# "Window Film" added to glass in hazardous location



## Joe.B (Jan 21, 2021)

Just did a rough inspection on a high-end house and they had some windows that are essentially at the floor level and were not tempered glass (R308.4.3 violation). The homeowner was severely distraught because they are very expensive custom windows that are not available in tempered glass. I think they were hoping I would miss that. They came up with a solution that I think is pretty genius, they found a "window film" that can be applied (with special glue) to both the inside and outside to essentially make the window "laminated". Waiting now for the architect to show that the material meets the requirements of R308.6.2 (1). Has anybody seen this used, or approved? Any feedback or experience greatly appreciated.


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## Teeshot (Jan 21, 2021)

Be careful with that, and make certain that they provide adequate testing/evidence that this product, as an assembly, is equivalent as you may be setting a precedent.


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## Joe.B (Jan 21, 2021)

Yes, exactly my concern. That's why the Building Official is requiring their Architect to submit the evidence for review, not the home owner. I hope it works for them because otherwise they are going to be looking for paddles.


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## cda (Jan 21, 2021)

Safety window film
					

Does anyone know of a safety window film that was tested accordance with CPSC 16 CFR 1201 that a home owner can install themselves or do the all of them need to be installed by professionals?



					www.thebuildingcodeforum.com


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## cda (Jan 21, 2021)

https://multimedia.3m.com/mws/media/1173255O/3m-safety-window-films-safety-glazing-segment-card.pdf


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## Joe.B (Jan 21, 2021)

Thanks for the links, I will share this info. I like this solution a lot, sure is better than having to replace a window. Hopefully their Architect can find/provide documentation that shows compliance.


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## fatboy (Jan 21, 2021)

I have seen documentation, some of the stuff is pretty stout, better than tempered, but PRICEY!


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## steveray (Jan 22, 2021)

Joe.B said:


> and were not tempered glass (R308.4.3 violation).


Funny...Did a Glenn class today....Safety glazing is the requirement of which tempered is a type, not the only solution...Read it again...

The field applied stuff has some pretty tough installation instructions if you really drill into it....In my experience...


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## e hilton (Jan 22, 2021)

steveray said:


> The field applied stuff has some pretty tough installation instructions if you really drill into it.


Like ... doesn’t the film have to go to the actual edge of the glass, not just the visible portion of the glass?


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## Joe.B (Jan 22, 2021)

fatboy said:


> I have seen documentation, some of the stuff is pretty stout, better than tempered, but PRICEY!


Probably cheaper than a new window though right? Less wasteful for sure.


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## Joe.B (Jan 22, 2021)

steveray said:


> Funny...Did a Glenn class today....Safety glazing is the requirement of which tempered is a type, not the only solution...Read it again...
> 
> The field applied stuff has some pretty tough installation instructions if you really drill into it....In my experience...


"R308.4.3 violation" is in regards to the location, specifically less than 18" from bottom of window.  "...meets the requirements of R308.6.2 (1)" references the section that lists the acceptable materials, (1) being "laminated" glass, (2) being tempered glass. <Said in a sarcastic, snarky, joking tone> maybe _you_ should read it again  JK I hear you, but yes I've read the section carefully many times. I also pulled the code book out and went over it with the owner. I never write a correction without a code reference.


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## ICE (Jan 22, 2021)

Joe.B said:


> I also pulled the code book out and went over it with the owner. I never write a correction without a code reference.


You are setting a bad example for the rest of us.


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## Inspector Gift (Jan 22, 2021)

It is a great solution.    And I have approved that solution for several jobs.   I believe they all used a 3M product.


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## Glenn (Jan 22, 2021)

Joe.B said:


> "R308.4.3 violation" is in regards to the location, specifically less than 18" from bottom of window.  "...meets the requirements of R308.6.2 (1)" references the section that lists the acceptable materials, (1) being "laminated" glass, (2) being tempered glass. <Said in a sarcastic, snarky, joking tone> maybe _you_ should read it again  JK I hear you, but yes I've read the section carefully many times. I also pulled the code book out and went over it with the owner. I never write a correction without a code reference.


308.6 is for skylights and sloped glazing.
308.6.2 is for materials for skylights and sloped glazing.
Wrong subsection for a window.

308.3.1 provides the test standards for safety glazing used required in hazardous locations as referenced from 308.3

You mention less than 18 inches to the ground, but be sure the top edge is also more than 36 inches. A horizontal member often runs across large picture windows at 18 inches above the floor specifically to eliminate safety glazing requirements.

There are many window films tested to safety glazing standards. Search "smash and grab". They are primarily marketed for security not safety.

Exception 1 to R308.1 makes it pretty welcoming for a building official to accept "a certificate, affidavit or other evidence" for other than tempered glass.


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## steveray (Jan 22, 2021)

And the 9sqft right.....


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## Joe.B (Jan 22, 2021)

Glenn said:


> 308.6 is for skylights and sloped glazing.
> 308.6.2 is for materials for skylights and sloped glazing.
> Wrong subsection for a window.
> 
> ...


I apologize, I'm in CA and I have the 2019 CA Residential Code in front of me (same in 2016) The numbers I referenced are correct in CA only.


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## Joe.B (Jan 22, 2021)

Glenn said:


> 308.6 is for skylights and sloped glazing.
> 308.6.2 is for materials for skylights and sloped glazing.
> Wrong subsection for a window.
> 
> ...


Apologies, I misread what you wrote. You're referencing that the materials listed in 308.6.2 only apply to 308.6 and cannot be applied to requirements of 308.4. Understood and agreed. Where then are the acceptable materials listed to satisfy 308.4?


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## Joe.B (Jan 22, 2021)

Joe.B said:


> Apologies, I misread what you wrote. You're referencing that the materials listed in 308.6.2 only apply to 308.6 and cannot be applied to requirements of 308.4. Understood and agreed. Where then are the acceptable materials listed to satisfy 308.4?


Just what it says in 308.1 then?


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## Joe.B (Jan 22, 2021)

It's when you think you know something that you better realize you don't really know anything. Thanks for catching that and correcting me.


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## Glenn (Jan 22, 2021)

Joe.B said:


> It's when you think you know something that you better realize you don't really know anything. Thanks for catching that and correcting me.


First of all.  Dude, you are awesome.  This is how people are supposed to be able to talk and learn together.  Keep it up!

I really think you would have enjoyed my webinar yesterday. It was IRC Chapter 3, Glazing. It was all about 308.

308.1 is about identification of safety glazing.

You want to look at R308.3.1 Impact Test.  Here you get the CPSC 16 and the ANSI standard.  Next time you look at a tempered glass etching, take note that these are the two standards you will also see.

Each standard (CPSC and ANSI) have two test categories (A/B and I/II) In the text frame assembly, these correspond to a 100 lb shot bag swinging into the glazing from either an 18" lift or a 48" lift. The standards then provide details for how small the pieces break into or did they not break (collapse) at all. This is how the security films (does not collapse) are approved as safety glazing yet work so differently than tempered glass (small pieces). The code is incredibly complicated and specific when it gets into the details of when the two standards and two classes are permitted. Tempered glass is good for both standards at the 48" drop. So, naturally, everyone just uses tempered glass. Its a case where industry standard is so standard that it even throws off us code folks.

All good stuff. Glad to converse with you. Have a great weekend.


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## my250r11 (Jan 22, 2021)

No room to raise? Add a guard?


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## Joe.B (Jan 22, 2021)

ICE said:


> You are setting a bad example for the rest of us.


At first it was a self-preservation method because I was so new and unprepared for this job, it was a way to keep my opinion out of any official corrections. As time progressed it has been a way to keep me on good terms with the local builders as it was clear I was only following the rules and that corrections were nothing personal. I try to put myself in the builders shoes, and I have been the employee on jobs where a "know-it-all" said his way or the highway. Works for me here in my little island where I'm alone in a see of "I've been doing it this way for 30 years" kind of attitude. I may be in CA, but way up here it's kind of still a wild west mentality.


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## Joe.B (Jan 22, 2021)

my250r11 said:


> No room to raise? Add a guard?


These particular windows are in a unique location attached to the main bedroom (I don't like to use the term "master bedroom" due to its origin in slavery) that they are calling the "plant room". the floor is recessed and they are going to have a water-proofed floor and an exhaust fan. They have huge floor-to-ceiling windows on both south-facing and east-facing walls.


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## ADAguy (Jan 23, 2021)

Used films in embassy's in CA on existing single pane windows, impact and explosion resistant


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## mark handler (Jan 25, 2021)

I have allowed it as an alternate means, but required a manufacture's certified installer.


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## Glenn (Jan 25, 2021)

mark handler said:


> I have allowed it as an alternate means, but required a manufacture's certified installer.


But it's not an alternative.  Nothing in the code requires tempered glass for safety glazing.  Tempered glass is not the "prescriptive benchmark" for which an alternative must be weighed against.  The code requires the standards be met, that's it.  A product meeting the IRC referenced standards is NOT an alternate means.  It's code.

Like preservative treated lumber. There might be a common type sold in your area, but that's not code. Code just says any product that complies with AWPA U1. Same thing as this subject.


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## steveray (Jan 25, 2021)

Glenn,

I think what Mark was saying was that we are a little more comfortable when stuff comes from a factory than when JimBob puts it on in the field....Sometimes even if that factory has no oversight in another country and JimBob is an excellent craftsman....

I can't remember all of the details, but I had a 200 unit apartment building where they missed the "tempered" glass next to a lot of doors...I suggest they could do field applied but wanted the product info. When I got it, I told them what i wanted to witness per the install instructions in the field and they decided to swap the glass....


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## Glenn (Jan 25, 2021)

steveray said:


> Glenn,
> 
> I think what Mark was saying was that we are a little more comfortable when stuff comes from a factory than when JimBob puts it on in the field....Sometimes even if that factory has no oversight in another country and JimBob is an excellent craftsman....
> 
> I can't remember all of the details, but I had a 200 unit apartment building where they missed the "tempered" glass next to a lot of doors...I suggest they could do field applied but wanted the product info. When I got it, I told them what i wanted to witness per the install instructions in the field and they decided to swap the glass....


Yes, when it comes to "identification" to verify compliance of said "products" tested to referenced standards, the BO's discretion is required.  This is made clear in exception 1 to 308.1.  This is where your follow through with verification of the install is perfect.  

The only two times I have approved with in the field, they were professionally installed. JimBob would get more scrutiny, indeed.


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## mark handler (Jan 26, 2021)

Glenn said:


> But it's not an alternative.  Nothing in the code requires tempered glass for safety glazing.  Tempered glass is not the "prescriptive benchmark" for which an alternative must be weighed against.  The code requires the standards be met, that's it.  A product meeting the IRC referenced standards is NOT an alternate means.  It's code.
> 
> Like preservative treated lumber. There might be a common type sold in your area, but that's not code. Code just says any product that complies with AWPA U1. Same thing as this subject.


First of all I said nothing about Tempered glass.
Adding after the fact film to a window does not suddenly make it safety glazing.
The code does not offer a film option, you can use film, as long as it complies with xyz.
Instead,  For other than tempered glass, manufacturer's designations are not required provided that *the building official approves the use* of a certificate, affidavit or *other evidence confirming compliance with this code.*
The Alternate means process allows for additional information on the film and scrutiny of the film applier.


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## Glenn (Jan 26, 2021)

mark handler said:


> Adding after the fact film to a window does not suddenly make it safety glazing.


It does if it meets the test standards.  The code doesn't offer any "options" for safety glazing.  It just provides a test standard.  It doesn't put any compliant safety glazing above any other or suggest any type to anyone.

Every single product has to be installed correctly to perform as intended, of course. Whether window film (meets a test standard) or a fall protection device (meets a test standard).

The building official approval you have quoted is not an approval for a product that meets a referenced standard.  It's approval for a form of identification to prove said product meets the test standard.  That is the discretion provided by the code to the official, and I think the distinction is important for folks with authority over others to realize.

I don't mean to challenge you or put you on the defensive, Mark. My apologies if it ended up that way. The safety glazing provisions are very detailed and complicated in the IRC, and I believe too many building authorities gloss over the details and mis-represent the freedom the code actually allows our fellow Americans. This is my primary goal in my comments here. Not to win any argument.

[EDITED]  I read your comment a few more times and I think we are arguing semantics.  Pretty sure we agree, after all.  Ignore my preaching.  Sorry... teacher in me.  I'm just dead set on extracting every choice for the free people I possibly can out of the code.  That's my bias and it's showing! ha, ha!


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## BringitBrit (May 2, 2022)

I Have a bathroom that has an old window that the clients don't want to touch but inspector wants it to be safety glass or the protective film that meets building code, does anyone know of a product i can buy and install myself?  the inspector is going to check that it complies obviously. 
i did get a 3M dealer to quote, but when i came to delivery he ghosted me. probably because its too smaller job.


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## steveray (May 3, 2022)

BringitBrit said:


> I Have a bathroom that has an old window that the clients don't want to touch but inspector wants it to be safety glass or the protective film that meets building code, does anyone know of a product i can buy and install myself?  the inspector is going to check that it complies obviously.
> i did get a 3M dealer to quote, but when i came to delivery he ghosted me. probably because its too smaller job.


What is requiring the upgrade of the old window?


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## BringitBrit (May 3, 2022)

Hey! Thanks for the question.
It’s a 1930’s colonial with original sash windows, the room previously was a study and we converted to a bathroom, it was questionable whether the window was close enough to the tub shower to need upgrading and the client preferably wanted to avoid, lead time for the window was 5months and didn’t know what they wanted etc because they are planning at some point on doing all the windows. this is just so permit can get closed out.


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## steveray (May 3, 2022)

Ask the inspector if the would allow the window to be boarded up on the inside?

R308.4.5 Glazing and wet surfaces. Glazing in walls,
enclosures or fences containing or facing hot tubs, spas,
whirlpools, saunas, steam rooms, bathtubs, showers and
indoor or outdoor swimming pools where the bottom
exposed edge of the glazing is less than 60 inches (1524
mm) measured vertically above any standing or walking
surface shall be considered to be a hazardous location. This
shall apply to single glazing and each pane in multiple glazing.

I would argue if there is no exposed glazing, there is no exposed glazing......And then they can order the correct window and pull another permit for that...


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## BringitBrit (May 3, 2022)

*we actually did board up one of 2 windows where the tub went which was fine with him, but client wants this window for natural light, its big, 40 x 60 odd. its starting to sound like there just isn't an off the shelf product for this, *


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## Sifu (May 3, 2022)

It has been awhile since I dealt with these films but I do remember most being required to be installed by a certified (by the MFR) installer, and I think most ESR reports have the same language.

On another note, many windows are double pane or triple pane.  Per code each pane must be meet the safety standards.  I have always understood this to be because a "tempered" glass will shatter, but not shard, but wouldn't prevent the next pane in the assembly from breaking and sharding.  If memory serves, a lot of the films are not approved when exposed to the exterior, which presents a problem.  Maybe products have improved since I had this happen, but it is something to watch out for.  Not sure how a laminated glass or if a film that prevents collapse would apply to this logic.  It is not as simple as just a peel and stick...unless things have really changed.


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## Paul Sweet (May 12, 2022)

Could you install a clear plastic light (similar to an interior storm sash) inside the existing window?


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## Glenn (May 13, 2022)

Sifu said:


> It has been awhile since I dealt with these films but I do remember most being required to be installed by a certified (by the MFR) installer, and I think most ESR reports have the same language.
> 
> On another note, many windows are double pane or triple pane.  Per code each pane must be meet the safety standards.  I have always understood this to be because a "tempered" glass will shatter, but not shard, but wouldn't prevent the next pane in the assembly from breaking and sharding.  If memory serves, a lot of the films are not approved when exposed to the exterior, which presents a problem.  Maybe products have improved since I had this happen, but it is something to watch out for.  Not sure how a laminated glass or if a film that prevents collapse would apply to this logic.  It is not as simple as just a peel and stick...unless things have really changed.


The film satisfies the test standard by not collapsing (as you mention) and prohibiting a body from going through it.  This is similar to why glass block and continuously backed mirrors are exceptions.  In some locations, simply a bar in front is all it takes to be back to plain glass.  The glass still breaks all over you, but you won't go through it.  If the hazardous location is on the inside, and the inside pane is unbreachable, the outer pane is a non issue.  Just like if there was a pane of glass on the other side of a glass block wall.  I lean to looking at the code as a minimum standard and really seeking out the intent of the words.  I would have a hard time explaining to the public why the outer pane needs something when the inner pane can't be breached.


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## Glenn (May 13, 2022)




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## ICE (May 13, 2022)

steveray said:


> Ask the inspector if the would allow the window to be boarded up on the inside?
> 
> I would argue if there is no exposed glazing, there is no exposed glazing......


Really?  I would argue that there's a window facing, and within five feet of, a bathtub.

The film is a non-starter.  In the many dozens of times that safety glazing was not provided not once did anyone suggest fim much less install film.  Now I know that some of the forum members have seen it installed.  I get that the film is a viable solution....it's just that it sounds so dumb that nearly everyone says "forget the film."


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## steveray (May 16, 2022)

ICE said:


> Really?  I would argue that there's a window facing, and within five feet of, a bathtub.


So...if there is an intervening wall? I can get through drywall easier than plywood....

The good news is, if you worked for me, I wouldn't "make you" approve it if you were uncomfortable with an alternative...I would....


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## ICE (May 16, 2022)

steveray said:


> The good news is, if you worked for me, I wouldn't "make you" approve it if you were uncomfortable with an alternative...I would....


I can't recall a time when someone "made me" approve something.  It probably happened but as I grew into the job I came to realize that my decisions were my own.  I suppose that not working "for" someone made a difference.  

I worked with a few people that referred to me as their inspector as in, "I'll send my inspector."  At least I wasn't shining their shoes.


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## e hilton (May 16, 2022)

ICE said:


> I can't recall a time when someone "made me" approve something.


I thought I remembered several comments you made about your office manager overriding your inspection decisions.


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## ICE (May 16, 2022)

e hilton said:


> I thought I remembered several comments you made about your office manager overriding your inspection decisions.


That was commonplace.  Managers came up with all manner of strange things.  Managers told me that I was not allowed to write corrections.  What they did not succeed in doing was to get me to go along with it.  I could be overridden by assigning another inspector or their signature but if I didn't want to approve something there was damned little that they could do about it.

I was insulated by civil service rules and more importantly, I was correct.  When I did acquiesce it was because I was wrong to begin with.  More than once I was threatened with being charged with insubordination..... I rose to that challenge and they folded.  You have to understand that the organization was rife with corruption of the soul.  There's only so much that anyone can do to me when the entire apparatus is fouled with neglect.

Independence comes with a price.  There's 120,000 people working for LA County.  I was inspecting a new furnace and AC when the owner asked for my name.  Upon hearing my name he said that he has heard about me.  I was surprised until he told me that he works for the airrport division of public works.  The point being, if you desire to advance in rank it's best if the airport division employees do not know a story that starts with your name.


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## ADAguy (May 17, 2022)

so, is a drop test better than a "swing " test of the weight?


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## mark handler (May 18, 2022)

ADAguy said:


> so, is a drop test better than a "swing " test of the weight?


3M Window film


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