American Architectural Manufacturers Association

Florida Product Approval Program Changes and Frequent Validation Mistakes

September 2, 2010

Mo Madani, the Senior Technical Manager of the Florida Product Approval System, provided an update during the AAMA Southeast Region Fall Meeting regarding changes mandated by Florida legislation HB 663 – Building Safety – that was signed into law this past May. The five-part presentation covered the organization of the Florida Building Commission (FBC) and the Building Codes and Standards Office, a review of the current Product Approval (PA) process and the number of certification, evaluation, testing, accreditation, quality assurance and validation entities participating, as well as the new application review process set forth in HB 663, 2010 Florida Building Code revision updates and a summary of proposed code changes affecting fenestration products. Common PA submittal errors resulting in denial of approval were also summarized.

Madani noted that the new rules statutorily limit the number of evaluation entities to five named organizations.

Proposed Florida code changes impacting fenestration were listed as:

• CA3611 - Require permit for all product approved opening protection
• CA4352 - Require the submittal of construction documents and plan review for impact resistant coverings or systems
• CA3615 - Require all fenestration flashing and rough opening dimensions to be on plans
• S4033 - Add impact standards “AMCA 540” for louvers
• S4447 - Remove SDI 250.13 as the standard for testing exterior door components
• S3584 - Define who is responsible for flashing installation while also clarifying that door and window installation must be in accordance with manufacturer’s instructions and the window and door flashing in accordance with FMA/AAMA 100, FMA/AAMA 200, FMA/WDMA 250 or AAMA 711

The steps and associated deadlines remaining in the current code development cycle were given as:

• 9/3/10 - Technical Advisory Committee (TAC) recommendations
• 10/18/10 - 45 day comment period ends
• 11/15/10 - TAC reviews comments on recommendations
• 12/7-8/10 - Commission considers TAC recommendation
• 4/11-6/11 - Code amended to resolve glitches
• 10/1/11 - Code printed
• 12/31/11 - Code implemented

In addition to the above changes, all structural licensees who use AAMA as their Certifier and Validator for the Florida Product Approval Program should take note of the following information, provided in order to give clarification on the most common improper validation mistakes.

The Florida Department of Community Affairs recently supplied the following information, which provides a reliable guide to avoiding common problems in uploaded applications. Please note that the “Certification Agency Certificate (CAC)” referenced in the list is the Authorization for Product Certification (APC) in the AAMA program.

Florida Building Commission Product Approval Validation Most Common Improper Validation Mistakes

Certification Method

1. Testing standards on Certification Agency Certificate (CAC) are not the same as on face of application. 
2. Testing standards are not as adopted and an equivalency of standards has not been provided. 
3. Design Pressure on application exceeds design pressure on CAC or load test has not been certified. 
4. Limits of use indicate impact resistance and testing standards for impact were not performed. 
5. Certification cannot be based on rational analysis. 
6. Description of product on application is not the same as on CAC. 
7. Installation Instructions are not in accordance with Rule 9B-72.070(5)(e) or as on the CAC. 
8. Certification Agency Certificate is expired. 
9. Installation Instructions are based on rational analysis and an Evaluation Report was not provided. 
10. Certification of plastic structural components was not provided or is expired (glass laminates, plastic extrusions). 
11. Validation checklist is for the correct method and signed and sealed after validation online.

If you have any questions, please contact Dean Lewis, AAMA Chief Engineer, Certification Programs.

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