SBCA’s Views on Creating Fair Code Policy in Contrast to the AWC & NAHB Proposal Effectively Banning Floor Truss and I-joist Use

Originally published by: SBCAApril 29, 2014

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: SBC Industry News has recently shared a series of firefighter-related news items that has made us reflect on the IRC code change proposal effectively altering the competitive landscape with respect to the use of trusses and I-joists in residential markets where basements are standard. The news items contained in this SBC Industry News-Special Edition! provide a retrospective on the facts surrounding the need for a ½ inch gypsum wallboard membrane to be applied to everything but 2x10 floor joists, which became part of the 2012 International Residential Code (IRC). It is clear this code change has altered the free market to favor 2x10s, where all other structural floor member alternatives now have to add a gypsum ceiling and are therefore more expensive. This is important news from a public policy point of view so we have included hyperlinks to other recent, related news items, which can be found at the bottom of the page.

As most readers are aware, the following code change proposal passed and was incorporated into the 2012 International Residential Code (IRC):

Sean DeCrane, Cleveland, OH, Fire Department, representing the International Association of Fire Fighters; Azarang (Ozzie) Mirkhah, Las Vegas, NV, Fire & Rescue, representing Fire & Life Safety Section of the International Association of Fire Chiefs); Steven Orlowski, National Association of Home Builders, Dennis Pitts American Wood Council, American Forest & Paper Association, requests Approval as  Modified by this Public Comment.

Replace proposal as follows:

R501.3 Fire protection of floors. Floor assemblies, not required elsewhere in this code to be fire resistance rated, shall be provided with a ½ inch gypsum wallboard membrane, 5/8 inch wood structural panel membrane, or equivalent on the underside of the floor framing member.


...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.

SBCA believes strongly in the intent of the IRC to protect the public:

R101.3 Intent. The purpose of this code is to establish minimum requirements to safeguard the public safety, health and general welfare through affordability, structural strength, …… 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.

SBCA also believes the following observations are true and form the basis for a more fair and equitable code policy:

  1. The structural framework of a building does not cause a fire.
  2. The contents of a building catch on fire, and in general, building contents differ from structure to structure. It is impossible for the fire service to know what the contents are in advance of a fire.  As a consequence, all fires are different and all fire ground activities are challenging work environments that are unique in evolution and prosecution.
  3. The best way to save lives is through the assurance of working smoke detectors, which are proven to be the most effective way to alert and compel people to leave a building during a fire, thus mitigating the risk of life loss. SBCA believes a primary public policy should be to provide assurance, through whatever means necessary, of “hard wired smoke detector” functionality. The fire service is best protected if they do not have to go into a burning building to save a life. The fire ground decision then becomes a decision about saving property, and there is no property worth a fire fighter death.
  4. The next best way to save lives, beyond sound smoke detector policy, is through the use of automatic sprinklers. If sprinklers are desired to protect the general public and fire fighter’s lives, and a public goal is also to reduce structural damage, public policy should allow be focused on allowing cost-effective, common-sense installation of sprinklers.
  5. Fire origin statistics from NFPA1  provide the following data:
  6. These NFPA statistics support the concept basement floors do not need to be protected for any structural element. Another public policy option, based on all these facts, would be to eliminate R501.3 from the code as follows: R501.3 Fire protection of floors. Floor assemblies, not required elsewhere in this code to be fire resistance rated, shall be provided with a ½ inch gypsum wallboard membrane, 5/8 inch wood structural panel membrane, or equivalent on the underside of the floor framing member  
  7. This would also eliminate the imposed competitve advantage where US law encourages the, "comprehensive charter of economic liberty aimed at preserving free and unfettered competition as the rule of trade." The AWC/NAHB-endorsed code language currently in the 2012 IRC has proven itself in the market to unfairly restrict free and unfettered competition based on the available science.
  8. If single membrane protection is desired, the only standardized comparative benchmark testing that has been done is through a comprehensive ASTM E119 test of unprotected (no protective membrane) structural floor members. The full design stress* standardized tests show the fire performance of all floors is less than 15 minutes in duration. 2x10s tested at full design stress levels today would have performance similar if not less than the USDA Forest Product Laboratory (FPL) tests performed in the 80s (the FPL report was published in March 1983),where the 2x10s were tested at precisely full design stress levels and yielded 5 to 6 minutes of unprotected performance. *The full design stress test is not the same as a non-standardized 50% design load test, nor an applied 40 psf floor load, nor a 250 lb. dummy standing test as some have suggested is allowed for public policy decision making. This was confirmed in 2012 by UL and SBCA testing. Further, 1/2 “ regular gypsum wallboard protection increases endurance up to about 30 minutes of overall performance for all floor types. UL suggests that the proper number for expected performance is 26 minutes using ASTM E119 testing.
  9. Hence, if none of the previously proposed public policies are satisfactory, a more fair public policy would be: if the fire safety policy goal is to safely protect the general public and fire fighter’s lives and also reduce structural damage, then the code should state it is necessary to, "protect all structural members with a ½ inch gypsum wallboard membrane, 5/8 inch wood structural panel membrane, or equivalent on the underside of the floor framing member." This then would provide code language where there is no arbitrary preferential treatment that alters the competitive marketplace.

Unless there are compelling facts in the public or private domain that have not been presented or have not been allowed to be transparently and critically assessed, the forgoing is a pragmatic rendering of the set of facts, all of which were available prior to the AWC/NAHB code change that resulted in the 2013 IRC Section R501.3. All facts provided above are well documented and new data confirms the historical data well.

SBCA has consistently provided public policy proposals and code change proposals based upon a fair assessment of the facts available to us. As President John Adams said2 long ago, “Facts are stubborn things; and whatever may be our wishes, our inclinations, or the dictates of our passion, they cannot alter the state of facts and evidence.” by NFPA Fire Analysis and Research

John Adams'Argument in Defense of the Soldiers in the Boston Massacre Trials,' December 1770, US diplomat & politician (1735 - 1826)  

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