 10:46 AM
Subject: RE: Fire Sprinklers
Here is a copy of the information that we have. As for the manufacturers comment on product discrimination, there are a number of code provisions that limit the type of products that can be used based on their inherent qualities that affect the health, safety and welfare of the occupant.
Political Negotiations Neglect Science, Safety & Welfare
The IRC R101 states the intention of the IRC as follows:
The purpose of this code is to establish minimum requirements to safeguard the public safety, health and general welfare through affordability, structural strength, means of egress facilities, stability, sanitation, light and ventilation, energy conservation and safety to life and property from fire and other hazards attributed to the built environment and to provide safety to fire fighters and emergency responders during emergency operations.
The question SBCA has consistently raised is how creating an exception for 2x10s adheres to the IRC’s intent to safeguard public safety and provide safety to firefighters. NAHB knew the contents of the October, 1992 National Fire Protection Research Foundation (NFPRF) report data well before they negotiated the language of R501.3. Within that report, the fire performance of various products used in floor assemblies was published in Table 22, found in Chapter 4-1:
This report was readily available in the public domain since 1992. It is fair to say SBCA was not the only entity that knew the fire performance duration of 2x10s when compared to other floor assembly materials. NAHB and AWC knew and understood it. Underwriters Laboratories (UL) also knew and has referenced it in their reports.
This data was more recently confirmed by both UL ASTM E119 testing in 2012 and SBCA E119 testing in the spring of 2015. The results of those tests can be found in the following table:
This UL data was published in a report entitled, “Improving Fire Safety by Understanding the Fire Performance of Engineered Floor Systems and Providing the Fire Service with Information for Tactical Decision Making.” (a review of this report can be found here).Yet, in April of 2013, Orlowski made the following assertions:
From: Orlowski, Steve [mailto:email@example.com]
Regarding the lightweight construction underfloor protection techniques, here is a bit of background on the issue. During the 2012 code development cycle, the construction codes and standards committee was put into an awkward position. The American Wood Council (AWC) was put into a corner by the International Assoc. of Fire Chiefs and the National Assoc. of State Fire Marshall. For a number of years both of these organizations have lobbied hard against the use of lightweight floor joist and trusses, claiming that these products burn faster than conventional lumber and have a failure rate much higher that puts fire fighters in jeopardy. Underwriters Laboratories, Inc. conducted a series of tests that showed the lightweight engineered trusses failed at a significantly faster rate that nominal lumber. At the Public hearing, there were five code change proposals that were submitted wanting to add requirements that would require drywall on all floor assemblies ranging from 1/2 inch drywall to 5/8 inch type x or require all floor assemblies to be constructed as a one hour fire resistant rated floor assembly.
NAHB meet (sic) with the International Assoc of Firefighters, AWC and the representative of the State Fire Marshals and was able to convince them that the proposals put forward were completely over reaching and that they needed to be scaled back. NAHB and the AWC talked to the fire service and explained that if their concern were the lightweight engineered wood products than those products need to be addressed specifically and not the conventional wood products which have proven to be safe building practices for both the occupants and the fire service. NAHB, the American Wood Council and the Fire Service reached an agreement and submitted the following code change that was approved at the final action hearing…
R501.3 Fire protection of floors. Floor assemblies, not required ……………..
The decision to cosponsor this code change was not an easy decision for CC&S members, as we knew it would increase the cost of construction. However by co sponsoring the proposed change, NAHB was able to accomplish three important items, 1) we were able to limit the application of under floor protection to only the specific products that were a concern of the fire service, 2) we were able to place several exceptions in the provisions to limit the application of the provisions and 3) we were able to take the argument away from the fire service that sprinklers needed to be mandated to protect the fire service.
What Orlowski’s comments make clear is the resulting R501.3 provision adopted into the 2012 IRC was not based on science, but on a political compromise that allowed the NAHB and AWC to achieve their own respective goals.