1. Florida Product Approval System Validator Training December 11, 2012 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

2. Florida Product Approval System DEPARTMENT OF BUSINESS & PROFESSIONAL REGULATIONS MO MADANI Senior Technical Manager Senior Technical Manager JOE BIGELOW Codes & Standards

3. 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

4. Objectives of Training UPDATES OF VALIDATION REQUIREMENTS DISCUSSION OF VALIDATION CHECKLISTS MOST COMMON MISTAKES

5. Product Approval Application 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

6. 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.

7. 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.

8. Revised Applications FBC 2010 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.

9. 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.

10. 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

11. New Application Process Changes made to the new application process include: Applications must be validated by COMPLETION DEADLINE Applications must be validated by COMPLETION DEADLINE Applicants work at their own pace to complete applications by the posted deadline date. Applicants work at their own pace to complete applications by the posted deadline date. Early submittals will have more correction time if needed. 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 Only those applications that are complete by the Completion Deadline are recommended to the Product Oversight Committee (POC) and listed on the meeting agenda

12. New Application Process

13. Product Approval Methods Four Methods for State Approval Certification Mark or Listing Certification Mark or Listing Test Report Test Report Evaluation Report from an Evaluation Entity Evaluation Report from an Evaluation Entity Evaluation Report from a Florida licensed Architect or a Florida Professional Engineer Evaluation Report from a Florida licensed Architect or a Florida Professional Engineer

14. Validations Rule 61G20-3.006 Product Validation Two Types of Validation Administrative Validation Administrative Validation Technical Validation Technical Validation NOTE: All applications, except Self-Affirmation, require validation. Applications requiring corrections have to be Re-Validated.

15. Administrative Validation Overview

16. Administrative Validation Applicable to: A certification mark or listing from an approved certification agency 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 a Florida Registered Architect or Licensed Engineer independent from the manufacturer An evaluation report from an approved evaluation entity. An evaluation report from an approved evaluation entity.

17. Administrative Validation Criteria Criteria consists of: 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 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 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. Verification of any limits are within the scope of certification or evaluation. Verify that certification is not based on rational analysis. 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. Verify that if rational analysis was used for installation instructions that an evaluation report is included.

18. Certification Validation Checklist

19. Administrative Validation Checklist

20. 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.

21. 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.

22. Evaluation Report by Florida PE/RA Administrative Validation Checklist

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

24. 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.

25. Evaluation Report by Evaluation Entity Administrative Validation Checklist Evaluation Report by Evaluation Entity Administrative Validation Checklist

26. 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.

27. 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).

28. Technical Validation Overview

29. Technical Validation Applicable to: A test report from an approved testing laboratory 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 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. Installation instructions designed by in-house to the manufacturer, non independent third-party professional.

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

31. 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 Checklist

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

33. 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.

34. 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.

35. Installation Instructions Installation instructions also require verification: If prepared by company engineers then technical validation is required 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) If prepared by independent engineers then administration validation is required, unless using the Test Report Method (which always requires a technical validation)

36. Installation Instructions Installation instructions criteria: Determination that the evaluator has complied with acceptable standards of engineering principles. Determination that the evaluator has complied with acceptable standards of engineering principles. Engineering verification that the evaluation complies with the Code. 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. 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.

37. 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, 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. Type, physical dimensions, material and grade of any accessory item or strap, if applicable. Spacing of anchors, shims, accessory items and straps. Spacing of anchors, shims, accessory items and straps. Illustrated diagrams of the attachment of the product structure. Illustrated diagrams of the attachment of the product structure.

38. RULE 61G20-3 Optional State Approval with updates

39. Validation Entities All approved Validation Entities must retain documentation of the product application All approved Validation Entities must retain documentation of the product application Approved Certification and Evaluation agencies can validate their own certifications/evaluations Approved Certification and Evaluation agencies can validate their own certifications/evaluations Testing Labs are not allowed to conduct validations Testing Labs are not allowed to conduct validations

40. Validation Entities 61G20-3.006(4) Violations and Penalties for 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 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 Disciplinary penalties could be fines up to $10,000 per occurrence, suspensions and revocations

41. 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: 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:

42. 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. (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.

43. 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.

44. Recent POC Issues Applications with Alternate Materials are not allowed for statewide product approval. 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. 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”. Example: Evaluation report with this language: “The system is an alternative exterior wall covering to those specified in Chapter 25”.

45. Recent POC Issues Underwriters Laboratories, Inc. is now UL LLC and approved as: Certification Agency Certification Agency Quality Assurance Entity Quality Assurance Entity Testing Laboratory Testing Laboratory Validation Entity 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.

46. Recent POC Issues PSI/Pittsburgh Testing Laboratory has been succeeded by Benchmark Holdings, L.L.C. and approved as: Quality Assurance Entity 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.

47. Role of Validator 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 Three Hundred Dollars ($500.00) ($300.00) per subcategory of product. The Commission shall review annually and adjust fees accordingly. 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.