You Can Influence Codes and Standards

As associate executive director of the Washington, D.C.-based EPDM Roofing Association (ERA), I focus a great deal of my time and energy on the codes and standards that regulate or guide the roofing business. In the current environment, driven by constant upgrades in technology, as well as the need to save energy, these codes—and the standards that often inform them—seem to be undergoing steady revision. Believe it or not—and the word “geek” does come to mind—I find participating in this process extremely interesting. In fact, following and sometimes influencing emerging codes and standards is among the most important responsibilities of my job.

I’ll be the first to admit that a detailed review of a standards manual is probably not anyone’s idea of exciting reading. But given the importance of codes and standards to the construction industry, we ignore them at our own risk.

For a start, what’s the difference between a code and a standard? Ask enough people in the roofing industry and you will get a variety of answers. But generally, codes are the “top-tier” documents, providing a set of rules that specify the minimum acceptable level of safety for manufactured, fabricated or constructed objects. They frequently have been enacted into local laws or ordinances and noncompliance can result in legal action. Standards, on the other hand, establish engineering or technical requirements for products, practices, methods or operations. They literally provide the nuts and bolts of meeting code requirements. If codes tell you what you have to do, standards tell you how to do it. Frequently, standards—especially “voluntary consensus standards”—are the precursors for what becomes law years down the road.

ERA has represented the manufacturers of EPDM roofing for more than a decade. Through the years, we have learned the importance of interfacing with standard-setting and regulatory bodies. One of our first, and most important, learning experiences was working with the Northeast and mid-Atlantic states when they issued regulations designed to achieve federally mandated air-quality standards. (See the article in Roofing’s September/October 2014 issue, page 58.) The initial regulations, which lowered the amount of VOCs in many roofing products, were based on those used in southern California and incorporated provisions that were effective in the climactic and market conditions of that state. But states in the affected areas, from Virginia to Maine, confronted a situation where the new regulations threatened to bring the roofing industry to a sudden halt. In some instances, no adhesives and sealants were available to meet the new standards. And the new products, when they became available, would need to be effective in very cold climates totally unlike those on the West Coast.

ERA worked with officials throughout the impacted areas, helping to create “phase-in” schedules that would give industry enough time to develop products to meet the new standards. In state after state, the local regulators welcomed our input. Our point-of-view was based on a deep understanding of the business needs of our industry. Just as important, we understood the science behind the proposed regulations and could work with the regulatory bodies to ensure the air-quality needs and the needs of the roofing industry were met.

This experience has informed our ongoing approach to code-setting and regulatory bodies. Since our work with the states setting VOC standards, we have invested staff time and resources to stay current with and even ahead of proposals that would impact our members and their customers. We have testified before the South Coast Air Quality Management District in California on its proposal to limit VOCs. ERA has organized an ad-hoc coalition to successfully oppose an unnecessarily stringent proposal to require reflective roofs in the Denver area. And our organization is currently providing input to Atlanta-based ASHRAE’s efforts to clarify its regulation regarding air leakage. This issue—of great importance to the roofing industry—relates to other work being done in ASHRAE working groups and subcommittees on thermal bridging, as well as the definition of walls and wall assemblies. ASHRAE has convened an “Air Leakage Work Group” whose charge is to review the pertinent sections of Standard 90.1 and make recommendations for revising it. ERA staff will be present at this group’s meetings and will once again provide input based on the expertise of our members.

When I work with code-setting and regulatory groups, I am reminded of that very familiar saying, “It’s not whether you win or lose, it’s how you play the game.” Based on our work at ERA, I’d like to revise that. Your skill at “playing the game” will definitely influence whether you win or lose. Our experience tells us that staying involved with regulatory groups and providing them with input based on firm science and field experience leads to a winning outcome for the roofing business.

ASHRAE and IES Release Guidance on New Compliance Path for Standard 90.1

A newly published document from ASHRAE and IES gives users of their energy-efficiency standard immediate access to an optional third path for compliance, providing more flexibility for the industry.

Standard 90.1-2013 Appendix G: Performance Rating Method is an excerpt from ANSI/ASHRAE/IES Standard 90.1 (I-P), Energy Standard for Buildings Except Low-Rise Residential Buildings. The document gives users immediate access to selected addenda slated to be published in the 2016 version of the standard. The majority of the document is comprised of addendum bm, which allows Appendix G to be used as a compliance path within the standard.

“This document is being provided at the request of users,” says Drake Erbe, chair of the Standard 90.1 committee. “This is the first time ASHRAE and IES have made available an interim clean publication of a portion of Standard 90.1, and we are doing so now because users have expressed a critical need for this guidance. Several entities have expressed interest in developing programs based on the revised appendix. This release also gives advanced notice to software developers that may be interested in automating the process of creating the Appendix G baseline.”

Erbe notes that the guidance in addendum bm had two significant impacts on Appendix G.

“Previously Appendix G was used only to rate ‘beyond code’ performance of buildings but could not be used to demonstrate compliance with the base 90.1 standard,” he says. “Now the standard provides that compliance path and gives credit for integrated design resulting in energy savings, such as efficient use of building mass, optimized building orientation, efficient HVAC&R system selection and right sizing of HVAC&R equipment.”

Using this new version of Appendix G to show compliance with the 2016 version of the standard, the proposed building design needs to have a Performance Cost Index (PCI) less than that shown in Table based on building type and climate zone.

The second change is that the baseline design is now fixed at a certain level of performance, the stringency of which is expected not to change with subsequent versions of the standard. By this, a building of any era can be rated using the same method with the same baseline of compliance. The intent is that any building energy code or beyond-code program can use this methodology and simply set the appropriate target for their needs analogous to those in the table. Therefore, a beyond-code program may wish to set a target less than is shown in the table (a target of 0 is a net zero building), while compliance with a previous version of the standard may wish to set a target above what is shown. Because unregulated loads are not included in the compliance target in Table, beyond-code programs that encourage improvement in unregulated loads may wish to modify the target to include those loads.

Other addenda included in the excerpt are:

  • Addendum k directs the modeler to use the default assemblies in Appendix A for baseline opaque envelope assemblies.
  • Addendum r establishes the hierarchy of the decision-making process for selecting baseline HVAC systems.
  • Addendum z provides detail on the simulation of base-line building heat pumps, including how auxiliary heat is used in conjunction with heat-pump heating.
  • Addendum aa provides direction regarding when it is appropriate to model a heating-only system in Appendix G.
  • Addendum ad clarifies when baseline HVAC systems should be modeled with preheat coils.
  • Addendum dx makes changes to the baseline lighting power allowances in Appendix G.

Erbe noted that while it is likely that the version of Appendix G published in the 2016 edition of the standard will include additional changes to Appendix G, it is not likely that they will be as extensive as those included in addendum bm. The primary focus is to make the new methodology with a fixed baseline available so users become familiar with it.