Modular Builders Counter Fire Service on Foam Adhesives

Originally published by: Modular Building Systems AssociationFebruary 3, 2014

The following article was produced and published by the source linked to above, who is solely responsible for its content. SBC Magazine is publishing this story to raise awareness of information publicly available online and does not verify the accuracy of the author’s claims. As a consequence, SBC cannot vouch for the validity of any facts, claims or opinions made in the article.

In response to an earlier Energy Efficiency & Building Science News article, Fire Service Takes Issue with Foam Adhesives, the Modular Building Systems Association submitted the following counter-point:

The author states that modular construction techniques are different from traditional stick built procedures and implies that modular homes are code compliant “only because of pretty large loopholes.”  While modular construction techniques are different, the end result is the same – an IRC code-compliant home.  The term “modular” is simply a construction process whereby components, sections or “modules” are assembled at a location other than the final building location, transported to the site and assembled on site.  These components are made of the same materials and must comply with the same local building codes.  Our industry builds the sections in three-dimensional modules, whereas other companies are building offsite wall panels, roof trusses or other home components. The building materials are simply brought to the site in larger sections that were preassembled under factory controlled settings.

The author says he witnessed a modular home that appeared to burn more quickly than he thought was logical. What he fails to mention is his article is a simple fact contained in the official fire report:  “First arriving fire personnel discovered heavy overlapping fire coming from the first and second floor windows on the front of the house and fire visible through most of the interior of the house.  Chief Gallagher described the house as seventy-five percent involved on arrival.”

He also ignores the report’s conclusion: “Scene exam and witness statements revealed fire originated in a window box that had been stored with several others on the front porch. The boxes contained peat moss, and the top box exhibited evidence of a slow, smoldering fire. Most probable cause is a carelessly disposed cigarette in the peat moss.”  This language is taken verbatim from the report. When did the fire from the window box ignite the house itself?  No one actually knows when the fire started. And because no one knows, it is impossible to determine how quickly or slowly the house became 75 percent involved by the time the fire chief arrived.

But the fire chief’s main issue in his article seems to be the ICC code development and evaluation report process itself.  He also takes a shot at the ASTM standards process.  When the chief began this campaign, he wrote to the ICC for an interpretation. Their interpretation was clear: “Section R104.11 addresses ‘alternate design and methods of construction’ that are not prescribed in the code.  The use of an ICC Evaluation Report is one method of addressing alternate design and methods of construction.” 

The evaluation report is one proprietary tool available for building officials to determine if homes are safe and code compliant. The ICC ES states this as its purpose:


These rules set forth procedures governing ICC Evaluation Service, LLC (ICC-ES), issuance and maintenance of evaluation reports on building materials and products, methods of construction, prefabricated building components, and prefabricated buildings.

ICC-ES evaluation reports assist those enforcing model codes in determining whether a given subject complies with those codes. An evaluation report is not to be construed as representing a judgment about aesthetics or any other attributes not specifically addressed in the report, nor as an endorsement or recommendation for use of the subject of the report. Approval for use is the prerogative and responsibility of the Code Official; ICC-ES does not intend to assume, nor can ICC-ES assume, that prerogative and responsibility.” 

In addition ICC develops acceptance criteria that are used for consideration with a current ICC-ES evaluation report:

"5.1 Acceptance criteria are established by the committee to provide a basis for issuing ICC-ES evaluation reports on products and systems under codes referenced in Section 2.0 of the Rules of Procedure for Evaluation Reports. They also clarify conditions of acceptance for products and systems specifically regulated by the codes.
Acceptance criteria may involve a product, material, method of construction, or service. Consideration of any acceptance criteria must be in conjunction with a current and valid application for an ICC-ES evaluation report, an existing ICC-ES evaluation report, or as otherwise determined by the Evaluation Committee."

The evaluation reports regarding this particular assembly are very specific in terms of use and application. Deviations from the evaluation report process should not be allowed by the code officials. But the process and the report exist to assist those enforcing model codes in determining whether a given subject complies with those codes, as do professional engineers and their engineered research reports that result from the use of ASTM and ANSI standards and generally accepted engineering practice. 

There have been at least four ICC evaluation reports detailing when and how these types of ceiling assemblies are accepted in the building code.

  1. ICC ES Report 1028
  2. ICC ES Report 1366
  3. ICC ES Report 2062
  4. ICC ES Report 5904

But even beyond the evaluation reports, any modular home plan must still be reviewed and approved by an independent third party engineer, a state registered design professional, and/or the state modular program staff directly.  The modular home industry has more oversight to ensure safety and code compliance than does the stick built industry. 

Considerable time and effort have gone into researching this issue. Is it fair to undermine that entire process because one person believes a home was burning “too quickly?”

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