BSR/RESNET/ICC 380-20xx, draft PDS-02, Standard for Testing Airtightness Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: 4th page but doc has no page numbers
Paragraph / Figure / Table / Note: Section 3, Definitions
Comment Intent: Objection
Comment Type: Technical

Comment:

Under definitions for Conditioned Space Volume, under the final bullet on the volume of mechanical closets, sould not be excluded from volume just because make-up air is provided for equipment like a furnace or water heater. A space that is conditioned for normal occupancy, such as a utility room often found in a detached dwelling unit, should not be exclued from the conditioned space volume simply because it contains natural draft water heater or gas furnace.

Proposed Change:

Under definition for Conditioned Space Volume, under the final bullet on the volume of mechanical closets, strike the 3rd sub-bullet that reads as follows:

  • combustion makeup air is not intentionally provided from outside the Dwelling Unit, and

Comment #2

Page Number: throughout
Paragraph / Figure / Table / Note: throughout
Comment Intent: Objection
Comment Type: Technical

Comment:

Since the option to conduct whole-building blower door testing was removed from this standard (4.3.3), the term "building" should be removed from most places in this standard.  This standard is now only applicable to attached and detached dwelling units, not a whole building that contains multiple dwelling units.

Proposed Change:

Standard for Testing Airtightness of Building, Dwelling Unit, and Sleeping Unit Enclosures,; Airtightness of Heating and Cooling Air Distribution Systems,; and Airflow of Mechanical Ventilation Systems

Standard 380 has been developed to provide a consensus national standard for consistent measurement of several air-flow related building metrics.

This Standard provides a consistent, uniform methodology for evaluating the airtightness of building, Dwelling Unit, and Sleeping Unit enclosures and heating and cooling air distribution systems, and the air flows of mechanical ventilation systems.

2.1. This Standard defines procedures for measuring the airtightness of building, Dwelling Unit, and Sleeping Unit enclosures, the airtightness of heating and cooling air distribution systems, and the airflow of mechanical ventilation systems.
 
This Standard provides separate procedures for measuring the airtightness of building enclosures and the airtightness of Detached Dwelling Units and aAttached Dwelling Unit and Sleeping Unit enclosures.
 
Blower Door – A device that combines an Air-Moving Fan as defined in Section 34.1.1, an
Airflow Meter as defined in Section 34.1.3, and a covering to integrate the Air-Moving Fan into the building or Dwelling Unit opening.
 
4. Procedure for Measuring Airtightness of Building or Dwelling Unit Enclosure
 
4.1.1. Air-Moving Fan. A fan that is capable of moving air into or out of the building
or Dwelling Unit to achieve one or more target pressure differences between the building or Dwelling Unit and the exterior.
 
4.1.5. Blower Door. A device that combines an Air-Moving Fan as defined in Section
4.1.1, an Airflow Meter as defined in Section 4.1.3, and a covering to integrate the Air-Moving Fan into the building Dwelling Unit opening.
 
4.2. Procedure to Prepare the Building or Dwelling Unit for Testing5
 
4.2.7. Chimney dampers and combustion-air inlets on solid fuel appliances.  Chimney dampers and combustion-air inlets on solid fuel appliances shall be closed. Precautions shall be taken to prevent ashes or soot from entering the building or Dwelling Unit during testing.
 
4.2.9. Fans. Any fan or appliance capable of inducing airflow across the building or Dwelling Unit enclosure shall be turned off including, but not limited to, clothes dryers, attic and crawlspace fans, kitchen and bathroom exhaust fans, air handlers, and ventilation fans used in a Dwelling Unit Mechanical Ventilation system6. The party conducting the test shall not turn on fans in adjacent attached Dwelling Units. For continuously operating central ventilation systems serving more than one Dwelling Unit in a building with multiple Dwelling Units, the registers shall be sealed in the subject Dwelling Unit. The central ventilation system shall be turned off where possible. If it is not possible to turn off the system, then it can be left operating provided sealing select registers will not compromise the system and the sealed registers remain sealed during the test.
 
4.4.2.7. The flow through the building or Dwelling Unit enclosure at 50 Pa (0.20 in.
H2O) (CFM50 or CMS50) shall be calculated using Equation 4:
 
4.5.1. If the results of the building or Dwelling Unit enclosure air leakage test are to be
used for conducting an energy rating or assessing compliance with a building or Dwelling Unit enclosure leakage limit25, then the corrected airflow determined using a one-point test shall be adjusted using Equation 5a or 5b.
 
Other applications of building or Dwelling Unit enclosure air leakage testing and the
results of multi-point testing do not require the corrections in this section.
 
4.5.2. If the results of the building or Dwelling Unit enclosure leakage test are to be converted to Air Changes Per Hour at 50 Pa (0.2 in. H2O) (ACH50), Specific Leakage Area (SLA), Normalized Leakage Area (NLA), or compartmentalization leakage ratio at 50 Pa (CFM50/ft2), then Equations 7 through 10 shall be used. Where adjusted or corrected CFM50, CMS50 or ELA values have been calculated in previous sections they shall be used in Equations 7 through 10.
 
5.2. Procedure to Prepare the Building or Dwelling Unit and the Duct System for Testing
 
5.3.3. The Manometer and tubing for the Duct Leakage Tester shall be connected to the pressure probe(s) installed in Section 5.3.2, in accordance with the manufacturer’s instructions, so that the duct system pressure is capable of being measured with reference to the inside of the building or Dwelling Unit.
 
5.4.1.1. If ducts run through Unconditioned Space Volume including attics, garages or crawlspaces, then any vents, access panels, doors, or windows between those spaces and the outside shall be opened. At least one door, window or comparable opening between the building or Dwelling Unit and the outside shall be opened to prevent changes in building or Dwelling Unit pressure when the Duct Leakage Tester is running.
 
6.1. Procedure to Prepare the Building or Dwelling Unit and Mechanical Ventilation
System for Testing
 
8.3. Debris and Fumes - The blower or fan forces a large volume of air into or out of a building or Dwelling Unit while in operation. Caution shall be exercised against sucking debris or exhaust gases from fireplaces and flues into the interior of the building or Dwelling Unit.  Care shall be exercised to prevent damage to internal furnishings, plants or pets due to influx of cold, warm or humid air. If the building or Dwelling Unit will not remain unoccupied, except for testing personnel during the test, care shall be exercised regarding the potential for the fans to introduce respiratory hazards to the breathing zone of the occupied space.

 

Comment #3

Page Number: 11
Paragraph / Figure / Table / Note: 4.3.2.4
Comment Intent: Objection
Comment Type: Technical

Comment:

Door sweeps may be made of different materials.  This section is intended to apply to EPDM, vinyl, brass, etc. door sweeps but not brush-type door sweeps.  Recommend adding "air-impermeable" to clarify this distinction, but I don't want to add confusion with respect to door sweeps that don't cover 100% of the bottom of the door.  The 140 CFM50 penalty isn't intended to apply when just a small amount of light is visible at the corners of vinyl weatherstripping, for example.

Proposed Change:
4.3.2.4. The doorway where the Blower Door is installed shall be inspected for the presence of an air-impermeable door sweep. Where an air-impermeable door sweep is not present, 140 CFM50 shall be added to the measured airflow. This adjustment, and the presence and condition of the door sweep, shall be documented in the final test report19.