Validator Training December 11 2012 Florida Building Commission Florida Department of Business and Professional Regulations 1940 North Monroe Street Tallahassee FL 32399 850 4871824 ID: 203776
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Florida Product Approval System
Validator Training
December 11, 2012
Florida Building Commission
Florida Department of Business and Professional Regulations1940 North Monroe Street | Tallahassee, FL 32399 | (850) 487-1824www.floridabuilding.orgSlide2
Florida Product Approval System
Department of Business & Professional Regulations
Mo Madani
Senior Technical Manager
Joe
bigelow
Codes & StandardsSlide3
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 SpecialistSlide4
Objectives of Training
UPDATES OF VALIDATION REQUIREMENTS
DISCUSSION OF VALIDATION CHECKLISTS MOST COMMON MISTAKESSlide5
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 applicationSlide6
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.Slide7
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.Slide8
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.Slide9
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.Slide10
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 THEREINSlide11
New Application ProcessChanges made to the new application process include:
Applications must be validated by
COMPLETION DEADLINEApplicants 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 agendaSlide12
New Application ProcessSlide13
Product Approval MethodsFour Methods for State Approval
Certification Mark or Listing
Test ReportEvaluation Report from an Evaluation EntityEvaluation Report from a Florida licensed Architect or a Florida Professional EngineerSlide14
ValidationsRule 61G20-3.006 Product Validation
Two Types of ValidationAdministrative Validation
Technical Validation
NOTE:All applications, except Self-Affirmation, require validation. Applications requiring corrections have to be Re-Validated
.Slide15
Administrative Validation
OverviewSlide16
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 manufacturerAn evaluation report from an approved evaluation entity.Slide17
Administrative Validation CriteriaCriteria 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. Slide18
Certification Validation
ChecklistSlide19
Administrative Validation
ChecklistSlide20
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.Slide21
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.Slide22
Evaluation Report by Florida PE/RA Administrative Validation ChecklistSlide23
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.Slide24
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.Slide25
Evaluation Report by Evaluation Entity Administrative Validation ChecklistSlide26
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.Slide27
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).Slide28
Technical Validation
OverviewSlide29
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 manufacturerInstallation instructions designed by in-house to the manufacturer, non independent third-party professional.Slide30
Technical Validation CriteriaIn 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.Slide31
For the technical validation when using the Certification, EvaluationReport 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 ValidationChecklistSlide32
For the technical validation when using the Test Report method,the validator needs to complete the following Validation checklist.
Technical ValidationTest Report Method ChecklistSlide33
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.Slide34
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.Slide35
Installation InstructionsInstallation 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)Slide36
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.Slide37
WindowsInstallation 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. Slide38
RULE 61G20-3Optional State Approval with updatesSlide39
Validation EntitiesAll approved Validation Entities must retain documentation of the product application
Approved Certification and Evaluation agencies can validate their own certifications/evaluationsTesting Labs are not allowed to conduct validationsSlide40
Validation Entities61G20-3.006(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 Slide41
Recent POC Issues61G20-3.005 (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:
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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. Slide43
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.Slide44
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”. Slide45
Recent POC IssuesUnderwriters Laboratories, Inc. is now UL LLC and approved as:
Certification Agency
Quality Assurance EntityTesting LaboratoryValidation EntityProduct Approval Applications still containing the old name will need to submit an Editorial Change to revise the application and select the appropriate approved entity.
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Recent POC Issues
PSI/Pittsburgh Testing Laboratory has been succeeded by Benchmark Holdings, L.L.C. and approved as:
Quality Assurance EntityProduct Approval Applications still containing the old name will need to submit an Editorial Change to revise the application and select the appropriate approved entity.
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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.Slide48
QUESTIONS?