“Layton Consulting Fenestration Nerds” By Anton Van Dyk: Am I Code-Compliant?

A few years ago, I got into a debate regarding the distance a window can be from the floor before it has to be tempered. This debate went back and forth about who was right and who was wrong, and then it occurred to me. Let's look it up in the code.  

Would you believe me that I could not find anything? Then I realized how hard it is to find something in a book as thick as the building code that might not actually exist. It turns out, there is nothing in the code that specifically requires a window to be tempered based on its proximity to the floor. There are safety glass requirements for door glass, but this can also be laminated glass and not necessarily tempered glass and there are requirements to design a window to meet guard load, but nothing that prescriptive requires tempered glass.

Then I was told, it was in older codes. So instead of arguing about this, I was able to look up codes that went back to the 80’s. I searched the sections that I figured were relevant and nothing stood out as an obvious link to the distance a window can be to the floor before it needs to be tempered glass.

Is this one of those things that evolves over time? Someone, one time (likely from a place of authority) made a comment that it is required and so then it was done and as time went on, it just became the norm. Let's face it, finding something that does not exist in the code is hard, unless you read the whole code book. It was at this point in my career when I realized that reading the code from front to back, when most others don’t, will give me an advantage in any situation.

So, is your product code compliant? How do you know if it is or not? Do you leave it up to a building official who at one time tried to tell me that glass within 8” from the floor had to be tempered? Well if you do, I recommend that it is time to change.

I have found that many window suppliers are a few tests short of being compliant with the code and just stopped short. Either because they did not know how far the end was, or that enforcement was so poor that it did not matter. But as NAFS and NFRC are becoming more and more prevalent due to higher awareness of efficiency and durability, it may not stay that way much longer.

Just like you hire an accountant to do your tax planning, how about a Fenestration consultant to do your compliance planning? Step one of this is to audit your current compliance strategy. Don’t worry if you don’t have one. Most manufacturers see compliance as a line in the sand to cross, not as a strategy for their business. But think about an accountant who can help you strategize your tax plan at the start of the year. By doing this, you can strategically reduce your tax burden over the year and optimize your returns.

Once you have audited all of your existing compliance documents, you can now align it with the current code requirements and highlight the gaps that exist. This is the critical step as not all gaps need to be filled. This is because a compliance strategy needs to align with your overall business strategy. There is no point in filling in the compliance gaps for a market that you are not planning to sell into. A good example of this is Passive House windows. Do you need one, or a window that has such a low U value? Some manufacturers do as this is their market, while others do not. So not all gaps need to be filled right away. In time maybe, but not in the next year.

Once you have identified all the gaps, a work plan can be put into place over the course of a year or two to test, simulate and engineer solutions as you grow your business. This allows you to spread out your compliance costs over time and will help reduce your overhead.

This strategy works well when combined with a sales and marketing strategy as it will empower sales teams to tackle a market in a way that contributes to your brand and strengthens your overall market impact.

So, are you wondering where to start? Step one is a simple audit of your current compliance documents.

If you have any questions feel free to reach out to me by email at anton@laytonconsulting.com or by phone at 778-908-2811.