# Permits for Window Replacements



## jar546 (Aug 17, 2019)

In many areas permits are not required for replacement windows unless they involve an egress window and sometimes, not even for that.  I never liked the fact that in some towns we did not do replacement window inspections because I found so many of them installed improperly, especially when it came time for window flashing and energy code but hey, it is what it is and I guess it is buyer beware.

Then I moved to south Florida about 7 years ago and that all changed.  I am now in a different world where you absolutely, positively require a permit and often 2 inspections, an in progress or "buck" inspection and a final.  Due to the high wind zone we are in, 170mph+, and high positive and negative pressures, windows have to meet a lot of requirements and require an NOA or Notice of Approval by the state of Florida.  Each manufacturer and each window must come with an NOA.  The NOA gives you different methods of attachment and is an absolute must in order to perform your inspection because every window type had different anchoring requirements.

It starts with plan review which has to verify the wind zone and exposure category along with mean roof height, the height of the window to get the minimum pressures then matching up the NOA's to the window and location and verifying the window's design pressures meet or exceed the calculated wind pressures.  The NOA has to be current and be approved for the current code cycle.  Once this information is verified, a permit can be issued and a copy of the NOAs must be kept on the jobsite.  On to inspections.

Some municipalities require buck inspections to make sure that the buck was properly installed and to verify which method of attachment the contractor will use as there are sometimes several or at least 2 options.  Many municipalities just require that the contractor take photos during the change out and provide photos and an affidavit for the final inspection.  For final, the attachment screws need to be verified and match the NOA and the window sticker must be kept on until the final inspection is over, otherwise it is difficult to match up and verify the NOA.  The NOA is used to verify compliance with the screw pattern, size and depth included.  The contractor will have to back out a few screws to verify they are using the right ones.  Here are some photos from NOAs that need to be on the jobsite for all inspections.  This process and inspections are taken very seriously here.  I am just giving the basics and this is not an all encompassing post, just the basics.

It is not uncommon to have an engineer's stamp with drawings and charts for a replacement window/door job, especially in commercial buildings and mid or high-rise condos.

What does your area do about replacement windows?


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## Pcinspector1 (Aug 18, 2019)

No permit required for replacement windows unless thier messing with the header framing or egress window.


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## e hilton (Aug 18, 2019)

Around here ... replacement windows means they pop out the old sash, pop in a new one, and as you write the big check they try again to tell you how much money you will save every month.


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## ADAguy (Aug 19, 2019)

Pcinspector1 said:


> No permit required for replacement windows unless thier messing with the header framing or egress window.


Not concerned about wind loads?


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## jar546 (Aug 19, 2019)

ADAguy said:


> Not concerned about wind loads?



Exactly.  Now that the majority of the country has been moved to the 115mph wind zone, how is this being verified?  If wall framing is important, so are the windows.  I started the thread below for this reason to be discussed:

https://www.thebuildingcodeforum.com/forum/threads/verifying-window-compliance-for-wind-loads.26689/


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## mark handler (Aug 19, 2019)

Mixed bag in So. CA
Some Jurisdictions require it, some don't.
Confuses the H*ll out of the contractors
Some BO's say they can't spend the resources to inspect all the windows, so they allow the foxes to watch the hen house by allowing self-certs.


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## rktect 1 (Aug 19, 2019)

I hate these things.  We unfortunately do require a permit for them.  One inspection and it is mostly energy efficiency that we look at as well as required tempered glass areas.  We do our best with EERO but will allow a replacement window into the old rough opening, not into the old frame, which means a new construction type window not a tilt in type for EERO.


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## mtlogcabin (Aug 19, 2019)

jar546 said:


> Now that the majority of the country has been moved to the 115mph wind zone,


This is in reference to the 2012 and 2015 codes.

ASCE 7-10, “Minimum Design Loads for Buildings and Other Structures”, introduces significant changes to wind load design. The 2010 edition is the first edition of ASCE-7 where the basic wind speed map from ASCE 7’s previous editions has been replaced with three ultimate design wind speed maps; one for each Occupancy Category. These “ultimate” wind speeds are higher than “nominal” or “basic” wind speeds that you have used in the past, *but do not fear, the resulting loads and reactions (uplifts) will be very similar to what you are used to.*

3 second gust
Sustained wind speed or
Ultimate Design Wind
They will all give you very similar designs. It is the exposure categories especially exposure "D" that will have significant load increases. We use exposure "C" but in reality once a subdivision is built out in 1-5 years it is then an exposure "B" by definition


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## tmurray (Aug 19, 2019)

We require permits. 

At the permit application stage, the applicant must provide the manufacturer's specification to ensure the windows meet the energy requirements of the code and the performance requirements of the A440 amalgamated standard. 

We only do a final inspection after the job is complete. We are only able to verify the flashing at this stage, but is the best we can do with our current load.


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## ADAguy (Aug 19, 2019)

This remains an ongoing permitting issue in older (pre 70's homes) change outs are more obvious and often cited by home inspectors at time of sale.


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## Rick18071 (Aug 19, 2019)

Don't need any permits for existing houses to do anything unless a structure change is done in PA. Some locals require more but I never herd of any window replacement permits required.


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## ADAguy (Aug 19, 2019)

Obviously a "Free" state, eh?


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## Rick18071 (Aug 20, 2019)

ADAguy said:


> Obviously a "Free" state, eh?



I don't make the rules. But there have been many discussions on what is a structure change is like if drilling a hole in a stud is a structure change. And we can only go by what the owner or contractor says their doing in the house. We might get curious when we see full dumpsters and contractor trucks at a house but I can only ask them to get a permit if they doing structure changes. So I guess that means it would be by the contractors option of what a structure change is.


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## ADAguy (Aug 20, 2019)

As always, "it depends" on the: what, where and when of the altered elements.


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## jar546 (Aug 20, 2019)

Rick18071 said:


> I don't make the rules. But there have been many discussions on what is a structure change is like if drilling a hole in a stud is a structure change. And we can only go by what the owner or contractor says their doing in the house. We might get curious when we see full dumpsters and contractor trucks at a house but I can only ask them to get a permit if they doing structure changes. So I guess that means it would be by the contractors option of what a structure change is.



So look at it this way.  Sheathing on a roof is a structural component.  Plywood or OSB on the outside walls are a structural component.  Since they have to comply with wind load designs, window, too, are part of the structure that is being modified.  That is not a stretch, that is a fact.


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## mtlogcabin (Aug 20, 2019)

Check out this site for wind, snow and seismic by zip code
https://hazards.atcouncil.org/#/
JAR
I believe you would need a Risk Category III  building and close to the coast before you are designing to 170 MPH wind unless Fl has some amendments


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## jar546 (Aug 21, 2019)

mtlogcabin said:


> Check out this site for wind, snow and seismic by zip code
> https://hazards.atcouncil.org/#/
> JAR
> I believe you would need a Risk Category III  building and close to the coast before you are designing to 170 MPH wind unless Fl has some amendments



Thanks, unfortunately it is not helpful due state, county and local amendments.  I tried it for FL and PA and did not find it to be useful.  Even with snow load it referred to CS or case study.


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## jar546 (Jun 10, 2020)

_R609.2  Performance.  Exterior windows and doors shall be capable of resisting the design wind loads specified in Table R301.2(2) adjusted for height and exposure in accordance with Table R301.2(3) or determined in accordance with ASCE 7 using the allowable stress design load combinations of ASCE 7.

R609.3  Testing and labeling.  Exterior windows and sliding doors shall be tested by an approved independent laboratory, and bear a label indentifying manufacture, performance characteristics and approved inspection agency to indicate compliance with AAMA/WDMA/CSA 101/I.S./A440.
_
We can then talk about anchoring methods (R609.7), energy code requirements, mullions, etc.  My comment is this:

If you don't require permits for replacement windows then what is your justification for not requiring a permit and inspection?  Do you minimize the importance?  Is it an inconvenience?


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## mtlogcabin (Jun 10, 2020)

We do not require an inspect for window placement on new construction so logically we would not require a permit and inspection for replacement windows.
The majority of the time the windows are not in place during framing. They are there during insulation and it is a 50/50 chance the siding is not on so we can observe the flashing and taping at that time. 

Then again all we see are flush mount windows with nailing fins


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## jar546 (Jun 11, 2020)

mtlogcabin said:


> We do not require an inspect for window placement on new construction so logically we would not require a permit and inspection for replacement windows.
> The majority of the time the windows are not in place during framing. They are there during insulation and it is a 50/50 chance the siding is not on so we can observe the flashing and taping at that time.
> 
> Then again all we see are flush mount windows with nailing fins



At what point do you verify window flashing and energy efficiency along with wind pressure compliance?


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## mtlogcabin (Jun 11, 2020)

Energy efficiency is verified by the sticker on the window which is there until it is cleaned for the final. Since we are in one zone (6) for the entire state only the required U-Factor window is stocked by the suppliers and big box stores. As for the flashing sometimes we see it and sometimes we don't and as for wind pressure we do not verify that the windows are compliant. Even though the terminology as changed, 3-second gust, sustained wind speed or ultimate wind speed the end result is basically the same for design of the window.  Neither the IBC or the IRC require an inspection for window installations. The majority of inspections are only a representative sampling of the work being done and as code officials we have to determine what is a priority to inspect and what is not. I think we can all agree that life safety items take priority in the inspection process energy codes and the proper flashing of a window will be further down the list. As for high wind coastal areas and the wind borne debris requirements that would probably be right up there with a life safety inspection requirement IMHO and windows should be permitted and inspected.


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## Mark K (Jun 11, 2020)

The Contractor does not determine what is structural work.  That is a  function of the building department.


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## my250r11 (Jun 11, 2020)

mtlogcabin said:


> Energy efficiency is verified by the sticker on the window which is there until it is cleaned for the final. Since we are in one zone (6) for the entire state only the required U-Factor window is stocked by the suppliers and big box stores. As for the flashing sometimes we see it and sometimes we don't and as for wind pressure we do not verify that the windows are compliant. Even though the terminology as changed, 3-second gust, sustained wind speed or ultimate wind speed the end result is basically the same for design of the window.  Neither the IBC or the IRC require an inspection for window installations. The majority of inspections are only a representative sampling of the work being done and as code officials we have to determine what is a priority to inspect and what is not. I think we can all agree that life safety items take priority in the inspection process energy codes and the proper flashing of a window will be further down the list. As for high wind coastal areas and the wind borne debris requirements that would probably be right up there with a life safety inspection requirement IMHO and windows should be permitted and inspected.



Some places don't do roofs either. Our state has the stand if it is not specifically exempt then it requires a permit. 
I agree door and window replacements are not high on the list but the State tell us to do so we do. Poor flashing of openings or roofs can be very costly to a homeowner. The code is to protect life And property. Just my 2 cents lol.


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## ADAguy (Jun 11, 2020)

mark handler said:


> Mixed bag in So. CA
> Some Jurisdictions require it, some don't.
> Confuses the H*ll out of the contractors
> Some BO's say they can't spend the resources to inspect all the windows, so they allow the foxes to watch the hen house by allowing self-certs.



Another field for the 'Suits" to plow.


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## tmurray (Jun 11, 2020)

One of the things I find often gets overlooked is that here, our code not only looks after life safety, but the health of the occupants. Water infiltration into the building envelope can have very serious negative impacts on occupant health. One would argue this could eventually become a structural and life safety issue as well, but how far do you chase that rabbit down the hole?


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## steveray (Jun 19, 2020)

Agree with you TM, just no time...We used to do a progress roof inspection, but not anymore due to staffing..


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## ADAguy (Jun 19, 2020)

Nasty "S" word again


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## jar546 (Jun 20, 2020)

So basically some municipalities just downplay the importance of window installations as not important.  If that is the case then why do sheathing inspections?


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## ICE (Jun 20, 2020)

What about safety glazing?


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## Mark K (Jun 20, 2020)

If the work is limited to replacement of the window sash it is considered a repair and is not subject to newer energy requirements.


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## Min&Max (Jun 22, 2020)

As long as the rough opening is not being made larger we do not require a permit. When replacing egress window openings cannot be made substantially smaller, again, a permit is not required.


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## jar546 (Jan 21, 2021)

Mark K said:


> If the work is limited to replacement of the window sash it is considered a repair and is not subject to newer energy requirements.


In Florida, it depends on what percent of the windows are being replaced concerning energy compliance.


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## MACV (Jan 24, 2021)

Such issues are often covered in a code for existing buildings.


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## fatboy (Jan 24, 2021)

Almost hate to post reply, for the backlash, but same camp as no permits unless openings enlarge horizontally. Safety glazing inspected at rough-in, see flashing at weather barrier, energy requirements are taken care of with the third-party energy certificate at final. 115 mph wind zone.


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## jar546 (Jan 25, 2021)

fatboy said:


> Almost hate to post reply, for the backlash, but same camp as no permits unless openings enlarge horizontally. Safety glazing inspected at rough-in, see flashing at weather barrier, energy requirements are taken care of with the third-party energy certificate at final. 115 mph wind zone.


Thanks for sharing.  Again, how are windows not structural like sheathing when there is a wind pressure requirement?


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## Beniah Naylor (Jan 25, 2021)

In our jurisdiction, for all of the new houses, the structural sheathing is calculated to be strong enough independent of the windows, and (almost) all of the windows are the nailing flange type previously mentioned. 

Since the windows don't hold anything up or together, the logic is that they are not structural.

We don't really worry about the energy efficiency requirements - everybody uses the same two brands of windows, you either buy them from one big box store or the other... we haven't noticed any problems.

No flashing being installed, or installed incorrectly, could definitely cause water leakage. 

We catch safety glazing issues at the framing inspection or the final.

We don't inspect window replacements because of time and resources. Maybe we should, but with a small department you have to prioritize...


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## Joe.B (Jan 25, 2021)

This is one of those grey areas, right? Situation specific? A lot of these replies covered many of the concerns, but I'll throw something out there just for conversation. If we (as a building department) permit something then we are responsible for making sure it's done right, yes? If we do not permit something then it's the owners responsibility, no? Worst case scenario, if someone replaces a bedroom window with a non-egress window, without a permit or inspection, and someone dies as a result, is the city liable in any way? Same scenario but they do get a permit and it's missed on inspection, or no inspection, is the city liable then? That's the extreme, but same logic applies to warranties or insurance claims. This is the discussion I like to have with customers in these grey areas. "If you do this work on your own it's your responsibility to do it right and you take on any liability. If you want our services we will issue a permit and provide our services." There are grants that a couple of local agencies can get for upgrading customers to energy efficient windows or clean burning wood stoves, the grants require permits and inspections. That's where I see window permits pulled most. Occasionally I get a customer who likes having us involved so we help out.


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## ADAguy (Jan 25, 2021)

great topic jar, 

now if you can just eliminate the initial ad from the opening site and the recent "X- rated" ads, whats with those?


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## jar546 (Jan 25, 2021)

ADAguy said:


> great topic jar,
> 
> now if you can just eliminate the initial ad from the opening site and the recent "X- rated" ads, whats with those?


Everyone's ads are different and Google based so I never see what others see.  At work, I see no ads because of the restrictions.


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## fatboy (Jan 25, 2021)

jar546 said:


> Thanks for sharing.  Again, how are windows not structural like sheathing when there is a wind pressure requirement?


Piss poor excuse, but I inherited the policy, and have never had the urge to revisit it, due to lack of problems with it.


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## Sifu (Jan 26, 2021)

mtlogcabin said:


> This is in reference to the 2012 and 2015 codes.
> 
> ASCE 7-10, “Minimum Design Loads for Buildings and Other Structures”, introduces significant changes to wind load design. The 2010 edition is the first edition of ASCE-7 where the basic wind speed map from ASCE 7’s previous editions has been replaced with three ultimate design wind speed maps; one for each Occupancy Category. These “ultimate” wind speeds are higher than “nominal” or “basic” wind speeds that you have used in the past, *but do not fear, the resulting loads and reactions (uplifts) will be very similar to what you are used to.*
> 
> ...


Wind speeds are a quagmire but I have arrived to the exact same place as you.


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## jar546 (Jan 26, 2021)

Beniah Naylor said:


> In our jurisdiction, for all of the new houses, the structural sheathing is calculated to be strong enough independent of the windows, and (almost) all of the windows are the nailing flange type previously mentioned.
> 
> Since the windows don't hold anything up or together, the logic is that they are not structural.
> 
> ...



That is great that structural sheathing is calculated that way but all is lost when the windows are compromised.  I still believe that this is one of the most neglected parts of the code that is in black and white yet we continue to find excuses as to why we don't have to verify compliance because "that's the way it has always been don."  I am not bashing but I am pretty hot on this subject.  I think that we need to step up to the plate rather than rely on the past.  With changing wind zones, it is more important than we may have bee use to.


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## steveray (Jan 26, 2021)

The windows don't resist shear like the sheathing does....Their structural requirements are unto themselves and do not affect the rest of the structure except for you high wind missile folks. And I believe that is a pressurization thing, not shear.......Like FB....We don't really inspect them so I wish we did not take permits for them...


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## jar546 (Jan 26, 2021)

steveray said:


> The windows don't resist shear like the sheathing does....Their structural requirements are unto themselves and do not affect the rest of the structure except for you high wind missile folks. And I believe that is a pressurization thing, not shear.......Like FB....We don't really inspect them so I wish we did not take permits for them...


There is more than sheer involved but everyone keeps focusing on sheer.  Wind pressures, wind pressures, wind pressures.


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## steveray (Jan 26, 2021)

Got it...answered in the other thread.....I think most of us don't have time to do all of the inspections we would like to do. I have never heard of that type of failure around here (so can't justify the inspection), maybe at the shore, I will ask some of my buds down there next time I see them...


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## tmurray (Jan 26, 2021)

Is compliance with the performance requirements of the A440 amalgamated standard required for you folks?

This came into our code 5 years ago and was initially a headache to enforce, but has gotten a lot better. Unlike the US where are the performance requirements are bound to the performance grade, in Canada we look at the positive and negative design pressures, water penetration rate, and air infiltration( only required in Canada under the Canadian supplement) in isolation. 

When we first started inspecting, many of the suppliers and even some of the manufacturers were sending windows that did not meet code into our market. Usually we were able to catch this at the time of ordering (we ask for the suppliers spec sheet as part of the permit process). So most of the time we catch it before the windows are even started at the factory. We continue to have some problems with a particular big box store that is associated with the colour orange. 

The issues can either be window failure due to excess deflection where the proper negative or positive design pressures are not used, the window leaking water where the proper water penetration pressure is not met, and in Canada, drafty windows where the air infiltration rate is not met.

We have a local home warranty company that tells us that their average cost of repair for a single leaky window is $7,000.


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## steveray (Jan 26, 2021)

Yes...

R609.3 Testing and labeling. Exterior windows and sliding
doors shall be tested by an approved independent laboratory,
and bear a label identifying manufacturer, performance characteristics
and approved inspection agency to indicate compliance
with AAMA/WDMA/CSA 101/I.S.2/A440. Exterior
side-hinged doors shall be tested and labeled as conforming
to AAMA/WDMA/CSA 101/I.S.2/A440 or AMD 100, or
comply with Section R609.5.


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## jar546 (Jan 26, 2021)

tmurray said:


> Is compliance with the performance requirements of the A440 amalgamated standard required for you folks?
> 
> *This came into our code 5 years ago and was initially a headache to enforce, but has gotten a lot better*. Unlike the US where are the performance requirements are bound to the performance grade, in Canada we look at the positive and negative design pressures, water penetration rate, and air infiltration( only required in Canada under the Canadian supplement) in isolation.
> 
> ...



And there it is


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## ICE (Jan 26, 2021)

Our Existing Building Code found in the CRC has quirks that seemingly make no sense.

_AJ102.4.3 Emergency escape and rescue openings.
Where windows are required to provide emergency escape and rescue openings, replacement windows *shall be exempt from *the maximum sill height requirements of Section R310.2.2 and the requirements of Sections R310.2.1 and R310.2.3 provided that the replacement window meets the following conditions:
1. The replacement window is the manufacturer’s largest standard size window that will fit within the existing frame or existing rough opening. The replacement window shall be permitted to be of the same operating style as the existing window or a style that provides for an equal or greater window opening area than the existing window.
2. The replacement window is not part of a change of occupancy.
3. Window opening control devices complying with ASTM F2090 shall be permitted for use on windows required to provide emergency escape and rescue openings._


If a retro-fit, block type, window is installed, an arguement can be made that fall protection is not required.

_AJ102.4.4 Window control devices.
Where window fall prevention devices complying with ASTM F2090 are not provided, window opening control devices complying with ASTM F2090 shall be installed where an existing window is replaced and where *all of the following* apply to the replacement window:
1. The window is operable.
2. The window replacement *includes replacement of the sash and the frame.*
3. The top of the sill of the window opening is at a height less than 24 inches (610 mm) above the finished floor.
4. The window will permit openings that will allow passage of a 4-inch-diameter (102 mm) sphere where the window is in its largest opened position.
5. The vertical distance from the top of the sill of the window opening to the finished grade or other surface below, on the exterior of the building, is greater than 72 inches (1829 mm).
The window opening control device, after operation to release the control device allowing the window to fully open, shall not reduce the minimum net clear opening area of the window unit._


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## tmurray (Jan 27, 2021)

It honestly is not that hard once we worked the kinks out. The supplier's quote sheet has the information on it, so we get it as part of the permit application. Even if most are not showing it now, it's usually just an option they need to turn on.

We had a local company that caries an international manufacturer of windows who did not have the functionality in their software, so the supplier had to submit the test results with every package. The manufacturer kept putting them off as to when the information was to be added to the quoting software, so the local company dropped the line.


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## jar546 (Mar 2, 2022)

So where are all of you verifying the wind pressure ratings of windows?  Let's forget about replacement windows, and just talk about new construction.  Rather than getting hung up on the U-Factor, the wind pressure rating is more important since it has to do with the membrane of the structure.


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