I
Issue: DCA09-DEC-411. The Petitioner is requesting clarification regarding the intent of Section 1714.6 of the Florida Building Code, Building (FBC) and specifically provides for the following questions:
Question #1: We need clarification from the committee of the intent of this section. Our interpretation is that window manufacturer is to test three samples in size, configuration and glazing?
Question #2: As the testing laboratory agency for the State are we correct in making such determination as to what was tested is ample or not and is in compliance.
Background:
Situation:
- The Petitioner is a testing facility approved by the State.
- The Petitioner has performed testing on three sliding wood doors for TAS 201, 202, and 203. These doors have the following differences two are pocket doors and the third is a straight door, the panel count and configuration are different for all three samples. The door panels are all constructed of same materials and profiles and they were all the same height and width.
- The reviewing engineer who is doing the evaluation is requesting a test report bearing our P.E. seal and he is telling us that it is not up to the laboratory to decide if what was tested is ample for a product approval.
2007
SECTION 1714 PRECONSTRUCTION LOAD TESTS
1714.6 Test specimens. Test specimens and construction shall be representative of the materials, workmanship and details normally used in practice. The properties of the materials used to construct the test assembly shall be determined on the basis of tests on samples taken from the load assembly or on representative samples (when TAS 202 is used, a minimum of three specimens) of the materials used to construct the load test assembly. Required tests shall be conducted or witnessed by an approved agency.
Rule 9B-72
9B-72.010 Definitions.
(5) Approved testing laboratory means a laboratory approved
by the Commission pursuant to subsection 9B-72.100(3), F.A.C., to test products
for compliance with the standards specified in the Code.
(16)(a) Evaluation report means a report based upon testing
or comparative or rational analysis, or a combination thereof, from an approved
product evaluation entity or a licensed Florida professional engineer or
architect indicating that the product was evaluated to be in compliance with
the Code or the intent of the Code and that the product complies with the Code
or is, for the purpose intended, at least equivalent to that required by the
Code.
(33) Test report means a report from an approved testing
laboratory which provides performance data showing compliance with a code
requirement as determined by a referenced standard test method or equivalent
standard test method pursuant to Rule 9B-72.180, F.A.C., and which identifies
products covered by the report and limitations on the products’ use.
9B-72.070 Product Evaluation and Quality Assurance
for State Approval.
(e) Rational engineering analysis cannot be used in lieu of a standard test required by the Code for approval of products within the scope of the standard, except that project specific approval by the local authorities having jurisdiction in accordance with alternate methods and materials authorized in the Code.
Analysis:
- Section 1714.6 of the FBC, Building specifies that when TAS 202 is used to test a product for demonstrating compliance with the FBC, a minimum of three specimens of the product must be tested.
- The specimens must be representative of the materials, workmanship details normally used in practice.
- According to Rule 9B-72.010, it is the responsibility of the approved test lab to test products for compliance with the standards specified in the Code including any specific code modification to such testing standards (i.e. testing a minimum of three specimens when testing using TAS 202).
- Rational engineering analysis cannot be used in lieu of a standard required by the Code for approval of products within the scope of the standard.
Staff recommendation:
Question #1: We need clarification from the committee of the intent of this section. Our interpretation is that window manufacturer is to test three samples in size, configuration and glazing?
Answer: Yes. According to Section 1714.6 a minimum of three specimens/samples must be tested for the product in question.
Question #2: As the testing laboratory agency for the State are we correct in making such determination as to what was tested is ample or not and is in compliance.
Answer: Yes. According to Rule 9B-72.010, it is the responsibility of the approved test lab to test a product in accordance with the applicable testing standards referenced in the Code including any specific modification by the Code to such standard.