Codes and Standards: Dealing With Decision Makers

During the past ten years, in my role as Associate Executive Director of the EPDM Roofing Association (ERA), much of my professional focus has been on monitoring the development of building codes and standards that could impact the products of our members, and the people who use those products. This past decade has been marked by intense debate, focusing on issues such as how the design of buildings can save energy, protect the health of the people who work there, and resist the ravages of increasingly frequent intense and even cataclysmic weather events. It has been an important time for the roofing industry to be engaged.

Given the complexity of the multiple codes and standards that impact roofing, it’s important to know the difference between codes and standards. To clarify, building codes are a set of rules that are frequently adopted into law, and are designed to specify the minimum requirements to safeguard the health, safety and welfare of building occupants. Building standards are set by national organizations such as ASHRAE and determine the performance requirements of the materials used in building construction. While standards are frequently incorporated into codes, that is not always the case.

Each year, ERA has increased its commitment of time and resources to stay abreast of proposed changes in codes and standards. As part of this commitment, I have sat through, and participated in, countless hours of codes and standards meetings and hearings, as well as related meetings with individuals and groups who share ERA’s goals. When I started out, I felt that it was important for members of the roofing industry to stay involved in the code and standard-setting processes. A decade later, I am convinced that participation by the roofing industry is essential if codes and standards are to support the best possible service and products that we can give our customers.

A few insights, based on my experience:

1. Science speaks.

ERA members, because of their close relationship with contractors and consultants, want to make sure that the choice of building materials is left in the hands of the design professional, the consultant, the architect, the engineer, the contractor and, of course, ultimately the building owner or facility manager. When we have codes and standards that do not reflect science-based evidence and/or the best practices within the roofing industry, then those stakeholders may not be able to choose the best product for the job at hand. In some cases, proposed modifications to existing codes or standards are suggested by people from the industry. In those instances, our role is to provide research and evidence to support the proposed change. Either way, science-based testimony usually carries the day. Not always, but without good scientific evidence to support a specific position, the chances of winning are nil to none. It takes time and clear thought to influence the codes and standards process, but without a base of indisputable scientific evidence, it’s hard to get out of the starting gate.

2. Collaboration is essential.

We have always welcomed forging partnerships with like-minded roofing professionals. But there have also been times when we have acted as consulting partners with regulatory agencies. A recent example: when regulatory agencies across the Northeast and Mid-Atlantic states were charged with improving air quality, they chose to reduce the amount of allowable volatile organic compounds, or VOCs, in adhesive sealants. This was a very good idea, and the industry was certainly supportive of the intent, but the way in which many of those states intended to enact those VOC regulations would have crippled the roofing industry. Essentially, the agencies were taking a regulation that was written for the state of California and applying it universally across the New England and Mid-Atlantic States.

So, ERA conducted studies, showing how the climate of those Northeastern and Mid-Atlantic states was dissimilar from the climate of California. We also provided technical information on how product would react differently in those different climates, and then we asked for a delayed implementation period to allow the research and development divisions in our companies to develop new products. These new products are appropriate for use in the climates in question and still allow the regulatory agencies to achieve their goals, successfully reducing the amount of the VOCs. Our participation was essential to help the regulatory agencies draw up a realistic timeline that would take into account the needs of the roofing industry.

3. Monitor the decision makers.

It’s important to monitor the discussion surrounding any proposed changes in codes and standards. It’s equally as important to monitor who will be making the final decisions on these issues. Since there are various facets of the roofing industry, code-setting bodies would be wise to ask the local roofing experts for advice on whom to include in their decision-making process. I’ve seen instances where committees have incorporated someone who may technically be from the roofing industry, but that person’s breadth and depth of knowledge is not appropriate for the topic at hand.

I would say we have seen mismatch of decision makers when urban heat island and cool roof issues are being debated. An individual may know a fair amount about climate change, but that doesn’t mean the person necessarily understands the nuances of cool roofing. Additionally, they may not be aware of the breadth of research on that topic and instead rely on dated information from college or grad school without being appropriately briefed on new and emerging research.

4. Prepare for a variety of responses.

We have worked with some regulatory agencies during a collaborative process and they’ve been very grateful for our input. There have been other situations where it seems that the policymakers just want us to rubber stamp their very well-intentioned but ill-conceived draft codes. That’s not something that we are willing to give. These initiatives, these outreach campaigns, take a tremendous amount of time and effort and financial resources, and difficult as it may be, our members feel that they owe it to the industry and their customers to make sure that anything that we’re involved in is done the right way and rooted in science-based evidence. There are no shortcuts in these sometimes very difficult fights.

5. Everyone can contribute.

Every member of the roofing community can be active and engaged and make a contribution to ensuring that codes and standards reflect the true needs of the construction industry and our customers. It’s very valuable to build relationships with state legislators and attend town hall meetings. It is crucial to identify candidates that are pro-business and pro roofing, and support them financially as well as from an educational perspective by sharing information with them about the roofing industry.

This is also critically important: When you are asked to write a letter to a key decision maker, be sure to do it. Recently, as part of a campaign to preserve choice of building products for roofers, I visited a city councilmember’s office. On the wall was an enormous white board where every single constituent member’s concern was tracked, along with a reference to the response. This particular city council member had an 87 percent “close rate,” meaning that 87 percent of the concerns that they had received in a given period had been responded to. My experience has been that municipal and state legislators take constituent outreach very, very seriously. Every letter, every e-mail makes a difference.

6. Gather intelligence for your professional organization.

If there is one takeaway that I want people to get from this article, it is to keep us informed. It is darned near impossible to track everything that happens on a city, county, state and national basis because there is no software that currently tracks these issues before they are formally proposed and published for review. And that is often too late to educate the policy makers. It is critical for the readers of this article to attend their local trade association meetings and become acquainted with the policy makers and the legislators in their area. Equally as important, everyone can become a resource for legislators and policymakers when they have a question about roofing.

I’m looking forward to the next decade of victories for the roofing industry, allowing us to deliver superior roofing systems to a broad range of customers. But this will happen only if key decisions about the roof are made by roofing experts, and not mandated by politicians who are far removed from the design process.

About Ellen Thorp

As associate executive director of the Bethesda, Md.-based EPDM Roofing Association, Ellen Thorp does advocacy work for ERA related to codes, standards and state regulations.

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