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CNCC TACKLES PRODUCT APPROVAL PROCESS IN CANADA
A National Standard and Revamped CCMC Approval Process is the Goal

Article reprinted from Principia Partner's - Natural and Wood Fiber Composites - April 2006 Newsletter.
www.PrincipiaConsulting.com

WPC companies seeking product Evaluation Reports (ER) from the Canadian Construction Materials Centre (CCMC) face a long, cumbersome, and expensive process. Without an ER, it is becoming increasingly more arduous to sell composite decking and railing in Canada. The Canadian Natural Composites Council (CNCC; Mississauga, ON) is working to standardize, to simplify, and to make the process similar to the U.S. evaluation process, while still putting consumer safety at the forefront.

WPC manufacturers without an ER are spending considerable resources to answer inquiries from local building code officials. A typical scenario is one customer wants to build one deck with one composite product that does not have an ER. One building code inspector is not comfortable with the product, so additional information is requested from the supplier. The supplier complies by sending test results and other relevant data to the inspector. The inspector then makes a yes or no decision. Now, multiply this process by many, many decks and it’s easy to see how a company can be expending a lot of resources to "sell" their product.

So, why doesn't every manufacturer have a CCMC ER?

First, to date, only three WPC companies have products with an ER. Trex was the first to receive a report in June 2003, followed by Millennium Decking and Weyerhaeuser (ChoiceDek) in July 2005. In the United States, every major WPC manufacturer and most smaller companies have an evaluation report from the International Code Council (ICC). Why the disparity?

The intent and structure of residential building codes in the USA and Canada are similar. However, code recognition for alternative deck and railing products in Canada is considerably more difficult to achieve because of CCMC's process of evaluating new building materials. If no building code standard exits, manufacturers of new products must contact CCMC to develop custom technical guides for them.

Custom technical guides are developed via the CCMC, in consultation with researchers within Canada’s National Research Council (NRC), and selected technical experts at Universities. The CCMC initially decided that the basis for granting building code recognition for alternative decking would be based on equivalency to typical 5/8" oriented strand board (OSB) type sub-floor sheathing. CCMC's decisions on the types of tests, and pass-fail criteria were made without input from manufacturers or testing agencies. As a result, the manufacturers believe many of the required tests are superfluous and could be eliminated without compromising consumer safety.

If a product doesn’t meet CCMC targets, they reserve the right to not issue an ER, or to issue a report with limited building code applicability. Often, after considerable expense of time and money, the manufacturer is forced to consider abandoning their application or accept limited applications because of CCMC's interpretation of what constitutes equivalency to OSB sub-floor sheathing.

Another barrier is the CCMC treats each material type and shape as a unique product, thus a custom technical guide for each and every profile is required. If the profile is made of the same materials, but the shape is different (i.e. sold, hollow, or tongue and groove) a separate guide is required. The cost and time to receive one technical guide for one product can be as high as US$20,000 and take about 6 to 12 months to complete. On top of that the testing costs is typically $100,000 to $150,000.

How does this differ from the US?

The International Code Council's Evaluation Service (ICC-ES) through public consultation with all interested parties issues Acceptance Criteria (AC), which contains the performance requirements, testing methods, and quality assurance items required to achieve building code recognition. The AC applies the same set of requirements to all alternative materials regardless of profile shape. Companies spend about $80,000 and 9 to 12 months of time to receive an ICC-ES.

CNCC has two primary goals, one short term and one long term. In the short term, the number one challenge is to simplify the ER approval method, and to open up CCMC's process to public input. CNCC hopes to work with the CCMC to develop a technical guide with a large percent of standard tests to create a common performance criteria guide. The guide also would contain a smaller percent of tests customized to each manufacturer's product. Companies could use this common guide to spring board from, and then incorporate product specific criteria to create their technical guide. This would reduce the amount of time and money to obtain a technical guide.

The CNCC is hoping the CCMC will allow interested parties to have input into the testing methodologies and the criteria used to determine pass and fail levels for each test. To date, efforts by the CNCC to do so have not resulted in any changes, but they continue to work with CCMC towards this goal.

In the long term, the CNCC is looking to create a standard that may be incorporated into the National Building Codes (NBC). They are in discussion with the Underwriters Laboratory of Canada to help create such a standard. It will take approximately two years to write the standard and then an undetermined amount of time to get it into the NBC. The objective is to have it included in the 2010 NBC. The cost to develop the standard is estimated to be $140,000 CDN.

The CNCC is working to get companies in the industry to share this cost, as it will benefit any manufacturers and distributors selling products in Canada. A letter was sent on behalf of the CNCC to parties that may be interested in supporting this effort. Any company interested in participating or learning more about this should contact Laurie Higgins (LHiggins@cpia.ca) or Andrew Rush (ARush@BriteMfg.com) on or before May 12th, 2006. A teleconference call with all interested parties will be scheduled shortly thereafter.

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