Validation Entities - Florida Building Code

Report
Florida Product Approval System
Validator Training
December 11, 2012
Florida Building Commission
Florida Department of Business and Professional Regulations
1940 North Monroe Street | Tallahassee, FL 32399 | (850) 487-1824
www.floridabuilding.org
Florida Product Approval System
DEPARTMENT OF BUSINESS & PROFESSIONAL REGULATIONS
MO MADANI
Senior Technical Manager
JOE BIGELOW
Codes & Standards
Ted Berman and Associates, LLC
THEODORE BERMAN, P.E.
Product Approval System Administrator
SIMON SEGAL, P.E.
Senior Engineer,
Product Approval
Application Reviewer
RANA RADMANESH, E.I.
Product Approval Specialist
Objectives of Training
• UPDATES OF VALIDATION REQUIREMENTS
• DISCUSSION OF VALIDATION CHECKLISTS
• MOST COMMON MISTAKES
Product 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 2010
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 2010
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 2010
Revised Application:
• If the standards or restrictions pertaining to your
product in the 2010 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 2010
New Application:
• Evidence such as a certification, test report or an
evaluation report demonstrating compliance must be
submitted.
• New Application cost $500.
Revision FBC 2010
IMPORTANT
IF 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 Process
Changes made to the new application
process include:




Applications must be validated by COMPLETION DEADLINE
Applicants work at their own pace to complete applications
by the posted deadline date.
Early submittals will have more correction time if needed.
Only those applications that are complete by the
Completion Deadline are recommended to the Product
Oversight Committee (POC) and listed on the meeting
agenda
New Application Process
Product Approval Methods
Four Methods for State Approval




Certification Mark or Listing
Test Report
Evaluation Report from an Evaluation Entity
Evaluation Report from a Florida licensed
Architect or a Florida Professional Engineer
Validations
Rule 61G20-3.006 Product Validation
Two Types of Validation


Administrative Validation
Technical Validation
NOTE:
All applications, except Self-Affirmation,
require validation. Applications requiring
corrections have to be Re-Validated.
Administrative Validation
Overview
1a.
Certification:
Certificate, Mark
Or Listing
1d.
Evaluation
report from an
architect or
engineer
EVALUATION
REPORT
3rd
PARTY
ADMIN
VALIDATION
1c.
Evaluation
report from
evaluation
entity ie. ICC
Administrative Validation
Applicable to:

A certification mark or listing from an approved
certification agency

An evaluation report from a Florida Registered
Architect or Licensed Engineer independent from
the manufacturer

An evaluation report from an approved
evaluation entity.
Administrative Validation
Criteria

Criteria consists of:
 Verification of certification or evaluation report, product
description, testing standards per Florida Building Code and
compliance documentation are compliant with the current
code.
 Verification of installation instructions, anchorage
requirements and product performance are as per certification
or evaluation report.
 Verification of any limits are within the scope of certification
or evaluation.
 Verify that certification is not based on rational analysis.
 Verify that if rational analysis was used for installation
instructions that an evaluation report is included.
Certification Validation
Checklist
Administrative Validation
Checklist
Certification Validation
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
Common Errors (2)
• Installation Instructions are not in accordance with Rule
61G20-3.005(4)(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
Administrative Validation Checklist
Evaluation Report by Florida PE/RA
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
Validation Common Errors (2)
• Installation Instructions are not in accordance with Rule
61G20-3.005(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 Entity
Administrative Validation Checklist
Evaluation Report by Evaluation Entity
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.
Evaluation Report by Evaluation Entity
Validation Common Errors (2)
• Description of product on application is not the same as
on ER.
• Installation Instructions are not in accordance with Rule
61G20-3.005(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 Validation
Overview
1b.
Test
report
1d.
Evaluation
report from an
architect or
engineer
EVALUATION
REPORT
IN HOUSE
TECHNICAL
VALIDATION
Technical Validation
Applicable to:

A test report from an approved testing laboratory

An evaluation report from an approved
evaluation entity that is not an independent third
party from the manufacturer

Installation instructions designed by in-house to
the manufacturer, non independent third-party
professional.
Technical Validation
Criteria
In addition to criteria for Administrative
Validation, Technical validation includes:
•
•
•
Determination that the evaluator has
complied with acceptable standards of
engineering principles.
Engineering verification that the evaluation
complies with the Code.
Copy of the application complying with all
aspects of rule 61G15-36 F.A.C. must be
filed with the Commission.
Technical Validation
Checklist
For the technical validation when using the Certification, Evaluation
Report 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 Validation
Test Report Method Checklist
For the technical validation when using the Test Report method,
the validator needs to complete the following Validation checklist.
Test Report Method Validation
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 Validation
Common Errors (2)
• Installation Instructions are not in accordance with Rule
61G20-3.005(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 Instructions
Installation instructions also require
verification:

If prepared by company engineers then
technical validation is required

If prepared by independent engineers then
administration validation is required, unless
using the Test Report Method (which always
requires a technical validation)
Installation Instructions
Installation instructions criteria:
 Determination that the evaluator has complied with
acceptable standards of engineering principles.
 Engineering verification that the evaluation complies with
the Code.
 Copy of the application complying with all aspects of rule
61G15-36 F.A.C. must be filed with the Commission.
Exception:
Technical Validation is not required if the installation
instructions including attachments are verified by the
product certification agency or the product evaluation
agency.
Windows
Installation instructions requirements for
windows must contain the following:




Type, and grade of anchor, and/or manufacturer’s
anchor specifications, including minimal nominal size,
minimum penetration into substrate and minimum
edge distances.
Type, physical dimensions, material and grade of any
accessory item or strap, if applicable.
Spacing of anchors, shims, accessory items and straps.
Illustrated diagrams of the attachment of the product
structure.
RULE 61G20-3
Optional State Approval with updates
INSTALLATION
INSTRUCTIONS
IN HOUSE
3rd
PARTY
REVIEW
BY CERT
AGENCY
TECHNICAL
VALIDATION
ADMIN
VALIDATION
Validation Entities



All approved Validation Entities must
retain documentation of the product
application
Approved Certification and Evaluation
agencies can validate their own
certifications/evaluations
Testing Labs are not allowed to conduct
validations
Validation Entities



61G20-3.006(4) Violations and Penalties
for Validation Entities.
Disciplinary penalties may be imposed
upon an approved Validation entity for
Rule 61G20-3 violations.
Disciplinary penalties could be fines up
to $10,000 per occurrence, suspensions
and revocations
Recent POC Issues
61G20-3.005 (2) Product Evaluation:

Method 2. Products for which there are no specific
standardized tests or comparative or rational analysis
methods of evaluation established as required by the
Code shall demonstrate compliance with the intent of
the Code through one of the following:
Recent POC Issues
(1) An evaluation report from an approved product
evaluation entity; (2) an evaluation report from a Florida
Registered Architect or a licensed Florida Professional
Engineer based on testing or comparative or rational
analysis or combination thereof, which provides verifiable
documentation indicating the product complies with the
intent of the Code. (3) A legacy report from a nationally
recognized model Code organization may be used if the
report demonstrates compliance with the code.
Rational engineering analysis cannot be used in lieu of
a standard test required by the Code for approval of
products within the scope of the standard.
Recent POC Issues
Examples of applications requiring Method 2:
1. Roof panels using plastic materials.
2. Non-organic roofing products (not all).
3. Wall panels outside HVHZ.
There are many other examples.
Recent POC Issues

Applications with Alternate Materials are not allowed
for statewide product approval.

Alternate materials is a claim that a product
compliance is equivalent to the provisions of the code,
but is not evaluated as required by the code.

Example: Evaluation report with this language: “The
system is an alternative exterior wall covering to those
specified in Chapter 25”.
Recent POC Issues
Underwriters Laboratories, Inc. is now UL LLC and
approved as:




Certification Agency
Quality Assurance Entity
Testing Laboratory
Validation Entity
Product Approval Applications still containing the old
name will need to submit an Editorial Change to revise
the application and select the appropriate approved
entity.
Recent POC Issues
PSI/Pittsburgh Testing Laboratory has been succeeded by
Benchmark Holdings, L.L.C. and approved as:

Quality Assurance Entity
Product Approval Applications still containing the old
name will need to submit an Editorial Change to revise
the application and select the appropriate approved
entity.
Role of Validator
 Validation means determination of compliance pursuant to Rule
61G20-3, 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.

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