When There’s No Public Comment

September 18th, 2013

When There’s No Public Comment

NADRA Technical Advisor – Glenn Mathewson

 

If a proposal in the IRC code development process doesn’t receive a public comment, the vote from the first hearing is generally the final result.  With the recent publishing of the public comments, we can now see what the 2015 IRC is starting to look like.  It’s been a lot of work keeping up with the high-profile deck code proposals on the table this summer, like the monstrous 268 with a depth of un-agreed-upon prescriptive code provisions that would rock the industry or the one that already has…the lateral load anchor.  Those most certainly received public comment, but there were other less glamorous proposals regarding our industry that did not.

NADRA had a simple proposal, RB 58, suggesting to change all wording of “guardrail” to “guard”, to seek consistency with the IRC defined term “guard”.  The definition for guard allows any assembly that meets the performance and geometric requirements.  This proposal was approved by the committee and received no public comment to challenge it.  With this code modification, no safety to deck guards was compromised and the cost to construction did not increase.  However, a more clear description of the architectural playing field was provided.  A win for all, and “rails” for those that want them.

NADRA was asked to support proposal RB 145 from the Colorado Chapter of the International Code Council, seeking to remove the requirement for measuring guard height from fixed seating.  We gave great testimony in support during the hearings, as did the Minnesota Building Officials Chapter.  All proponents agreed that deck safety and backyard freedom must be balanced on the scale, and this regulation was too far a reach for a building code.  The committee agreed, and no one challenged it.  Should the bulk vote go as it always does at the final hearing, built-in bench seats will no longer affect guard height.  Developing IRC provisions (minimum standards of construction) is different than developing best practices or appropriately accommodating your clients.  Take care to evaluate the needs of your client and help them find the level of safety that’s right for them.  If their kids are jumping on the couch while your designing their deck…maybe don’t suggest those benches.

Even if NADRA’s proposal for deck and joist span tables, RB 264, is not approved at the final hearing, the flexibility it provided for blocking at dropped beams will still be accommodated by the NAHB’s proposal RB 247.  With no public comment, the first approval will likely stand, and blocks between joists cantilevered no more than two feet will no longer be required.  This may be very helpful for deck drainage systems and for minimizing locations for trapped water and decay.  Keep in mind that without blocking, the material connected to the top and bottom of the joist is what resists the rotational force the joist is subjected to.  Be sure you’ve got good connections to the beam below, and be careful about using a concealed fastening system for the decking that only relies on friction.  The blocking served a purpose; the argument for the code modification is that in short cantilevers these connections can do the job.

The proposal RB 253, which would have prohibited supporting joists from the bottom half of another member, was turned down, and did not receive comment.  While perhaps a rare design necessity, this proposal would have restricted opportunity for some deck design, but without clear evidence of the benefit.  However, coming from the American Wood Council, there’s certainly an engineering basis for their proposal.  Though a short-spanning 2×6 likely won’t rip the bottom half of a 2×12 beam apart, I’m sure a creative designer could come up with a loading condition that could be questionable.

RB 260 proposed that the “permitted” hold down anchors for lateral loads must be installed at the outer 24 inches of the ledger.  This proposal was approved and received no direct public comment.  However, in light of the recent research from Washington State University, NADRA submitted a public comment modification to remove this anchor detail altogether.  If you haven’t seen the video, take a look.  It will be worth your 13.5 minutes.  Click HERE to view.  If not successful, at least the new location for the permitted anchors, at the ends of the ledger, would be at the highest point of load concentration per the WSU testing.  One small bit of real science to a detail not otherwise scientifically justified.

There is a lot to be learned in the code modification process.  While we may not all agree on every proposal, they usually all have a justification reasonable to someone or some group.  Don’t take that lightly.  Take what can be learned from ideas and experiences of professionals looking to increase the minimum standard…and use it to increase the knowledge behind your best standard.

Never forget the difference between minimum standard and best standard, and the freedom and the market that thrive on the distinction.

Deck Lateral Load – The Truth Revealed

Deck Lateral Load – The Truth Revealed

The lateral load anchor provisions that came into the 2009 IRC have had a dramatic affect on the decking industry.

Born from a fear of band joists being ripped from homes by the decks they support, a best guess to bypass the band joist altogether came into the code. Though only “permitted” it is often required.

New testing from Washington State University dismantles the fear and shows the strength of a lag-screw connected ledger…without the extra metal.

NADRA has been diligently representing and supporting the decking industry in the code development process. Now, in 2013, the 2015 IRC is being created, and NADRA took the opportunity to get these research results included in the discussion. NADRA’s work can be reviewed HERE

This video explains how the anchor provisions came to be, how they’ve affect the industry and the truth revealed in the recent research. Please click the image to watch the video:

 

 

BUILDING CODE OR PRODUCT CATALOG?

August 21, 2013 – Glenn Mathewson, NADRA Technical Advisor

How many hold-down anchors does it take to build a deck?

The development of the 2015 IRC is halfway through, and there’s likely going to be some new regulations for the construction industry to adjust to.  For the decking industry, there’s lobbying working to create new building codes around specific product lines.  We’ve already seen the costly results of including “permitted” details in the code depicting specific products.  The lateral load anchor detail, that was published this way in the 2009 IRC, is quickly read as “required” by many building departments.  Now, as new research is revealing that ledgers fair quite well without lateral anchors, there is a proposal seeking to “permit” the use of anchors on every guard post in the 2015 IRC.  Will history be repeated and this also be read as “required”?

Proposals like this risk turning a standards document into something that looks more like a product catalog.  More importantly, this lobbying, if successful, adds significant time and cost to deck installations in an increasingly competitive industry, while at the same time limiting design options and architectural freedom.

There’s a lot on the table this year in the development of the 2015 IRC.  NADRA has submitted a public comment modification that reveals new information about ledger connection performance and seeks to remove the 1500 lb. lateral-load anchor detail from the IRC.  At the same time, NADRA is fighting against proposal 268 that seeks to include new requirements for guard construction, complete with pictures of specific hardware.

LATERAL LOAD REQUIREMENTS-RB263

Proposal 263 seeks to include an exception to the lateral-load anchor for decks that are less than 30” above grade.  While sensible, an exception to something merely “permitted” does not make much sense, and implies that what is permitted is actually required.

 With new and exciting test results from Washington State University, NADRA’s public comment to RB263 attempts to remove the lateral-load anchor not only for low-level decks, but completely from the IRC.  It turns out…people can only generate so much lateral load, and lag screwed ledgers can resist a whole lot more…four times more, and the test was stopped before the ledger ever failed.  With a force four times greater than humans could generate, deflecting the deck 17 inches to the side, ripping the joists down the center…the ledger with nothing but lag screws held.  The rim joist in the house held.  The necessity of a 1500 lb. anchor clearly serves questionable value.

Does this detail belong as a minimum standard of deck construction now that the performance of a lag-screwed deck ledger is known to be quite sufficient?

Read Full Article HERE

See  RB 268 details HERE

GIVING VOICE TO NADRA MEMBERS

 If the issues of increased costs, inflexible design, and heavy-handed industry regulation with no material benefit matters to you, consider joining me at the code hearing in Atlantic City NJ on October 3 and 4th.  Your presence, your voice, your attention and your passion will make a difference…after all…it is YOUR industry.  Stand up and fight for it, but don’t do it alone.  If you want to know more or get more involved, please contact me at glennmathewson@nadra.org.  Together we can bring truth and insight to the development of the building codes.

NADRA Code Update by Glenn Mathewson

Code Update , By Glenn Mathewson
“NADRA has submitted public comments for the Public Comment Hearing (formally the Final Action Hearing). Links to public comments are posted below. As always, NADRA welcomes feedback from our members.”

RB6 Public Comment

RB262 Public Comment

RB264 Public Comment

RB265 Public Comment

RB465 Public Comment

RB26-13 Public Comment

*** ICC Group B Public Comment Hearings take place  Oct. 2-10 , Atlantic City Convention Center — Atlantic City, N.J. Register HERE

Please check back to NADRA’s Code Page on www.NADRA.org for all updates on Code and how NADRA is participating. Click HERE to view.

Vision: Safe decks with well-thought-out engineering and a common sense practical approach to code requirements.

Code Mission Statement: To advance and protect industry interests in the code development arena and to promote member involvement; to promote governmental and agency reliance on NADRA as a voice for the industry; to create and maintain relationships with key government agencies and code officials; to be a forum for the discussion, study, and investigation of proposed and existing model code development, federal and state legislation and programs, and to report such findings to the Board of Directors and the Membership.

This section of NADRA’s website is dedicated to building code requirements and best building practices related to outdoor living structures.

Here you will find references to help you interpret code topics, links to jurisdiction websites for licensing and code requirements, and much more.

NADRA is always looking to add to the information provided in this section of the website, so please feel free to suggest a link by clicking here.

Code Question from a NADRA Builder

The below inquiry came in from a NADRA Maryland Deck Builder. With permission from Dave, we opted to post this publicly so we could accept replies from fellow members and industry leaders. Please reply in the comments section. There will be an approval process, so give us a day or two to post your comments. Thank you!
  1. What does code require in regards to wood rail post attachment……outside of RB61-13
  2. Why are some jurisdictions mandating the Simpson or USP bracket…..???
  3. What is testing results of 2 thru bolts and blocking??
  4. Can the  “FRANK”  VT  testing be published or accessible for use by all jurisdictions or is it only for sale to those who benefit????  Seems to be yet another PRIME example of how code is more a for profit industry and not for the public good
  5. Why are we being forced to spend on average $200.+ on hardware and 3 hours of time + to install this crap when EVERYONE BUT code officials and testers know that 2 bolts and proper blocking would meet the  code requirements of RB61-13  ????
Thanks,
David Lombardo

Recap of 2013 Group B Committee Action Hearing

Recap of 2013 Group B Committee Action Hearing (Dallas, TX) 

Last week the IRC code hearings were held in Dallas, TX. NADRA’s Technical Advisor, Glenn Mathewson represented the association on numerous proposals. This work is just beginning & your support is NEEDED on key issues that WILL effect your businesses and will effect this industry.  Your support is encouraged so these efforts can continue on behalf of the membership and industry the association serves. NADRA Headquarters and the entire board would like to personally thank Glenn Mathewson for his time and efforts at these hearings.

Recap of 2013 Group B Committee Action Hearing (Dallas) – By NADRA Technical Advisor, Glenn Mathewson:

Take Action: Now that the ICC Committee Action Hearings are over, be sure to follow the link about the public comment hearings. The first recap of an approved proposal is a good example of WHY we need your support so we can continue to be heard at these hearings! 

Here is a recap of proposed changes due to NADRA’s efforts at the hearings: 

On Monday,  April 22nd, the proposals to the pool and spa code were heard.  SP47-13 was disapproved.  Here was the proposal: “Walking surfaces of decks within 4 feet of a pool or spa that are not equivalent in the strength, durability and slip resistance of the surface of a concrete deck shall be prohibited.  Wooden walking surfaces and carpeted walking surfaces shall not be placed within 4 feet of a pool.”
RB143-13, proposing to return to measuring the height of a deck at the very edge of the deck (for determining if guards are required) was defeated with the help of NADRA.  Our professionals stood by the actual hazard and the current code that requires that height to be measured at a point three feet horizontally from the deck edge.  We know where our customers will hit the ground if they fall, and it is not directly at the edge of the deck.  With integrity for our industry and an understanding of the actual determination of hazard, we stood, we spoke and we were heard.”

RB145-13 proposing to eliminate the requirement to measure guard height from a fixed bench seat was approved.  This requirement in the 2009 and 2012 IRC effectively put an end to bench seating.  While some with small children may prefer not to have a bench against guards, the majority of our membership believe that is an individual choice, not a minimum standard.  The architectural liberties of our customers are one step closer to returning to them.  Other professional associations had helpful testimony to this goal, but our intimate perspective of how this affected our industry came only from us.  This approval supports a balance between minimum design and safety, the latter of which can always be improved by the personal choice of the homeowner or builder.”


RB75-13 proposed that all decks, detached or attached, ground level or upper level, regardless of materials, would be prohibited from being less than five feet from property lines to prohibit fire spread.  NADRA stood and shared the reality that many noncombustible decking and framing materials are available.  We explained that low level decks have different dynamics of fire spread than upper level decks.  We described how this proposal would unnecessarily put the decking market at an unfair disadvantage to patio pavers and flagstone for ground level decks.  The committee heard our sole voice on these concerns and unanimously disapproved the proposal.  NADRA made it clear that work is needed to figure out how decks contribute to fire spread and how to regulate it in the code, but not to do it without us in the conversation.  We plan to work with these proponents during the public comment period so we can get this issue figured out the right way.”


RB74-13 proposed some serious consequences to the decking industry regarding placement of stairs.  While well intentioned for other purposes, it was dangerously flawed.  Imagine a deck connecting between a house and a detached garage.  This proposal would have prohibited any stairs within five feet of the garage.  Huh?  No wide steps from house to garage on one side of the deck, even for a few steps to the backyard.  NADRA stood against this proposal and the committee unanimously agreed and disapproved the proposal.”


“NADRA’S proposal, RB58-13, for replacing all use of the term “guardrails” for the IRC defined term “guard” has been approved as submitted unanimously by the committee.  This simple change secures architectural freedom for guards, and that they don’t have to have a “rail”.  On with the custom work of kitchens counters, planters, benches or whatever other feature that can be built to the requirements of a guard.”


 “RB6-13 was approved.  The size limit of 200sf for requiring a permit on low level decks was approved.  This will allow more under bid decks to be built poorly, putting our professionals (who build right regardless of permits) at an unfair disadvantage.  I encourage our members to support a public comment to disapprove this at final action.”

2015 Code Update, By Glenn Mathewson

Two weeks ago the code proposals for the creation of the 2015 IRC were posted for public review, and NADRA quickly made our industry aware.  There are a lot of them to review.  In building codes alone there were 1132 pages of proposals.

 

I have read and skimmed through all these pages and found the proposals related in some way to our industry.  These proposal numbers and a brief explanation can be read HERE

 

There’s some good stuff, some questionable stuff and some…other stuff proposed.  I will be at the hearings in Dallas at the end of April representing NADRA and our industry…so let NADRA know what you think.  Here are some highlights of what may be ready and waiting for you in the future.  I know 2015 is years away…but the decisions are being made now.

 

RB61 suggests adding various deflection limitations for guards.  This is a tough one.  Manufactured guard assemblies are already tested to these limits, so it’s generally business-as-usual.  It’s the custom built guards that take the hit.  How will the inspector verify these limits?  How will you know your standard cedar guardrail meets these limits?  Speaking of deflection, RB61 proposes to nail down a deflection limit of L/360 for decks.  Is that too much for a deck with no ceiling below?  Take a look and see what you think of the proposed deflection limits, but give a long read to RB268 as well.  Among many other requirements, take a look at how it could affect your guard design and construction.  Do these ideas work for you, or could they be refined?

 

The lateral load tension device provision that is neither required nor validated will get more involved if RB260, RB261, RB262 and RB263 are approved.  Should this flawed code provision get further complicated and accepted through new exceptions to what is not even a rule…  Should more lateral load methods, based on loads that are yet to be understood, be printed in the ever-growing IRC?  Research on lateral live loads has occurred and more sound and validated standards will be produced in the future.  Will it be a greater uphill struggle to this goal if this section is made more complicated now?

 

“Fire separation distance” is the IRC’s version of “setbacks”.  Decks have long been ignored in the IRC in regard to how close to property lines they can be built.  RB74 and RB75 would end this, and decks and stairs would simply be prohibited from being any closer than 5 feet from the lot line.  Should there be an exception for decks under a certain height?  RB66 also proposes new fire separation ideas for decks, but they’re less restrictive.  Should we interject our experiences and opinions on this topic?

 

The 2009 and 2012 IRC effectively killed built-in seating at guards with the requirement to measure the minimum 36-inch guard height from the seat.  RB145 proposes to eliminate that requirement and bring back some architectural freedom to guard design.  How does that one sound to you?  Should it get NADRA support?  What about eliminating blocking over cantilevers 2 feet or less, as described in RB247.  That might help in installing some deck drainage systems.

 

Well, there’s a start to understanding what’s on the table for the IRC, and I hope it’s caught your interest.  There are more than just those.  Proposals can be modified during the whole process, so proposals that may have flaws, can be built upon and corrected.  As the voice of the decking industry, we have a chance to help build on these proposals and take a hold of the future of our industry.

 

Please send your feedback to Info@NADRA.org

Stay Ahead of The Change; 2015 Codes Underway Now

The time has come again for us to be a part of our future…for you to be a part of your future.  The International Code Council released the proposed changes to the 2012 International Residential Code (IRC) on March 11th.  The ideas contained in these proposals come from professionals and non-professionals from all corners of the construction industry and from all over the nation and result in the 2015 IRC.  Now is the time for the decking industry to review these ideas and see how they affect our industry, both positive and negative.

 

In only a handful of weeks, I will be in Dallas at the ICC Committee action hearings representing NADRA to speak in opposition or support for any proposals that affect our industry.  The hearings run from April 20th to 31st, where over 2,000 individual proposed changes will be discussed.

 

The decisions made from now until this Fall will be those that determine what code will be published in 2015 and what you will be working under in 2016 and beyond.  NADRA needs your help reviewing these proposals to determine which ones matter to us and our opinion of them.  Please follow the link found HERE to ICC’s website and choose a PDF to download and begin reviewing.  Please keep us informed of your efforts and opinions in the next few weeks, as official NADRA positions on proposals need to be determined well before the hearings.  We need your opinions to know our position.  Now is the time, and there’s not much of it.

 

On behalf of the NADRA leadership and membership and most certainly on behalf of myself, I look forward to working together to create our future.

 

Thank you,

 

Glenn Mathewson

NADRA Technical Advisor

Code Proposal – Thumbs Up? Thumbs Down?

The Fairfax Group is a group that attended a meeting a few weeks ago in Fairfax, VA to work together on deck code proposal that originated in Fairfax. Those in attendance were the AWC, NAHB, CLMA, NADRA, VBCOA, CCICC, Simpson Strong Tie and others. The group also had a conference call-in from Dr. Don Bender. The group is looking for support from organizations and associations throughout the industry for the proposed code suggestions found HERE.
This started as an eleven page document. With NADRA’s involvement in this committee, and the efforts of Glenn Mathewson, NADRA’s Technical Advisor, the proposed changes now consist of the 3 pages – again, found HERE.
Please provide your “Thumbs Up” or “Thumbs Down” by Wednesday, 12/19/12 at 2pm EST.
The original 11 pages can be found here on the NADRA Blog, just scroll down.NADRA has until tomorrow to decide if we want to endorse this proposal with our name on it.  If not, we can always continue to work on it during the hearings next year as modification can occur throughout the process.  A thumbs down that comes with a reason “why” is helpful, as we can address the “why” during the hearings. Please post your feedback in this feed.

Thank you,

NADRA HQ & Glenn Mathewson, Technical Advisor

Update: ICC Action Committee Proposal

The ICC Building Code Action Committee is considering a very large proposal for deck construction provisions to be included in the 2015 IRC.  Anyone is invited to provide feedback, both opponent and proponent, on the proposal.  The committee wishes to work on the document with the industry, prior to the hearings next year.  Take a look at this proposal and see if you want these provisions to become code? Code, such that any other option is an “alternative” that has to be convinced to the building official over “just doing what the code says”.

You decide, NADRA.  What are your opinions about this?

There are some helpful provisions…and some…others.  It’s a long document…but it’s very, very serious. Code that comes out of an ICC Action Committee comes with some serious power.  Get involved and help NADRA represent our industry in the code development process.  We need you.

NADRA is positioned as the voice of the deck, dock and railing industry. Send your input toInfo@NADRA.org.

Read Proposal