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What the Safety Regulations Are for Glass

An overview of CPSC 16 CFR Part 1201 and model code safety glazing requirements

By Valerie Block

The history of safety glazing regulation spans a 30-year period starting with the formation of the Consumer Safety Glazing Committee (CSGC) in 1968. CSGC was an ad hoc committee of industry, labor, safety, and general interest groups interested in passage of a model safety glazing bill at the state level. It then joined others in lobbying Congress for legislation creating a new federal agency, the Consumer Product Safety Commission (CPSC), with powers to develop and adopt federal safety standards for consumer products that would preempt all inconsistent or non-identical state and local standards.

On November 1, 1973, CPSC granted CSGC's petition to develop a federal safety standard for architectural glass on the basis of information submitted by CSGC, consideration of injury data reported by the National Electronic Injury Surveillance System (NEISS), and a review of data and information gathered by the National Commission on Product Safety. Two years later, in response to CPSC's invitation, CSGC submitted its model safety glazing bill to CPSC as a recommended federal standard, and, the following year, CPSC published its own proposed standard in the Federal Register for public comment.

The proposed standard was designed to reduce or eliminate the unreasonable risks of injury associated with architectural glazing materials by ensuring that the glazing materials used in certain architectural applications (hazardous locations) would not break when impacted with a prescribed force of energy or would break with characteristics that were less likely to cause an unreasonable risk of injury.

In 1977, CPSC standard 16 CFR Part 1201 was enacted by the federal government. Initially, the standard applied to glazing in doors and other glazed panels in hazardous locations, such as sidelites and panels adjacent to walkways. However, in 1981, CPSC withdrew its glazed panel provisions to permit regulation and enforcement of glazings in those locations by state and local building code authorities. State and local building code officials were expected to impose criteria for the use of glass, subject to human impact, that was consistent with the regulations of CPSC. As required by the federal preemption mandate, the three regional model code bodies enacted safety glazing provisions for all hazardous location applications conforming to CPSC standards.

The federal CPSC standard and model building codes established two product "risk" categories for glazings. In the International Building Code (IBC), for example, Category I applies to swinging doors where no single piece of glazing material exceeds 9 square feet in area, and glazed panels adjacent to doors containing a single piece of glazing material less than 9 square feet in surface area.

Category II products included all sizes of glazing in shower doors and enclosures, all sizes of glazing in bathtub doors and enclosures, all sizes of glazing in sliding glass doors (patio type), swinging doors containing glazing greater than 9 square feet, and glazed panels where the glazing material exceeded 9 square feet.

Impact Load Test Requirements
Originally, CPSC's impact load test requirements and risk-rating categories were based on studies of the amount of energy it takes for children and adults to break glass upon body impact. The CPSC found that a 100 foot-pound impact requirement (12-inch drop height) offered protection to children under five, but concluded this was insufficient protection for glazing in doors and panels, except in fire-rated applications. The 150 foot-pound requirement (18-inch drop height) offered protection to children under 10 on full-body impact and adults on hand and arm impact. The 400 foot-pound (48-inch drop height) impact requirement was considered to be the minimum impact requirement to protect adults against full-body impacts.

CPSC deferred application of the 16 CFR 1201 standard to wired glass used in fire-rated applications in compliance with fire codes. The exemption left regulation of wired glass up to the model codes and state and local laws.

In addition, 16 CFR Part 1201 did not apply to the curved sidelites of revolving doors, commercial refrigerated glass cabinet doors, transoms, overhead garage door windows, and decorative leaded glass when no individual pane exceeds 30 square inches in area. CPSC exempted louvers of jalousie doors, as well as glazed panels in nonresidential buildings that were not adjacent to doors and had a horizontal member or chair rail located between 24 and 36 inches above a walking surface.

Model Code Safety

Glazing Requirements
The three regional model code organizations, BOCA, SBCCI, and ICBO, as well as the new International Code Council (ICC), the first organization to publish a national model building code in the United States, publish model codes containing requirements for the safe use of glass in Chapter 24 of their codes. For more than 20 years, the model codes have contained safety glazing requirements patterned after CPSC 16 CFR 1201.

United States model codes require each pane of safety glazing installed in hazardous locations to be identified by a label that identifies the labeler as manufacturer or installer, the safety glazing standard with which the glass complies, and the type and thickness of the glass or glazing material. In the case of multi-lite assemblies, where individual lites do not exceed 1 square foot in exposed area, at least one lite in the assembly must display the complete label. The others must be marked CPSC 16, CFR 1201, or ANSI Z97.1, as appropriate. Except for tempered glass, affidavits or certificates may be substituted for labels when approved by the local code official.

Hazardous locations requiring labeled safety glazing materials in the model codes are defined to include:
· Glazing in swinging doors except jalousies.
· Glazing in fixed and sliding panels of sliding patio door assemblies and panels in other doors, including walk-in closets and wardrobes.
· Glazing in storm doors.
· Glazing in unframed swinging doors.
· Glazing in doors and enclosures for hot tubs, whirlpools, saunas, steam rooms, bathtubs, and showers.
· Glazing in any portion of a building wall enclosing these compartments where the exposed edge of the glazing is less than 60 inches above a standing surface.
· Glazing in an individual fixed or operable panel adjacent to a door where the nearest exposed edge of the glazing is within a 24-inch arc of either vertical edge of the door in a closed position and where the bottom exposed edge of the glazing is less than 60 inches above a walking surface. (Panels where there is an intervening wall or other permanent barrier between the door and the glazing are exempt.)
· Glazing in an individual fixed or operable panel where the exposed area of an individual pane is greater than 9 square feet and the exposed bottom edge is less than 18 inches above the floor, the exposed top edge is greater than 36 inches above the floor, and one or more walking surface(s) are within 36 inches horizontally of the plane of the glazing. Exceptions include a panel with a protective bar (1 1/2 inches or more in height and capable of withstanding a horizontal load of 50 pounds per linear foot without contacting the glass installed on the accessible sides of the glazing 34 inches to 38 inches above the floor), and an outboard pane in insulating glass units or multiple-lite construction where the bottom exposed edge of the glass is 25 feet or more above any grade, roof, walking surface, or other horizontal or sloped surface adjacent to the glass interior.
· Glazing in guards and railings, including structural baluster panels and nonstructural in-fill panels, regardless of height above a walking surface.
· Glazing in walls and fences enclosing indoor and outdoor swimming pools and spas when the bottom edge of the glazing on the pool side is less than 60 inches above a walking surface on the pool side of the glazing and the glazing is within 60 inches horizontally of a water's edge.
· Glazing adjacent to stairways, landings, and ramps when it is within 36 inches horizontally of a walking surface, within 60 inches horizontally of a bottom tread of a stairway in any direction, and the bottom edge is less than 60 inches above the plane of the adjacent walking surface (or stairway, measured from the nose of the tread).

Skylight Safety Provisions
The sloped glazing and skylights provisions of Chapter 24 address safety issues related to overhead glass. Laminated glass with a minimum 30-mil polyvinyl butyral (or equivalent) interlayer, wired glass, light-transmitting plastic materials, and heat-strengthened or fully tempered glass are allowable glazing materials for monolithic and multiple-layer glazing systems. Screening shall be provided below heat-strengthened glass and fully tempered glass in monolithic glazing systems, as well as below heat-strengthened, fully tempered, and wired glasses when the glass is the bottom glass layer in a multiple-layer glazing system.

Screens are not required below fully tempered glass installed between intervening floors at a slope of 30° or less from the vertical plane where the highest point of the glass is 10 feet or less above the walking surface. They are not required under any glazing material, including annealed glass, where the walking surface below the glazing material is permanently protected from the risk of falling glass or the area below the glazing material is not a walking surface. In addition, screens are not required under sloped glazing systems or in commercial or detached non-combustible greenhouses used exclusively for growing plants and not open to the public, provided the height of the greenhouse at the ridge does not exceed 20 feet (or 30 feet in the IBC) above grade.

In dwelling units, screens are not required under fully tempered glass when each pane of the glass is 16 square feet or less in area, the highest point of the glass is 12 feet or less above any walking surface, and the glass is 3/16 inch or less. Laminated glass with a 15-mil interlayer is acceptable in dwelling units provided each pane of glass is 16 square feet or less in area and the highest point of the glass is 12 feet or less above a walking surface.

Handrails and Guards
U.S. model codes require a minimum glass thickness of 1/4 inch of either single fully tempered glass, laminated fully tempered glass, or laminated heat-strengthened glass when using glass as structural balustrade panels in railings. Glazing in railing in-fill panels must conform to ANSI Z97.1 or be of an approved safety glazing material.

Athletic Facilities
Glazing in racquetball and squash courts and similar uses are required to conform to CPSC 16 CFR, Part 1201. Test methods, loads, and deflection limits are specified in the model codes. Glass panels installed in these areas are to be specifically designed to provide safety upon impact.

Floors and Sidewalks
A section on glass in floors and sidewalks has been developed through a cooperative effort between the glass industry and the building codes. As a means of providing safety, laminated glass having a minimum of two plies, capable of supporting the total design load with any one ply broken, must be used.

The evolution of glass as a building product has resulted in a myriad of building code requirements, exemptions, and exceptions that define and clarify proper usage. Starting with CPSC's preemptive regulations for safety, the model codes have expanded and clarified parameters around the use of glass in buildings.

The codes are continually addressing new proposals related to glass through the ongoing model code hearing process. Unlike the CPSC federal standard that is fixed in place and preemptive, existing model building code requirements are often the focus of new proposals that result in revisions and changes.

Changes in code requirements may also occur at the state and local levels. However, as building code officials consider proposed additions and changes to Chapter 24 requirements, they will no doubt keep safety at the forefront.

Valerie Block is chairman of the Glazing Industry Code Committee (GICC). She is also technical director of the Primary Glass Manufacturers Council (PGMC), Topeka, KS. She has over 20 years of experience in the glass industry and has served on many industry committees, including the ANSI Z97.1 Accredited Standards Committee of the American National Standards Institute (ANSI), the American Society for Testing Materials (ASTM), and the International Organization for Standardization (ISO).

Source: The Glass Guide to Codes, Glass Magazine, September 2001.