DECLARATORY STATEMENT – High Speed Door Air Leakage

Issue: DS 2015-134

Petition for Declaratory Statement concerning Table C402.4.3 of the 5^th Edition (2014) Building Code, Energy Conservation.

Background:

The Petitioner, Joseph R. Hetzel, P.E., Technical Director, Door & Access Systems Manufacturers Association has a project that concerns a high speed door to be installed in a facility in Tampa, Florida. The petitioner requests a declaratory statement concerning the maximum air leakage requirements for doors that are found on Table C402.4.3 of the 5^th Edition (2014) Florida Building Code, Energy Conservation.

The maximum air leakage requirements for doors are found in the Table C402.4.3 of the Florida Energy Conservation. The 2014 Florida Energy Code uses the 2012 International Energy Conservation Code (IECC) as its base code. No maximum air leakage value for high speed doors is shown in Table C402.4.3 of that IECC edition. However, Table C402.5.2 of the 2015 IECC shows high speed doors requiring a maximum air leakage rate of 1.30 cubic feet per minute per square foot.

The petitioner also attached documentation of International Code Council (ICC) code change proposal C182-13 which was approved by the ICC membership at the 2013 fall final hearings during the 2015 IECC code development cycle. The petitioner feels the Commenter’s Reason supporting the public comment provides technical justification.

---

Reference Material:

5^th Edition (2014) Florida Building Code, Energy Conservation

Chapter [CE] - C402.4.3 Air leakage of fenestration.

The air leakage of fenestration assemblies shall meet the provisions of Table C402.4.3. Testing shall be in accordance with the applicable reference test standard in Table C402.4.3 by an accredited, independent testing laboratory and labeled by the manufacturer.

Exceptions:

1. Field-fabricated fenestration assemblies that are sealed in accordance with Section C402.4.1.

2. Fenestration in buildings that comply with Section C402.4.1.2.3 are not required to meet the air leakage requirements in Table C402.4.3.

TABLE C402.4.3 (See below)

$Description: C:\Users\Norman.Bellamy\Desktop\fbcec table.JPG$

---

2015 International Energy Conservation Code

Chapter 4 [CE] - C402.5.2 Air leakage of fenestration.

The air leakage of fenestration assemblies shall meet the provisions of Table C402.5.2. Testing hall be in accordance with the applicable reference test standard in Table C402.5.2 by an accredited, independent testing laboratory and labeled by the manufacturer.

$Description: C:\Users\Norman.Bellamy\Desktop\iecc table.JPG$

---

5^th Edition (2014) Florida Building Code, Energy Conservation

SECTION C102 ALTERNATE MATERIALS—METHOD OF CONSTRUCTION, DESIGN OR INSULATING SYSTEMS

C102.1 General.

This code is not intended to prevent the use of any material, method of construction, design or insulating system not specifically prescribed herein, provided that such construction, design or insulating system has been approved by the code official as meeting the intent of this code.

C102.1.1 Above code programs.

The code official or other authority having jurisdiction shall be permitted to deem a national, state or local energy efficiency program to exceed the energy efficiency required by this code. Buildings approved in writing by such an energy efficiency program shall be considered in compliance with this code. The requirements identified as “mandatory” in Chapter 4 shall be met.

---

2015 International Energy Conservation Code

Chapter 2 [CE] Definitions

HIGH SPEED DOOR. A nonswinging door used primarily to facilitate vehicular access or material transportation, with a minimum opening rate of 32 inches (813 mm) per second, a minimum closing rate of 24 inches (610 mm) per second and that includes an automatic-closing device.

---

Staff Analysis

Question 1) Can the maximum air leakage rate requirement for high speed doors as shown in Table C402.5.2 of the 2015 IECC be used for the high speed door to be installed in the facility in question, to meet the intent of the Florida Energy Code Fifth Edition based on technical justification? Our understanding is that the answer is Yes, provided that the authority having jurisdiction approves the use of the Table per the "alternate method" allowance in the Code

Answer/Staff: The answer is yes, provided that the authority having jurisdiction approves the use of Table C402.5.2 of the 2015 IECC for the high speed door in question in accordance with Section C102, Alternate Material –Method of Construction, Design or instillation System, of the 5^th Edition (2014) FBC, Energy Conservation.

Question 2) Is the Florida Energy Code Fifth Edition Section C102, "Alternate Materials - Methods of Construction, Design or Insulating Systems", applicable toward use of the Table described in Question #1? Our understanding is the answer is Yes, provided that the authority having jurisdiction finds the Table referenced in Question #1 to be itself applicable to the door in question.

Answer: Please see answer to question 1.