National Association of Home Builders

Recommended State & Local Amendments to the

2012 Edition of the International Building Code (IBC)

Issue: Window Sill Height

2012 IBC Section Number: 1013.8 Window Sill Height

Recommended Amendment:
Delete the portion of the code and replace as shown below:

1013.8 Window sills. In Occupancy Groups R-2 and R-3, one- and two-family and
multiple-family dwellings, where the opening of the sill portion of an operable window is
located more than 72 inches (1829 mm) above the finished grade or other surface
below, the lowest part of the clear opening of the window shall be at a height not less
than 24 inches ( 610mm) 36 inches (610 mm) above the finished floor surface of the
room in which the window is located. Operable sections of windows shall not permit
openings that allow passage of a 4-inch-diameter (102mm) sphere where such openings
are located within 24 inches ( 610mm) 36 inches (915mm) of the finished floor

Remainder left unchanged

Reason:

NAHB encourages local jurisdictions to wait for the ICC process to rectify the
discrepancies between the 2012 IRC and the 2012 IBC that was created during the
2009-10 code development cycle. The 2012 International Residential Code does not
require window guards for windows with a sill height greater than 24 inches off of the
finish floor. The International Building Code requires the installation of windows guards
on windows with a sill height less than 36 inches off of the finished floor. During the
2009-10 code development cycle, the IRC-BE committee disapproved a similar
proposal to raise the window sill height to 36 inches and the committees decision was
upheld at the final action hearing. A similar public comment to raise the window sill
height to 36 inches also failed to pass the final assembly.

For the many years the debate for requiring fall protection devices the most contentious
issue has been the height of the window sill in which the device should be required.
NAHB agrees with many of the concerns that were raised by the opponents of the
proposal. By raising the window sill height requirement to 36 inches there is the potential
for unintended consequences as it may cause children to prop items or move furniture to
allow them to see over the window sill which is no longer below their field of vision.

Many of the children safety advocates focus their efforts to relay safety messages to
parents regarding the prevention of falls by recommending that windows should be
closed in rooms where children are playing, where children are unsupervised, avoid
placing furniture near windows and if windows are going to be left open, open them from
the top down.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Building Code (IBC)

Issue: Compliance with Federal Fair Housing Law

2012 IBC Section Number: Various (3411.1, 3411.4, 3411.4.2, 3411.6, 3411.7, 3411.8.9)

Recommended Amendment:
Modify the sections as shown below:
3411.1 Scope. The provisions of Sections 3411.1 through 3411.9 apply to maintenance, change of
occupancy, additions and alterations to existing buildings, including those identified as historic buildings.

Exception: Type B dwelling or sleeping units required by Section 1107 of this code are not
required to be provided in existing buildings and facilities being altered or undergoing a change of
occupancy.

3411.4 Change of occupancy. Existing buildings that undergo a change of group or occupancy shall
comply with this section.

Exception: Type B dwelling units or sleeping units required by Section 1107 of this code are not
required to be provided in existing buildings and facilities undergoing a change of occupancy in
conjunction with alterations where the work area is 50 percent or less of the aggregate area of the
building.

3411.4.2 Complete change of occupancy. Where an entire building undergoes a change of occupancy,
it shall comply with Section 3411.4.1 and shall have all of the following accessible features:

1. At least one accessible building entrance.

2. At least one accessible route from an accessible building entrance to primary function areas.
3. Signage complying with Section 1110.
4. Accessible parking, where parking is being provided.
5. At least one accessible passenger loading zone, when loading zones are provided.
6. At least one accessible route connecting accessible parking and accessible passenger loading
zones to an accessible entrance.

Where it is technically infeasible to comply with the new construction standards for any of these
requirements for a change of group or occupancy, the above items shall conform to the requirements to
the maximum extent technically feasible.

Exception: The accessible features listed in Items 1 through 6 are not required for an accessible
route to Type B units.

Page 1 of 3
3411.6 Alterations. A facility that is altered shall comply with the applicable provisions in Chapter 11 of
this code unless technically infeasible. Where compliance with this section is technically infeasible, the
alteration shall provide access to the maximum extent technically feasible.

Exceptions:
1. The altered element or space is not required to be on an accessible route, unless required by
Section 3411.7.
2. Accessible means of egress required by Chapter 10 are not required to be provided in existing
facilities.
3. The alteration to Type A individually owned dwelling units within a Group R-2 occupancy shall
be permitted to meet the provision for a Type B dwelling unit.
4. Type B dwelling or sleeping units required by Section 1107 of this code are not required to be
provided in existing buildings and facilities undergoing a change of occupancy in conjunction
with alterations where the work area is 50 percent or less of the aggregate area of the
building.

3411.7 Alterations affecting an area containing a primary function. Where an alteration affects the
accessibility to, or contains an area of primary function, the route to the primary function area shall be
accessible. The accessible route to the primary function area shall include toilet facilities or drinking
fountains serving the area of primary function.

Exceptions:
1. The costs of providing the accessible route are not required to exceed 20 percent of the costs
of the alterations affecting the area of primary function.
2. This provision does not apply to alterations limited solely to windows, hardware, operating
controls, electrical outlets and signs.
3. This provision does not apply to alterations limited solely to mechanical systems, electrical
systems, installation or alteration of fire protection systems and abatement of hazardous
materials.
4. This provision does not apply to alterations undertaken for the primary purpose of increasing
the accessibility of a facility.
5. This provision does not apply to altered areas limited to Type B dwelling and sleeping units.

3411.8.9 Type B dwelling or sleeping units. Where four or more Group I-1, I-2, R-1, R-2, R-3 or R-4
dwelling or sleeping units are being added, the requirements of Section 1107 for Type B units apply only
to the quantity of the spaces being added. Where Group I-1, I-2, R-1, R-2, R-3 or R-4 dwelling or sleeping
units are being altered and where the work area is greater than 50 percent of the aggregate area of the
building, the requirements of Section 1107 for Type B units apply only to the quantity of the spaces being
altered.

Page 2 of 3
Reason:

These sections, new to the 2012 edition of the IBC, should be stricken as they far exceed the
Federal Fair Housing Act (FHAct) requirements for accessibility. The addition of the Exception
shown in Section 3411.1, an exception that was part of previous editions of the IBC, needs to be
reinstated. Of most importance is that this change requiring compliance with IBC "Type B Units"
in an alteration or change of use of an existing building is contrary to Federal law. First, these
requirements expand the Federal law that only “multifamily buildings" constructed for first
occupancy after March 13, 1991 need to be constructed to the FHAct requirements. Second,
these requirements would apply to ALL existing buildings converted to multifamily use, no matter
when they were first constructed. But, Federal law does not require existing buildings to comply
with the FHAct. This is mainly due to the design and construction of the components of older
buildings such as door and hallway widths, and the location of structural elements that that
cannot be changed without great expense. This added expense can deter inner-city
revitalization efforts of converting older existing buildings into residential occupancies.

Another problem is that this HUD supported change seems to be an attempt to circumvent and
nullify the FHAct and the rulings handed down by the Federal Courts. The FHAct Rules includes
a two-year statute of limitations on bringing suit and making corrections to an existing non-
compliant multifamily building, a statute of limitations upheld by the Federal Circuit Courts of
Appeals. It also appears this change is an attempt by a department of the federal government to
mandate a change to the federal regulations without going through the Federal Administrative
Procedure Act rulemaking process.

There is also the aspect of Federal preemption. The inclusion of these requirements in the IBC is
contrary to Federal Law. As Federal Law will preempt any state or local law, there will be
challenges to the adoption of this Code. There is no benefit for any state or local jurisdiction to
have to fight a challenge in court if the adoption of the IBC contains these requirements. Until
such time as the U.S. Congress passes Federal law, and HUD goes through the rulemaking
process and develops such accessibility requirements for inclusion in the FHAct design manual,
these requirements should not be included in the adoption of the IBC.

Staff Contact: Steve Orlowski – sorlowsk@nahb.org 1-800-368-5242, ext. 8303

Page 3 of 3
 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Existing Building Code
(IEBC)

Issue: Compliance with Federal Fair Housing Law

2012 IEBC Section Number: Various (705.1, 705.2, 1012.8, 1012.8.2)

Recommended Amendment:
Modify the sections as shown below:
705.1 General. A facility that is altered shall comply with the applicable provisions in Sections 705.1.1
through 705.1.14, and Chapter 11 of the International Building Code unless it is technically infeasible.
Where compliance with this section is technically infeasible, the alteration shall provide access to the
maximum extent that is technically feasible.

A facility that is constructed or altered to be accessible shall be maintained accessible during occupancy.

Exceptions:
1. The altered element or space is not required to be on an accessible route unless required by
Section 705.2.
2. Accessible means of egress required by Chapter 10 of the International Building Code are not
required to be provided in existing facilities.
3. Type B dwelling or sleeping units required by Section 1107 of the International Building Code
are not required to be provided in existing facilities undergoing less than a Level III alteration.
4. The alteration to Type A individually owned dwelling units within a Group R-2 occupancy shall
meet the provisions for Type B dwelling units.

705.2 Alterations affecting an area containing a primary function. Where an alteration affects the
accessibility to a, or contains an area of, primary function, the route to the primary function area shall be
accessible. The accessible route to the primary function area shall include toilet facilities or drinking
fountains serving the area of primary function.

Exceptions:
1. The costs of providing the accessible route are not required to exceed 20 percent of the costs
of the alterations affecting the area of primary function.
2. This provision does not apply to alterations limited solely to windows, hardware, operating
controls, electrical outlets and signs.
3. This provision does not apply to alterations limited solely to mechanical systems, electrical
systems, installation or alteration of fire protection systems and abatement of hazardous
materials.
4. This provision does not apply to alterations undertaken for the primary purpose of increasing
the accessibility of a facility.
5. This provision does not apply to altered areas limited to Type B dwelling and sleeping units.

1012.8 Accessibility. Existing buildings that undergo a change of group or occupancy classification shall
comply with this section.

Exception: Type B dwelling or sleeping units required by Section 1107 of the International
Building Code are not required to be provided in existing buildings and facilities undergoing a
change of occupancy in conjunction with less than a Level III alteration.

Page 1 of 2
1012.8.2 Complete change of occupancy. Where an entire building undergoes a change of occupancy,
it shall comply with Section 1012.8.1 and shall have all of the following accessible features:

1. At least one accessible building entrance.

2. At least one accessible route from an accessible building entrance to primary function areas.
3. Signage complying with Section 1110 of the International Building Code.
4. Accessible parking, where parking is provided.
5. At least one accessible passenger loading zone, where loading zones are provided.
6. At least one accessible route connecting accessible parking and accessible passenger loading
zones to an accessible entrance.

Where it is technically infeasible to comply with the new construction standards for any of these
requirements for a change of group or occupancy, the above items shall conform to the requirements to
the maximum extent technically feasible.

Exception: The accessible features listed in Items 1 through 6 are not required for an accessible
route to Type B units.

Reason:

These sections, new to the 2012 edition of the IEBC, should be stricken as they far exceed the
Federal Fair Housing Act (FHAct) requirements for accessibility. Of most importance is that this
change requiring compliance with IBC "Type B Units" in an alteration or change of use of an
existing building is contrary to Federal law. First, these requirements expand the Federal law that
only “multifamily buildings" constructed for first occupancy after March 13, 1991 need to be
constructed to the FHAct requirements. Second, these requirements would apply to ALL existing
buildings converted to multifamily use, no matter when they were first constructed. But, Federal
law does not require existing buildings to comply with the FHAct. This is mainly due to the design
and construction of the components of older buildings such as door and hallway widths, and the
location of structural elements that that cannot be changed without great expense. This added
expense can deter inner-city revitalization efforts of converting older existing buildings into
residential occupancies.

Another problem is that this HUD supported change seems to be an attempt to circumvent and
nullify the FHAct and the rulings handed down by the Federal Courts. The FHAct Rules includes
a two-year statute of limitations on bringing suit and making corrections to an existing non-
compliant multifamily building, a statute of limitations upheld by the Federal Circuit Courts of
Appeals. It also appears this change is an attempt by a department of the federal government to
mandate a change to the federal regulations without going through the Federal Administrative
Procedure Act rulemaking process.

There is also the aspect of Federal preemption. The inclusion of these requirements in the IEBC
is contrary to Federal Law. As Federal Law will preempt any state or local law, there will be
challenges to the adoption of this Code. There is no benefit for any state or local jurisdiction to
have to fight a challenge in court if the adoption of the IEBC contains these requirements. Until
such time as the U.S. Congress passes Federal law, and HUD goes through the rule making
process and develops such accessibility requirements for inclusion in the FHAct design manual,
these requirements should not be included in the adoption of the IEBC.

Staff Contact: Steve Orlowski – sorlowsk@nahb.org 1-800-368-5242, ext. 8303

Page 2 of 2
 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Plumbing Code (IPC)

Issue: Developed Length of Hot Water Piping

2012 IPC Section Number: 607.2 Hot water supply temperature maintenance.

Recommended Amendment:
Modify the section as shown below:

607.2 Hot water supply temperature maintenance. Where the developed length of hot
water piping from the source of hot water supply to the farthest fixture exceeds 50 feet
(15 240mm), the hot water supply system shall be provided with a method of maintaining
the temperature in accordance with the International Energy Conservation Code.

Exception: Where the developed length of hot water piping from the source of hot water
supply to the farthest fixture is 50 to 100 feet (15 240 to 30 480mm), the piping from the
source of hot water supply to all fixtures exceeding 50 feet (15 240mm) in developed
length shall be insulated to a minimum of R-4.

Reason:
There is no supporting data for the given distance of 50 feet. Why not 40 or 60? 100
feet is a benchmark for when additional systems are needed. This section, as written,
would require placement of water heaters to areas of a home that are not efficient for
utility location, the installation of circulation systems, as well as increase the insulation
requirements to meet the IECC.

The amendment adds an exception allowing greater flexibility while still reducing energy
and water consumption. It brings back the long-standing distance of 100 feet with the
addition of pipe insulation. The insulation value in the amendment is taken from the
National Green Building Standard (ICC 700-2008).

Staff Contact: Dan Buuck – dbuuck@nahb.org 1-800-368-5242, ext. 8366

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Fire Separation Distance

2012 IRC Section: Table R302.1(1) & Table R302.1(2)

Recommended Amendment:
Modify the Table as shown below (Delete text):

Table R302.1(2) – Exterior Walls

MINIMUM
MINIMUM
EXTERIOR WALL ELEMENT FIRE SEPARATION
FIRE-RESISTANCE RATING
DISTANCE
1 hour-tested in accordance with
(Fire-resistance rated) ASTM E 119 or UL 263 with < 5 Feet 0 Feet>3 Feet
Walls
exposure to both sides
(Not fire-resistance rated) 0-Hours > 5 Feet >3 Feet
(Fire-resistance rated) 1-Hour on the underside > 5 Feet <3 Feet 2 Feet
Projections
(Not fire-resistance rated) 0-Hours 3 Feet

Not Allowed N/A 3 Feet < 3 Feet

Openings
Unlimited 0-Hours 5 Feet 3 Feet

Comply with
< 5 Feet < 3 Feet
Section R302.4
Penetrations All
None Required 5 Feet 3 Feet

For SI: 1 foot= 304.8 mm

N/A = Not Applicable
 Table R302.1(2) – Exterior Walls
MINIMUM
MINIMUM
EXTERIOR WALL ELEMENT FIRE SEPARATION
FIRE-RESISTANCE RATING
DISTANCE
1 hour-tested in accordance with
(Fire-resistance rated) ASTM E 119 or UL 263 with 0 Feet
Walls
exposure to both sides
(Not fire-resistance rated) 0-Hours >3 Feet
(Fire-resistance rated) 1-Hour on the underside 2 Feet
Projections
(Not fire-resistance rated) 0-Hours 3 Feet

Not Allowed N/A < 3 Feet

Openings
Unlimited 0-Hours 3 Feet

Comply with
< 3 Feet
Section R302.4
Penetrations All
None Required 3 Feet

a. For residential subdivisions where all dwellings are equipped throughout with an automatic sprinkler systems installed in
accordance with Section P2904, the fire separation distance for non-rated exterior walls and rated projections shall be permitted to
be reduced to zero feet, and unlimited unprotected openings and penetrations shall be permitted, where the adjoining lot provides
an open setback yard that is 6 feet or more in width on the opposite side of the property line.

Reason:
NAHB urges all state and local jurisdictions to adopt the 2012 International Residential
Code with the above referenced amendment to the fire separation distance
requirements for exterior walls. For years NAHB has requested the IRC code committee
to return the fire separation distances of exterior walls to those found in the 2003 IRC.
During the supplemental code cycle, the fire separation distances were increased
without any scientific data or reports that proved the allowable distance found in the
2003 IRC contributed to any increase in exposure fires from one dwelling to another.
The fire separation distances were arbitrarily increased by a distance of 2’-0’’, without
any justification or testing showing that the previously allowed distances were an
increased fire hazard.

To this day, there are no known reports or studies that demonstrate the previously
allowed 3 foot separation distance from the property line and 6 foot separation between
structures failed to provide the minimum required safe distance for fire separation. We
encourage the adoption of this amendment.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Opening Protection

2012 IRC Section Number: R302.5.1 Opening Protection

Recommended Amendment:
Delete the Section in its entirety as shown below:

R302.5.1 Opening protection. Openings from a private garage directly into a room
used for sleeping purposes shall not be permitted. Other openings between the garage
and residence shall be equipped with solid wood doors not less than 13/8 inches (35
mm) in thickness, solid or honeycomb core steel doors not less than 13/8 inches (35
mm) thick, or 20-minute fire-rated doors equipped with a self-closing device.

Reason:
NAHB strongly disagrees with the new requirement for door closures to be required on
openings between the garage and the house. For many years, the committee was
requested to approve closures on the doors between the house and the garage with
reason that fires that originate in the garage could pass through these openings. For
many years the proponents failed to provide any reliable data or statistics on the number
of fires that originated in the garage and passed through the opening resulting in the fire
spreading into the interior of the dwelling. As a result, the committee and the
governmental members repeatedly disapproved this requirement.

During the 2009-10 Code development, the proponents returned with a new reason for
requiring that these doors be equipped with door closures, to prevent the spread of
carbon monoxide from vehicles and the by-products produced by the burning
thermoplastics. While the proponents were able to produce a extremely lengthy
dissertation on the hazards of carbon monoxide and the number of false alarms that are
created by carbon monoxide detectors, nowhere in their written or oral testimony were
they able to link any statistical substantiation to need for closures on these openings. To
this day there are no reports that support the addition of door closures on doors between
the dwelling and the garage will reduce the number of fires spreading into the dwelling,
prohibit the flow of carbon monoxide into the dwelling, or reduce the number of false CO
alarms.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Stair Geometry (8 ¼“x 9”)

2012 IRC Sections: R311.7.5.1 and R311.7.5.2

Recommended Amendment:
Modify the Section as shown below (Delete text, add new text)

R311.7.4.1 Riser height. The maximum riser height shall be 8 ¼ inches (210 mm) 7 ¾
inches (196 mm). The riser shall be measured… (no further change)

R311.7.4.2 Tread depth. The minimum tread depth shall be 9 inches (229 mm) 10
inches (254 mm). The tread depth shall be measured… (no further change)

Reason:
The purpose of this amendment is to retain the stair geometry requirements to those
that have historically been allowed under the Building Officials and Code Administrators
National Building Code (BOCA). This amendment will allow for the continued use of the
8¼” x 9” geometry, which is also the historically accepted requirement of many other
state and local jurisdictions across the country. Many others actually adopt stair
geometry requirements of 8 ¼” x 9.”

These dimensions, originally accepted in the First Draft of the International Residential
Code (IRC) and the historic dimensions in the Council of American Building Official’s
CABO One- and Two-family Building Code, adequately provide for stair safety in
residential occupancies.

The 8¼” x 9” geometry has always adequately provided for occupant safety in
residential occupancies. No sound documentation or data has ever been presented
demonstrating that the 8 ¼” x 9” geometry is any less safe than a stair geometry of 7 ¾”
x 10” or other even more stringent geometries. More specifically, there is no sound data
showing or otherwise indicating a stair geometry of 8 1/4 ” x 9” is a contributing factor in
accidental residential falls anymore than a stair geometry of 7 ¾” x 10” or any other stair
geometry that has been proposed.

The safety benefits of the 7 ¾“riser and 10” tread stair geometry are technically
unsubstantiated and are not practical in many home designs. If the footprint of the
house must be increased to accommodate the additional space needed for 7 ¾” x 10”
vs. an 8 ¼” x 9” geometry, adequately sized living spaces are sacrificed without any
demonstrated gain. This can lead to an economic hardship upon first-time homebuyers
of smaller homes, and in particular for construction on smaller lots, in-fill projects, and
townhomes.
As outlined in Section R101.3 of the IRC, the purpose the requirements in the code are
to provide minimum requirements for occupant safety and health. There is adequate
substantiation to show that 8¼” x 9” geometry provides this minimum level of occupant
safety.

Notes/additional background:
Prior to the Building Officials and Code Administrators 1996 BOCA National Building
Code, and the 1995 CABO One-and-Two Family Building Code, stair geometry
requirements were set at the 8¼” x 9” dimensions.

An alternative amendment is available for jurisdictions that wish to retain the use of past
UBC requirements of an 8-inch maximum riser height and 9-inch minimum tread depth.
For that amendment, please see suggested amendment “Stair Geometry (8” X 9”)”.

NAHB Policy on Stair Geometry Standards states: NAHB's Board of Directors

recommends that all state and local governments which adopt the National Building
Code (BOCA) and the Council of American Building Officials (CABO) model building
codes, postpone the adoption of any new stair geometry. Also, NAHB's Board of
Directors calls on all state and local governments that automatically adopt BOCA and
CABO model building codes to amend the 1996 and 1995 editions respectively to
continue the use of the 1993 BOCA and CABO model codes as they relate to stair
geometry provisions. Also, NAHB's Board of Directors urges all state and local affiliated
Home Builders Associations to contact state and local code authorities and persuade
them to postpone the adoption of the new CABO and BOCA stair geometry
standard. Also, NAHB's Board of Directors calls on NAHB to continue to vigorously
pursue the adoption of a stair geometry standard consistent with the 1993 BOCA Code.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Stair Geometry (8“ x 9”)

2012 IRC Sections: R311.7.5.1 and R311.7.5.2

Recommended Amendment:
Modify the Section as shown below (Delete text, add new text)

R311.7.5.1 Riser height. The maximum riser height shall be 8 inches (210 mm) 7 ¾
inches (196 mm). The riser shall be measured… (no further change)

R311.7.5.2 Tread depth. The minimum tread depth shall be 9 inches (229 mm) 10
inches (254 mm). The tread depth shall be measured… (no further change)

Reason:
The purpose of this amendment is to retain the stair geometry requirements to those that
have historically been allowed under the Uniform Building Code (UBC). This
amendment will allow for the continued use of the 8” x 9” geometry which is also the
historically accepted requirement of many other state and local jurisdictions across the
country. Many others actually adopt stair geometry requirements of 8 ¼” x 9.”

The 8” x 9” geometry has always adequately provided for occupant safety in residential
occupancies. No sound documentation or data has ever been presented demonstrating
that the 8” x 9” geometry is any less safe than a stair geometry of 7 ¾” x 10” or other
even more stringent geometries. More specifically, there is no sound data showing or
otherwise indicating a stair geometry of 8” x 9” is a contributing factor in accidental
residential falls anymore than a stair geometry of 7 ¾” x 10” or any other stair geometry
that has been proposed.

The safety benefits of the 7 ¾“riser and 10” tread stair geometry are technically
unsubstantiated and are not practical in many home designs. If the footprint of the
house must be increased to accommodate the additional space needed for 7 ¾” x 10”
vs. an 8” x 9” geometry, adequately sized living spaces are sacrificed without any
demonstrated gain. This can lead to an economic hardship upon first-time homebuyers
of smaller homes, and in particular for construction on smaller lots, in-fill projects, and
townhomes.

As outlined in Section R101.3 of the International Residential Code (IRC), the purpose
the requirements in the code are to provide minimum requirements for occupant safety
and health. There is adequate substantiation to show that an 8” x 9” geometry provides
this minimum level of occupant safety.

Notes/additional background:
This is an alternative amendment provided to accommodate for jurisdictions that are
accustomed to and wish to retain the use of past UBC requirements of an 8 inch
maximum riser height and a 9 inch minimum tread depth.

Prior to changes in the Building Officials and Code Administrators 1996 BOCA National
Building Code, and 1995 CABO One-and-Two Family Building Code, stair geometry
requirements in these codes were set at an 8 ¼ “ maximum for risers and a 9 inch
minimum tread depth. For these dimensions, please see suggested amendment “Stair
Geometry (8 ¼“ X 9”)” which is consistent with NAHB policy.

NAHB Policy on Stair Geometry Standards states: NAHB's Board of Directors

recommends that all state and local governments which adopt the National Building
Code (BOCA) and the Council of American Building Officials (CABO) model building
codes, postpone the adoption of any new stair geometry. Also, NAHB's Board of
Directors calls on all state and local governments that automatically adopt BOCA and
CABO model building codes to amend the 1996 and 1995 editions respectively to
continue the use of the 1993 BOCA and CABO model codes as they relate to stair
geometry provisions. Also, NAHB's Board of Directors urges all state and local affiliated
Home Builders Associations to contact state and local code authorities and persuade
them to postpone the adoption of the new CABO and BOCA stair geometry
standard. Also, NAHB's Board of Directors calls on NAHB to continue to vigorously
pursue the adoption of a stair geometry standard consistent with the 1993 BOCA Code.

Staff Contact: Steve Orlowski – sorlowski@nahb.com – 800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Window Sill Height/Window Opening Devices

2012 IRC Section: R312.2

Recommended Amendment:
Modify the Section as shown below (Delete text, Add new text)

R312.2 Window fall protection. Where window fall protection is provided it shall be
installed provided in accordance with Sections R312.2.1 and R312.2.2

R312.2.1 Window sills. In dwelling units, where the opening of an operable window is
located more than 72 inches (1829 mm) above the finished grade or surface below, the
lowest part of the clear opening of the window shall be a minimum of 24 inches (610
mm) above the finished floor of the room in which the window is located. Operable
sections of windows shall not permit openings that allow a 4 inch (102mm) diameter
sphere where such openings are located within24 inches (610 mm) of the finished floor.

Exceptions:

1. Windows whose openings will not allow a 4-inch-diameter (102 mm) sphere to pass
through the opening when the opening is in its largest opened position.
2. Openings that are provided with window fall prevention devices that comply with
ASTM F-2090
3. Windows that are provided with window opening control devices that comply with
Section R312.2.2.

R312.2.2 Window opening control devices. Window opening control devices shall
comply with ASTM F2090. The window opening control device, after operation to
release the control device allowing the window to fully open, shall not reduce the
minimum net clear opening area of the window unit to less than the area required by
Section R310.1.1

Reason:
The purpose of this amendment is to retain the provision for the installation of window
opening limiting devices or window fall prevention devices where they are installed, and
delete the reference of requiring these devices based on a window sill height. This
change will allow the builder and the building official to use their judgment for when
these devices shall be installed and insure that where these devices are provided they
will conform with the referenced industry standard.

During the 2007/2008 Code Development Cycle and the International Code Council’s
Code Technology Committee (CTC) meetings, the Window and Door Manufacturers
Association (WDMA) presented credible information that raised questions and concerns
regarding the established minimum window sill heights. Despite the Consumer Product
Safety Commission (CPSC) reports indicating a decrease in the number of injuries and
deaths from children falling from windows, WDMA had discovered that in Denver,
Colorado, one of the few areas in the country that has had a minimum sill height
requirement for the past decade, the number of child injuries and deaths were
increasing. One of the many concerns is that there is the potential for the occupant to
place furniture or other objects under the window that a child could climb upon. It is our
opinion that the CTC needs to earnestly review the information presented by the WDMA
and reconsider their position on minimum window sill heights.

Furthermore, the recommendation to require window opening limiting devices

contradicts conclusions of the CTC Work Study Group. It was clear to many in the CTC
Work Group that public education was the most effective means of reducing the number
of falls by children through windows.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Guardrails

2012 IRC Section: R312.1.1

Recommended Amendment:
Modify the Section as shown below (Delete text)

R312.1.1 Where required. Guards shall be located along open-sided walking surfaces
of all decks, porches, balconies, including stairs, ramps and landings that are located
more than 30 inches measured vertically to the floor or grade below. at any point within
36 inches (914 mm) horizontally to the edge of the open side Insect screening shall not
be considered as a guard.

Reason:
The purpose of this amendment is to retain the provisions of the 2006 International
Residential Code (IRC), where guardrails were required when the elevation difference
between the walking surface was greater than 30 inches to the floor or grade directly
below. The 2009 IRC now requires a guardrail where the elevation difference is greater
than 30 inches from the walking surface to a horizontal point 36 inches adjacent to the
leading edge of the walking surface to the grade or floor below. This change will now
require the building official to carry a four foot level to conduct inspections.

During the 2007/2008 Code Development Cycle, the proponent referred to work
conducted and reports written by the International Code Council’s Code Technology
Committee (CTC). Though, at no time during the Public Hearing, nor the Final Action
Hearing, was any technical justification presented to substantiate the change requiring
the building official to measure thirty-six inches away from the leading edge of the
walking surface or tread to determine when a guardrail should or should not be
required. After reviewing the many reports from the CTC website, it is still unclear from
where the thirty-six inch requirement was derived. Currently there are no studies that
can support the claims made that this will have an effect on reducing possible injuries.
While the proponent promotes this as a means for consistent enforcement of the guard
requirements, there was no evidence that showed an increased risk to the safety of the
occupant if the current method of measuring from the edge of the walking surface to
grade below is used.

Furthermore, the new language now requires a guardrail to be applied to any open-
sided walking surface. This could very well be interpreted by building officials to include
driveways, landscaped walkways, retaining walls and other elevated surfaces used for
the purpose of walking. This change substantially expands the areas needing to be
equipped with guards, beyond the previous edition of the code.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Residential Fire Sprinklers

2012 IRC Section Number: R313 Automatic Fire Sprinkler System

Recommended Amendment:
Delete the Section in its entirety as shown below:

R313 AUTOMATIC FIRE SPRINKLER SYSTEMS

R313.1 Townhouse automatic fire sprinkler systems. An automatic residential fire

sprinkler system shall be installed in townhouses.

Exception: An automatic residential fire sprinkler system shall not be required when
additions or alterations are made to existing townhouses that do not have an automatic
residential fire sprinkler system installed.

R313.1.1 Design and installation. Automatic residential fire sprinkler systems for
townhouses shall be designed and installed in accordance with Section P2904.

R313.2 One- and two-family dwellings automatic fire sprinkler systems. An

automatic residential fire sprinkler system shall be installed in one- and two-family
dwellings.

Exception: An automatic residential fire sprinkler system shall not be required for
additions or alterations to existing buildings that are not already provided with an
automatic residential fire sprinkler system.

R313.2.1 Design and Installation. Automatic residential fire sprinkler systems shall be
installed in accordance with Section P2904 or NFPA 13D.

Reason:
Since the inclusion of the mandatory requirement for residential sprinklers in the 2009
Edition of the International Residential Code, more than 34 states have amended or
passed legislation prohibiting communities from mandating residential sprinklers in new
one- and two family dwellings. NAHB urges all state and local communities to oppose
the mandatory requirement and continue to support the voluntary installation of
residential sprinklers as the buyer’s choice.

In 1977, less than 0.008% of the housing market was affected by structure fires. In 2005,
that number was reduced to less than 0.002%. Over the past three decades, there has a
substantial decrease in the number of residential structure fires in relation to the growth
of American housing. No one can predict when and where a fire will occur, but to require
all homes to be equipped with a residential sprinkler system based on the figures above
don’t make sense.

1. Should the requirement for fire sprinklers in dwellings be a local issue? The sole
purpose of an appendix is to allow local jurisdictions the means to adopt a code or
standard that is applicable to their community. Not every jurisdiction agrees that
radon resistant construction, patio coverings, and safety inspections of existing
appliances need to be regulated or inspected. And contrary to belief of some
activist groups, several jurisdictions have decided that appendix p is not
applicable to their state or local jurisdictions. So far twelve states have adopted
the 2006 International Residential Code and none have adopted the Appendix P.
In six of these states, there was a motion made to include appendix P in the
formal adoption of the 2006 IRC and the motion was voted down at the state
level. According to the U.S. fire administration more than half states in America
are below the national fire death rate of 13.6 per million and over the past ten
years the number of one- and two- family dwelling fires, deaths and injuries have
fallen (6%, 18% and 26% respectively).

2. Perception is each person’s own reality and while the fire service and sprinkler
advocates acknowledge that the median age of a home is 32 years, it seems that
the connection between fire deaths and the age of the home is still allusive to
some people. For several years data has been collected for several relevant facts
about fires, the cause of the fire, whether smoke alarms were present and were
working, type of smoke alarm present, whether the fire was confined or not. With
all the information that is gathered and can be determined after the event, one of
the most crucial pieces of information that is not gathered is the age of the home.
This information could open a whole new realm of understanding about how the
home is built and whether or not the codes changes over the course of time have
been beneficial.

While there have been no studies conducted to support or dispute the

claim that newer homes are less susceptible to fire, there is supporting evidence
in the most recent report issued by NFPA on the performance of smoke alarms.
According to the report of the there is a significant difference in the number of
fatalities and the number of fires when the smoke alarm present were either
battery operated, hardwired with battery backup and hardwired. According to April
2007 Report “U.S. Experience with Smoke Alarms and other Fire Detection/Alarm
Equipment” by Marty Ahrens, 65% of the reported residential home fire deaths
occurred in homes where there was no smoke alarm present (43%) or did not
operate (22%). Of the 35% fire fatalities that occurred when a smoke alarm was
present and operated, it was reported that two-thirds of the non-confined home
structure fires occurred in dwellings with battery operated smoke alarms with the
remaining third evenly divided between homes with hardwired and hardwired with
battery backup.
 Source Code # of # of # of Property
Cycle Fires Fatalities Injuries Damage in
Required Millions
Battery only Before 88,300 1,230 5,850 $2,353
1982
Hardwired Only 1982-1992 19,900 170 1,300 $743
Hardwire/Battery 1992- 18,000 210 1,490 $568
Present
Reference: April 2007 Report “U.S. Experience with Smoke Alarms and other Fire Detection/Alarm Equipment” by Marty Ahrens

From this information we can see that as the requirements for smoke alarms
changed, as well as other requirements over the years, that the newer stock has
had fewer fires and fewer fire fatalities. Along with improvements to the power
source, the National Fire Code has also increased the number of required smoke
alarms in a one- and two- family dwelling over the years and in 1992 it required
that all smoke alarms were interconnected. When you consider the advances
made in the requirements of smoke alarms and look at the results in reducing the
number of fire fatalities, the solution is educating the public about the importance
of working smoke alarms and practicing proper fire prevention.

There is a more cost effective means of reducing the loss life that we see every
year and that is through increasing public awareness on the use and importance of
smoke alarms. According to NFPA reports an estimated 890 live could be saved
annually if home were equipped with working smoke alarms. 65% of the reported fire
fatalities from 2000-2004 occurred in homes were smoke alarms were either not present
or were present but failed to operate. CPSC surveys have shown that while 88% of the
households screened had at least one smoke alarm, 72% of these smoke alarms were
battery powered only.

It is NAHB’s opinion that the figures presented in the proponents substantiation is

incorrect when it come to the dollars spent per life saved. According to the Canada
Mortgage and Housing Corporation, the cost per life saved would be about $38 million
dollars if there were a mandate and NIST has estimated that the cost per life saved
would be $35 million. There are trends that are observed and acknowledged by both
sprinkler proponents and opponents, that the majority of fire fatalities occur in homes
that do not have smoke alarms, or a smoke alarm that did not operate.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Carbon Monoxide Detectors

2012 IRC Section Number: R315.1 Carbon Monoxide Alarms

Recommended Amendment:
Delete the Section in its entirety as shown below:

R315.1 Carbon monoxide alarms. For new construction, an approved carbon

monoxide alarm shall be installed outside of each separate sleeping area in the
immediate vicinity of the bedrooms in dwelling units within which fuel-fired appliances
are installed and in dwelling units that have attached garages with a communicating
opening.

R315.3 Where required in existing dwellings. Where work requiring a permit occurs in
existing dwellings, that have attached garages or in existing dwellings within which fuel-
fired appliances exist, carbon monoxide alarms shall be provided in accordance with
Section R315.1 for the following:

1. Mechanical or gas work requiring a permit in which fuel-fired appliances are being
replaced or installed.
2. Addition and/or renovation of attached garages with communicating openings
requiring building permit.

Reason:
In an attempt to provide clearer guidance into the requirements for where and when a
CO detector is required, NAHB urges the local jurisdiction to apply the same provisions
found in NFPA Building Code. There are situations where one- and two- family dwellings
are constructed with an attached garage that does not open directly into the dwelling
unit, such as is found with homes with breezeways that separate the garage from the
dwelling but share the same roof. When there is no direct communication between the
garage and the dwelling unit or when there is adequate ventilation to reduce the
transmission of any potential CO emission from entering the dwelling, CO detection
should not be required.

As for the second modification, there are many in the code enforcement community that
interpret the existing language to include any work that is performed under a permit,
requires existing homes to be equipped with a carbon monoxide detector. The premises
for requiring any retrofitting requirement must be tied to the potential cause of the hazard
and not an unrelated act. Carbon monoxide detectors should only be required when the
work being performed is related to potential causes of carbon monoxide. Bathroom
renovation, kitchen upgrades and additions that do not involve fuel-fired appliances
should not trigger the installation of carbon monoxide detectors.

Staff Contact: Steve Orlowski - sorlowski@nahb.com 1-800-368-5242, ext. 8303

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Foundation Anchorage

2012 IRC Section Number: 403.1.6

Recommended Amendment:
Modify the section as shown below:
R403.1.6 Foundation anchorage. Where wood sSill and sole plates are and walls supported directly on
continuous foundation walls or monolithic slabs with integral footings required by the provisions of this
code, they shall be anchored to the foundation in accordance with this section.

Cold-formed steel floor and wall framing shall be anchored to the foundation in accordance with Section
R505.3.1 or R603.3.1.

Wood sole plates at all exterior walls on monolithic slabs, wood sole plates of braced wall panels at
building interiors on monolithic slabs with integral footings, and all wood sill plates shall be anchored to the
foundation with minimum 1/2 inch (12.7 mm) diameter anchor bolts spaced a maximum of 6 feet (1829
mm) on center or approved anchors or anchor straps spaced as required to provide equivalent anchorage
to the 1/2-inch-diameter (12.7 mm) anchor bolts. Bolts shall be at least 1/2 inch (12.7 mm) in diameter and
shall extend a minimum of 7 inches (178 mm) into concrete or grouted cells of concrete masonry units. A
nut and washer shall be tightened on each anchor bolt. There shall be a minimum of two bolts per plate
section with one bolt located not more than 12 inches (305 mm) or less than seven bolt diameters from
each end of the plate section. Interior bearing wall sole plates on monolithic slab foundations with integral
footings that are not part of a braced wall panel shall be positively anchored with approved fasteners. Sill
plates and sole plates shall be protected against decay and termites where required by Sections R317 and
R318. Cold-formed steel framing systems shall be fastened to wood sill plates or anchored directly to the
foundation as required in Section R505.3.1 or R603.3.1.

Exceptions:

1. Foundation anchorage, spaced as required to provide equivalent anchorage to 1/2-inch-

diameter (13 mm) anchor bolts.

12. Walls 24 inches (610 mm) total length or shorter connecting offset braced wall panels shall be
anchored to the foundation with a minimum of one anchor bolt located in the center third of the
plate section and shall be attached to adjacent braced wall panels at corners as shown in item
8 of Table R602.3(1).

23. Connections of walls 12 inches (305 mm) total length or shorter connecting offset braced wall
panels to the foundation without anchor bolts shall be permitted. The wall shall be attached to
adjacent braced wall panels at corners as shown in item 8 of Table R602.3(1).

Reason:
The purpose of this amendment is to revise and clarify the language for anchorage of
light-frame wood and cold-formed steel stud walls to the foundations of the house. We
are concerned that the provisions as stated will be interpreted as requiring a continuous
footing and anchor bolts along the entire length of an interior, non-bearing wall used as
part of a braced wall line. Chapters 4 and 6 of the IRC do not explicitly require a
continuous foundation in these locations and they are not traditionally provided in low-
wind, low-seismic areas. If interpreted and enforced as such by plan reviewers and
inspectors in this area, disputes and project delays will result.

The ICC Ad-Hoc Committee on Wall Bracing revised this section during the 2007/2008
code cycle with the intent of insuring that sufficient anchorage is provided on braced wall
lines and panels inside a dwelling to transfer lateral loads to either monolithic (thickened)
slab foundations or continuous footings. While we agree that providing a continuous load
path is important, the new language is overly broad in its application. In addition to the
concern about non-bearing walls used as braced wall lines, we are also concerned the
language could be taken to require all light-frame walls to be provided with anchor bolts
to the foundation. Thus, a non-bearing interior partition that is not part of a braced wall
line but which just happens to sit atop a foundation wall or continuous foundation (e.g. at
a partial basement, crawlspace, or interior knee wall) would also be required to be
fastened to the wall or footing below with 1/2" diameter anchor bolts at 6 foot spacing.
The ability to use wedge anchors, expansion bolts, mudsill straps, or other equivalent
anchorage in lieu of anchor bolts needs to be strengthened. This permission should be
granted in the main text of the section similar to the IBC, not just as an exception.
Among other benefits, this will help prevent a possible issue with requiring anchor bolts
in the middle of a post-tensioned slab-on-grade used where expansive soils exist.

Further, there was no technical justification provided for the increased anchorage
requirements. It is noted that the bottom plate of a braced wall line on the interior of a
dwelling and supported on floor framing (including a raised floor system over a
crawlspace or pier-and-beam foundation) can be attached to the framing with 3-16d nails
at 16" spacing. In most dwellings, braced wall lines inside the dwelling will use Method
GB bracing, reflecting the fact gypsum board is the typical interior finish. The ultimate
capacity for Method GB when used on both sides of a braced wall is 400plf (or 200plf
allowable). Clearly, this can easily be achieved not only by the standard nailing on a
raised floor system, but also by short post-installed anchors or even power-actuated
fasteners. 1/2" diameter anchor bolts at 6 foot spacing are not necessary.

Finally, the pointer to the foundation anchorage requirements in Chapter 5 and 6 for
cold-formed steel framing is moved from the end of the paragraph on anchorage
requirements for wood framing to the beginning of Section 403.1.6 where it can serve as
charging language and an appropriate pointer. As part of the move the text regarding
wood sill plates is deleted as this option is covered by the Chapter 5 and 6 provisions.

Staff Contact: Gary Ehrlich – gehrlich@nahb.org 1-800-368-5242, ext. 8545

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Cripple Wall Bracing

2012 IRC Section Number: R602.10.11

Recommended Amendment:
Modify the section as shown below:
R602.10.11 Cripple wall bracing. Cripple walls shall be constructed in accordance with Section R602.9
and braced in accordance with this section. Cripple walls shall be braced with the length and method of
bracing used for the wall above in accordance with Tables R602.10.3(1) and R602.10.3(3), and the
applicable adjustment factors in Table R602.10.3(2) or R602.10.3(4), respectively, except that the length
of cripple wall bracing shall be multiplied by a factor of 1.15. The distance between adjacent edges of
braced wall panels shall be reduced from 20 feet (6096 mm) to 14 feet (4267 mm).

Reason:
The purpose of this amendment is to correct an error made in correlating the 2012 braced wall
provisions. The reduction in spacing between braced wall panels in a cripple wall originated from
cripple wall failures observed in seismic events such as the 1994 Northridge Earthquake.
Working through the ICC Ad-Hoc Committee on Wall Bracing, NAHB developed a proposal for
the 2009/2010 Code Development Cycle that reorganized the cripple wall bracing provisions and
removed the spacing reduction for low-seismic areas. The proposal was approved at the Public
Hearings and ratified by the consent agenda vote at the Final Action Hearings. Unfortunately, a
separate effort by the Ad-Hoc Committee to correlate their comprehensive reorganization of the
wall bracing section with a modification made by the IRC-Building/Energy Committee
inadvertently resulted in the spacing reduction being reinstated for low-seismic areas. This
amendment corrects that oversight and restores the original intent of the cripple wall proposal.

Staff Contact: Gary Ehrlich – gehrlich@nahb.org 1-800-368-5242, ext. 8545

 National Association of Home Builders
Recommended State & Local Amendments to the
2012 Edition of the International Residential Code (IRC)

Issue: Window and Door Flashing

2012 IRC Section Number: 703.8

Recommended Amendment:
Modify the section as shown below:
PAN FLASHING. Corrosion-resistant flashing at the base of an opening that is integrated into the building
exterior wall to direct water to the exterior and is pre-manufactured, fabricated, formed or applied at the job
site.

R703.8 Flashing. Flashing Approved corrosion-resistant flashing shall be provided in accordance with this
section applied shingle-fashion in a manner to prevent entry of water into the wall cavity or penetration of
water to the building structural framing components. Self-adhered membranes used as flashing shall
comply with AAMA 711. Flashing The flashing shall extend to the surface of the exterior wall finish or to
the water resistive-barrier for drainage and. Approved corrosion-resistant flashings shall be installed at all
of the following locations:

1. Exterior window and door openings. Flashing at exterior window and door openings shall extend to the
surface of the exterior wall finish or to the water-resistive barrier for subsequent drainage. Flashing at
exterior window and door openings shall be installed in accordance with one or more of the following:
1.1. The fenestration manufacturer’s installation and flashing instructions, or for applications not
addressed in the fenestration manufacturer’s instructions, in accordance with the flashing
manufacturer’s instructions. Where flashing instructions or details are not provided, pan flashing
shall be installed at the sill of exterior window and door openings. Pan flashing shall be sealed
or sloped in such a manner as to direct water to the surface of the exterior wall finish or to the
water-resistive barrier for subsequent drainage. Openings using pan flashing shall also
incorporate flashing or protection at the head and sides.
1.2. In accordance with the flashing design or method of a registered design professional.
1.3. In accordance with other approved methods.
2. At the intersection of chimneys or other masonry construction with frame or stucco walls, with
projecting lips on both sides under stucco copings.
3. Under and at the ends of masonry, wood or metal copings and sills.
4. Continuously above all projecting wood trim.
5. Where exterior porches, decks or stairs attach to a wall or floor assembly of wood-frame construction.
6. At wall and roof intersections.
7. At built-in gutters.

R703.8.1 Flashing Materials. Approved flashing materials shall be corrosion-resistant. Self-adhered

membranes used as flashing shall comply with AAMA 711. Pan flashing shall comply with Section
R703.8.2. Installation of flashing materials shall be in accordance with Section R703.8.3.

R703.8.2 Pan Flashing. Pan flashing installed at the sill of exterior window and door openings shall
comply with this section. Pan flashing shall be corrosion-resistant and shall be permitted to be pre-
manufactured, fabricated, formed or applied at the job site. Self-adhered membranes complying with
AAMA 711 shall be permitted to be used as pan flashing. Pan flashing shall be sealed or sloped in such a
manner as to direct water to the surface of the exterior wall finish or to the water-resistive barrier for
subsequent drainage.
R703.8.1 Flashing Installation. Installation of flashing materials shall be in accordance with one or more
of the following methods:

1. The fenestration manufacturer’s installation and flashing instructions.

2. The flashing manufacturer’s installation instructions.
3. Flashing details approved by the building official.
4. As detailed by a registered design professional.

Reason:
The purpose of this amendment is to revise and clarify the language regarding window and door
flashing.

Our members are concerned with the hierarchy that was established for window and door
flashing. As written, if a builder cannot obtain flashing instructions from the window or door
manufacturer or from a flashing manufacturer, they must either hire an architect or engineer to
design the flashing, or utilize pan flashing. We believe the window manufacturer is best
positioned to and should provide the flashing instructions and details and are concerned about
language that could transfer much of the liability for flashing to the builders. We also do not want
to involve a registered design professional in flashing design. Besides the cost of retaining an,
architect or engineer, many design professionals, once involved in one portion of design, will
insist on addressing other related items, if not designing the entire home. This could result in
considerable added expense and delays to the builder and homeowner. Thus, we propose to
replace the hierarchy with a new section that permits any combination of four sources to be used
to obtain flashing installation requirements.

In addition, a new section on flashing materials is created. This section is populated with material
requirements which currently appear in the charging language of R703.8. This allows R703.8 to
introduce flashing requirements and identify the locations before proceeding with material or
installation requirements. A subsection under the new flashing materials section is then provided
for pan flashing. The new subsection picks up the language from the pan flashing definition and
the installation details from item #1 in the list of locations. A second reference to AAMA 711 is
provided to underscore that peel-and-stick membranes formed and applied on the jobsite are an
accepted method for providing pan flashing.

Staff Contact: Gary Ehrlich – gehrlich@nahb.org 1-800-368-5242, ext. 8545