AMD Urges Members to Take Action Against S141

The Association of Millwork Distributors (AMD) recently released a statement to its members, urging them to take notice and action against a building code amendment titled S141 proposed by the Window and Door Manufacturers Association (WDMA). AMD alleges the amendment, as proposed, would have negative repercussions across the United States and abroad for the commercial and residential side-hinged door distributor, prehangers and door component manufacturers. The International Code Council (ICC) will address S141 at its 2009 edition code development hearings, beginning February 18, 2008, in Palm Springs, Calif.

In a letter to its membership, executive director and chief executive officer Rosalie Leone published the following explanation for S141:

“The S141, if adopted, will remove text from the existing International Building and Residential Codes that exempts side-hinged exterior doors from testing to the standard AAMA/WDMA/CSA 101/I.S.2/A440. This amendment also proposes the adoption by reference of the newest edition of this standard A440-08. The standard includes five separate tests for each door system configuration, meaning that all side-hinged exterior doors or combinations thereof will need to be tested, certified and labeled for performance criteria in the areas of force to latch, air infiltration, water penetration resistance, structural performance, forced entry, door cycling and vertical loading. WDMA states in the S141 that this amendment will, ‘increase complexity and cost of manufacturing side-hinged door assemblies because it requires side-hinged door assemblies to be tested, and labeled, to performance requirements previously not required.’”

Leone says, depending upon the combinations of door types: (steel, fiberglass, wood); glass types (insert, flush glaze); frame components (jambs, sill, mulls, astragal); swing direction (in-swing, out-swing); door height (6 foot 8 inch, 8 foot); and configuration (single, sidelite, hinged patio, French patio); the cost of testing of every door combination can run anywhere between $20,000 and $80,000 per combination.

Leone says no provisions are made for the substitution or interchange of rated components within a door unit in S141 or the current Code. She says allowance for some substitution may be possible with existing labeling entities, but it is believed that some level of additional testing will be required to validate additional door system combinations. AMD suggests this would result in a significant restriction of trade affecting the slab, hardware and other component manufactures and prehangers representing the vast majority of the millwork industry.

Leone says AMD has committed to partnering with the American Architectural Manufacturer Association (AAMA) to develop data and a solution for component interchangeability.

“Currently, we are in that process and need more time to adequately complete the necessary rounds of testing the interchangeability of components,” she says. “Additionally, AMD is continuing to work with AAMA and WDMA in finding a mutual agreement to the S141 amendment.”

Leone suggests members take initiative.

“So we must develop strategies to modify and oppose the S141 code request and protect our member’s interest,” her letter states. “AMD will represent the association’s position at the ICC code hearings. In addition, we are also contacting potential partner associations for their support, and we are researching the legality of planned actions.”

For more information and specific suggestions for AMD members, Leone can be reached by email at: rleone@amdweb.com.

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