Florida Product Approval System Validator Training February 1, 2010 Florida Building Commission...

Florida Product Approval Florida Product Approval SystemSystem

Validator TrainingValidator TrainingFebruary 1, 2010February 1, 2010

Florida Building Commission Florida Building Commission Florida Department of Community AffairsFlorida Department of Community Affairs

2555 Shumard Oak Blvd | Tallahassee, FL 32399-2100 | (850) 487-1824

www.floridabuilding.org

Florida Product Approval SystemFlorida Product Approval SystemDepartment of Community Affairs Product Approval Department of Community Affairs Product Approval

TeamTeam

Ted Berman and Associates, LLCTed Berman and Associates, LLC

THEODORE BERMAN, P.E.THEODORE BERMAN, P.E.Product Approval System AdministratorProduct Approval System Administrator

SIMON SEGAL, P.E.SIMON SEGAL, P.E.Senior Engineer, Senior Engineer, Product Approval Product Approval Application ReviewerApplication Reviewer

VERDA LA RUEVERDA LA RUEProduct Approval Product Approval SpecialistSpecialist

RANA RADMANESHRANA RADMANESHProduct Approval Product Approval Application ReviewerApplication Reviewer

Florida Building Code 2007Florida Building Code 2007

• The 2007 Florida Building Code is available online.

http://www2.iccsafe.org/states/florida_codes/

Objectives of TrainingObjectives of Training

•UPDATES OF VALIDATION REQUIREMENTS

•UPDATES ON CHANGES TO RULE 9B-72 FAC

•DISCUSSION OF VALIDATION CHECKLISTS

•MOST COMMON MISTAKES

Product Approval ApplicationProduct Approval Application

There are four ways to apply for a Florida Product Approval

• New Application• Full Revision of an existing

application • Editorial Change• Self-Affirmation of existing

application

Self–Affirmation FBC 2007Self–Affirmation FBC 2007

Application Using Self Affirmation

Self Affirmation indicating that the change in building code does not affect the performance of product.

Does not require validation

Self Affirmations cost $100.

Editorial Change FBC 2007Editorial Change FBC 2007

Editorial Change

Used for editorial corrections with no new performance evidence provided. Used to change quality assurance entity Requires validation (ensure that application is limited to the above restrictions).

Editorial Change cost $150.

Revised Applications FBC 2007Revised Applications FBC 2007

Revised Application:

• If the standards or restrictions pertaining to your product in the 2007 Code have changed, then a full revision application must be submitted.• New evidence such as a certification, test report or an evaluation report demonstrating compliance must also be submitted.•New products may be added to application.

•Full Revisions cost $500.

New Application FBC 2007New Application FBC 2007

New Application:

• Evidence such as a certification, test report or an evaluation report demonstrating compliance must be submitted..

•New Application cost $500.

Revision FBC 2007Revision FBC 2007

IMPORTANTIF THERE ARE MULTIPLE PRODUCTS WITHIN THE SAME APPLICATION (FL#), THEN EVIDENCE FOR ALL THE PRODUCTS MUST BE SUBMITTED. THE ENTIRE PRODUCT LINE MUST ALSO COMPLY WITH THE NEW STATE PRODUCT APPROVAL RULE AND ALL THE REQUIREMENTS THEREIN

New Application ProcessNew Application Process

Changes made to the new application Changes made to the new application process include:process include:

Applications must be validated by Applications must be validated by COMPLETION COMPLETION DEADLINEDEADLINE

No more recommendation for Conditional Approval No more recommendation for Conditional Approval or Deferral by the Administrator.or Deferral by the Administrator.

Applicants work at their own pace to complete Applicants work at their own pace to complete applications by the posted deadline date. applications by the posted deadline date.

Early submittals will have more correction time if Early submittals will have more correction time if needed.needed.

Only those applications that are complete by the Only those applications that are complete by the Completion Deadline are recommended to the Completion Deadline are recommended to the Product Oversight Committee (POC) and listed on Product Oversight Committee (POC) and listed on the meeting agendathe meeting agenda

New Application ProcessNew Application Process

Product Approval MethodsProduct Approval Methods

Four Methods for State ApprovalFour Methods for State Approval

Certification MethodCertification Method Evaluation Report from a Florida licensed Evaluation Report from a Florida licensed

Architect or a Florida Professional EngineerArchitect or a Florida Professional Engineer Test ReportTest Report Evaluation Report from an Evaluation EntityEvaluation Report from an Evaluation Entity

ValidationsValidations

9B-72.080 Product Validation9B-72.080 Product ValidationTwo Types of ValidationTwo Types of Validation

Administrative ValidationAdministrative Validation Technical ValidationTechnical Validation

NOTE:All applications, except self-affirmation, require validation. Applications requiring corrections have to be re-validated.

Administrative ValidationAdministrative ValidationOverviewOverview1a.

Certification: Certificate, Mark

Or Listing

1c.Evaluation report from evaluation

entity ie. ICC

1d.Evaluation

report from an architect or

engineer

EVALUATIONREPORT

3rd PARTY

ADMINVALIDATION

Administrative ValidationAdministrative Validation

Applicable to:Applicable to: A certification mark or listing from an A certification mark or listing from an

approved certification agency approved certification agency An evaluation report from a Florida An evaluation report from a Florida

Registered Architect or Licensed Engineer Registered Architect or Licensed Engineer independent from the manufacturerindependent from the manufacturer

An evaluation report from an approved An evaluation report from an approved evaluation entity.evaluation entity.

Administrative Validation Administrative Validation CriteriaCriteria

Criteria consists of:Criteria consists of: Verification of certification or evaluation report, Verification of certification or evaluation report,

product description, testing standards per Florida product description, testing standards per Florida Building Code and compliance documentation are Building Code and compliance documentation are compliant with the current code.compliant with the current code.

Verification of installation instructions, anchorage Verification of installation instructions, anchorage requirements and product performance are as per requirements and product performance are as per certification or evaluation report.certification or evaluation report.

Verification of any limits are within the scope of Verification of any limits are within the scope of certification or evaluation.certification or evaluation.

Verify that certification is not based on rational Verify that certification is not based on rational analysis. analysis.

Verify that if rational analysis was used for installation Verify that if rational analysis was used for installation instructions that an evaluation report is included. instructions that an evaluation report is included.

Certification ValidationCertification ValidationChecklistChecklist

Administrative ValidationAdministrative ValidationChecklistChecklist

Certification Validation Certification Validation Common Errors (1)Common Errors (1)

•Testing Standards on Certification Agency Certificate (CAC) are not the same as on face of application.•Testing standards are not as adopted and an equivalency of standards has not been provided.•Design Pressure on application exceeds design pressure on CAC or load test has not been certified.•Limits of use indicate impact resistance and testing standards for impact were not performed.•Certification cannot be based on rational analysis.•Description of product on application is not the same as on CAC.

Certification Validation Certification Validation Common Errors (2)Common Errors (2)

•Installation Instructions are not in accordance with Rule 9B-72.070(5)(e) or as on the CAC.•Certification Agency Certificate is expired.•Installation Instructions are based on rational analysis and an Evaluation Report was not provided.•Certification of plastic structural components was not provided or is expired (glass laminates, plastic extrusions).•Validation checklist is for the correct method and signed and sealed after validation on-line.

Evaluation Report by Florida PE/RA Evaluation Report by Florida PE/RA Administrative Validation ChecklistAdministrative Validation Checklist

Evaluation Report by Florida PE/RA Evaluation Report by Florida PE/RA Validation Common Errors (1)Validation Common Errors (1)

•Testing Standards on Evaluation Report (ER) are not the same as on face of application.•Testing standards are not as adopted and an equivalency of standards has not been provided.•Design Pressure on application exceeds design pressure on ER.•Limits of use indicate impact resistance and testing standards for impact were not performed.•Certificate of Independence was not provided or is not from the evaluation engineer/architect.•Description of product on application is not the same as on ER.

Evaluation Report by Florida PE/RA Evaluation Report by Florida PE/RA Validation Common Errors (2)Validation Common Errors (2)

•Installation Instructions are not in accordance with Rule 9B-72.070(4)(e) or as described on ER.•Testing was not conducted at an accredited, by an approved accreditation agency, testing laboratory.•Testing was not performed on the product as described on ER and the data cannot be verified.•Certification of plastic structural components was not provided or is expired (glass laminates, plastic extrusions).•Validation checklist is for the correct method and signed and sealed after validation on-line.•Verify that rational analysis was not performed in-lieu of testing standards required by the building code.

Evaluation Report by Evaluation Evaluation Report by Evaluation Entity Administrative Validation Entity Administrative Validation

ChecklistChecklist

Evaluation Report by Evaluation Entity Evaluation Report by Evaluation Entity Validation Common Errors (1)Validation Common Errors (1)

•Testing Standards on Evaluation Report (ER) are not the same as on face of application.•Testing standards are not as adopted and an equivalency of standards has not been provided.•Design Pressure on application exceeds design pressure on ER.•Limits of use indicate impact resistance and testing standards for impact were not performed.•Certificate of Independence was not provided or is not from the evaluation entity.

Evaluation Report by Evaluation Entity Evaluation Report by Evaluation Entity Validation Common Errors (2)Validation Common Errors (2)

•Description of product on application is not the same as on ER.•Installation Instructions are not in accordance with Rule 9B-72.070(4)(e) or as described on ER.•Evaluation Report is not based on the model code for the Florida Building Code.•Validation checklist is for the correct method and signed and sealed after validation on-line.•Evaluation Report based on alternate materials. (Not allowed for statewide product approval).

Technical ValidationTechnical ValidationOverviewOverview

1d.Evaluation

report from an architect or

engineer

EVALUATIONREPORT

IN HOUSE

TECHNICALVALIDATION

1b.Test

report

Technical ValidationTechnical Validation

Applicable to:Applicable to: A test report from an approved testing A test report from an approved testing

laboratorylaboratory An evaluation report from an approved An evaluation report from an approved

evaluation entity that is not an evaluation entity that is not an independent third party from the independent third party from the manufacturermanufacturer

Installation instructions designed by in-Installation instructions designed by in-house to the manufacturer, non house to the manufacturer, non independent third-party professional.independent third-party professional.

Technical Validation Technical Validation CriteriaCriteria

In addition to criteria for In addition to criteria for Administrative Validation, Technical Administrative Validation, Technical validation includes:validation includes: Determination that the evaluator has Determination that the evaluator has

complied with acceptable standards of complied with acceptable standards of engineering principles.engineering principles.

Engineering verification that the Engineering verification that the evaluation complies with the Code.evaluation complies with the Code.

Copy of the application complying with Copy of the application complying with all aspects of rule 61G15-36 F.A.C. must all aspects of rule 61G15-36 F.A.C. must be filed with the Commission.be filed with the Commission.

For the technical validation when using the Certification, EvaluationReport by Florida PE/RA and Evaluation Report by Evaluation Entity methods,the validator needs to complete the corresponding Administrative Validation checklist plus the following Technical Validation checklist.

Technical ValidationTechnical ValidationChecklistChecklist

For the technical validation when using the Test Report method,the validator needs to complete the following Validation checklist.

Technical ValidationTechnical ValidationTest Report Method ChecklistTest Report Method Checklist

Test Report Method ValidationTest Report Method Validation Common Errors (1) Common Errors (1)

•Testing Standards on test report are not the same as on face of application.•Testing standards are not as adopted and an equivalency of standards has not been provided.•Design pressure on application exceeds design pressure on test report.•Limits of use indicate impact resistance and testing standards for impact were not performed.•Certificate of Independence was not provided or is not from the testing laboratory.•Description of product on application is not the same as on test report.

Test Report Method ValidationTest Report Method Validation Common Errors (2) Common Errors (2)

•Installation Instructions are not in accordance with Rule 9B-72.070(4)(e) or as on the test report.•Testing was not conducted at an approved testing laboratory or the laboratory was not accredited for the test performed.•Testing was not performed on the product as described on the application.•Certification of plastic structural components was not provided or is expired (glass laminates, plastic extrusions).•Validation checklist is for the correct method and signed and sealed after validation on-line.•Verify that rational analysis was not performed and the product performance is as tested.

Installation InstructionsInstallation Instructions

Installation instructions also Installation instructions also require verification:require verification:

If prepared by company engineers then If prepared by company engineers then technical validation is requiredtechnical validation is required

If prepared by independent engineers If prepared by independent engineers then administration validation is required, then administration validation is required, unless using the Test Report Method unless using the Test Report Method (which always requires a technical (which always requires a technical validation)validation)

Installation InstructionsInstallation Instructions

Installation instructions criteria:Installation instructions criteria: Determination that the evaluator has complied with Determination that the evaluator has complied with acceptable standards of engineering principles.acceptable standards of engineering principles. Engineering verification that the evaluation complies Engineering verification that the evaluation complies with the Code.with the Code. Copy of the application complying with all aspects of Copy of the application complying with all aspects of rule 61G15-36 F.A.C. must be filed with the Commission.rule 61G15-36 F.A.C. must be filed with the Commission.

Exception:Exception: Technical Validation is not required if the installation Technical Validation is not required if the installation

instructions including attachments are verified by instructions including attachments are verified by the product certification agency or the product the product certification agency or the product evaluation agency.evaluation agency.

WindowsWindows

Installation instructions requirements for Installation instructions requirements for windows must contain the following:windows must contain the following:

Type, and grade of anchor, and/or Type, and grade of anchor, and/or manufacturer’s anchor specifications, including manufacturer’s anchor specifications, including minimal nominal size, minimum penetration minimal nominal size, minimum penetration into substrate and minimum edge distances.into substrate and minimum edge distances.

Type, physical dimensions, material and grade Type, physical dimensions, material and grade of any accessory item or strap, if applicable.of any accessory item or strap, if applicable.

Spacing of anchors, shims, accessory items and Spacing of anchors, shims, accessory items and straps. straps.

Illustrated diagrams of the attachment of the Illustrated diagrams of the attachment of the product structure. product structure.

RULE 9B – 72 OptionalRULE 9B – 72 OptionalState Approval with updatesState Approval with updates

INSTALLATION INSTRUCTIONS

3rd PARTY

IN HOUSE

TECHNICALVALIDATION

ADMINVALIDATION

REVIEW BY CERT AGENCY

Validation EntitiesValidation Entities

All approved Validation Entities All approved Validation Entities must retain documentation of the must retain documentation of the product applicationproduct application

Approved Certification and Approved Certification and Evaluation agencies can validate Evaluation agencies can validate their own certifications/evaluationstheir own certifications/evaluations

Testing Labs are not allowed to Testing Labs are not allowed to conduct validationsconduct validations

Validation EntitiesValidation Entities

9B-72.080 (4) Violations and 9B-72.080 (4) Violations and Penalties for Validation Entities.Penalties for Validation Entities.

Disciplinary penalties may be Disciplinary penalties may be imposed upon an approved Validation imposed upon an approved Validation entity for Rule 9B-72 violations.entity for Rule 9B-72 violations.

Disciplinary penalties could be fines Disciplinary penalties could be fines up to $10,000 per occurrence, up to $10,000 per occurrence, suspensions and revocations suspensions and revocations

Quality Assurance ExpirationQuality Assurance Expiration

For all methods of compliance, a field is For all methods of compliance, a field is added to collect the Expiration Date of added to collect the Expiration Date of the Quality Assurance Entity contract for the Quality Assurance Entity contract for each product on the applicationeach product on the application

An email is sent to the Manufacturer with An email is sent to the Manufacturer with a copy to DCA when the Expiration Date a copy to DCA when the Expiration Date has elapsed.has elapsed.

Search criteria on the Product Search Search criteria on the Product Search webpage allows searching for expired webpage allows searching for expired Quality Assurance Entity contracts.Quality Assurance Entity contracts.

Recent POC IssuesRecent POC Issues

Applications with Alternate Materials are not Applications with Alternate Materials are not allowed for statewide product approval.allowed for statewide product approval.

Alternate materials is a claim that a product Alternate materials is a claim that a product compliance is compliance is equivalentequivalent to the provisions of the to the provisions of the code, but is not evaluated as required by the code, but is not evaluated as required by the code.code.

Example: Evaluation report with this language: Example: Evaluation report with this language: “The system is an alternative exterior wall “The system is an alternative exterior wall covering to those specified in Chapter 25”. covering to those specified in Chapter 25”.


Roof Insulation ApplicationsRoof Insulation Applications (1) The approval is limited to roof insulation(1) The approval is limited to roof insulation (2) Fire classification and thermo (2) Fire classification and thermo

performance of the insulation is not part of performance of the insulation is not part of the approvalthe approval

(3) Not a structural component – may be (3) Not a structural component – may be considered part of the load pathconsidered part of the load path

(4) Scope of approval is limited to an (4) Scope of approval is limited to an approved roof covering which list specific approved roof covering which list specific insulation as a component part of an insulation as a component part of an approved roof assemblyapproved roof assembly


Testing/Certification of Plastic Testing/Certification of Plastic ComponentsComponents

Plastics used as structural components of Plastics used as structural components of an assembly [i.e. vinyl (PVC), fiberglass an assembly [i.e. vinyl (PVC), fiberglass and laminates (for impact glazing)] are and laminates (for impact glazing)] are required to be tested and or certified as required to be tested and or certified as required on Chapter 26 and be under a required on Chapter 26 and be under a quality assurance audit contract. quality assurance audit contract.

Recent RULE 9B – 72 ChangesRecent RULE 9B – 72 Changes

9B – 72.0109B – 72.010(31)(31)(f)For shutters:(f)For shutters:

Shutters subcategory has been expanded to add fabric Shutters subcategory has been expanded to add fabric storm panel.storm panel.

9B – 72.0709B – 72.070(1)(g)Demonstration of Compliance:(1)(g)Demonstration of Compliance:

Products required to demonstrate compliance using referenced testing standard(s) Products required to demonstrate compliance using referenced testing standard(s) and also requiring rational analysis that falls outside the scope of the agency and also requiring rational analysis that falls outside the scope of the agency certificate designating product certification, must demonstrate compliance using an certificate designating product certification, must demonstrate compliance using an evaluation report from an approved evaluation entity.evaluation report from an approved evaluation entity.

Recent Rule 9B-72 ChangesRecent Rule 9B-72 Changes

1. Upload certification to new code on Self-Affirmation Self-Affirmations now allow an uploaded letter of certification of compliance to the new code, as documentation supporting a product approval to a preceding edition of the Code specifically refers to that earlier edition. The rule is amended to ensure accuracy of the affirmation and to address the potential for violation of law pertaining to licensure of those performing engineering services in the State.


9B-72.090 Product Approval by the Commission.(1)(a) through (d) No change.(e) When a new edition of the Code does not require a material or substantive change for an approved product, the manufacturer of the approved product shall affirm that his or her approved product meets the new edition of the Code. As part of application for self-affirmation, if the evaluation report refers to the previous edition of the Code, the manufacturer of the approved product shall submit a statement from the original evaluation entity necessary to certify that the product complies with the subsequent code version via an attachment uploaded and submitted through the BCIS. Self-affirmation is subject to review and verification by the Program Administrator.


2. Equivalence of Standards 9B-72.180 Equivalence of Standards.

(1) Equivalence of product standards. Where conformance to the Code is based on standards, then product evaluation shall rely on national and international consensus standards referenced in the Code. …………

* * * *


(3) Standards which meet or exceed standards referenced by 2007 edition of the Code and recognized as equivalent for determining Code Compliance are:

(a) ANSI/DASMA108-02 Standard Method for Testing Sectional Garage Doors and Rolling Doors: Determination of Structural Performance under Uniform Static Air Pressure Difference equivalent to ANSI/DASMA 108-05; (b) TPI 1-02 National Design Standards for Metal-Plate-Connected Wood Truss Construction equivalent to TPI 1-07; and(c) ASTM E 1300-02 Practice for Determining Load Resistance of Glass in Buildings equivalent to ASTM E 1300-04.


(4) Equivalence of product standards for specific product application. Standards which meet or exceed standards referenced by the Code and certified as equivalent for determining code compliance by one of the following entities shall be considered as equivalent by the Commission:

(a) An approved certification agency;(b) An approved test lab;(c) An approved evaluation entity;(d) Florida licensed professional engineer or architect; or(e) A nationally recognized standard writing organization.


3. State Increase of Fees for Product Approval 9B-72.090 Product Approval by the Commission.(1) Approval of a product or system of construction for state acceptance shall be performed by the Commission through the following steps:(a) A product manufacturer or owner of a proprietary system or method of construction, or its designee (applicant) shall apply to the Commission for approval by filing an application in accordance with subsection 9B-72.130(2), F.A.C., validated in accordance with Rule 9B-72.080, F.A.C., and submitting fees pursuant to subsection 9B-72.090(2), F.A.C. Application shall be made through the Building Codes Information System on the Internet, www.floridabuilding.org, and payment shall be by credit card or electronic check.(b) through (g) No change.(2) Fees for state approval of products.(a) Fee for approval, Five Hundred Dollars ($500.00) per subcategory of product. The Commission shall review annually and adjust fees accordingly.


(b) Fee for reinstatement after suspension, Fifty Dollars ($50.00) per product, plus billable staff hours at Fifty Dollars ($50.00) per hour, plus consultant fees.(c) Fees for approval of evaluation entities, certification agencies, testing laboratories and validation entities; for first time approval, Six Hundred Dollars ($600.00), annual renewal fee, Two Hundred Fifty Dollars ($250.00), revision fee, Two Hundred Dollars ($200.00).(d) Fee for revision of an existing approval, Five Hundred Dollars ($500.00) for a revision that results in a material change to the performance of a product or product design specification or both, and which may include addition of products within the same subcategory.(e) Fee for editorial revisions of an existing product approval that does not result in material change to the performance of a product or product design specification or both, One Hundred Fifty Dollars ($150.00).(f) Fee for affirmation of an existing product approval for compliance with a new edition of the standards adopted by the Code, One Hundred Dollars ($100.00).(3) Applications, affirmations and revisions shall be made through the Building Codes Information System on the Internet, www.floridabuilding.org, and payment shall be by credit card or electronic check.

Role of ValidatorRole of Validator

•Validation means determination of compliance pursuant to Rule 9B-72.080, F.A.C., for state approval.

•The validator certifies to the Commission the product’s compliance with the standards specified in the Code or intent of the Code for use in state approval.

•All product approval applications, except self-affirmation, require that the validator reviews the documentation and executes the proper validation checklist that includes the determination of compliance.

Florida Product Approval System Validator Training February 1, 2010 Florida Building Commission...

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