Rosalind Fazel. Comments on Criteria AC212. David A Johnston EIFS Industry Members Associat

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1 Rosalind Fazel From: Sent: To: Subject: Attachments: Wednesday, October 31, :54 PM Rosalind Fazel AC212 Comments Attachment to EIMA Comments on AC pdf; ICC-ES Ltr - Jess Beitel.pdf Comments on Criteria AC212. David A Johnston EIFS Industry Members Associat djohnston@eima.com Comments: October 30, 2012 Yamil Moya, PE Staff Engineer International Code Council Evaluation Service, LLC 5360 Workman Mill Road Whittier, California Dear Mr. Moya: The EIFS Industry Members Association thanks the International Code Council Evaluation Service for the opportunity to comment on the proposed revisions to the Acceptance Criteria for Water-Resistive Coatings Used as Water-Resistive Barriers over exterior sheathing. EIMA comments follow. EIMA generally supports the revisions proposed by ICC-ES, but EIMA has some minor revisions to enhance those suggested by ICC-ES. Most of those can be found in the attachment to these comments. EIMA believes that all of these changes are supported by the voting membership of the International Code Council as evidenced by its approval at the Final Action Hearings on October26th for inclusion in the 2015 edition of the International Building Code (IBC). The approval was for acceptance of FS 147, Public Comment #1. EIMA notes that this Public Comment is technically supported and coordinates with other sections of the IBC. EIMA s Technical and Research Committee at this time gives qualified support to the values for the cone calorimeter testing as included in a previous letter to you from Mr. Jesse Beitel of Hughes Associates (copy also attached). EIMA does have concern over the values in the cone calorimeter since tests by EIMA EIFS manufacturing members have yet to be completed on their various and respective water-resistive barrier (WRB/air barrier) materials. Until these tests are completed, EIMA respectfully requests that ICC-ES withhold making a final determination on these values until the results are in hand. EIFS Industry Members Association (EIMA) is a trade association comprised of product manufacturers, distributors, applicators, architects, raw material and related product manufacturers and other interested parties. EIFS stands for Exterior Insulation and Finish Systems, multi-layered exterior wall systems that are used on both commercial buildings and homes. Founded in 1981, EIMA is the national technical trade association that 10/31/2012 3:39 PM - 1

2 promotes the advancement of technology while providing outstanding industry representation and services to members. EIMA exists to support the EIFS industry by developing consensus technical, training, installation, and design standards for use by architects, designers, code bodies, and other technical associations to monitor and positively influence government actions, and works to assure the long-term availability of qualified contractors. Thank you for your consideration of these comments. Respectfully yours, David A. Johnston, CEP Executive Director/CEO EIFS Industry Members Association Suite West Broad Street Falls Church, Virginia Attachments: Attachment to EIMA Comments on AC pdf ICC-ES Ltr - Jess Beitel.pdf 10/31/2012 3:39 PM - 2

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11 June 4, 2012 Ms. Yamil Moya, P.E. Staff Engineer ICC Evaluation Service, LLC Los Angeles Regional Office 5360 Workman Mill Road Whittier, CA Re: Comments on MISC R1 Effect of 2012 IBC Section on Use of Waterresistive Barriers in Exterior Walls of Type I IV Construction HAI Project No. 1JJB Dear Ms. Moya: I am providing the following comments to the proposed guidelines to the various Acceptance Criteria pertaining to water-resistive barriers (WRBs). This topic is scheduled for discussion at the ICC-ES Hearings on Tuesday, June 5, On this topic, I am representing the Extruded Polystyrene Foam Association (XPSA). I will not be in attendance at the hearings, but I did want to provide several comments and they are: 1. The use of water-resistive barriers in Types I IV construction is becoming more common. NFPA 285 testing of several of these materials has shown that there is a potential issue with respect to significant vertical flame-spread. Admittedly however, there are a wide range of water-resistive barriers that also exhibit a wide range of flammability properties. 2. NFPA 285 testing is required for WRBs to be used in exterior walls in Type I IV construction and that are greater than 40 ft. in height above grade plane. This would require every WRB to be tested in every assembly in which it will be used. While some NFPA 285 testing will have to be performed, I feel that small-scale testing and analysis can be used to qualify many WRBs in many different assemblies. 3. As an example, if WRB X is used in a successful NFPA 285 test, then WRB Y can be substituted for WRB X if it can be shown that the flammability properties of WRB Y are the same or similar as those of WRB X. In order to accomplish this, both WRBs can be tested in the ASTM E1354 Standard Test Method for Heat and Visible Smoke Release Rates for Materials and Products using an Oxygen Consumption Calorimeter. The

12 Ms. Yamil Moya, P.E. June 4, 2012 Page 2 samples must be applied over a consistent substrate such as interior gypsum wallboard and be evaluated at a significant heat flux exposure such as 50 kw/m 2. Comparison of the fire performance characteristics should include items such as: o Time to ignition (s) o Flame Duration (s) o % Mass Loss o Peak heat release rate (kw/m 2 ) o Heat release rates averaged over various time periods, such as 60s, 180s, and 300s starting with the time of ignition (kw/m 2 ) o Effective heat of combustion (MJ/kg) o Heat Release per unit area (MJ/m 2 ) Based on the data for the proposed WRB Y being comparable to the data for the tested WRB X, then the substitution can be allowed. In my work on this topic, the use of ASTM E84 data alone is not sufficient for this comparison of WRBs. 4. It should be noted that the use of the analysis described above is limited to the location of the WRB in the assembly being at the same location as in the tested assembly. If the WRB is moved to a different layer/location within the assembly, then the analysis may not hold true. Retesting via NFPA 284 may be required. 5. There is no single NFPA 285 test that will qualify a WRB for all assemblies and with all materials. In some cases, the other combustible materials within the assembly may dictate the amount of additional combustible material supplied by the WRB that can be introduced into the assembly and still pass NFPA While this subject is complex and potentially confusing, I believe that there are ways to significantly reduce the required NFPA 285 testing while still providing compliant and good fire-performing exterior wall systems. 7. The use of small-scale testing as described above in conjunction with NFPA 285 testing and the application of these results via knowledgeable and appropriate analyses can be used to qualify many WRBs and can be used to demonstrate equivalent performance of WRBs. I hope that the above information assists ICC-ES staff and the Committee and if you have any questions, or if I can be of further assistance, please feel free to contact me. Sincerely, Jesse J. Beitel Senior Scientist/Principal HUGHES ASSOCIATES, INC.

13 Rosalind Fazel From: Sent: To: Subject: Wednesday, October 31, :49 AM Rosalind Fazel AC212 Comments Comments on Criteria AC212. Mark Franciosi W.R. Grace & Co. - Conn mark.a.franciosi@grace.com Comments: Per section of the proposed ICC-ES AC 212 revisions, the requirement for water resistive coatings to meet a Class A rating per ASTM E84 for buildings less than 40 ft should be removed. ASTM E84 has historically been used to evaluate interior wall and ceiling finishes per Section 8 of the IBC. ASTM E 84 tests the material in a tunnel like configuration that does not correlate to the actual use of the coating in an exterior wall assembly such as NFPA 285 or engineering judgments per ASTM E1354. Having different fire resistive requirements for coatings used in the same application should be avoided. Utilizing NFPA 285 or an engineering judgment based on ATSM E1354 would allow the products to be evaluated by the same method and provide the designer and the building owner the reassurance that the selected products will perform as intended in relation to fire resistance. 10/31/2012 9:50 AM - 1