Spring has sprung and BC is now neck deep into the new 2012 BC Building Code, and with it NAFS 08, the fenestration standard for new construction residential buildings. On Dec.20 2013 the code took effect for all BC except the city of Vancouver. If product was installed prior to Dec. 20 2013 it fell under the old code, installed on or after Dec. 20 it falls under the new code. With the odd project still falling under the old code it will not take long until all projects are governed by the new code.
So now that the majority of projects are under the new code, this puts most all fenestration products under NAFS and the Canadian Supplement. Here is where the fun begins. The Fenestration Association of BC and Fenestration Canada have been talking about this for 5 to 10 years. Fortunately that was plenty of warning and everyone was able to prepare and learn the rules to play by, horse hockey! It is true, many of us have been shouting from the rooftops for years in the hopes that we would see a building code with this much impact arrive with a good general understanding by all parties. Many manufacturers have embraced this change to raise the bar for product performance, assuming we might see competition based on product quality and performance, not by price driven down by low quality and poor performance. Unfortunately there are still manufacturers putting out unrated products, living by the “I will comply when I see the whites of their eyes” mantra. Building departments are grappling with what it all means, what they need to look for, what their jurisdiction requires for performance, what open and rough terrain looks like, who provides the project performance grades, what to look for on labeling, what the label requirements are for temporary and permanent markings, and many other questions. Many jurisdictions are still not prepared for this change; giving the lack of resources to effectively manage the change as the reason. If NAFS is coming to your province soon, get your building departments engaged well before the change, it will make the transition much easier.
So a few months in and still we see many unrated products going in to projects, not code compliant and sometimes unfair competition to rated products. I know, I have had some people tell me there is nothing wrong with many of these untested products and all competition is good, cow cookies! If a product has never gone through any testing, you can only assume that the product performs as it should, only testing can prove this. I have seen many of my own product’s weak points exposed to know testing improves products. I am a strong supporter of competition, I agree it is good for industry to have healthy competition, but it must be fair competition. We can only rely on the rules given to us in the form of our building code to bring some level of fair competition to the market. I get it; the rules are tough, really tough. Manufacturing products to meet the rigorous testing under NAFS is challenging, and in many cases it could be argued that the testing goes too far. For example putting a residential swing door under structural loads that cause the slabs to bow up to 3” to qualify in an area where the chances of the need to survive this are extremely remote if not impossible may seem unreasonable. As my door plant manager said, “If my door is bowing 3”, I’m not hanging around to see if it fails”. But if this is the requirement, then it is only reasonable that if one manufacturer must and can meet this performance, then all their competition should also.
This is where the system can really stumble. In BC we have a provincial code based on the National Building Code. The rules of our code are the minimum requirements to what a house must be built. This makes sense. But recently I was given this little gem by a government employee, “building officials in BC are authorized but not obligated to enforce the code”, what???? If not them, then who? What this means is that each jurisdiction is free to determine how and what they will enforce. In fact the recent implementation of the BCBC is widely varied through each jurisdiction in BC. For example remember the province wide (excluding Vancouver) NAFS implementation date of Dec 20/13 for installed products? Well there are jurisdictions that made that date January 1/14 permit date for implementation of NAFS, imagine how confusing that is if you supply product into multiple jurisdictions where NAFS is in force here, but not there for many more months. Further to this there are some jurisdictions that have “decided to not enforce the door requirements for now” until they have a better handle on it. Oh, and don’t forget Vancouver, it has its own building bylaw. This was to take effect March 1/14, but has been delayed until July 1/14. So if you supply product into Burnaby for example, and must meet NAFS, it is likely the project across the street in Vancouver will not require the same NAFS rated product until well into fall of 2014. And further to this, once the VBBL takes effect the Vancouver product will require a thermal performance U value of 1.4. While the Burnaby product across the street will require a 2.0 U value (rumour of 1.8 coming), as Vancouver will have its own very aggressive thermal performance requirements. Having fun yet?
So here we are neck deep and paddling like mad. 2014 will be challenging as industry tries to understand the requirements and what each jurisdiction will do with respect to enforcement. As it stands today, here in BC for a manufacturer it is a crap shoot on what they can expect for definitive requirements by project and by jurisdiction. Some say it should be simple, just bid based on meeting the requirements, this works great if everyone else is doing the same. But if the local jurisdiction is letting anything go, you are likely bidding against unrated products, that will put you at a disadvantage. So, while this transition plays out, the Fenestration Association of BC and Fenestration Canada are working together to help clear up the confusion via many training seminars and webinars, as well as drafting bulletin style documents clarifying some of the specific points under NAFS. And it is clear these efforts are working as there is change here; we are seeing more rated products, more inspector attention, more discussion, more questions, more training, and more understanding every day. If you are still waiting for the whites of their eyes, you won’t have to wait much longer, times are changing. Oh, and to answer the if not them, then who question, you may want to point out to your client that here in BC, by code, it is their responsibility to insure their project meets all the minimum requirements of code, regardless of whether an inspector checks or not. Including making sure all their fenestration products are NAFS rated.