AC16 -1016-R1 – Comments from Paul Simony at Skyco Skylights
Below are comments concerning the current draft of AC16:
Section 2.1.1.6: There are several manufacturers who produce a capless skylight design whereby the
dome is fastened to a skylight frame by drilling through the plastic dome and fastening to the interior
frame. These units are not tested for air, water or structural performance and it should be very clear
that this design is not compliant with AC16 and does not have an ICC-ES Report. There is confusion
among the Architects and GC’s concerning this design as these companies also have an ICC-ES Listed
model, and there should be very clear language in AC16 to note the capless design does not satisfy the
performance requirements in AC16, unless it has been tested to AC16 requirements as a capless unit.
Section 2.1.1.10: Shape of dome. There are manufacturers who have tested a smooth dome only, and
market a parabolic dome as being ICC-ES Listed which is not what was tested, or what is referenced in
their ICC-ES Report. There needs to be very clear language concerning this aspect to eliminate any
confusion or misinformation in the marketplace.
Section 2.1.3.1: General: The label should also list the thinnest and thickest dimensions of the glazing so
the consumer is very clear what they are purchasing. The Performance Grade should also be noted on
the label.
Section 3.7.3: Class B. Add optional Class A qualification as an option if a manufacturer can validate the
higher fire rating. This would allow a Class A to be referenced in the ICC-ES Report, and included on the
skylight label.
Section 4.3.3: Add burning brand test requirement for capless skylight domes and for PVC or other
plastic framed skylights
Section 6.7: New Section that the report will clearly designate if the skylight dome is capped or capless
and clearly shown on the drawings provided on ICC-ES reports.
Add new Section: after Section 3.1.5.2.2: Impact Testing: As there are requirements for skylights to meet
Federal OSHA Impact resistance of 200 lbs, and for CALOSHA to meet an impact resistance of 400 lbs,
there should be a section that addresses, the impact resistance for skylights. Perhaps it is set up as an
optional testing and certification procedure if a manufacturer would like to have the impact rating
added to their respective ICC-ES Report. If the option is selected, then the impact rating should also be
added to the ICC-ES Label.
Section 5.3.4: Add new Section to address the replacement of domes in the field on ICC-ES Listed
skylights. ICC units are factory assembled in accordance with the quality control procedures submitted
by the manufacturers when they submit the required information to ICC-ES. When domes which are
failing, cracked, or damaged in the field, there are no quality control procedures in place to ensure that
the repaired skylight will continue to meet the air, water and structural performance requirements even
though the label on the skylight may indicate so. This would be misleading to the end user. It is very
possible that a dome that is thinner, or a different material than the original dome, could be installed in
an ICC-ES Listed skylight frame. In this case, the unit would no longer be ICC-ES Listed as it has an
alternative glazing material, with different structural performance, different fire rating and different
weathering characteristics. There may also be variations or changes on the types of sealants utilized to
install a replacement dome. An ICC-ES Label would not be pertinent to a skylight which has had the
dome replaced in the field and it is important that this point be addressed in some manner in the
Acceptance Criteria.