Product Approvals in High-Wind and Wildfire States

Why this matters

In most of the country, a product with a recognized listing mark and installation instructions is enough for the inspector. In hurricane country and in wildfire zones it often is not. Florida, Miami-Dade and Broward counties, coastal Texas for insurance purposes, and California's fire hazard zones each run their own approval or listing systems on top of the national ones, and a garage door, window, roof covering, vent or skylight that is perfectly listed can still be rejected because it has no approval number in the system that governs that address. The rejection comes at final inspection, after the product is installed, which means tearing it out. The check takes ten minutes before you order.

What a state or county approval adds to a listing

A listing (see related: Listed, Labeled and Approved: Three Words That Are Not the Same) tells you a testing laboratory evaluated a product against a standard. A state or county product approval is a separate administrative act: a government body reviews the test reports, the engineering and the installation method, and issues an approval number for use in its jurisdiction. Three things come with that number that a listing alone does not give you.

• A rated performance figure tied to the local design requirement. For wind products, that is usually a design pressure, positive and negative, in pounds per square foot, and sometimes an impact rating for windborne debris. The product has to meet or exceed what the opening requires.
• An installation drawing that is part of the approval. Fastener type, spacing, edge distance and substrate are specified. Install it any other way and you have installed an unapproved product, even with the approved door.
• A validity window. Approvals carry an expiration date or are tied to a specific edition of the state code, and they get revised when the code changes. An approval number on a two-year-old brochure may be superseded.

These systems sit on top of listing, not instead of it. You need both where both apply.

Florida's product approval

Florida runs a statewide product approval system under Florida Statutes section 553.842 and the Florida Building Commission's rules (Florida Administrative Code Chapter 61G20-3). It covers building-envelope products in defined categories: exterior doors including garage doors, windows, skylights, storm shutters and other impact-protective systems, roofing products, panel walls, and certain structural components. Products in those categories need either a statewide approval (a number beginning with FL, followed by a revision suffix) or a local approval granted by the jurisdiction for that project.

The approval record states the product, the design pressures, any impact rating, the limitations (maximum size, required reinforcement, substrate), the installation instructions, and whether the product is approved for use in the High-Velocity Hurricane Zone. It is searchable by number, manufacturer or category through the Florida Building Commission's product approval search.

The High-Velocity Hurricane Zone

The Florida Building Code defines a High-Velocity Hurricane Zone (HVHZ) covering Miami-Dade and Broward counties, with stricter testing protocols and stricter installation rules. In the HVHZ a product needs approval specifically for HVHZ use. The best-known form is a Miami-Dade Notice of Acceptance (NOA), issued by the county's product control office after testing to the HVHZ protocols; a Florida approval marked for HVHZ use is the other path. NOAs carry expiration dates and are revised, so check the current one rather than the number printed on a carton.

Two practical consequences. A product approved statewide but not for HVHZ use is not acceptable in Miami-Dade or Broward. And HVHZ installation drawings tend to be more prescriptive about anchors into concrete masonry, which is how most houses there are built.

Coastal Texas: an insurance gate, not a building code

Texas has no statewide residential building code for unincorporated areas, and its windstorm program works through insurance. In the designated catastrophe area along the coast, a structure must be inspected and certified under the Texas Department of Insurance windstorm program to be eligible for coverage through the state's windstorm insurance association. The department maintains product evaluations for products used in that program.

So the binding mechanism is different: a homeowner who needs that coverage needs the work certified, and the certification needs products and installation the program accepts. A city in the area may also have its own adopted building code on top. Ask the customer early whether they carry, or will need, that windstorm coverage, because it changes what you can install.

California's wildfire-zone listings

California's wildland-urban interface rules (California Building Code Chapter 7A and California Residential Code Section R337, applying in designated fire hazard severity zones and other mapped areas) set ignition-resistant requirements for roofs, vents, exterior walls, eaves, decks, windows and doors. See related: The Wildland-Urban Interface Code in Plain Terms for what those rules require.

The approval layer is the State Fire Marshal's Building Materials Listing program, which lists products shown to meet the State Fire Marshal's test standards for these categories. Many inspectors in hazard zones look for the product in that listing. Vents are the item trades hit most: Chapter 7A, in recent editions, requires attic and foundation vents tested for ember and flame intrusion to a named ASTM standard, so a standard louvered vent or an ordinary bath-fan or dryer termination may not pass even though it is a listed product. Other states with wildfire codes (Oregon, Washington, Colorado and Utah have adopted or allowed local adoption of WUI rules in some form) may reference the International Wildland-Urban Interface Code rather than a state listing. Check the jurisdiction.

Worked example: a garage door in a coastal Florida county

A garage door shop replaces a 16 ft by 7 ft door on a concrete-block house in a coastal Florida county outside the HVHZ. The figures below are illustrative, chosen to show the method; real values come from the permit's wind design and the approval record.

Step 1: get the required design pressure for the opening. The building department requires the permit application to state the opening's design pressure from the wind design (calculated under the standard the Florida Building Code references). For this opening it comes to +28.2 psf positive and -31.6 psf negative. The negative number usually governs, because suction on the door is what tears it out.

Step 2: check the candidate doors.

Door A meets: -33.0 psf against a required -31.6 psf leaves 1.4 psf of margin on the governing side, and +30.0 against +28.2 leaves 1.8 on the other. Door B may be a good door, but "wind rated" printed on a carton is a marketing phrase, not an approval, and with no number there is nothing for the inspector to accept. Door C is the trap: the shop's brochure shows the higher rating, but the current revision of the approval no longer covers a 16 ft width, and the inspector reviews the current revision.

Step 3: read the installation drawing before the install, not after. Door A's approval drawing specifies the strut kit, the track-to-jamb fasteners, and the anchorage of the wood buck into the block, with spacing and minimum embedment stated. The tech finds the existing buck is anchored at roughly twice the spacing the drawing calls for. Re-anchoring the buck is now part of the job, because the door's approval assumes the substrate the drawing describes. That adds about 1.5 hours to a 5-hour install, so 6.5 hours, 30 percent more labor, which goes on the quote as a separate line with the reason.

Step 4: put the number where the inspector looks. The FL number and revision go on the permit application. The door's label stays on the door (inspectors read it). The approval record and the installation drawing are printed and left on site.

What changes the answer. In Miami-Dade or Broward, Door A would also need HVHZ approval, and its statewide approval does not say HVHZ, so it would be out regardless of pressure. If the opening had a design pressure of -34.0 psf, Door A would fail too, and the search would continue. If the house were in a coastal Texas county, the gate would be the windstorm program's acceptance and inspection for the customer's insurance, and a Florida approval would be informative but not the question asked.

The failure modes that are specific to these systems

Reading the brochure instead of the record. Approvals are revised and narrowed; marketing material lags. Always pull the current revision by number on the day you order.

Approving the product and ignoring the drawing. The installation drawing is the half of the approval installers skip, and it is the half an inspector checks with a tape measure.

Substituting a component. Swapping the approved strut kit, anchors or glazing for a "same thing" part voids the approval for that installation. If a substitution is unavoidable, it goes to the building department before the install.

Assuming one state's system travels. A Florida approval does not satisfy California's wildfire listing, and neither one is a national listing. Each is a gate for its own jurisdiction.

How to verify you got this right

• You can state the opening's required design pressure (or the wildfire category the component falls in) and where that figure came from.
• The product's approval or listing number has been looked up in the governing system on the day of ordering, and the current revision covers this size, this substrate and, where relevant, HVHZ use.
• The installation drawing from the approval was read before quoting, and any substrate work it implies is on the quote.
• The number is on the permit application, the label is on the product, and the drawing is on site.

Where the required design pressure itself is in question (an unusual opening, an addition, a building on an exposure the tables do not cover), that is engineering, not a lookup. Walk the opening dimensions, the photos and the approval record to a licensed engineer.

References

• Florida Statutes section 553.842 and Florida Administrative Code Chapter 61G20-3, product approval; Florida Building Code, High-Velocity Hurricane Zone provisions
• Miami-Dade County product control, Notice of Acceptance program
• Texas Department of Insurance, windstorm inspection program and product evaluations
• California Building Code Chapter 7A and California Residential Code R337; California State Fire Marshal Building Materials Listing program
• See related: The Wildland-Urban Interface Code in Plain Terms; How to Check a Listing Before You Buy an Unfamiliar Product