# Window sill guards and EE openings



## Sifu (Apr 27, 2012)

IRC 2006, 613.2 Window sills.  Requires guards on windows >72" above grade & <24" AFF which prevent opening >4".

IRC 2006, 310.1 Emergency escape openings.  Requires minimum clear openings without keys, tools or special knowledge.

If a compliant EE opening is located >72" above grade and < 24" AFF and is the only window in a bedroom can these codes both be complied with?

The code permits an ASTM F 2006 or 2090 device by exception, maybe those devices address the concern.  Anybody seen those listings?  The devices I have seen require an extra motion and special knowledge but maybe they are not the listed devices.

The code does not apply to fixed windows, had a builder try to screw a window shut.  I said not permitted (not an EE opening) but now am wondering why.  No different than a builder putting up a handrail then taking it down after I leave, right?

Got a house full of casements set lower than 24" AFF.  Wondering what device would be installed on them.


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## mtlogcabin (Apr 27, 2012)

The 2009 edition adds some clarity for limiting devices

 R612.4 Window opening limiting devices.

When required elsewhere in this code, window opening limiting devices shall comply with the provisions of this section.

R612.4.1 General requirements.

Window opening limiting devices shall be self acting and shall be positioned to prohibit the free passage of a 4-in. (102-mm) diameter rigid sphere through the window opening when the window opening limiting device is installed in accordance with the manufacturer's instructions.

R612.4.2 Operation for emergency escape.

Window opening limiting devices shall be designed with release mechanisms to allow for emergency escape through the window opening without the need for keys, tools or special knowledge. Window opening limiting devices shall comply with all of the following:

1. Release of the window opening-limiting device shall require no more than 15 pounds (66 N) of force.

2. The window opening limiting device release mechanism shall operate properly in all types of weather.

3. Window opening limiting devices shall have their release mechanisms clearly identified for proper use in an emergency.

4. The window opening limiting device shall not reduce the minimum net clear opening area of the window unit below what is required by Section R310.1.1 of the code.


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## rogerpa (Apr 27, 2012)

ASTM F 2006 was removed from the 2009 IRC because it is not appropriate in the IRC (residential 3 stories or less).

ASTM F 2090 *1. Scope*

1.1 This specification establishes requirements for devices  intended to address the risk of injury and death associated with  accidental falls from windows by children five years old and younger.

1.2 This specification is not intended to meet the unique requirements of Americans With Disabilities Act (ADA).

*1.3  This specification applies to window fall prevention devices that are  to be used on any windows, including those that are designated for  emergency escape (egress) and rescue (ingress).*

Note 1—A separate safety specification, Safety Specification F 2006,  covers window fall prevention devices for non-emergency escape (egress)  and rescue (ingress) windows in installations more than 75 feet (23 m)  above ground level in multiple family dwelling buildings.

ASTM F2006 *1. Scope *

1.3 This safety specification applies only to devices intended to be  applied to windows installed at heights of more than 75 ft  (23 m) above  ground level in multiple family dwelling  buildings. *This safety  specification is not intended to apply to windows below 75 ft (23 m)  because all windows below 75 ft (23 m) that are operable  could be used  as a possible secondary means of escape.*


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## Francis Vineyard (Apr 27, 2012)

At first several major window manufacturers were not up to date and had to quickly make retrofits for existing windows.

http://angel-ventlock.com/product.php

http://angelguards.com/

http://www.stopat4.com/wp-content/uploads/2011/02/Windows-Fall-Prevention-Safety-Products-Overview.pdf



Francis


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## Sifu (Apr 27, 2012)

Many thanks, should have though of looking at newer codes myself.  Does the 2090 standard give specific requirements for these devices?  Should the devices have the listing on them?  Anyone have thoughts on the "I'll just screw the window shut" approach?


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## Francis Vineyard (Apr 28, 2012)

Is the screw the non-EE&RO window shut any different than over-riding the installed device or permanently removing the listed guards?

I don't see the screw it shut approach as a modification, but should you allow it as an alternative method; document it.

Francis


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## Sifu (Apr 28, 2012)

Like I said in the OP, I don't see a big difference in the the screw it shut approach and the handrail to pass inspection approach.  Both would meet the code on the day of inspection.  I don't think the inspector has a great responsibility to prevent willfull disregard after initial compliance.  As with any situation like this I take pics and document when I believe a condition exists that is a temporary measure meant only to pass an inspection.  In the case this post was started over I convinced the builder that it was far easier to just install a listed device, which he did, which is often the case when I explain how even a temporary handrail/guard must meet the codes.  However, I am sure the question will come up again and again....and again.


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## GBrackins (Apr 28, 2012)

Sifu,

just remember section R303.1 on inspection day. if it's screwed shut can your still provide natural ventilation (4% of the room's square footage) through windows?


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## Sifu (Apr 28, 2012)

I have fallen back to that section in the past but never really gotten a lot of traction out of it.  I often see rooms without natural light or ventilation that could be considered habitable.  The sticky point is the exception allowing the absence of such light and ventilation when artificial light and mechanical ventilation are provided.  I assume (I know, maybe a mistake) the HVAC system provides the required air change and the light provides the required illumination listed in the exceptions and really wouldn't want to press that calculation or test without substantial reasons.  In this particular case I did consider it but since there is another window that did not require the window guards that would provide the required ventilation that provision wasn't in play.

The reality is this large home had one window that required a guard to satify what I consider a nanny-state code.  I encouraged compliance with the intent of the code but wasn't sure about the letter of the code (fixed window) when asked about a way around it.  I told them they could not screw it shut but wasn't satisfied that I was 100% correct.  The builder did the smart thing and I wasn't forced to defend it but I still like clarity.


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## Francis Vineyard (Apr 28, 2012)

Consistent approaches with installation of materials, equipment and devices are installed in accordance to their listing and meet manufacturer’s warranty. Occasionally alterations are made to satisfy the intent but I do not allow being the exceptions to the rule.

IMO, in this OP the cost is nominal it can be easily be made to meet the both the manufacturer and code requirements.

Francis


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## FM William Burns (Apr 28, 2012)

Ironically, I was just asked a question about a type of related situation yesterday by a manufacturer.  I informed the caller that residential EERO windows have to be 

*operable to and with* opening provisions in accordance with R310 without requiring the use of “special knowledge”.



R612.4.2 [4] sets the EERO opening to 5.7.s.f.  

ASTM F2090 says the release mechanism must be operated by either two independent single actions or one dual action. IMO that is special knowledge.



So, do EERO’s have to have opening limiting devices?


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## peach (Apr 29, 2012)

making sure the sill is >24" AFF at framing inspection is the easiest way to ensure compliance (and reduce the arguements).


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## Sifu (May 2, 2012)

FM William Burns said:
			
		

> Ironically, I was just asked a question about a type of related situation yesterday by a manufacturer.  I informed the caller that residential EERO windows have to be *operable to and with* opening provisions in accordance with R310 without requiring the use of “special knowledge”.
> 
> 
> 
> ...


I think the code says yes but I also think the code conflicts itself here, at least in the 06.  Maybe the 09 or 12 has worked it out but I havn't got to them yet.


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## floydman (May 3, 2012)

here is another link to opening limiting devices

http://www.andersenwindows.com/servlet/Satellite/AW/Page/awGeneral-3/1251716419235


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## peach (May 6, 2012)

I saw some window opening limiters the other day that I really like.  All you need to do is push the limiter back into the window frame (a little button resets them).  It may require "special knowledge" to open them, but little kids shouldn't be trying to escape by themselves... it's called parenting.


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## Sifu (May 6, 2012)

peach said:
			
		

> it's called parenting.


AMEN!  What I've been saying about this one.


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## Cincinati (May 7, 2012)

Sorry, what

you are best!


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## FM William Burns (May 7, 2012)

sifu said:
			
		

> I think the code says yes but I also think the code conflicts itself here, at least in the 06. Maybe the 09 or 12 has worked it out but I havn't got to them yet.


Yea, they still conflict.  I advised the customer that if the sill is >24" AFF and within 2 stories EERO window does not have to have the OLD since that's how I interpret the conflicting directions for safety (right or worng)


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