Emerging Regulatory Issues In Canada

Al Jaugelis

Technical Director, Fenestration Canada

2020 Spring Conference

Topics

•The “Future is Triple Glazed”: Energy Step Codes and Window Market Transformation

•Use of ASTM E1300 in Canada

•New prescriptive glass tables in NBC 9.6

•Guard load on glass

•Why local knowledge is more important than ever

The future is triple glazed . . .

The Future is Triple Glazed (in Canada)

•Natural Resources Canada (NRCan) is a government department responsible for development of Canada's natural resources, including energy, forests, minerals and metals

• In August 2017, NRCan announced a Market transformation program for residential windows, space heating, and water heating—three product categories considered essential for constructing Net Zero Ready homes (https://www.nrcan.gc.ca/sites/www.nrcan.gc.ca/files/emmc/pdf/Market-Transformation-Strategies_en.pdf)

• It announced aspirational goals for the energy performance of residential windows for 2025 and 2030

The Future is Triple Glazed (in Canada)

(https://www.nrcan.gc.ca/sites/www.nrcan.gc.ca/files/emmc/pdf/Market-Transformation-Strategies_en.pdf)

UIP 0.21

UIP 0.14

UIP 0.28

R-3.5

R-7

The Future is Triple Glazed (in Canada)

From the executive summary of the market transformation document:

The Pan-Canadian Framework on Clean Growth and Climate Change outlines the commitments of the federal, provincial and territorial governments . . . to reduce greenhouse gas emissions and promote clean, low-carbon economic growth for Canadians. . . .

Residential and commercial buildings account for 17% of total greenhouse gas emissions in Canada. For this reason, the Pan-Canadian Framework outlines a building strategy with measures to improve energy performance of new and existing buildings through codes and labels and set new standards for energy using equipment.

The Future is Triple Glazed (in Canada)

The NRCan aspirational goals do not exist in a vacuum . . .

They are intended to support the objectives of the Canadian National Building code which has the mandate to achieve a Net Zero Ready level of energy performance by 2030.

Canadian research programs and pilot projects with builders across the country have demonstrated the viability of Net Zero Ready construction.

A 2013 NRCan R-2000 Net Zero Energy Pilot program invited Canadian builders to submit designs and construct Net Zero Energy residential buildings. Six builders constructed 23 homes conforming to the requirements. All used triple-pane windows.

Step Codes and Tiered Energy Performance

• British Columbia was the first province to adopt a Net Zero Ready code approach

• In Spring of 2017 the province introduced the Energy Step Code which defined a 5-step code path to Net-Zero Ready buildings by 2032

• The steps defined a 15-year roadmap to give all stakeholders in the design and construction sector clarity about future energy performance code requirements

• The steps gave industry certainty of what the next code step will be, and what the ultimate goal will be in 2032

• The Energy Step Code allowed individual jurisdictions to “jump ahead” of the provincial code to require higher-than-current steps, at the scale of a rezoned parcel of land, or for the entire jurisdiction

BC Energy Step Code—Homes and Small Buildings• Step 1: Existing 2017 code

requirements with “Enhanced Compliance”

• Steps 2 – 5 require building-specific energy modeling and air-tightness testing to defined performance levels, giving builders flexibility in design and construction choices

• Step 5: the Net Zero Ready whole-building energy use level approximates Passive House requirements, and Passive House certified buildings automatically comply with Step 5

Local governments can choose to incentivize builders to meet higher Steps as an alternative to the code’s existing requirements.

Step Code Concept

“For governments, the BC Energy Step Code offers assurance that new buildings are

performing as billed. Meanwhile, on the other side of the counter, builders have a more

flexible option to comply with the energy-efficiency provisions of the provincial legislation.

The new standard empowers builders to pursue innovative, creative, cost-effective

solutions—and allows them to incorporate leading-edge technologies as they come available.

“Local governments can choose to require or incentivize a given step of the BC Energy Step

Code in new construction. In addition, beyond the regulatory context, builders and

developers can adopt a given step to use across all of their projects, if they wish.”

(https://energystepcode.ca/how-it-works/)

BC Energy Step Code—Large Buildings• Step 1: Existing 2017 code

requirements with “Enhanced Compliance”

• Steps 2 – 3 require building-specific energy modeling and air-tightness testing to defined performance levels, giving builders flexibility in design and construction choices

• Step 4: the Net Zero Ready whole-building energy use level approximates Passive House requirements, and certified Passive House buildings comply with Step 4

Tiered (Step) Energy Performance in the NBC

• “Tiered” (stepped) energy performance requirements similar to those of the BC Energy Step Code were introduced in the Winter 2020 public review of proposed changes to national codes (Jan. 13–Mar. 13, 2020)

• Small buildings: prescriptive (point-based) and Performance (simulation-based) approaches were proposed for Section 9.36 of the National Building Code (NBC)

• Large buildings: a simulation-based 4-step Tiered performance path was added to the National Energy Code for Buildings (NECB)

• In both small and large buildings the highest Tier represents a Net Zero Ready performance level

• Code Committees are currently reviewing these changes

Step/Tiered Energy Codes Create Demand

•By allowing jurisdictions to voluntarily adopt and incentivize builders to comply with predefined levels of energy performance before those levels are incorporated into the base code, the step code/tiered code approach builds industry capacity incrementally, from now to 2030, and creates an initially limited, but increasing demand for triple pane windows that will be an integral component of Net Zero Ready homes and large buildings

Step Code, Net Zero Ready Homes, and Windows

•Of the five pilot Step 3 homes builders voluntarily chose to build in various climate zones of BC, which cost no more than 0% to 4% more than base code, three builders chose to use affordable BC-made vinyl triple pane windows (https://energystepcode.ca/case-studies/)

•The cost-effectiveness of triple pane windows become evident to builders when homes are designed to reach Step Code level 3 and above

• In a 2018 study of Net Zero Ready homes constructed by members of the Canadian Home Builders Association, 45 of 47 builders chose to use triple pane windows

ENERGY STAR

•The current Canadian ENERGY STAR qualifying criteria for windows:

•265 manufacturers are offering ENERGY STAR Most Efficient single casement windows in Canada today

(ER may survive for use in existing buildings, but will not be a code compliance path in 2020 NBC and beyond)

ENERGY STAR Most Efficient (U-value path) Style Max U-value (W/m2-K) Min U-value (W/m2-K)

Number of Manufacturers Offering Product

Awning

1.05

0.8 288

Casement 0.8 265

Double Hung 1.0 46

Double Slider 0.9 39

Dual Action 0.8 31

Fixed Picture 0.7 546

Fixed Awning 0.8 18

Fixed Casement 0.7 263

Single Hung 0.9 49

Single Slider 0.9 56

ENERGY STAR Most Efficient (U-value path)

Observations on the lowest U-value products (<USI-1.0):

•Only a small proportion of Most Efficient products achieve USI-0.8 at this time

•Existing Most Efficient designs indicate we have the technology to reach USI-0.8 in casement, awning, dual action and fixed windows, and 0.9 in vertical and horizontal sliders

•All but one product line feature triple pane glass

•Only one manufacturer offers quad pane units at this time

How are we doing on the NRCan Roadmap?

UIP 0.21

UIP 0.14

UIP 0.28

R-3.5

R-7

•Progress on the long-term goals will depend on whether Tiered Energy Code or government incentives will create market demand

Use of ASTM E1300 in Canada

Glass design using ASTM E1300 in Canada

•Part 4 of the building code requires design wind pressures to be calculated using the 1-in-50-year hourly wind pressures (1/50 HWP) published in Division B Table C2 of the 2015 NBC

•The design pressure calculations in CSA A440S1, the Canadian Supplement to NAFS, are based on Table C2, 1/50 year wind pressures

•The code now allows use of ASTM E1300 in addition to CGSB-12.20, but requires use of an adjustment factor

•The adjustment factor accounts for differences in the load duration values between the ASTM and CGSB methodologies (3 sec vs. 60 sec.)

Glass design using ASTM E1300 in Canada

DISCLAIMER: This slide presents information available to us at this time and does not constitute design advice.

FENESTRATION CANADA ADVISES CONSULTING A CANADIAN REGISTERED PROFESSIONAL ENGINEER FOR GLASS DESIGN IN CANADA

Glass design using ASTM E1300 in Canada

DISCLAIMER: This slide presents information available to us at this time and does not constitute design advice.

FENESTRATION CANADA ADVISES CONSULTING A CANADIAN REGISTERED PROFESSIONAL ENGINEER FOR GLASS DESIGN IN CANADA

•A load factor of 1.4 must be applied to the adjusted wind load W for glass design

Glass design using ASTM E1300 in Canada

DISCLAIMER: This slide presents information available to us at this time and does not constitute design advice.

FENESTRATION CANADA ADVISES CONSULTING A CANADIAN REGISTERED PROFESSIONAL ENGINEER FOR GLASS DESIGN IN CANADA

Can we use ASTM E1300 with CSA A440S1-17?

•Yes, in principle, the simplified calculation method in the Canadian Supplement to NAFS may be used as a starting point to determine the wind pressure for glass strength calculations using ASTM E1300• The design wind pressures computed with CSA A440S1 are Serviceability Limit

State (SLS) values appropriate for deflection analysis

• In Canada glass design is based on Ultimate Limit State (ULS) loads

• To convert the CSA A440S1 SLS design pressure to a ULS design pressure it must be multiplied by 1.0/0.75 = 1.33

• The resulting pressure must also be multiplied by a load factor of 1.4

•Design pressure for use with ASTM E1300: CSA A440S1 DP x 1.33 x 1.4

DISCLAIMER: This slide presents information available to us at this time and does not constitute design advice.

FENESTRATION CANADA ADVISES CONSULTING A CANADIAN REGISTERED PROFESSIONAL ENGINEER FOR GLASS DESIGN IN CANADA

Can we use ASTM E1300 with CSA A440S1-17?

•Note that the Design Pressures determined using the CSA A440S1-17 Canadian Supplement cannot be used as inputs to ASTM E1300 or CGSB-12.20 without additional factors

•The most accurate (least conservative) glass design will be determined by engineering calculations based on the 1/50 HWP tables in Appendix C of the code

• Less precise, more conservative, and more convenient calculations can be performed using design wind pressures from CSA A440S1-17 (or the Fenestration Canada online calculator) with the appropriate factors

DISCLAIMER: This slide presents information available to us at this time and does not constitute design advice.

FENESTRATION CANADA ADVISES CONSULTING A CANADIAN REGISTERED PROFESSIONAL ENGINEER FOR GLASS DESIGN IN CANADA

Can we use ASTM E1300 with CSA A440S1-17?For calculations to determine CGSB-12.20 input values:

•Can use CSA A440S1 design pressure x 1.4 load factor• DP30 example: 30 psf x 1.4 = 42 psf (1440 Pa x 1.4 = 2016 Pa)

For calculations to determine ASTM E1300 input values:

•Can use CSA A440S1 design pressure x 1.4 load factor x 1.33 adjustment factor• DP30 example: 30 psf x 1.4 x 1.33 = 56 psf

In Canada, glass is designed to a higher wind pressure than the window or door product it is installed in

DISCLAIMER: This slide presents information available to us at this time and does not constitute design advice.

FENESTRATION CANADA ADVISES CONSULTING A CANADIAN REGISTERED PROFESSIONAL ENGINEER FOR GLASS DESIGN IN CANADA

Code enforcement of glass design

•Historically, code enforcement of the code’s glass design requirements has been weak to non-existent, and it is not clear to what extent Canadian and American manufacturers have addressed it

•Recent developments in the province of Ontario may be changing that . . .

New prescriptive glass tables in NBC 9.6

First, a bit of code context . . .

. . . for why the new glass tables have been added

•There are three subsections in Part 9 of the NBC that are critically important to understand the role of NAFS

• Subsection 9.7.3 presents the high-level performance expectations for ALL windows, doors and skylights

• Subsection 9.7.4 presents the NAFS compliance path which applies only to products in the scope of NAFS

• Subsection 9.7.5 presents a different compliance path which applies to products outside the scope of NAFS, which the code calls Site-Built products

First, a bit of code context . . .

First, a bit of code context . . .

Why are glass area tables in Part 9 of the code?

• In previous editions of the national code, glass tables were presented in the Appendix which is not normative

•This did not change when the 2010 code introduced NAFS

•The 2010 code created two categories of products: 1. Manufactured Windows, Doors and Skylights (products within the scope

of NAFS)

2. Site-Built Windows Doors and Skylights (products outside the scope of NAFS)

•The new glass tables are intended to apply to Site-Built products only . . .

Technically the glass tables apply only to Site-Built products

•The new glass tables are not mentioned in Subsection 9.7.4 because the code “knows” manufacturers are supposed to supply code-compliant glass

•The new glass tables are called for in Subsection 9.7.5

There is no explicit requirement in Section 9.6 for it to apply to Manufactured Windows

•The Code is apparently aware that NAFS-11 Clause 10.2.3.1 requires manufacturers to supply products with glass strength as required by local codes:

“. . . the selection of glazing for testing purposes shall be the weakest glass according to either glass strength Standard.” [ASTM E1300 or CAN/CGSB 12.20] The glazing for projects shall be the glazing required by the building code having jurisdiction, using the reference Standard specified in the building code.”

What about Manufactured products?

Ontario building officials

•Ontario building officials have come to believe that glass in windows supplied to the market may not conform to code, and that the tables in Section 9.6 should apply to all windows and glass doors, in all buildings in Part 9

•They have come to this conclusion in spite of the fact that Section 9.6 explicitly says the tables apply to site-built products which are defined as “product outside the scope of NAFS”.

•The glass tables are not that useful to manufacturers, as they address a limited range of dual pane glass options, and no triple pane options

The code language

The code language

Table for HWP < 0.55 kPa Rough Terrain(applies to all of Ontario)

Table for HWP < 0.55 kPa Open Terrain(applies to all of Ontario)

Glass in doors (no wind pressure or terrain limits)

Status of glass table issue in Ontario?

• Issue came to light in early March, just before the pandemic shutdown

• Fenestration Canada is working with our Manufacturers Council and Technical Services Committee on a response

Guard load on glass

Walls acting as guards

• In the NBC, wind is not the only design load applicable to glass in windows

•Code interpretations in several jurisdictions require exterior walls to act as guards where there is a height difference of 24 inches or more from the interior floor to an exterior surface ≥24 in. (600)

Windows acting as guards

≥24 in. (600)

< 42 in. (1070)

Windows acting as guards

•When window sills are below the guard height of 1070 mm (42 in.), windows are required to protect occupants from a falling injury

•The glass or a horizontal mullion must be designed to resist the same guard load as the wall

•This requirement is in Article 4.1.5.16, Loads on Walls Acting As Guards

≥24 in. (600)

< 42 in. (1070)

Windows acting as guards—enforcement

•This code requirement is not actively enforced because it is in Part 4 of the code, which deals with Structural Design

•Building officials are not generally aware of the need for windows with sills below guard height to act as guards

• Fenestration engineers aware of this requirement cannot ignore it, and glass in windows on large buildings is routinely designed for this condition

Windows acting as guards—enforcement

•Awareness of this requirement is greatest in British Columbia

•Canadian fenestration consulting engineers for large buildings are in general consensus that windows must be designed to resist the code-specified guard loads for walls

•On single family homes and Part 9 buildings, you will only encounter the need to address this if engineering by a licensed professional is required for some reason, such as qualifying unlabeled windows at untested sizes

Why local knowledge is more important than ever

Local knowledge is becoming essential

•Knowledge of local codes and local enforcement practices has always been a challenge when selling to multiple jurisdictions

•Tiered energy codes increase the challenge as jurisdictions are permitted to adopt more stringent requirements on a scale as small as that of rezoned properties

•The requirement for windows and glass to act as guards should be expected on large buildings, but may arise on small buildings if a local engineer is required to address a compliance concern, such as unlabeled windows supplied at sizes larger than tested

Local knowledge is becoming essential

•Enforcement of the Section 9.6 glass tables had just begun in Kitchener when the pandemic struck• Companies doing business in Ontario should be careful to proactively

address this concern with local dealers• Fenestration Canada is working on an industry response to this issue

•Companies relying on ASTM E1300 to design glass need to consider the implications the NBC 4.3.6.1 “adjustment factor” will have on qualifying glass for use in Canada

Thank-youThank-you