Legislation in PA Seeks to Correct R501.3, AWC Seeks to Undermine with Letter to State's Code Council

Originally published by: SBCRI-SBCA Investigative Report #1October 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 nine key summary points to provide context for the following article below:

1.    A letter form the American Wood Council (AWC) 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), and the lengths to which one of its original authors, namely AWC, will go to preserve it.

2.    A floor assembly constructed of 2x10s subjected to a standardized ASTM E119 fire test lasts approximately 10 minutes or less. A floor assembly constructed of Weyerhaeuser’s Flak Jacket I-joists last less than 7 minutes.

3.    AWC represents 2x10 manufacturers who benefit from competitive advantages created by code provisions like the IRC’s R501.3.

4.    AWC state's in the letter the following points of view:

a.     The exception for 2x10 dimension lumber is appropriate.

b.    The exception for 2x10s was recommended by a broad task group consisting of building and fire service officials.

c.     The exception for 2x10s is the baseline performance the fire service expects, but not equal to what the code expects, which is a 15 minute membrane rating.

d.    The provisions of Act No. 1 were specifically written to enhance fire safety in buildings, and began with the fire service comfort around the known fire performance of traditional products.

5.    The intent of the IRC states it is to provide safety to fire fighters.

6.    Do AWC and NAHB take into account they do not meet the intent of the IRC with respect to the safety of firefighters as they continue to advocate for maintaining R501.3 as they originally wrote it?

7.    Further, ASTM E119 testing shows the ICC-ES Acceptance Criteria is inaccurate, and as such is misleading. 

8.    SBCA continues to raise this issue with the hope a fire fighter does not have to be seriously injured or killed in order for an answer to be reached, which would likely then happen through litigation.

9.  If AWC (and NAHB) truly cares about fire righter safety they will become advocates of taking the right action, which is to delete IRC R501.3 Exception 4, which states: 4. Wood floor assemblies using dimension lumber or structural composite lumber equal to or greater than 2-inch by 10-inch (50.8 mm by 254 mm) nominal dimension, or other approved floor assemblies demonstrating equivalent fire performance. 

On October 16, the American Wood Council (AWC) wrote a letter to the Pennsylvania Bureau of Occupational & Industrial Safety, which oversees the state’s building code. This letter is in response to House Bill 1575 in the Pennsylvania legislature that was recently amended to eliminate the 2012 IRC R501.3 exception 4 for 2x10s, which is currently part of the Pennsylvania building code. A key excerpt from the AWC letter is as follows:

Below are additional excerpts from this letter, along with SBCA’s analysis of the claims put forth by AWC (for complete context, a full copy of this letter can be found here). This letter 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), and the lengths to which one of its original authors, namely AWC, will go to preserve it.

AWC Advocates for 2x10s

The AWC letter states,

“The exception for dimension lumber is appropriate, was recommended by a broad task group consisting of building and fire service officials, and, has been often repeated, is the baseline performance the fire service expects…..

The provisions of Act No. 1 were specifically written to enhance fire safety in buildings, and like the model language (a.k.a. IRC R501.3) from which it is drawn, began with the fire service comfort around the known fire performance of traditional products.”

However, the contents of the NIST/ARRA/UL 2012 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”.[1][2] suggest a much different point of view. Underwriter Laboratories (UL) stated, “the objective of this study by the Underwriters Laboratories Fire Safety Research Institute was to improve firefighter safety by increasing the level of knowledge on the response of residential flooring systems to fire.”

The 2012 report UL draws conclusions in stark contrast to AWC’s assertions:

  • Page 67 (emphasis added):

 

  • Pages 3 and 68:

  • Page 64 (emphasis added):

  • Page 52 (emphasis added):

AWC Facts Not Supported by Science

The AWC letter also states:

However, science supports a much different conclusion.  Below is data from UL’s ASTM E119 testing, published in the 2012 report referenced above, as well as SBCA E119 testing conducted in the spring of 2015. The results of those tests can be found in the following table:

Equivalency Claims by ICC-ES Not Supported by Science

The AWC letter goes on to state:

SBCA’s NGC ASTM E119 test data shows that 2x10s and Flak Jacket (a product deemed equivalent to 2x10 performance by the ICC-ES) are not equivalent to each other. Further, neither are equivalent to the performance of a ½ inch gypsum wallboard membrane, which provides a 15 minute membrane rating per IBC Table 722.6.2(1). Again, the following table shows 2x10 and Flack Jacket fire performance:

*Note: 100% design load is the same as full-design stress level tests. This testing yields much different results than non-standardized 50% design load test, or an applied 40 psf floor load, or a 250 lb. dummy standing test as some have suggested is allowed for public policy decision making. ICC-ES allows both non-standard testing and some kind of char rate calculations to prove equivalency as well.

The 9 ½” Flak Jacket test times are 3 minutes less than 2x10s and equivalent to the best floor truss test.  2x10s are 5 to 8 minutes less than the 15 minute membrane performance level and another 5 to 8 minutes less than the traditional 20 minute rule.

Political Negotiations Neglect Science, Safety & Welfare

The IRC R101 states the intention of the IRC as follows:

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, 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, and/or adopting the notion of 2x10 equivalency, adheres to the IRC’s intent to safeguard public safety and provide safety to firefighters. Do AWC and NAHB take into account the intent of the IRC with respect to the safety of firefighters as they continue to advocate for maintaining R501.3 as they originally wrote it? Further, ASTM E119 testing shows the ICC-ES Acceptance Criteria that defines how Flak Jacket and other products can be equivalent to 2x10s is inaccurate and is misleading. SBCA continues to raise this issue with the hope a fire fighter does not have to be seriously injured or killed in order for an answer to be reached, which would likely then happen through litigation.

SBCA will continue to take its stand based on science, which has been previously published by the National Fire Protection Research Foundation [3], UL and SBCA from 1992 to the present. The science is compelling, and supports what House Bill 1575 in the Pennsylvania legislature is attempting to do, amend the original exception 4 of IRC R501.3 out of the building 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 1/2-inch (12.7 mm) gypsum wallboard membrane, 5/8-inch (16 mm) wood structural panel membrane…….

4. Wood floor assemblies using dimension lumber or structural composite lumber equal to or greater than 2-inch by 10-inch (50.8 mm by 254 mm) nominal dimension, or other approved floor assemblies demonstrating equivalent fire performance.