NAHB’s appeal is based on technical flaws in the standards and on procedural grounds — that the committee did not follow ANSI-approved ASHRAE rules for the development of consensus standards.
The technical flaws cited by NAHB include:
- Whole-House Mechanical Ventilation — The standard permits continuous exhaust ventilation in hot, humid climates and supply ventilation in cold climates — as much as 150 cfm continuously in a 2,000 square-foot house — which may cause mold and structural damage and which the ASHRAE Handbook of Fundamentals advises against.
- Kitchen Ventilation — Kitchen ventilation rates and a requirement for the exhaust fan to be in a range hood are based on air changes per hour that cannot be determined for kitchens that are open to other rooms.
- Sone Ratings — Fans are required to meet maximum sone ratings, but the standard does not define “sone” or state how to calculate it. Definitions from other sources conflict. ASHRAE and ANSI procedures require that, “All terms shall be defined when they deviate from an ordinarily accepted meaning or dictionary definition” in standards intended to be referenced by building codes.
- Gas and Oil Fuel Appliance Backdrafting Testing — Research has determined that short-term tests that induce backdrafting by closing up the house and turning on all its exhaust systems are unreliable in predicting backdrafting under normal conditions.
- Solid Fuel-Burning Appliance Backdrafting Testing — The standard is not specific about which tests are required, and it allows laboratory tests, which do not even test backdrafting, to be performed in the field.
The procedural violations cited by NAHB include:
- Improper classification of members — Two general members were classified as producers, throwing the committee out of balance.
- Designating substantive comments as editorial — The committee:
— Changed the definition of “Air Change Per Hour” without public review; and
— Deleted a portion of the NFPA 54 Annex H backdrafting test from Appendix A Section A2 without public review.
- Conflicting Overlapping Standards — Standards 90.2 (residential energy), 62.2001 (ventilation) and NFPA 501 (manufactured housing) all contain conflicting ventilation requirements. ANSI requires harmonization of its standards. The committee never even discussed the requirements in two of the standards.
- Non-Responsiveness — The committee provided no reason in writing for its disposition of NAHB’s comment on solid fuel backdrafting testing.
- Using Informative Language in a Mandatory Appendix — The standard uses informative (non-mandatory) language in a normative (mandatory) appendix in violation of ASHRAE rules.
If ASHRAE denies the appeals, NAHB and the other appellants will consider taking their appeals to ANSI, which could require ASHRAE to address procedural violations and seek new public approvals before ANSI would approve 62.2 as an ANSI standard.
Should all appeals fail, the standard would still not be mandatory until building codes reference it and state and local jurisdictions adopt and enforce the code.
For more information e-mail Dick Morris or call him at 800-368-5242 x8444.
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