UL-Listed does not mean code-approved
It’s undeniable that Underwriters Laboratories (UL) has built a reputation as a premiere agency that tests and lists fire rated glazing products. In addition to doing a tremendous job at testing and listing products, UL is also an accredited standards developer in the US:
- For fire protective (or fire-protection-rated) glazing, UL has developed UL 9, “Fire Tests of Window Assemblies”, UL 10B “Fire Tests of Door Assemblies”, and UL 10C “Positive Pressure Fire Tests of Door Assemblies.” Glazing products tested to these standards are used in opening protectives, such as fire windows and fire doors. If glazing over 100 sq. inches is to be used as a component in temperature rise doors, it must limit the temperature rise to less than 450 degrees after 30 minutes into the test.
- For fire resistive (or fire-resistance-rated) glazing, UL has developed UL 263, “Fire Tests of Building Construction Materials.” Glazing products tested to this standard are used in fire resistive walls, ceilings or floors and must be able to limit the temperature rise on the non-fire side to less than 250 degrees F for the duration of the test.
I believe that the test standard and the glazing’s tested performance have confused design professionals into thinking that if a glazing product is tested and listed by a well-known and respected laboratory such as UL, it must also be code approved. This is not the case, and this belief has led to a number of non-code-compliant applications.
Part of the confusion is in the way fire rated glass manufacturers and distributors has asked the testing agencies to test and list their products. For example, fire rated ceramics like FireLite NT and FireLite Plus have a UL-listing for 90-minute sidelights and transoms up to 3,325 sq. inches. However, there is currently no building code in the US that allows fire protective ceramics in 90-minute sidelite and transom applications. FireLite NT and FireLite Plus also boasts of having fire ratings up to 180 minutes in their paid advertising without any qualifications to its UL-listing or approved use. When in fact that at 180 minutes, FireLite NT and FireLite Plus can only be used in very small 100 sq. inch vision area in 3-hour doors.
Below is an excerpt of Table 716.5 in the 2012 and 2015 IBC (715.4 in the 2006 and 2009 IBC) that shows that sidelites and transoms in 1-1/2 and 2 hour wall applications must be fire resistive and marked with a “W” to indicate that is has been tested to meet ASTM E-119 or UL 263. Fire protective products like ceramics, although fire tested up to 180 minutes as referenced above, are Not Permitted because it does not meet, nor have they been tested to, the more stringent ASTM E-119 or UL 263, which is very difficult to pass. These ceramic products are considered in the code as FIRE PROTECTIVE, not FIRE RESISTVE (see chart). We’ve enclosed in red the areas where fire protective products like ceramics are either not permitted or limited to 100 sq. inches in the door vision area.
To avoid confusion, we are proposing separate charts for fire protective and fire resistive products. Here is what it will look like:
Another widespread misconception among design professionals is that only UL-listed products are code-approved. There are other nationally recognized testing laboratories (NRTL) that are accredited to perform the same UL 9, UL 10B, UL 10C and UL 263 test standards for fire rated glazing products. But just like UL, these products are tested and listed by what the manufacturer requested it be tested to. The listing issued by the NRTL does not give the design professional any guidance whether or not the product is code-approved for the application based on IBC requirements.
Some door manufacturers and distributors also mistakenly believe that only UL-listed glazing can go in UL-listed vision kits or UL-listed fire doors. This is not the case. Unless there is a specific restriction on the vision kit or fire door method of manufacture, the codes do not prohibit mixing and matching components that are listed by different laboratories. For example, a UL-listed glazing product can be used in a vision kit or fire door listed by UL or any NRTL constructed to HMMA specifications. As long as glazing, vision kit and fire door components meet the required standards, it can be used. Here are excerpts from NFPA 80:
So what should architects and owners BE AWARE OF to avoid costly code mistakes that put the project and building occupants at risk? We suggest architects should always make sure that the product chosen specifically meets the code requirements for the application – not just a product’s UL or NRTL performance listing or paid advertising.
There are products like SAFTI FIRST’s SuperLite I-XL, used in fire protective applications only, that meet the European standard for fire protective areas where the hose stream test is not required, but do not meet the US standard where the hose stream test is part of the test procedure in UL 9, UL 10B and UL 10C (except for 20-minute doors). SuperLite I-XL’s listings with UL and another NRTL clearly states that this product is tested without hose steam. This is also stated in SuperLite I-XL’s product literature and the quotes that go out with it to alert design professionals that AHJ approval may be required in order to use this product. SuperLite I-XL does put its limitations at the forefront so it does not confuse or mislead the public – something that competitive products do not do with their listings or advertising. Through the years, SuperLite I-XL has developed wide use as an alternate product per the alternative methods and materials clause in IBC section 104.11. Building officials and jurisdictions, like Los Angeles and the General Services Administration (GSA), have pre-approved its use after investigating the performance, affordability and wide spread use in Europe.
Luckily, there are a number of educational resources out there such as SAFTI FIRST’s AIA-registered “Designing with Fire Rated Glass,” an on-demand video program that explains the different IBC requirements for fire rated door, window, wall and floor applications. This program is available 24 hours a day, 7 days a week and the participants who pass the AIA-required quiz in the end are eligible to receive 1 AIA LU/HSW continuing education credit.
Hopefully, this blog can start a dialogue between other fire rated glass suppliers, testing agencies, design professionals and even building officials. Every day, we see quotes and submittal for fire rated glazing product materials (see above) that are not code compliant for the application. It’s time to make it easier for designers, building officials and end-users to select and receive quotes and submittals using code-approved products for the application. Possibly common exceptions stated of applications where they does not meet the IBC code requirements in the listing, like what SAFTI FIRST with SuperLite I-XL (needs AHJ approval) could be a start.