Bugged by labeling

Labeling for safety or fire glazing has been a requirement by code for years. These labeling requirements have not always been enforced, however, with increased litigation, manufacturers, code officials and buyers of fire-rated glazing now look at labeling requirements more seriously.

When a purchaser looks at a piece of fire-rated glass today, he or she will find labels indicating that the glazing product was tested for fire. Labels, called “bugs” in the trade, indicate that the product was tested for fire and is under a follow-up service by the agency providing the testing; some bugs indicate that it has been tested for both fire and safety.

Producing each bug can cost $180 to $200; $150 for artwork and $35 for a rubber stencil.

Two major companies provide fire-testing service. One is Underwriters Laboratories in Northbrook, Ill., a nonprofit testing service for code compliance. The second is Intertek Testing Services in Middleton, Wis., recognized as a worldwide specialist for testing fire windows, fire doors and fire walls.

The fire-rated glazing manufacturers—Vetrotech St. Gobain in Auburn, Wash.; Schott in Elmsford, N.Y.; Asahi Glass Co. in Japan; Pilkington North America in Toledo, Ohio, and others like my company, Safti First Fire Rated Glazing Solutions in San Francisco—agree that new labeling or bugging requirements are needed with the advent of fire-rated products that surpass traditional wired glass in function and performance.

The original area of confusion in the specification and use of fire-rated glazing came with the introduction of fire-resistive glazing that met the wall-performance standards in the early 1980s. This glazing performs as a wall for more than one hour, stopping flames, smoke and radiant heat. It passes the hose-stream test and is safety impact rated. Today, several products meet these criteria, including SuperLite II-XL, Pyrostop, Swissflam and Pyrobel. These high-performance “resistive” products greatly outperform traditional wired glass made by Pilkington in England, and Central Glass Co. and Asahi Glass Co., both in Japan. Traditional wired glass can fail in as little as 16 minutes and is not safety-impact rated to any standard.

For example, independent tests on the impact performance of traditional wired glass by Safti First in 1989 failed ANSI in 1991 and again in 1993; the ITS’ testing on traditional wired glass failed ANSI in 1992; British testing equal to ANSI on traditional wired glass failed; and in 2001, Architectural Testing Inc. of York, Pa., tested wired glass for impact performance to ANSI, and it failed again.

A few years after the introduction of the fire-resistive products to this market, fire protective ceramics were introduced to the U.S. market by Technical Glass Products of Kirkland, Wash. This fire-protective glazing, sold under the name FireLite, obtained a fire-endurance bug of 20, 45, 60 and 90 minutes. However, if you look for the small asterisk in TGP advertising, you’ll find that it must be approved by building-code officials to utilize the 60- or 90-minute ratings. Though TGP officials claimed that ceramics were not required to meet any safety code because they were crystalline and not amorphous—and therefore were not considered glass—an official code interpretation explained that the product must meet the safety code even if it is not covered by the narrow definition of glass issued by the U.S. Consumer Products Safety Commission of Washington, D.C.

This ceramic product was to be sold as fire-protective glazing in the place of traditional wired glass. Like wired glass, ceramics were restricted to 45-minute applications in all but small sizes in doors. Radiant heat and impact concerns were the reasons that fire-protective glazings are limited to 25 percent of the wall area and limited to 1,296 square inches in doors. While ceramic material could last in the opening longer, it fails to meet the code requirements for any 60- or 90-minute applications—other than the 100-square-inch view ports in doors—and does not meet any safety standards unless filmed or laminated.

In 1995, a patented radiant-heat-reducing tempered glass product called SuperLite I-XL was added to the fire-protective mix by Safti First. This product also was tested to 60 minutes but was not code approved for fire-resistive applications, even though it does provide modest radiant-heat protection. ITS required the bugs to say “No hose stream” and “Special restrictions apply”; therefore, it is required to have building-code officials’ approval for fire-protective applications greater than 20 minutes. Interestingly, because the hose-stream test is not a requirement in most countries, ceramics have almost no market in fire-protective applications outside the United States. Improved specialty edge-treated and highly tempered glass—of products such as SuperLite I-XL and Vetrotech Saint-Gobain’s Pyroswiss—have been used worldwide for more than 30 years in fire-protective applications up to 45 minutes—at great savings to consumers, building owners and glass fabricators. 

Look at options
To clarify the labeling of these various fire-rated glazings, in 2004, I submitted a code change for the 2004-05 cycle to help building officials and the public in determining what type of glazing was being supplied: “P” for fire protective or “R” for fire resistive, the duration of time achieved and an indication of its safety performance. Any important variations from this labeling should be noted on the bug, as currently done with SuperLite I-XL. It is unfair that a similar notification of special use is not placed on wired glass and ceramics when they are sold for use in non-code approved applications for safety and fire protection. To this day, wired glass and ceramics are being used in large sizes for 60- and 90-minute applications with no warnings about their heat or impact limitations. Because of this practice, building-code officials have no clue that this type of glazing is often unsafe and inappropriate. It was for this reason I want to have it clearly stated whether the glazing is fire protective or fire resistive, and to introduce the products’ ability to be used in safety and non-safety applications.

This code change was fought, and a labeling proposal that I consider much weaker was introduced by Pilkington. Last year, the Pilkington proposal was accepted by the International Code Council of Falls Church, Va., and is now contained in the 2006 version of the code. Below, my concerns with the Pilkington code change:

• Today, all manufacturers of fire-rated glazing, including manufacturers of doors, door components, and more importantly, stockers and fabricators of fire-rated glazing, must label any glazing going into a fire-rated application with a much expanded labeling system that requires 168 bugs (see chart on p. 24), rather than the manageable 11 bugs in my proposal (see chart on p. 28). All of these bugs will have to be available to mark the glass, and still without any requirement to indicate whether it is safety or non-safety glazing.
• Testing laboratories turned a blind eye to the practice of approving non-safety-rated products for applications that clearly require a safety rating. They test for fire only, with no interest in impact safety or the dangers of radiant heat when products carrying these labels are to be used in large sizes with fire ratings greater than 45 minutes or in applications requiring safety glazing.
• Are these labels going to improve safety? Will they stop the misuse of fire-protective glazing in fire-resistive applications?
• What will the impact of this change be on the glazing industry? Will this change stop the application of improper labeling of fire-rated glazing products? Who will be responsible for monitoring mislabeled products or, in the worst case, replacing glazing that has been mislabeled?
• Glass and glazing shop owners will have to fully understand the system to order fire glass. Will they be able to assume this responsibility?

I recently read an article whose author mentioned the integrity of the glass industry. I share the belief that we are a sincere group that cares about public interest. That said, after battling representatives of Pilkington, Asahi Glass Co. and Central Glass Co. to improve public safety by limiting the unsafe use of wired glass in hazardous locations for more than 20 years, I have to laugh when I hear the word integrity as it relates to this group. I am a small independent manufacturer have spent almost a million dollars in legal fees, contributions to Advocates for Safe Glass of Eugene, Ore., a nonprofit organization founded by parents of children severely injured by traditional wired glass in buildings, independent testing and attending code hearings. These are the same manufacturers that fought for, and successfully passed, an American National Standards Institute ANSI Z97.1 standard that lists traditional wired glass as safety glass, even when independent tests showed that traditional wired glass could not even pass the lowest ANSI Z97.1 testing. When these manufacturers were asked during the ANSI hearings if they could make a safe wired glass, Pilkington’s Brian Waldron said they would “go out of business first.” Yet when the code for the fire-glazing safety changed, Pilkington had its Pyroshield Plus product on the market in a matter of weeks. Pyroshield Plus is a laminated, polished wired glass that is impact safety rated to Category I only.  

Conflicts of interest abound
So who represents the glazing industry with regard to how these safety, fire and labeling code issues are changed and adopted? There is a conflict of interest on this issue, and I ask the members of the National Glass Association of McLean, Va., and the Glass Association of North America of Topeka, Kan., to look into it. Why? Because the same code consultant—William E. Koffel, president of Koffel Associates Inc. of Elkridge, Md.—represents the Glazing Industry Code Committee dominated by prime manufacturers and the Fire Rated Glazing Industry, a newly created group formed with Pilkington’s help. The interests of these groups are not all the same, and no single consultant can fairly say he represents all of them. Similarly, many of the same individuals serve both the GANA and GICC. GANA and GICC also share the same general counsel. If GANA decided to challenge the GICC, how can the same general counsel represent both?

Room for dissent
Obviously, we need a simple, concise way of labeling a life-safety product like fire-rated glazing, both for its fire performance and for the more inevitable likelihood of being injured in the panic of a fire by impact with the glazing. Remember the most commonly used application is in exit doors and exit sidelites.

Without a doubt, the current labeling scheme accepted by the ICC was muscled by Pilkington without consensus of the fire-rated glazing industry, glazing providers and contractors, architects or other end users.  Maybe if there had not been conflict of interest, a more balanced and well-thought-out code change would have been developed.

This issue will be before the ICC again. Fire-glass labeling should be clear and easy to accomplish without being confused by:
• Where it is going, an opening, wall or door
• Whether it meets that hose stream or is non-hose stream
• If it is temperature rise or non-temperature rise.

Much more importantly, the bug must provide the simple concise information of whether it is fire resistant or fire protective for the time rated, whether it is safety or non safety and whether it has any special qualifications. If you agree, tell your association to send someone to the next meeting of the ICC. Eleven bugs versus 168? Yes, I am fired up by this issue.