Fire-Rated Glazing Labeling Remains Unchanged for Now

Fire-rated glazing will retain its current labeling system under the International Code Council (ICC), following a unanimous vote by the ICC's Fire Safety Code Committee to disapprove proposed changes FS12-07/08 and FS13-07/08.

In FS12, Donn Harter, representing the Americas Glass Association, and William O'Keeffe, representing SAFTI FIRST, had proposed changes to section 703.5 and parts of section 715 that would add glazing material classifications that stipulate the rating and testing of materials. FS12 offered the new language: "[f]ire-resistance rated glazing determined in accordance with ASTM E119 shall be classified as R-Rated glazing;" "[f]ire-protection rated glazing determined in accordance with NFPA [National Fire Protection Association] 252 or NFPA 257 shall be classified as P-Rated glazing" and "[g]lazing classified in accordance with 715.3 shall be identified by a designation of R-xxx or P-xxx, in accordance with Sections 703.5, 715.4.6.3.1, and 715.5.8.1."

As part of the reason he gave for supporting the changes, Harter wrote that "[t]he current labeling system is cumbersome, presents practical application problems that will cost time and money to manufacturers and building owners, and, in the end, fails to achieve the important goal fire-rated glazing manufacturers and end-users share-identification of which products limit radiant heat transfer, and which don't. The proposed classification and labeling of products as P-xxx for fire-protection-rated, or R-xxx for fire-resistance rated, is simple, straightforward, and provides that critical information." He further stated that coding with the letters R and P would reinforce the very specific definitions of "resistance" and "protection" as defined by the International Building Code and National Fire Protection Association (NFPA).

O'Keeffe wrote in support that "[t]he current labeling system of W-xxx to designate fire-resistance rated glazing tested to ASTM E 119, and D-T or NT, H or NH-xxx, and OH-xxx is cumbersome and confusing, and is resulting in misapplications of fire protection-rated glazing in the field, where fire resistance-rated glazing is required." He noted that, as a manufacturer of both fire-protection rated and fire resistance-rated glazing, he rarely gets orders that provide more than size, shape and quantity and thus is "unable to determine how to mark the glazing as required according to end use."

Diana San Diego, also of SAFTI FIRST, told the code committee yesterday that "in the real world" when an order is placed by the glazing contractor, the manufacturer gets a size and rating and not a location of where the glass needs to be installed.

"We have to go back to glazing contractor who has to go back to architect to find where the glass is going," she said.

In her support of the change, Kate Steel, representing the Americas Glass Association's Fire and Safety Glazing Council, said that the labels have been in use for several years and "what we now know is the markings when applied to existing openings are confusing." She added, "The marking of R and P is very simple system that can be implemented by the manufacturer with ease, understood by the glazing contractor."

One code official that took the microphone agreed that the current labeling system can be confusing. "As the end user, we need to be able to go out there and look at it and understand what it's actually being used for … Right now it's so confusing it's hard for us to do our job."

Opponents to the labeling proposal indicated that the proposed change might actually be more confusing than the one currently in practice-because it would put two labeling systems in practice.

With regard to lessening confusion, William Koffel of Koffel and Associates, representing the Glazing Industry Code Committee (GICC), pointed out that, due to the NFPA standard, "If you make a change there's going to be two labeling systems out there."

According to Steel, discussion with NFPA indicated that the ICC "has to fix this first" before that association updated its labeling system. Not everyone agreed that the other standard would follow suit, however.

But, for many of the opponents, confusion was less of an issue than an omission on the suggested label. Section 715.4.6.3.1 would have been amended to leave out this language: "'H' shall indicate that the glazing meets the hose stream requirements of NFPA 252. 'NH' shall indicate that the glazing does not meet the hose stream requirements of the test. 'T' shall indicate that the glazing meets the temperature requirements of Section 715.4.4.1."

The current system indicates whether a product has to undergo a hose stream test or not, Koffel said.

"The problem is it would replace the system with P and R," added Thomas Zaremba, representing Pilkington North America. "The problem with that is P would be designated to NFPA 257 and 252. One of the proponents has a product that is listed with no hose stream. This labeling system would put the product in market with a P and no one would know it hasn't passed hose stream test."

The similarly stated FS13 would have addressed such exceptions, Steel noted.

FS13, proposed by O'Keeffe, added: "715.4.6.3.1.1 Identification of test exceptions. The label shall include identification of exceptions to the provisions of the test standard."

According to Zaremba, that addition would permit manufacturers to deviate from test standard "unless you identify exceptions on the label … That means you could have a 60-minute rated product with no hose stream characterized as complying with NFPA 257," he said, so long as it is labeled with exceptions.

"Could you say 'see product literature for exceptions?' I think you could," he said. "What this would do is allow you to alter consensus standards by adding a few words to the label. And I'm not sure you'd even have to tell them on that label [where exceptions are listed]."

Steel noted that every test lab that does test a product without hose stream "has required the product listing to mark it without hose stream."

Both proposals were ultimately defeated, but not before a member of the panel asked: "Are there any glass manufacturers opposed to this change or is this pretty much a universal concern?"

Steel, at the microphone at the moment, responded, "I think there's a consensus that the existing system doesn't work."

There did seem to be agreement on that front, but how to go about changing it was another matter.

"I was present last week at a Glass Association of North America (GANA) Fire-Rated Council meeting where they developed a task group to look at this," Zaremba told the committee. "Those proponents [of FS12] were at the GANA meeting and there was a unanimous vote to create a task force."

The committee motioned, and ultimately voted, to disapprove FS12, for a range of reasons.

"It will reduce the amount of information available on the label; it will reduce the amount of safety provided by not making hose stream obvious," reasoned Robert Davidson, representing the Fire Marshal's Office in Red Bank, N.J.

For Lorin Neyer, representing the California Fire Chief's Association, the biggest concern was the conflict between the proposal and the NFPA 252 and 257 standards.

"I do think the existing system has some confusion to it," said Gene Boecker of Code Consultants Inc. "However, I don't think this is going to provide the clarity we need."

Marcelo Hirschler of GBH International agreed with FS12 proponents that P and R are an easy-to-understand way to label, and he would be interested in seeing in the future a label "that could include P and R and include the hose stream …"

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