Issue: DCA10-DEC-002. The Petitioner is requesting clarification regarding Rule 9B-72 to show that the product in question falls outside the scope of Rule 9B-72. The Petitioner provides the following to specific inquires:
Background:
Situation: This
product is a proprietary system and is designed as a custom one of a kind unit. The Petitioner manufactures
a proprietary structural system that integrates a light gauge steel stud frame
assembly with an EPS insulation core. The structural supports are recessed in
the polystyrene on both the interior and the exterior, and is provided by steel
framing members placed 24" on center and screw connected to steel angles
at both top and bottom of the panels.
The Petitioner’s Pre-Insulated Steel Framing system(s) are used in new
construction projects for both residential & commercial buildings. The
design of our building systems and components are governed by FBC Section 2210.
2007
SECTION 2205, STRUCTURAL STEEL
2205.1 General. The design, fabrication and erection of structural steel for buildings and structures shall be in accordance with AISC 360.
SECTION 2210
COLD-FORMED STEEL LIGHT-FRAMED CONSTRUCTION
2210.1 General. The design, installation and construction of cold-formed carbon or low-alloy steel, structural and nonstructural steel framing shall be in accordance with AISI-General and AISI-NAS.
2210.2 Headers. The design and installation of cold-formed steel box headers, back-to-back headers and single and double L-headers used in single-span conditions for load-carrying purposes shall be in accordance with AISI-Header, subject to the limitations therein.
2210.3 Trusses. The design, quality assurance, installation and testing of cold-formed steel trusses shall be in accordance with AISI-Truss, subject to the limitations therein.
2210.4 Wall stud design. The design and installation of cold-formed steel studs for structural and nonstructural walls shall be in accordance with AISI-WSD.
2210.5 Lateral design. The design of light-framed cold-formed steel walls and diaphragms to resist wind loads shall be in accordance with AISI-Lateral.
2210.6 Prescriptive framing. Detached one- and two-family dwellings and townhouses, up to two stories in height, shall be permitted to be constructed in accordance with AISI-PM, subject to the limitations therein.
553.842,
553.842(10), Florida Statutes, states, products, other than manufactured buildings, which are custom fabricated or assembled shall not require separate approval under this section provided the component parts have been approved for the fabricated or assembled product's use and the components meet the standards and requirements of the Florida Building Code which applies to the product's intended use.
Rule 9B-72:
9B-72.005 Scope.
(1) Products in the following categories as
defined by subcategories of subsection 9B-72.010(31), F.A.C., shall be
available for approval by the Commission pursuant to Rule 9B-72.090, F.A.C.,
for use in the state:
(a) Panel Walls;
(b) Exterior Doors;
(c) Roofing Products;
(d) Skylights;
(e) Windows;
(f) Shutters; and
(g) Structural Components.
(2) This rule applies to approval of
products and systems, which comprise the building envelope and structural
frame, for compliance with the structural requirements of the Florida Building
Code.
9B-72.030
Exceptions.
Products listed in Rule 9B-72.005, F.A.C., shall
be approved according to the provisions of this rule.
(1)
Prescriptive. Products that have
prescriptive specification standards and are manufactured under quality
assurance procedures as specified in the Code will be deemed approved. Such products shall include but not be
limited to the following:
(a)
Structural components covered by United States Department of Commerce Product
Standards;
(b)
Structural components comprised of products that are assembled or placed in the
field and are subject to standardized field testing procedures contained within
nationally recognized standards adopted within the Code may demonstrate
compliance by a batch ticket or bill of lading made available at the site of
assembly or placement; and
(c)
Custom (one of a kind) pre-engineered buildings.
(2) Performance. Products, methods and systems of
construction specifically addressed in the Code through performance criteria
shall demonstrate compliance pursuant to Rule 9B-72.070, F.A.C., and shall be approved
pursuant to Rule 9B-72.090, F.A.C.
DCA04-DEC-070. The Petitioner requested clarification relative to whether or not their product falls under any of the sub categories of Rule 9B-72. The Petitioner is a manufacturer of large metal buildings which consists of a specially designed, integrated set of components and assemblies that function synergistically in form of a complete building shell, which is governed the building code of jurisdiction and recognized design specification published by the American Institute of Steel Construction AISC and the American Iron and Steel Institute ANSI.
Action: The Buildings in question are custom fabricated buildings in accordance with Section 553.842(11), Florida Statutes. Thus, separate approval for individual buildings per Rule 9B-72 is not required. However, local approval for components of the building, which are required to be designed and fabricated in accordance with specification standards referenced in the Florida Building Code, may be achieved through building plans review and inspection providing such products/construction are inspected by an approved inspection agency in accordance with Rule 9B-72…etc.
Analysis:
Staff recommendation:
.
Question #1: When we design and engineer a system for a custom home or commercial building for a client, and the system is designed consistent with FBC Section 2210. The purpose and use of our system in this capacity would constitute an exception to the Florida Product Approval rule and requirements, as stated in 9B-72-030 exceptions to the rule. Is this correct? If not, please explain why?
Answer: To the extent that the Petitioner’s pre-engineered system is constructed specific to plan or design “custom /one of a kind” and designed in accordance with specification standards referenced in the FBC, the system itself falls outside the scope of the state approval established by Rule 9B-72. However, local approval of the Petitioner’s system may be achieved through building plans review and inspection providing the system is manufactured under quality assurance procedures as specified in the Code.
Question #2: When we design and engineer a system for the roof of a custom home or commercial building for a client and the system is designed consistent with FBC Section 2210. The purpose and use of our system in this capacity would constitute an exception to the Florida Product Approval rules and requirements, as stated in 9B-72-030 exceptions to the rule. Is this correct? If not, please explain why?
Answer: See answer to Question #1.
Question #3: If we design a wall section that is not sold as part of a pre-engineered custom whole building, but rather intended for use in a custom design or addition, and it is manufactured, designed and installed consistent with FBC Section 2210, then the purpose and use of our system in this capacity would constitute an exception to the Florida Product Approval rules and requirements, as stated in 9B-72-030 exceptions to the rule. Is this correct? If not, please explain why?
Answer: See answer to Question #1.
Question #4: If we design a roof section that is not sold as a part of a pre-engineered custom whole building, but rather intended for use in a custom design or addition, and it is manufactured, designed and installed consistent with FBC Section 2210, the purpose and use of our system in this capacity would constitute an exception to the Rule 9B-72 Florida Product Approval rules and requirements as stated in 9B-72-030 exceptions to the rule. Is this correct? If not please explain why?
Answer: See answer to Question #1.