Lisa Pate, Executive Director, FRSA
We all have heard the terms “Florida Product Approval” and “Miami-Dade NOA,” but what do they really mean? Why is it important that we understand how these certifications work and why we need to make sure the products we’re installing have these numbers?
There are two ways that products for construction trades are approved in Florida – through the Florida Product Approval System and through Miami-Dade Notice of Acceptance (NOAs). Florida Product Approvals are products that the state approves for use in all areas of Florida. Many of the roofing products that are listed with Florida Product Approval numbers are also linked to a Miami-Dade Notice of Acceptance, which are set forth by Miami-Dade County, and have additional performance requirements than other areas of the state. Florida Product Approvals are for products and components, while Miami-Dade NOAs are based on the system being approved.
The Florida Product Approval System was implemented on October 1, 2003 by Florida Statutes section 553.842 and provides an optional statewide approval for eight identified building envelope and structural frame products (panel walls, exterior doors, roofing products, skylights, windows, shutters, structural components, impact protective systems) that are intended to be replicated during the manufacturing process. The Product Approval System, in coordination with the Florida Building Code, ensures safe product technologies are used in building construction and encourages development of new products and technologies that increase safety or meet safety requirements less expensively.
Florida Product Approvals fall under the guidance of the Florida Building Commission, which is comprised of 26 members appointed by the governor. Along with their primary responsibilities, some of which include adopting and amending the Florida Building Code (FBC), they coordinate with the State Fire Marshall to minimize conflicts between the FBC and the FFPC, issue interpretations on Declaratory Statements, determine types of products which may be approved by the Commission for statewide use, and implement the state Product Approval System.
The Florida Building Commission ensures accountability, a higher standard of practice for product evaluations, and uniformity and consistency of enforcement statewide. Evaluations of products covered by the Commission’s rule can only be conducted by nationally accredited and state approved entities or by state licensed engineers (PEs) and architects (RAs). These entities must meet national standards for independence from the manufacturers whose products they evaluate. Manufacturers of covered products must also
maintain third-party monitored quality assurance programs to verify continued compliance of approved products. Once the manufacturers’ PE has verified compliance, a different PE must evaluate and verify the product being submitted for approve. In return, building departments must accept Florida Building Commission approved products evaluated by approved entities or Florida PEs and RAs without requiring further testing, evaluation or documentation. Building officials can appeal the required acceptance to the Commission, but must accept the evaluation until the Commission rules on
the appeal.
There is no mandate for state product approval in the law or the rule. Local building officials must offer local product approval to a manufacturer when requested (553.8425 F.S.), requiring that “products or systems of construction shall demonstrate compliance with the structural windload requirements of the FBC through one of the following methods: a certification mark, listing or label from a commission, a test report from a commission, a product-evaluation report from a commission, a product-evaluation report from a Florida professional engineer or registered architect, or a statewide product approval issued by the Florida Building Commission.”
Local building officials may accept modifications to products or their installations provided sufficient evidence is submitted to the official to demonstrate compliance with the Code or the intent of the Code, including such evidence as certifications from a Florida Registered Architect or Florida Professional Engineer.
Is there an advantage to using the state approval option vs. the local approval? Yes. State approval by the Florida Building Commission shows builders, architects, building officials and inspectors that your products have completed rigorous testing requirements and meet the standards specified in the Florida Building Code. No further documentation is required. However, the local approval option requires the same level of documentation and is good in that jurisdiction only.
The FBC establishes standards for performance of products, materials and systems of construction. When the designer selects and the contractor installs building products, the building department verifies compliance with the Code through plans review and inspection. The project/site-specific use of a product is based on the product’s performance and limitations of use and compared to the design requirements for the project. (For instance, the required design pressure ratings for roofing based on the wind speed map in the Florida Building Code.)
To have a product approved through the state Florida Product Approval, manufacturers must first register with the Florida Building Commission and submit an application for approval for products or subproducts, sorted alphabetically by model, number or name. There are four ways to apply for a Florida Product Approval: as a new application, through a full revision of an existing application, editorial change, or self-affirmation of existing application. If standards or restrictions pertaining to products change when a new code goes into effect, then a full revision application must be submitted. New evidence such as a certification, test report or an evaluation report demonstrating compliance must also be submitted with the application. If there are multiple products within the same application (with the same FL Product Approval Number), then evidence for all the products must be submitted. Once all the correct paperwork is completed, the process usually takes about two months for approval by the Commission, except for the Certification Mark or Listing Method, which could take as little as two weeks. Once approved, the product receives a Florida Product Approval Number, commonly known as the “FL number.” Why should you care about an updated Florida Product Approval Number? Because when you apply for a roofing permit, you’ll need to provide the FL Product Approval Number and documentation that the roofing system you’re installing is in compliance with the current code, and will also serve as your installation guidelines.
Miami-Dade County NOAs are issued only to manufacturers and their private labelers. Manufacturers outside the USA must have a distributor in the USA and must submit a properly executed distributor agreement. NOAs are required with: new product approvals, revision to a current Notice of Acceptance, renewal of a current Notice of Acceptance (without changes), Association Member, one-time approval (special project), private labeler, or distributor agreement. In addition, testing and engineering reports, manufacturers’ design drawings, and calculations must be included. Tests must be performed by laboratories approved by Miami-Dade County per TAS 301. Tests over 10 years old require verification testing for NOA renewal. Reports with test standard version/edition not referenced in the current code edition must be complemented with
an equivalency of standards letter.
In Miami-Dade and Broward Counties you must comply with the Miami-Dade building code, which over-rides the Florida Product Approval.
Now that you know what Florida Product Approvals and Miami-Dade NOAs are, how do you find them? For Florida Product Approvals, visit www.floridabuilding.org and on the home page you’ll see the Product Approval link on the left. Here you’ll be able to view all Florida Product Approvals by product, application, number or organization (manufacturer). Make sure that you are viewing the “2017 Code” version.
To search for products with Miami-Dade NOA’s, visit www.miamidade.gov/building/ and select the Product Approvals button on the left and use the “Product Control” button in the upper-center portion of the screen to search by products, certificates and listings.
The Florida Building Code is the minimum standard for building. Florida Product Approvals, NOAs and the authority having jurisdiction can require more stringent guidelines.
Previous Article
Next Article