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NFPA 285-Extending Data with Comparative Engineering Analysis

March 26, 2021

Exterior wall assemblies have
become increasingly complex and
are critical elements of the building
enclosure. Advancements in
our understanding of building
science, coupled with the need
to improve the energy efficiency and resilience
of buildings, have led to innovative solutions
in both building products and construction
methods. Many of the innovative products
available to the market today are subject to
compliance with prescriptive fire testing and
performance requirements as regulated under
the International Building Code (IBC). One
of the critical prescribed fire tests within the
IBC for exterior wall assemblies is the National
Fire Protection Association’s Standard Fire
Test Method for Evaluation of Fire Propagation
Characteristics of Exterior Wall Assemblies
Containing Combustible Components (NFPA
285).1 This article discusses engineering judgments
and their use as a practical tool to assist
designers and building officials with assessing
the compliance of exterior wall assemblies with
the acceptance criteria of NFPA 285.
In recent years, the code-enforcement community
has expressed concerns about engineering
judgments regarding NFPA 285. This
article discusses the code basis for engineering
judgments, the actual data, and how the
data can be used to determine compliance.
Following the discussion, the article closes with
an update regarding efforts to improve transparency
and consistency of these engineering
judgments via an annex to NFPA 285, bringing
together current industry best practices.
ENGINEERING JUDGMENTS AND THE
INTERNATIONAL BUILDING CODE
Section 104.11 of the IBC provides the
building official with authority to approve alternative
materials, design and methods of construction,
and equipment. Approval is granted
on the basis of the building official’s finding
that the alternative “is satisfactory and complies
with the intent of the provisions of this code,
and that the material, method or work offered
is, for the purpose intended, not less than the
equivalent of that prescribed in this code in
quality, strength, effectiveness, fire resistance,
durability and safety.” Data, analysis, and engineering
judgments are often provided to the
building official to support a finding that the
proposed alternate complies with the applicable
provisions of the code. Engineering judgments
that extend NFPA 285 results to modifications
of tested assemblies fall within the scope and
intent of IBC 104.11.
20 • IIBEC Interface March 2021
Editor’s note: In this article, the term “engineering judgments” is used to refer to analyses
performed by qualified engineers or consultants and used to support code compliance
under the IBC alternate materials and methods provisions. These engineering judgments
could be among the data supporting a design listing or code evaluation report published
by an accredited certification agency or an unpublished report held by a material supplier
that is submitted to the engineer of record or building official. “Engineering judgments” is
the term used within the fire safety and building products communities.
Photo by Max Kukurudziak on Unsplash
For exterior
walls complying
with NFPA 285,
an engineering
judgment is a
report that provides
a comparative
analysis of
the effects that
one or more
variations to a
tested assembly
will have on compliance with the acceptance
criteria of NFPA 285. These reports are prepared
by qualified individuals and organizations
and must be based on actual NFPA 285
fire test data and, if appropriate, supplemental
test data. Engineering judgments may be general
or specific to one construction project or
project condition.
The complexity of today’s wall assemblies
that results from compliance with all code
requirements (such as energy efficiency, fire
safety, water/weather resistance, air leakage,
vapor transmission, structural loading, and the
like), combined with the multitude of products
and design options, renders full-scale testing of
every possible assembly combination or slight
variation impractical.
Other realities of today’s construction
industry necessitate the use of engineering
judgments to validate compliance. For example,
unforeseen issues, such as errors or in-field
conditions that arise during construction, can
result in in-place assemblies that deviate from
tested assemblies, third-party-listed design(s),
or the design described in the approved construction
documents. Such deviations from
approved assemblies can “red tag” a project,
either halting construction or preventing issuance
of a certificate of occupancy until a determination
of compliance is made or the condition
is rectified in a satisfactory manner.
For these reasons, engineering judgments
evaluating variations of full-scale fire-tested
assemblies offer building officials a practical
tool for establishing compliance of alternate
assemblies with the acceptance criteria of
NFPA 285 in support of granting approval.
The model codes recognize that principles
of fire science and fire protection engineering
allow for the reasonable extension of test results
to modifications of tested assemblies using comparative
analysis of pertinent fire test data. For
example, IBC Chapter 7 on Fire and Smoke
Protection Features contains provisions in IBC
Section 703.2 and 716.1.1 that permit the use of
engineering analysis to determine fire resistance.
For those situations where the code does not provide
prescriptive provisions, IBC Section 104.11
provides building officials with duties and powers
to consider supporting information, such
as test data and engineering analysis, in their
review and approval of alternative materials,
designs, and methods of construction as meeting
the intent of the code. Both IBC Sections 703.2
and 716.1.1 include reference to Section 104.11 as
a compliance method.
Several certification agencies, within the
scope of their ISO/IEC 170652 accreditation,
provide listing and certification services for wall
assemblies complying with NFPA 285. These
agencies routinely perform analyses and engineering
judgments regarding modifications
to recognized products and the recognized
assemblies containing them. These analyses are
performed as part of the ongoing maintenance
of certifications for recognized products and
designs. Additionally, test programs developed
for purposes of third-party certification will
often include “worst-case” assembly design(s) to
allow for subsequent analysis and engineering
judgments to provide a scope of recognition
beyond only the tested assembly.
Product manufacturers also engage with
independent fire-protection engineers (FPEs)
and other qualified consultants to prepare engineering
judgments. Judgments by FPEs and
consultants are most often prepared for submission
to building officials in support of approval;
and to certification agencies in support of test
programs, recognition expansion, and ongoing
certification.
Whether issued by a certification agency,
an independent FPE or consultant, or an
independent fire-protection consulting firm,
the final duty and power to accept engineering
judgments in support of approval rests with the
building official as stated in Section 104.11 of
the IBC.
THE TEST AND THE DATA
The NFPA 285 test method evaluates vertical
and lateral flame propagation characteristics
of full-scale exterior wall assembly designs.
The fire exposure simulates a fire scenario
where a post-flashover fire has breached the
window of the room of origin, exposing the
wall assembly to a flame assault and heat plume.
Test specimens are full-scale (minimum 17-ft.-
6-in. high × minimum 13-ft.-4-in. wide) and
fully configured wall assemblies, containing all
assembly layers (such as the exterior wall covering,
water-resistive barrier, air barrier, vapor
barrier/retarder, and insulation), accessories
(for example, sealants, brackets, or shims), and
a base wall (most typically a light-gage metal
frame curtainwall). Each test wall assembly is
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March 2021 IIBEC Interface • 21
highly instrumented with each assembly layer
(including air gaps) containing multiple thermocouples
(TCs). The specific number of TCs,
TC locations, and any applicable acceptance
criteria are specified by the NFPA 285 test
method and determined by the materials of
construction and the configuration of the wall
assembly. The criteria determining the pass/fail
result are a combination of temperature limitations,
temperature-rise limitations, and visual
observations of flaming at certain locations in
the specimen and the second-story room of the
test apparatus. Information required for test
reports includes: time versus temperature data
for all TCs, visual observations, photographs of
the assembly (pre-test exterior, pre-test interior,
post-test exterior, post-test interior, and wall
cavity insulation post-test), damage sketch(es),
other burn-related and calibration-related
information, and detailed drawings for the
assembly and window opening area.
The data collected during an NFPA 285 test
record the “real-time” dynamic behavior of each
individual assembly layer. When combined, the
data from all assembly layers describe how heat
and fire moved throughout the assembly in all
three dimensions during the entire test duration.
It is this quality of NFPA 285 test data that
makes it possible for qualified individuals, using
experience and sound principles of fire science
and fire engineering, to evaluate and predict
performance effects presented by certain modifications
to tested assemblies. If the comparative
evaluation supports a finding of equivalent
performance, then the engineering judgments
will confirm that the alternative assembly will
continue to comply with the acceptance criteria
of NFPA 285. It is important to keep in
mind, however, that there are limitations to the
appropriate use of evaluation and engineering
judgments to extend full-scale fire test results to
modified assemblies. In some cases, extension
via evaluation may not be recommended for a
proposed modification; examples could include
doubling or tripling of an air-gap depth behind
an exterior cladding, doubling the thickness of
a combustible continuous insulation at a given
insulation density, and extensions without consideration
of supporting fire test data.
EQUIVALENCE AND DEVELOPING
GUIDELINES FOR ENGINEERING
JUDGMENTS
Engineering judgments extending full-scale
NFPA 285 test results are a determination of
equivalence; that is, whether a modified assembly
will perform at least equivalently to the tested
assembly in terms of meeting the acceptance
criteria of NFPA 285. As discussed previously,
NFPA 285 data tell a detailed story of how
an assembly performed during the test. These
detailed data, when reviewed by qualified and
knowledgeable individuals, provide valuable
insight into each assembly layer’s behavior as well
as its influence on, and reaction to, the behavior
of adjacent assembly layers. Ongoing testing
within the fire testing and certification community,
and the community of building product
manufacturers, continues to increase experience
and understanding of comparative performance
and performance trends for products and assemblies
subjected to the NFPA 285 test.
In March 2018, efforts to improve the transparency
and consistency of engineering judgments
led to the NFPA Committee on Fire
Tests approving the formation of a task group
for the purpose of developing guidance for
extending NFPA 285 test results. Under the
task group, experts from fire test laboratories,
certification bodies, and independent consultants
came together to collect experience and
industry best practices into the NFPA 285 test
standard regarding the extension of test results
for assemblies meeting NFPA 285. At the time
of this article, two public comments containing
guidance for the extension of NFPA 285 test
results will have been submitted under the
current NFPA revision cycle (Fall 2021 cycle)
for inclusion in the 2022 edition of NFPA 285.
The guidance provided in both comments is
similar: one adds the guidance as a new section
to the standard, whereas the other adds the
guidance as a new annex.
Both approaches provide guidance regarding
items for which evaluation and engineering
judgments are more commonly requested
or required today. These items include analyses
regarding base walls, exterior sheathing,
water-resistive barriers, air gaps, exterior insulations,
drainage media, exterior claddings and
attachment systems, and the window perimeter.
Key elements of the guidance include, but are
not limited to, the following:
• These wall assemblies are treated as
systems.
• Analyses are based on assemblies tested
in accordance with, and meeting the
acceptance criteria of NFPA 285.
• Changes to the assembly under evaluation
are normal and reasonable within
the limits of standard construction.
It is not possible to analyze every configuration,
every potential change, or every combination
of changes to a tested configuration.
SUMMARY AND CLOSING
Engineering judgments to extend NFPA
285 test results are a necessary and practical
tool to assess exterior wall assemblies with
specific alterations from an assembly tested and
shown to comply with the acceptance criteria.
Efforts among fire testing, certification, and
independent-consulting communities to collaborate
under NFPA to develop an annex to
the NFPA 285 standard providing consensus
guidance regarding extensions of test results are
underway to improve transparency and address
concerns expressed by the code-enforcement
community. When completed, the annex will
provide increased transparency regarding the
process, scope, and limitations for engineering
judgments regarding NFPA 285 and to improve
their consistency among providers.
The guidance submitted for possible
inclusion into the 2022 edition of NFPA 285
comes directly from the work and experience
of those individuals and organizations regularly
engaged in performing the testing, analyzing
the data, and preparing the engineering
judgments. These assessments are based
on sound principles and used for the purpose
of providing building officials with the
22 • IIBEC Interface March 2021
About the North American
Modern Building Alliance
The North American Modern Building Alliance (NAMBA) is focused on
addressing fire safety through the development and enforcement of building codes.
Members of NAMBA are: ACC Center for the Polyurethanes Industry, ACC North
American Flame Retardant Alliance, Atlas Roofing Corp., BASF Corporation,
Carlisle Construction Materials, Covestro, DuPont, EIFS Industry Members
Association, GAF, Huntsman, Kingspan Insulation LLC, Metal Construction
Association, Owens Corning, Polyisocyanurate Insulation Manufacturers
Association, and Rmax – A Business Unit of the Sika Corporation.
supporting information they need when considering
approval of wall assemblies with reasonable
deviations from one or more tested assemblies
based on comparative analysis with additional
supplemental data when needed.
REFERENCES
1. NFPA 285, Standard Fire Test Method
for Evaluation of Fire Propagation
Characteristics of Exterior Wall Assemblies
Containing Combustible Components.
National Fire Protection Association.
https://www.nfpa.org/codes-and-standards/
all-codes-and-standards/list-ofcodes-
and-standards/detail?code=285.
2. ISO/IEC 17065, Conformity assessment
– Requirements for bodies certifying
products, processes, and services. ISO.
2012. Reviewed 2018. https://www.iso.
org/standard/46568.html.
March 2021 IIBEC Interface • 23
Eric W. Banks is a
technical consultant
specializing in the
development, testing,
certification, and
codes and standards
compliance of building
products with an
emphasis on foam
plastic and other
insulation materials.
Banks has over 20
years of experience in
the building products industry and is actively
engaged in codes and standards development
work.
Eric W. Banks
Jeffrey H. Greenwald,
PE, CAE, is a technical
consultant
with the North
American Modern
Building Alliance
(NAMBA). In this
role, Greenwald supports
implementing
the NAMBA’s mission,
work plans, and
building codes and
standards development.
Greenwald is
a registered professional engineer in Virginia
and earned a master’s of civil engineering degree
from the University of Delaware. Greenwald was
awarded the ASTM Alan H. Yorkdale Memorial
Award for best paper concerning masonry in
2004 and 2005.
Jeffrey H. Greenwald,
PE, CAE
The supertall tower at 432 Park Avenue, New York City, was the
tallest residential building in the world when it was built in 2015.
Extremely tall, narrow “pencil” towers have been popping up in
Manhattan’s skyline. According to The New York Times, more than
20 buildings that are more than 1,000 ft. tall have been built or
planned since 2007, and many are experiencing trouble. At nearly
1,400 ft. tall, 432 Park Avenue has only one apartment on each
floor. Two-story electrical breaks allow the wind to go through
at intervals every 12 stories. Six years after it was built, residents
have expressed a spate of complaints, ranging from flooding, to
nonfunctional elevators, to excessive noise. Multiple incidences of
flooding from purportedly varied causes have occurred, causing an
estimated $500,000 in damage to one apartment alone. The walls
reportedly “creak like the galley of a ship.” This sound is common in
tall buildings as they sway in the wind, a problem that is even more
acute in very tall, very thin buildings.
A 1,200-ton tuned mass damper was installed near the top of
432 Park Avenue to counteract its sway. You can see the damper in
action in this video: https://tinyurl.com/jf2jmb34, taken by Terri
Boake of the University of Waterloo.
A group commissioned by engineering firm SBI Consultants
to study mechanical and structural issues reported initial findings
of failure to “conform with the developers’ drawings” in 73% of
mechanical, electrical, and plumbing components.
— The New York Times, Treehugger
By Epistola8 – Own work, CC BY-SA 4.0, https://commons.
wikimedia.org/w/index.php?curid=68233946
Trouble
in the Sky