The Importance of Good References
This month’s column focuses on a topic that’s becoming increasingly “hot” within the International Code Councilcommunity. No, it’s not the use of Life Cycle Assessment in the International Codes. And it doesn’t address Environmental Product Declarations either. It’s a topic that, on the surface, might appear to be rather mundane—perhaps even dry. But it is a topic that has the potential to impact each of you and the way you do business…in a big way.
That topic is referenced standards. And the reason it has the potential to impact your business is because the International Codes rely upon referenced standards to establish the criteria for every component of the built environment. The 2012 International Codes reference more than 1500 standards promoted by 118 Standards Developing Organizations. They rely upon referenced standards to determine everything from the design wind pressures your product must resist, to the requirementsyour glass must meet, to the number of ADA-compliant doors you must use in a commercial building.
One of the topics the ICC is currently wrestling with has to do with the update of these referenced standards. Prior to splitting up the I-codes into separate groups, the International Codes all were updated within the same year. Updates of any referenced standards also had to be completed that year. Under this system, it was relatively easy to keep the standards referenced in each new edition of the codes relatively up-to-date.
Now the International Codes have been split into three groups: Group A, Group B and Group C. While maintaining the three-year cycle of updating the International Codes, we now have a situation in which Group A codes are completed two years prior to Group C codes, and one year prior to Group B codes.
In order for the newest edition of the International Codes to reference the newest editions of the referenced standards, the ICC permits existing referenced standards to be “preapproved,” even if the revision process is still underway, for inclusion in the International Codes.
More than 900 referenced standards were preapproved for the 2015 I-codes, despite the fact that many were still under revision. Two standards were not approved, including ANSI A117 due to its unknown ramifications on existing buildings.
The parties objecting to the preapproval of ANSI A117-14 for reference in the 2015 International Building Code raised a validconcern. How could approval be given to a standard whose contents had not yet been finalized?
It also raised a bigger question with regards to the update of other referenced standards in the International Codes. Specifically, how is the ICC to maintain reference to the most current editions of existing referenced standards, given thestaggered process for completion currently in place? Should the updating of referenced standards occur during the first, second or third year of the code change cycle? If a standard is referenced in multiple codes, should its update be considered with the first code or the second one? For example, AAMA 711-07 was proposed for inclusion in the 2015 IBC in 2012, while its reference in the 2015 IRC was updated from the 2007 edition to the 2013 edition in 2013. If both proposals had been approved, should the reference to the 2007 edition be automatically updated in the 2015 IBC for consistency with the 2015 IRC? Obviously, it can be confusing to even keep track of the possibilities raised by the current process, much less figure out how to make it work.
Due to the concerns raised, the ICC held a Standards Development Organization Forum in February 2014. While it appeared that updating all of the standards in the third year of the cycle was a possible solution, it was also noted that of the 900+standards that were preapproved, only two were cited as being of possible concern. So perhaps this was not an issue that required further attention?
Referenced standards in the IgCC
Another topic concerning referenced standards has arisen within the proposed changes to the International Green Construction Code. The IgCC includes more referenced standards that do not comply with ICC Procedures for Referenced Standards than any other International Code. Part of the reason for this could be the relatively new nature of the topics addressed in the IgCC. Many of them have simply not been addressed yet by the more established Standards Development Organizations.
Some of the referenced standards, and some of the standards proposed for reference, are developed by government agencies—both U.S. and foreign. As a rule, these types of standards are not typically developed in an open and consensus process,as is required for standards referenced by ICC Council Policy #28.
An “open and consensus process” basically means that all parties that have an interest in a document have an opportunity to participate in its development. This does not necessarily mean they have a vote, but they do need to be able to participate in the discussions and present their own viewpoints on them. And they need to be able to be aware of who is voting on the document, how they voted and what information they considered when making their voting decision.
An even greater difficulty for the IgCC is the fact that some of the standards proposed for reference this cycle are not in English. ICC Council Policy #28 does not specifically require referenced standards to be written in English. To properly evaluate a document, the reader needs to be at least somewhat fluent in the language in which it’s written. While the ICC, by its very name, aspires to be used internationally, it seems unlikely that foreign standards that are not written in English will be approved for reference in codes that are primarily enforced by people for whom English is their primary language.
These issues raise some interesting questions with regards to which document will be used to determine the requirements for your products over the next few years.