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Purchase Orders Wording Samples - Excel

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					Date Last Revised:
09-30-2006
                                                                                                                                                                 Comment/Response Code
Sub Committee Ballot-                                                                                                                                            Green = added text,
                                                                                                                                                                 Red = Deleted text,
July 2006.           CB-                                                                                                                                         * = From Informational draft,
PCP, Comments and                     BC= Bruce Croak, BS=Brad Schultz, CAR=Mahabir Bhabdari, CGC=Greg Carney, DCC=Charlie Curcija,                              P&E = Persuasive and Editorial, ballot not req.
                                      JAH=Joe Hayden, JH=John Hogan, JS=Joel Smith, LL=Larry livermore, MDE=Mitch Edwards, MiT=Mike                              P&S = Persuasive and Substantive, ballot req.
Negatives -- Resolution               Turner, MJT=Mike Tolmen, MT=Mark Toffelmire, MKW=Marg webb, PM=Pat Meusig, TDC=Tom Culp,                                   NP = Not Persuasive,
By Section                            TK=Tony Kamber, RCW=Rick Wright                                                                                            NG = Not Germane, not reletive to balloted draft

               Negative
                 (N) /
               approval
         Comm    with
         entor commen
 #       name   t (AC) Section #      Comment / Alternate language                                                                                               Resolution of Comment

          TDC      N    Forward       The rating shall then be reviewed by an Independent Certification and inspection Agency (IA) which has                     P & S - Draft will be revised and be consistent with page
                                      been licensed/approved by NFRC. Comment: IA not necessary to review whole-product rating calculation, issue                2 of the flow chart and the revised frame language
     1                                CAR, or issue label certificate. These can be done directly by ACE                                                         approved by the working group.
          TDC      N    Forward       For a portion of the product ratings, NFRC-licensed IAs also review label certificate format and content, and              P & S - Draft will be revised and be consistent with page
                                      Ddocumentation trail reviews for quality assurance in accordance with the requirements of the CAP. and issue a             2 of the flow chart and the revised frame language
                                      product Certification Authorization Report (CAR) , or an NFRC Label Certificate for component-based rated                  approved by the working group.
                                      products. Comment: IA does not audit every product rating, only a prescribed fraction
     2
          TDC      N    1.2.2.1.A     A. Participate in the NFRC Certification Program with more than one IA or Approved Calculation Entity and                  P & S - Draft will be revised and be consistent with page
                                      Comment: Add ACE, because that is who issues label certificate                                                             2 of the flow chart and the revised frame language
     3                                                                                                                                                           approved by the working group.
          TDC      N    1.2.2.1.B     Participate in other product certification programs not related to energy performance referencing NFRC                     P & S - deleted the entire 1.2.2.1.B Sentence
                                      procedures. Comment: under AAMA/WDMA/CSA 101/I.S.2/A440 could be considered "energy related" since it is
     4                                required in IECC and ASHRAE. This language is not really necessary, anyway.
          TDC      N    1.2.3.4 C&D   C. If approval of a framing system is sought by the use                                                                    P & S - Draft will be revised and be consistent with page
                                      of computer simulation, Providing a simulation model of the framing system in accordance with NFRC                         2 of the flow chart and the revised frame language
                                      procedures and using the approved NFRC software. D. Ssubmitting the simulation model and data for NFRC                     approved by the working group.
                                      Expert Review. Expert Reviewer shall be an NFRC approved accredited simulator. Comment: Redundant with
     5                                above - Comment: Need to define expert reviewer; include IA or independent simulator.
          TDC      N    1.2.3.4.A     Arranging for framing systems to be submitted for approval either through (a) use of the appropriate default               P & S - Draft will be revised and be consistent with page
                                      frame categories, or (b) Ccontracting with an NFRC accredited simulation laboratory to have the framing system             2 of the flow chart and the revised frame language
                                      modeled. An Accredited Simulator may also model the framing system. Comment: Also see section 2.3. The ability             approved by the working group.
                                      to use default frame categories and default performance values without simulation is essential for minimizing
                                      complexity, especially for custom extrusions which may only be used once. Language added to clarify the two
                                      options: default categories without simulation, or detailed simulation by a sim lab. Some argue that this issue should
                                      be ignored until the categories have been developed, but it does affect the PCP process, and it is important enough
     6                                to include the framework now.
          TDC      N    1.2.3.4.B     Providing a bill of material, detailed parts drawings, glazing details such as glazing bite and gasket materials, system   P & S - Draft will be revised and be consistent with page
                                      dimensional tolerances and shop drawings to the accredited simulation laboratory or NFRC accredited simulator.             2 of the flow chart and the revised frame language
                                      The framing manufacturer/fabricator shall also, be responsible for providing thermo-physical properties of materials       approved by the working group.
                                      not listed in NFRC materials database in accordance with NFRC 101.
     7
     TDC   N   1.2.3.5   Frame Grouping:                                                                                                          P & S - Draft will be revised and be consistent with page
                         A framing Manufacturer/Supplier may opt to have their frame rating subject to frame grouping rules. Frame systems        2 of the flow chart and the revised frame language
                         may be categorized in a pre-determined group. All framing systems within a group shall be assigned the                   approved by the working group. The section will be
                         performance value of the group leader for modeling purposes. Submission of frame systems to a frame grouping             deleted but the note will be retained.
                         shall follow the requirements of section 1.2.3.4.
                         Note: Any component manfucaturer/supplier may also qualify to be an Approved Calculation Entity provided
                         they meet all NFRC requirements to perform those calculations.
                         Comment: Added note that any manufacturer may qualify as an ACE, similar to the language in section 1.2.6 for sim
8                        labs.
     TDC   N   1.2.4.C   Reviewing all submissions from the Specifying Authority, including simulation reports and test reports for products      P & S - Draft will be revised and be consistent with page
                         that can not be simulated to determine whether all data appears complete and in compliance with requirements of          2 of the flow chart and the revised frame language
9                        NFRC program                                                                                                             approved by the working group.
     TDC   N   1.2.4.E   Conducting Documentation-trail reviews/audit of a fraction of whole product systems for verification and challenge       P & S - Draft will be revised and be consistent with page
                         purposes; Comment: IA only audits a selected fraction of product ratings                                                 2 of the flow chart and the revised frame language
10                                                                                                                                                approved by the working group.
     TDC   N   1.2.4.F   Maintaining component-based whole product audit Documentation files/records as well as data files for a period of        P & E - Wording will be revised as indicated and the 2
                         two (2) years. Comment: Save the IA some burden – only store electronic files, and only for                              year period retained because it represents the longest
11                       audited ratings.                                                                                                         expected time to complete a project.
     TDC   N   1.2.4.G   Requiring the Specifying Authority to submit documentation verifying that the label certificate was recorded             P & S - Draft will be revised and be consistent with page
                         in project site records. Comment: Only required if selected for audit, and then that is part of the normal               2 of the flow chart and the revised frame language
12                       documentation trail.                                                                                                     approved by the working group.
     TDC   N   1.2.5     {Comment: Need to create requirements for ACE}                                                                           P & S - Language to be written in the LAP per Chicago
13                                                                                                                                                discussions of Working Group..
     TDC   N   1.2.5     Specifying Authorities and Component Manufacturers participating in the NFRC Component-Based                             P & S - Draft will be revised and be consistent with page
                         Fenestration Product Certification Program shall use accredited Simulation Laboratories or an accredited                 2 of the flow chart and the revised frame language
                         Simulator for fenestration system frame modeling files. Accredited Laboratories and Simulators are                       approved by the working group.
                         responsible for meeting current requirements in the PCP and LAP, including but not limited to the following functions:
                         Comment: redundant with previous language in Sections 1.2.2 and 1.2.3
14
     TDC   N   1.2.5.C   C. Performing component-based fenestration product calculations and issuing label certificates for Specifying            P & S - Draft will be revised and be consistent with page
                         Authorities for design evaluation or product certification in accordance with NFRC requirements. Comment: ACE            2 of the flow chart and the revised frame language
15                       can directly issue label certificate.                                                                                    approved by the working group.
     TDC   N   1.3       Approved Component: glazing, spacer, or framing system of a fenestration product/system for which NFRC                   P & E - Wording will be revised as requested.
                         component approval has been granted, remains current, in accordance with the requirements of the NFRC.
16
     TDC   N   1.3       Computer simulation: the process by which, a matrix is developed utilizing NFRC-approved computer                        P & S - Definition will be deleted because the term is not
                         software and product/ component specifications and drawings provided by a licensed design professional                   used in the current draft.
                         (specifying authority), in accordance with the requirements of the NFRC Rating System. Comment:
17                       Simulation is already defined below.
     TDC   N   1.3       Fabricator: any entity that receives reissued reports as authorized from an NFRC-licensed Lineal Supplier                P & S - Definition will be deleted because the term is not
                         Company and meeting all of the requirements for a fabricator in the NFRC PCP may be deemed to be a                       used in the current draft.
                         fabricator.Comment: This definition of fabricator does not apply in component-based approach. See comment on
18                       reissued reports.
     TDC   N   1.3       Independent Certification and Inspection Agency (IA): an independent certification and inspection agency which has       P & S - Draft will be revised and be consistent with page
                         been licensed by NFRC in accordance with the provisions of the CAP to provide services and grant Product                 2 of the flow chart and the revised frame language
                         Certification Authorizations in accordance with the CAP and the PCP. Comment: ACE can also issue label                   approved by the working group.
19                       certificate, and this wording is unnecessary.
     TDC   N   1.3       Peer Review Committee: A NFRC-recognized review committee comprised of spacer and/or glazing and/or                      P & S - Peer Review has been deleted from the draft
                         spacer manufacturers and experts in field, for the review and approval of component products for accuracy before         per the decisions made by the Subcommittee at the
                         being uploaded to NFRC database and libraries data for inclusion into the NFRC-Approved Component Library.               Minneapolis meeting.
20
     TDC   N   1.3       Quality Control Auditor: a Specifying Authority representative(s) who is responsible for the coordination of             P & S - Definition will be deleted because the term is not
                         production, fabrication, erection and installation to ensure the products meet the energy performance rating             used in the current draft. {Comment: Terms specific to
                         for which certification authorization has been granted. Comment: This term never used in the document.                   CMA should be listed and then incorporated in master
                                                                                                                                                  PCP document under CMA section}
21
     TDC   N   1.3     Reissued Report: a simulation originating from an NFRC-licensed Extruder that is reissued by an NFRC-                   P & S - Definition will be deleted because the term is not
                       accredited simulation laboratory in the name of a fabricator identified on the Extruder Schedule III, for the           used in the current draft.
                       purpose of seeking NFRC Product Line certification authorization for a fabricator seeking NFRC certification
                       for the Product Line. The reissued reports shall meet the requirements as stipulated in NFRC PCP Section
                       2.2.A.6.a.iv and should only contain those products that are manufactured, or intended to be manufactured,
                       by the fabricator. Comment: This term is never used in this document, and appears to be copied over from the old
                       PCP. Doesn’t really apply in component-based approach.
22
     TDC   N   1.3     Simulation: any computer software program for the calculation simulation of the energy performance rating of            P & E - wording will be revised to clarify the definition
                       fenestration products, adopted by the NFRC Board of Directors, as each may be amended, updated or interpreted           and avoid a circular reference.
                       from time to time, whether by action of the NFRC Board of Directors, the NFRC Certification Policy Committee, or the
23                     NFRC Accreditation Policy Committee.
     TDC   N   1.3     Spacer manufacturer: the entity that produces the insulating glazing spacer, excluding all insulating glazing unit      P & E - wording will be revised to clarify the definition.
                       sealants which has been granted approval by a NFRC-IA and entered into the NFRC Component Database.
24                     Comment: Spacers not approved by an IA, right?
     CGC   N   1.1     A. Glazing System - Delete "System" as this typically describes these entire glass and glazing system not just the      P & S - wording will be revised as follows:
                       glass. Alternative language would be "Glazing Infill."                                                                  Glazing/Glazing in-fill: a generic term used to describe
                                                                                                                                               an infill material, such as glass, plastic or other
                                                                                                                                               transparent or translucent material, used to enclose
                                                                                                                                               openings in a building created by a specific framing
                                                                                                                                               system. Opaque in-fill panels are allowed to be
                                                                                                                                               substituted for glazing in any of the calculations in this
25                                                                                                                                             document.
     CGC   N   1.1     Third paragraph calls for "…an NFRC-Approved Calculation Entity (“ACE”) for the calculation of fenestration system      P & S - Language to be written in the LAP per Chicago
                       energy indices for which NFRC certification is required…" however, the details of what is required for "NFRC-           discussions of Working Group..
                       Approval" has not been defined. Once the glazing infill, spacer and frame databases have been fully developed, we
                       do not believe the use of the performance calculation will be a difficult task and therefore, the approval process
                       should be minimal in terms of training and cost. Individuals not interested in serving as an "NFRC-Approved
                       Calculation Entity" should be allowed to use the software and databases for design considerations that may or may
                       not lead to product/project certification. (NOTE: Reference to the NFRC-Approved Calculation Entity also appears in
                       numerous other sections of the draft and therefore must be further defined.)
26
     CGC   N   1.1     Fourth paragraph calls for "Products for which certificates are issued shall be recorded in the NFRC Certified          P & S - new language will be developed pertaining to
                       Products Directory." We have previously raised the question that once "products" are listed, can that product           Reissuance of Label certificate under section 4.1.B.3
                       construction be used for multiple projects by multiple parties? To date, this question has not been addressed by the
                       Subcommittee Chair or Vice Chair, therefore, we recommend the addition of the following language: Once listed in
                       the NFRC Certified Products Directory, identical products and systems maybe certified for additional applications and
27                     projects by additional users.
     CGC   N   1.2.2   Paragraph B second bullet calls for "Detailed information on the spacer system." We have previously questioned the      P & S - Draft will be revised and be consistent with page
                       meaning of "detailed information" without response from the Subcommittee Chair, Vice - Chair or NFRC staff.             1 of the flow chart and the revised spacer language
                       Pervious drafts and discussions related to the spacer system information have included the sealant materials and        approved by the working group.
                       dimensions. In order to avoid multiple simulations related to minor variations in the sealant dimensions (silicone
                       secondary seals for structural silicone glazing applications for example); we recommend that default sealant system
                       (dimensions) be established for the various spacer systems that are entered into the spacer database.
28
     CGC   N   1.2.2   Last paragraph reads "Additional requirements may be established by NFRC as necessary to assure continued               P & E _ Foreword will be revised to accommodate
                       program credibility." In lieu of such an open ended statement at this location, we would recommend a general            requested statement. Statement deleted in this section.
                       statement in the Forward stating that program requirements may be modified at times based on committee and
29                     membership actions.
     CGC   N   1.2.2.    Paragraph D. provides the first reference to the "…whole product rating specification data retention (Documentation-       P & S - requirements will be revised to reflect the votes
                         trail)…" The requirements of the documentation trail and individual project requirements have yet to be defined. As        of the Subcommittee in the Minneapolis meeting and
                         we have mentioned in numerous previous meetings, the contractual nature of the commercial construction industry            pages 1 and 2 of the revised flow charts.
                         and well established documentation requirements of purchase orders, acknowledgements, shipping case tags, etc.,
                         are an ongoing part of the commercial fenestration industry. The subcommittee needs to carefully consider the
                         requirements of the documentation trail. We strongly recommend a minimal audit program where five percent of
                         certified projects require submittal of a limited number of defined documents. (NOTE: The documentation trail is
                         mentioned in several sections of the draft and needs to be properly discussed and defined before the product
                         certification program moves forward for adoption.)
30
     CGC   N   1.2.2.1   Paragraph B. states: "Participate in other product certification programs not related to energy performance                P & S - Sentence will be deleted.
                         referencing NFRC procedures." We have previously questioned the intended meaning of this paragraph and have
                         not received response from the Subcommittee Chair, Vice-Chair or NFRC staff. We again question the intent of the
31                       paragraph
     CGC   N   1.2.3.1   Paragraph B. states: "Appropriate sealants are specified during the IGU component definition using approved NFRC           P & S - Draft will be revised and be consistent with page
                         software tools." The requirements for insulating glass unit sealants need to be further discussed. As noted above, in      1 of the flow chart and the revised spacer language
                         order to avoid multiple simulations related to minor variations in the sealant dimensions (silicone secondary seals for    approved by the working group.
                         structural silicone glazing applications for example), we recommend that default sealant system (dimensions) be
                         established for the various spacer systems that are entered into the spacer database.
32
     CGC   N   1.2.3.3   The subcommittee needs to develop/finalize the spacer grouping rules before this product certification program             NP - language under development in Technical
                         moves forward for adoption                                                                                                 committee. PCP needs to reference the process to
                                                                                                                                                    follow for approval. The current wording is a
                                                                                                                                                    placeholder for a reference to the requirements in the
33                                                                                                                                                  technical documents when developed.
     CGC   N   1.2.3.4   Add paragraph F: Choose to use only component product databases and simulation tools under the NFRC program                P & E _ Foreword will be revised to accommodate
34                       for design evaluation without the intent of product or project certification and labeling.                                 requested statement.
     CGC   N   1.2.3.5   The subcommittee needs to develop/finalize the frame grouping/default rules before this product certification program      NP - language under development in Technical
                         moves forward for adoption. As we have expressed at numerous meetings and in previous comment periods, we                  committee. PCP needs to reference the process to
                         strongly believe that framing system grouping/defaults represent a critical element of developing a product                follow for approval. The current wording is a
                         certification program that can be fair, accurate and cost effective. Failure to recognize the ability to develop framing   placeholder for a reference to the requirements in the
                         system grouping/defaults and pushing the program forward without this aspect will dramatically affect the program          technical documents when developed.
                         cost, support, and acceptance by the commercial fenestration industry.
35
     CGC   N   1.2.4     First paragraph correct the "NRFC" by changing to NFRC. We called attention to this error during the last comment          P & E - Spelling will be corrected.
                         period; however, the Subcommittee Chair, Vice-Chair and NFRC staff did not make the correction.
36
     CGC   N   1.2.4     Overall comment: We question the role of the IA in a whole product certification based on calculations with materials      P & S - requirements will be revised to reflect the votes
                         from the databases. Once the glass, spacer and framing system(s) have been documented in the project                       of the Subcommittee in the Minneapolis meeting and
                         specifications, a calculation entity combines the specified products and framing system and calculates the thermal         pages 1 and 2 of the revised flow charts.
                         and optical performance values. The cost of having the IA check to see if the calculation entity used the specified
                         products in the calculation is unnecessary. We believe the cost and role of the IA can be dramatically reduced by the
                         properly designed software using glass, spacer grouping and frame grouping/default opportunities.
37
     CGC   N   1.2.4.    Paragraph D. delete the text "Approving framing component performance values for listing in the Approved                   P & S - requirements will be revised to reflect the votes
                         Component Library." The Accredited Simulator or Simulation Laboratory should provide approval of component                 of the Subcommittee in the Minneapolis meeting and
                         performance values.                                                                                                        pages 1 and 2 of the revised flow charts.
38
     CGC   N   1.2.5     Paragraph B. revise to read: "Entering into a license agreement with NFRC for authorization to conduct component-          P & S - new wording will be developed by the working
                         based fenestration product calculations for products/projects requiring NFRC rating and certification using the NFRC       group.
39                       Approved Component Library database and software tools."
     CGC   N   1.2.5     Add paragraph D. "Perform component-based fenestration product calculations for design evaluation purposes when            P & E - Foreword will be revised to accommodate
40                       product/project certification may or may not be intended."                                                                 requested statement.
     CGC   N   1.3         Where text states "the meaning as set forth and described in NFRC technical documents" delete the language and         NP - language under development in Technical
                           insert the definition from the other document(s). This occurs for the following terms: Glass, Product, Product Line,   committee. PCP needs to reference the process to
                           Total Fenestration Product.                                                                                            follow for approval. The current wording is a
                                                                                                                                                  placeholder for a reference to the requirements in the
41                                                                                                                                                technical documents when developed.
     CGC   N   1.3         License Agreement - second paragraph use lower case "f" for the word fenestration, and third paragraph delete          P & E - corrections will be made to draft.
42                         "Responsible Parties"
     CGC   N   1.3         Project Certificate - Delete "The project certificates list the average energy rating values for these labeled         NP - Project certificates are part of the draft and
43                         fenestration systems."                                                                                                 average values are referenced elsewhere..
     BS    N   Forward     Through the Certification Program and its companion laboratory accreditation program (the "Accreditation Program")     P & E - corrections will be made to draft.
44                         , set forth in the NFRC Laboratory Accreditation Program
     BS    N   Forward     At present, specifying authority may elect to rate products for U-factor, solar heat gain coefficient, visible         P & E - corrections will be made to draft.
                           transmittance, air leakage, or any other procedure adopted by NFRC, and to include those ratings on the NFRC label
                           affixed to its products (or the NFRC Label Certificate for component-based rated products) . U-factor,
45
     BS    N   Forward     Documentation trail reviews for quality assurance in accordance with the requirements of the CAP, and issue a          P & E - corrections will be made to draft.
                           product Certification Authorization Report (CAR) , or an NFRC Label Certificate for component-based rated products.
46
     BS    N   Forward     NFRC manages the Rating System and regulates the Product Certification Program (PCP) , Laboratory Accreditation        P & E - corrections will be made to draft.
47                         Program (LAP)
48   BS    N   1.2.2.B     Detailed information on the spacer system..                                                                            P & E - corrections will be made to draft.
     BS    N   1.2.2.C     Verifying that the insulating glass units used in the rated products are certified by a nationally recognized IG       P & E - corrections will be made to draft.
                           Certification Program.a nationally recognized IG Certification Program certifies the insulating glass units
49                         used in the rated products.
     BS    N   1.2.3.4.D   Submitting the simulation model and data for NFRC Expert Review. Expert Reviewer shall be an NFRC                      P & S - New language developed in the Foreword by the
                           accredited simulator.(Expert Review not defined, but seems to indicate a certified simulator. This step must           Working Group.
50                         be clarified.)
     BS    N   1.2.4.D      Approving framing component performance values for listing in the Approved Component Library database                 NP - per Minutes from Minneapolis meeting.
51
     BS    N   1.2.4.E     E. Conducting Documentation-trail reviews/audit of whole product systems for verification and challenge purposes       P & S - Draft will be revised and be consistent with page
                                                                                                                                                  2 of the flow chart and the revised frame language
52                                                                                                                                                approved by the working group.
     BS    N   1.2.4.H     Nullifying or making void the label certificates of a component based whole product system if the system is            Part #1 - NP - this wording pertains to the audit
                           found to be non-compliant with PCP requirements.                                      (Certificates not                percedure not the approval process in general.
                           originated by IA, and beyond our control. The review should be accomplished before the Label Certificate is            Part #2 - NP - per Minutes from Minneapolis meeting.
                           generated, not afterwards. Rescinding certification is much more difficult than withholding it: and not an
                           incentive for promoting
53                         initial correctness. This is not practical, and not the current practice in the program.)
     BS    N   1.2.5       Role of the Approved Calculation Entity Under the Component-Based Fenestration Product Certification Program,          NP - per Minutes from Minneapolis meeting.
                           an approved Calculation Entity is responsible for meeting the
54                         NFRC
     BS    N   1.2.5.A     Being approved by NFRC to conduct component-based whole product calculations using the NFRC Approved                   NP - per Minutes from Minneapolis meeting.
55                         Component Library Database for certification authorization.
     BS    N   1.2.5.B     Entering into a license agreement with NFRC for authorization to conduct component-based fenestration product          NP - per Minutes from Minneapolis meeting.
56                         calculations using the NFRC Approved Component Library database and software tools.
     BS    N   1.2.5       {Comment: Need to create requirements for ACE}                                                                         P & S - Language to be written in the LAP per Chicago
57                                                                                                                                                discussions of Working Group..
     BS    N   1.2.6       Role of Accredited Simulator or Simulation Laboratory                                                                  NP - Simulators are certified, simulation laboratories are
58                                                                                                                                                accredited.
59   BS    N   1.2.6.C     Maintain independence per the criteriaon found in the NFRC LAP                                                         P & E - corrections will be made to draft.
     BS    N   1.2.6.D     D. Enter into a license agreement with NFRC authorizing use of the NFRC simulation programs and conduct                NP - per Minutes from Minneapolis meeting.
                           component-based fenestration product calculations using the NFRC Approved Component Library database and
60                         software tools.
     BS   N   1.2.6   Specifying Authorities and Component Manufacturers participating in the NFRC Component-Based Fenestration                 NP - Simulators are certified, simulation laboratories are
                      Product Certification Program shall use accredited Simulation Laboratories or an accredited Simulator for                 accredited.
                      fenestration system frame modeling files. Accredited Laboratories and Simulators are responsible for meeting
                      current requirements in the PCP and LAP, including but not limited to the following functions:
61
     BS   N   1.2.6   Note: An NFRC- Accredited Simulation Laboratory may also qualify to be an Approved Calculation Entity provided            NP - per Minutes from Minneapolis meeting.
                      they meet all NFRC requirements to perform those calculations. For information on the
62                    Laboratory Accreditation Program, see the NFRC LAP.
     BS   N   1.2.8   NFRC certification is the authorized act of a fenestration licensee in labeling a fenestration product/component with     NP - per Minutes from Minneapolis meeting.
                      an NFRC label, label certificate and/or project certificate, which bears one or more energy performance ratings
                      reported by NFRC-accredited Simulation and Testing Laboratories or Approved Calculation Entity and authorized for
63                    certification by NFRC
     BS   N   1.2.8   NFRC therefore disclaims any and all liability that may arise from or in connection with services provided by,            NP - per Minutes from Minneapolis meeting.
                      decisions made by or reports or certifications issued or granted by any NFRC-Accredited Laboratory, NFRC
64                    Approved Calculation Entity,
     BS   N   1.3     Approved Calculation Entity: Entity that employs at least one individual that has attended a NFRC Calculation             NP - per Minutes from Minneapolis meeting. However,
                      Training Workshop, completed and passed all necessary examinations, and is approved by NFRC to carry out                  delete {to be developed} as editorial.
                      component-based whole product certification calculations. This individual will be the individual in responsible charge.
                      The Approved Calculation Entity shall have met NFRC requirements of the LAP {to be developed}
65
66   BS   N   1.3     Approved Component Library:                                                                                               NP - per Minutes from Minneapolis meeting.
     BS   N   1.3     Applicable Simulation : NFRC 100, NFRC 101, NFRC 102, NFRC 200, NFRC 201, NFRC 300, NFRC 301, NFRC                        P & S - Definition will be deleted because the term is not
                      400, or any other calculation for the determination of the energy performance of fenestration products,                   used in the current draft. {Comment: Terms specific to
                      adopted by the NFRC Board of Directors in addition to or in lieu of any computer software program for                     CMA should be listed and then incorporated in master
                      simulating the energy performance rating of fenestration products, adopted by the NFRC Board of Directors,                PCP document under CMA section}
                      as each may be amended, updated or interpreted from time to time, whether by action of the NFRC Board of
                      Directors, the NFRC Certification Policy Committee or the NFRC Accreditation Policy Committee. (Covered
67                    by Simulation definition.)
     BS   N   1.3     Certification: the issuance of a label certificate to an NFRC-Licensed Specifying Authority for a fenestration system     NP - commentor did not provide substitute wording
                      for which NFRC Certification Authorization has been granted, and remains current, in accordance with the
68                    requirements of the PCP.
     BS   N   1.3     Certification Program: the NFRC program for granting authorization to Specifying Authorities to submit data and           NP - submission of documentation is part of the
                      documentation which can be used to rate and label products under the NFRC Rating System, as set forth in the              process.
69                    PCP.
     BS   N   1.3     Certified Fenestration System: a fenestration system for which a NFRC label certificate is generated using the            NP - the Label constitutes certification Carl to contact.
70                    NFRC Component Library and is issued upon execution of the NFRC License Agreement.
     BS   N   1.3     Certified Simulator: Any individual that has attended at least one NFRC-sanctioned Simulation Training Workshop,          P & E - NFRC to use at least the current required NFRC
                      completed and satisfactorily passed all necessary examinations, participated in NFRC simulation round robins, and is      approved simulation software tools for which services
                      approved by NFRC to use the current at least one NFRC-approved simulation software tools.                                 are provided..
71
     BS   N   1.3     Component: any glazing, spacer, or framing system which has been granted approval by NFRC procedures and                  NP - per revisions to section 2.3 and page 2 of the
                      entered into the NFRC Component Library                                                                                   revised flowchart. ',' has been added after frameing
72                                                                                                                                              system.
73   BS   N   1.3     Component Library: see Approved Component Library                                                                         NP - per Minutes from Minneapolis meeting.
     BS   N   1.3     Independent Certification and Inspection Agency (IA): an independent certification and inspection agency which            P & E - corrections will be made to draft.
                      has been licensed by NFRC in accordance with the provisions of the CAP to provide services and grant Product
74                    Certification Authorizations in accordance with the CAP and the PCP.
     BS   N   1.3     Peer Review Committee: An NFRC-recognized review committee comprised of spacer and/or glazing and/or spacer               NG - peer review has been removed from the draft.
                      manufacturers and experts in field, for the review and approval of component products for accuracy before being
                      uploaded to NFRC database and libraries data for inclusion into the NFRC-Approved Component Library.
75
     BS   N   1.3     Product Line: the meaning as set forth and described in NFRC technical documents, which is being applied to group         NP - commentor did not provide reason for deletion
                      of fenestration products for which NFRC Product Certification Authorization is being sought.
76
     BS    N    1.3              Project Certificate: a document providing values calculated using the label certificate ratings of each fenestration       NP - commentor did not provide reason for deletion -
                                 system to be installed in a particular project. The project certificates list the average energy rating values for these
                                 labeled fenestration systems. The project certificate shall be part of the project records in order to comply with all
                                 applicable requirements of the PCP which shall be met. (What NFRC approved software tool is used to provide
                                 these values? What provides this certificate? Who issues this certificate? How does this certificate relate to
                                 the PCP? Project certification is beyond the scope of NFRC and should not be included in any required
77                               section of this certification document.)
     BS    N    1.3              Specifying Authority: architects and/or engineers who specify the fenestration products, systems and suppliers to be       P & S - section reworded by the working group.
                                 used on a project in order to meet the design and performance requirements as designated by the building codes,
                                 building owner/developer and enters into a license agreement with NFRC. This entity confirms that the individual
                                 systems (glazing, spacer, and framing system) used to generate the whole product rating are those in the final
                                 assembly. The Specifying Authority is responsible for taking any corrective actions necessary if the final assembly
                                 does not conform to the whole product rating.
78
     BS    N    1.3              Spacer manufacturer: the entity that produces the insulating glazing spacer, excluding all insulating glazing unit         P & E - corrections will be made to draft.
                                 sealants which has been granted approval by an NFRC-IA and entered into the NFRC Component Database.
79
     PM    AC   General, 1.2.3.3 Additional I would like to see a definition of " Group Leader" that is used in section 1.2.3.3 and 1.2.3.4 etc...          P & S - Draft will be revised and be consistent with page
                and 1.2.3.4 etc.                                                                                                                            1 of the flow chart and the revised spacer language
80                                                                                                                                                          approved by the working group.
     PM    AC   1.2.3.3          Have the predetermined Keff values for spacer systems in section 1.2.3.3 been estabilshed?                                 P & S - Draft will be revised and be consistent with page
                                                                                                                                                            1 of the flow chart and the revised spacer language
81                                                                                                                                                          approved by the working group.
     PM    AC   1.3              Accredited Simulator: An individual who has passed the NFRC simulator testing criteria and maintains their                 NP - Simulators are certified, simulation laboratories are
                                 accreditation according to NFRC policy. This person can be but is not limited to staff of a testing                        accredited.
82                               laboratory, consultants, employee of a manufacturer or an association employee.
     PM    AC   1.3              Expert Reviewer: An NFRC accredited simulator not employed by the framing system manufacturer or                           P & S - New language developed in the Foreword by the
83                               submitter of the simulation model to be reviewed.                                                                          Working Group.
     JAH   N    Forward          U-factor, SHGC and VT, and AL,                                                                                             NP - Simulators are certified, simulation laboratories are
                                 rating reports shall be obtained from an approved calculation entity and/or accredited                                     accredited.
                                 laboratory, which have been approved/accredited by NFRC in accordance with the
84                               requirements of the LAP {{Section to be developed}}.
     JAH   N    1.2.3.2.C        C. Submitting the spacer data for NFRC peer review in accordance with the procedures in NFRC {to be developed}.            NP - Peer review no longer required.
85
     JAH   N    1.3              Applicable Simulation Procedure : NFRC 100, NFRC 101, NFRC 102, NFRC 200, NFRC 201, NFRC 300, NFRC                         P & E - corrections will be made to draft.
                                 301, NFRC 400, or any other calculation for the determination of the energy performance of fenestration products
86
     JAH   N    1.3              Certification: the issuance of a label certificate to an NFRC-Licensed Specifying Authority for a fenestration system,     P & E - corrections will be made to draft.
                                 or the affixing of a label by an NFRC-Licensed Specifying Authority to a fenestration system, for which NFRC
                                 Certification Authorization has been granted, and remains current, in accordance with the requirements of the PCP.
87
     JAH   N    1.3              Certification Mark: the distinctive logotype a “sunflake” incorporating the initials NFRC in the center and the work       P & E - corrections will be made to draft.
                                 “CERTIFIED” appearing at the base, which has been registered with the United States Trademark Office, and it
                                 intended to appear as a component of an NFRC Label or label certificate to indicate that the fenestration product to
                                 which the NFRC Label is affixed, or to which the label certificate applies, has met the requirements of the PCP.
88
     JAH   N    1.3              Certified Fenestration System: a fenestration system for which an NFRC label certificate is generated, or label is         P & E - corrections will be made to draft.
                                 affixed, using the NFRC Component Library and is issued upon execution of the NFRC License Agreement.
89
     JAH   N    1.3              Glass: an inorganic, amorphous substance, usually transparent, composed of silica (sand), soda (sodium                     P & S - defer to GANA and check current definition, add
90                               carbonate) and lime (calcium carbonate) with small quantities of other materials.                                          if there is no conflict.
     JAH   N    1.3              Lineal Supplier: a company that manufacturers lineals (i.e. extrusions or other similar frame/sash components made         P & E - corrections will be made to draft.
                                 from vinyl, aluminum, wood, fiberglass, or other components materials), and supplies those lineals to a glazing
                                 contractor, may obtains simulation reports and testing reports for initial validation or recertification, authorizes re-
                                 issuance of those reports to a fabricator for submission for certification authorization, and agrees to comply to those
                                 non-compliance issues directly related to the material which they supply.
91
      JAH   N   1.3         Rating: the energy performance rating value obtained using NFRC-approved simulation procedures that is used for       P & E - corrections will be made to draft.
92                          comparative purposes.
      JAH   N   1.3         Rating Procedure: an NFRC approved document describing all the necessary steps to obtain a rating (i.e.               P & E - corrections will be made to draft.
93                          NFRC 100, NFRC 200, etc.)
      JAH   N   1.3         Specifying Authority: architects, engineers, and/or manufacturers (???) who specify the fenestration products,        P & E - corrections will be made to draft in accordance
                            systems and suppliers to be used on a project in order to meet the design and performance requirements as             with wording submitted by M. Webb..
                            designated by the building codes, building owner/developer and enters into a license agreement with NFRC. This
                            entity confirms that the
                            individual systems (glazing, spacer, and framing system) used to generate the whole product rating are those in the
                            final assembly. The Specifying Authority is responsible for taking any corrective actions necessary if the final
94                          assembly does not conform to the whole product rating.
      MiT   N   Foreword    COMMENT: "air leakage" should be removed from this component based certification program. To my                       P & E - corrections will be made to draft.
                            knowledge, there is not a software tool to certify this performance. This program should be limited to what
95                          can only be computer simulated.
      MiT   N   Foreword    COMMENT: "accredited calculation entity" should read "approved calculation entity"                                    P & S - New language developed in the Foreword by the
96                                                                                                                                                Working Group.
      MiT   N   Foreword    COMMENT: "NFRC-licensed" IAs also review label certificate format and content". Certificate should be a               P & S - Language to be written in the LAP per Chicago
97                          set format. So, there should be no need to review.                                                                    discussions of Working Group..
      MiT   N   1.2.1.D     COMMENT: Need to define how NFRC "approves" an "Approved Calculation Entity".                                         P & E - Language to be written in the LAP-Chicago
98                                                                                                                                                discussions.
      MiT   N   1.2.2       COMMENT: (3rd paragraph)                                                                                              P & E - corrections will be made to draft.
99                          "... and NFRC-licensed fenestration Specifying Authority" Remove the word fenestration.
      MiT   N   1.2.2.B     COMMENT: Need to develop a clear, concise form for the person responsible for submitting this                         NP - no specific wording or form was suggested -
                            documentation. Reference it as an Appendix attachment.                                                                commentor should resubmit with requirement to use
100                                                                                                                                               form wording and draft form.
      MiT   N   1.2.3.4.B   COMMENT: I'm assuming this section applied to Product Line Simulations (see section 4.1 H). I don't                   NP - issues have been addressed. Draft will be revised
                            believe "system dimensional tolerances" is appropriate. Maybe "nominal system dimensions". Also, what                 and be consistent with page 2 of the flow chart and the
                            is the procedure for adding a section to a product line? (ie adding a 4" wide curtain wall vertical mullion to        revised frame language approved by the working group.
101                         a standard 2 1/2" curtain wall system.)
      MiT   N   1.2.3.4.C   COMMENT: I believe the "simulation model" should match the NFRC default gateway size for that product                 NP - the current wording of the site-built program is the
102                         category. Is this supposed to be provided in the form of an elevation drawing?                                        precedent for the wording in this section.
      MiT   N   1.2.3.4.E   COMMENT: Delete this section - not necessary. Challenge procedures are in place to handle numbers that                P & S - Draft will be revised and be consistent with page
                            appear erroneous. The manufacturer has already contracted with an Accredited Laboratory / Simulator to                2 of the flow chart and the revised frame language
103                         prepare the data.                                                                                                     approved by the working group.
      MiT   N   1.2.3.5     COMMENT: New frame grouping rules need to be developed for the commercial market. It is essential that                P & S - Draft will be revised and be consistent with page
                            these rules be developed prior to the approval of this certification program. It is not feasible to require           2 of the flow chart and the revised frame language
                            framing manufacturers to model the thousands of options available within their product lines. I also believe          approved by the working group.
                            that default values should be developed. A MFG could choose to use default values or simulate their own.
104
105   MiT   N   1.2.4       COMMENT: Rework per comments above.                                                                                   P & E - corrections will be made to draft.
      MiT   N   1.2.5.C     COMMENT: You should not have to be an ACE to utilize the software for preliminary design purposes.                    P & S - Language to be written in the LAP per Chicago
                            Framing manufacturers should be allowed to use the software for their own product lines. Component                    discussions of Working Group. Also addrressed by
                            Manufacturers should also be allowed to be an ACE.                                                                    revisions to the Foreword developed by the Working
106                                                                                                                                               Group.
      MiT   N   1.3         COMMENT: Approved Calculation Entity - By requiring an ACE to meet NFRC requirements of the LAP, I                    P & S - issues have been discussed and addressed the
                            believe you are limiting the ACE to be an Accredited Laboratory or Simulator. This is not acceptable.                 revised language approved by the working group. Draft
                                                                                                                                                  will be revised and be consistent with the flow chart.
107
      MiT   N   1.3         COMMENT: Quality Control Auditor - Since the Specifying Authority definition is restricted to Architects,             P & S - Definition will be deleted because the term is not
                            Specifiers, and Project Engineers, I don't believe the SA would be able to provide this type of assurance.            used in the current draft. {Comment: Terms specific to
                                                                                                                                                  CMA should be listed and then incorporated in master
                                                                                                                                                  PCP document under CMA section}
108
      MiT   N   1.3         COMMENT: Specifying Authority - Too restrictive. See earlier comment.                                                 P & E - corrections will be made to draft in accordance
109                                                                                                                                               with wording submitted by M. Webb..
      MJT   N   Foreword    COMMENT: I believe that the ACE should be an “accredited” agent, meeting similar criteria to a lab. The               NP - addressed by language developed by the working
                            definition of accredited in the LAP embodies the process which should be required of an ACE. This change              Group per Minutes of the Minneapolis meeting.
110                         should be made throughout the document.
111   MJT   N   Foreword    The correct terminology from the CAP is “licensed”                                                                    P & E - corrections will be made to draft.
      MJT   N   1.1.A       Glazing System; Comment: In both cases, the systems are not included in the component database.                       P & S - wording will be revised as follows:
                                                                                                                                                  Glazing/Glazing in-fill: a generic term used to describe
                                                                                                                                                  an infill material, such as glass, plastic or other
                                                                                                                                                  transparent or translucent material, used to enclose
                                                                                                                                                  openings in a building created by a specific framing
                                                                                                                                                  system. Opaque in-fill panels are allowed to be
                                                                                                                                                  substituted for glazing in any of the calculations in this
112                                                                                                                                               document.
      MJT   N   1.1.B       Spacer Assembly; Comment: In both cases, the systems are not included in the component database.                      P & S - Draft will be revised and be consistent with page
                                                                                                                                                  1 of the flow chart and the revised spacer language
113                                                                                                                                               approved by the working group.
      MJT   N   1.1         The Calculation Entity shall be approved by NFRC to use the component library. COMMENT: This is                       NP - calculation entity needs to be approved by NFRC
114                         redundant language.                                                                                                   and agreement signed.
      MJT   N   1.2.1.D     Approves Accredits Calculation Entities to provide calculations for certified whole product fenestration systems;     NP - per Minutes from Minneapolis meeting.
115
      MJT   N   1.2.2       Under either the web based procedure or the hard copy procedure of the Component-Based Fenestration                   P & S - the draft no longer references two procedures.
                            Product Certification Program, an NFRC-licensed Specifying Authority is responsible for meeting the requirements in
                            the PCP including, but not limited, to the following functions: COMMENT: In this document, no mention is made
116                         of a hard copy procedure, so this language is meaningless.
      MJT   N   1.2.2.B     Identification of the spacer manufacturer including name and contact information. COMMENT: The spacer                 P & S - delete the text. The draft will be revised.
                            manufacturer is not a direct contact of the specifying authority, and therefore name and contact information
                            should not be required. The detailed information on the spacer system will come from the IG manufacturer,
117                         not the spacer manufacturer.
      MJT   N   1.2.2.C     Verifying that the insulating glass units used in the rated products are certified by a nationally recognized IG      NP - it is a requiremnt of the program.
                            Certification Program. COMMENT: This responsibility is NOT the Specifying Authority’s. It needs to be
118                         verified by either the IA or ACE.
      MJT   N   1.2.2.D     Selecting and contracting with a Licensed Certification and Inspection Agency (IA) for whole product rating           P & S - the draft will be revised.
                            specification data retention (Documentation-trail) and review, updates to the whole product data if the review
                            necessitates a revision, product verification, and in lieu of specifying Authority access to the components
                            library, issuance of label certificates. COMMENT: The specifying authority cannot issue their own label
119                         certificate, so this language is meaningless.
      MJT   N   1.2.2.1.B   Participate in other product certification programs not related to energy performance referencing NFRC                P & S - statement will be deleted and wording added to
                            procedures. COMMENT: Specifying Authorities (Architects and Engineers) should not be precluded from                   Foreword to outline permitted use of the software.
120                         participating in other certification programs. It is unrealistic to expect them to agree to this.
      MJT   N   1.2.2.3.A   Obtaining the optical properties of the glazing in accordance with NFRC 300 for for inclusion in Spectral Data        P & E - the draft will be revised.
121                         Listing Library
      MJT   N   1.2.3.2.A   Submitting detailed die drawings, listed dimensions, and one 150 mm (6 in) long cut sample (if required) for peer     P & S - Draft will be revised and be consistent with page
                            review to NFRC. COMMENT: Spacer modeling and maintenance of the spacer library should be an NFRC                      2 of the flow chart and the revised frame language
                            function, potentially subcontracted, for consistency. This would streamline the process and ensure                    approved by the working group.
122                         consistency in modeling and coordination with the software tools.
      MJT   N   1.2.3.2.B   Modeling the spacer using NFRC approved software and submitting it for peer review to NFRC.                           P & S - Draft will be revised and be consistent with page
                            Note: the model of the spacer should not include sealants necessary when the spacer is incorporated into              1 of the flow chart and the revised spacer language
                            an insulating glass unitthe spacer information excludes sealants. Appropriate sealants are specified during           approved by the working group also peer review is no
123                         the IGU component definition using approved NFRC software tools.                                                      longer in the draft..
      MJT   N   1.2.3.2.C   Submitting the spacer data for NFRC peer review in accordance with the procedures in NFRC {to be                      P & S - peer review is no longer in the draft..
124                         developed}.
      MJT   N   1.2.3.4.A   Contracting with an NFRC accredited simulation laboratory to have the framing system modeled. An Accredited           NP - per Minutes from Minneapolis meeting.
                            Simulator may also model the framing system. COMMENT: Only an accredited simulation laboratory
125                         should be allowed to perform and/or submit the framing system modeling.
      MJT   N   1.2.3.4.B   Providing a bill of material, detailed parts drawings, glazing details such as glazing bite and gasket materials, system   P & S - Draft will be revised and be consistent with page
                            dimensional tolerances and shop drawings to the accredited simulation laboratory or NFRC accredited simulator.             2 of the flow chart and the revised frame language
                            The framing manufacturer/fabricator shall also, be responsible for providing thermo-physical properties of materials       approved by the working group.
                            not listed in NFRC materials database in accordance with NFRC 101.
126
      MJT   N   1.2.3.4.C   Providing a simulation model of the framing system in accordance with NFRC procedures and using the                        P & S - Draft will be revised and be consistent with page
                            approved NFRC software                                                                                                     2 of the flow chart and the revised frame language
127                                                                                                                                                    approved by the working group.
      MJT   N   1.2.3.4.D   Submitting the simulation model and data for NFRC Expert Review. Expert Reviewer shall be an NFRC                          P & S - Draft will be revised and be consistent with page
                            accredited simulator.                                                                                                      2 of the flow chart and the revised frame language
128                                                                                                                                                    approved by the working group.
      MJT   N   1.2.3.4.E   If approved the framing system manufacturer/fabricator shall arrange for the framing system to be uploaded by              P & S - Draft will be revised and be consistent with page
                            NFRC to the NFRC approved Frame Framing System library.                                                                    2 of the flow chart and the revised frame language
129                                                                                                                                                    approved by the working group.
      MJT   N   1.2.4.F     Maintaining component-based whole product Documentation files/records as well as data files for a period of two (2)        NP - the 2 year period retained because it represents
                            four (4) years. COMMENT: This requirement should be in line with the remainder of the program. 2 years is                  the longest expected time to complete a project.
                            also too short considering the timelines involved with many commercial projects.
130
      MJT   N   1.2.5.C     {Comment: Need to create requirements for ACE}                                                                             P & S - Language to be written in the LAP per Chicago
                                                                                                                                                       discussions of Working Group. Also addrressed by
                                                                                                                                                       revisions to the Foreword developed by the Working
131                                                                                                                                                    Group.
      MJT   N   1.2.5.D     Maintain independence per the criterion found in the NFRC LAP.                                                             P & S - Language to be written in the LAP per Chicago
                                                                                                                                                       discussions of Working Group. Also addrressed by
                                                                                                                                                       revisions to the Foreword developed by the Working
132                                                                                                                                                    Group.
      MJT   N   1.2.5.E     Comply with all requirements as specified in the NFRC LAP . COMMENT: LAP requirements need to be                           P & S - Language to be written in the LAP per Chicago
                            created.                                                                                                                   discussions of Working Group. Also addrressed by
                                                                                                                                                       revisions to the Foreword developed by the Working
133                                                                                                                                                    Group.
      MJT   N   1.2.5.F     Verifying that the insulating glass units used in the rated products are certified by a nationally recognized              P & S - will be revised to "Verifying that a nationally
                            IG Certification Program. COMMENT: See comment on section 1.2.2.C.                                                         recognized IG Certification Program certifies the
134                                                                                                                                                    insulating glass units used in the rated products.
      MJT   N   1.2.6       Note: An NFRC- Accredited Simulation Laboratory may also qualify is automatically qualified to be an Approved              NP - since the CMA approach involves new procedures
                            Calculation Entity provided they meet all NFRC requirements to perform those calculations. For information on the          the automatic inclusion of Accredited Simulation
                            Laboratory Accreditation Program, see the NFRC LAP. COMMENT: The technical and other requirements for                      Laboratories is not warranted.
135                         an ACE are a subset of those required by an accredited simulation lab.
      MJT   N   1.2.8       NFRC certification is the authorized act of a fenestration licensee in labeling a fenestration product/component with      NP - correct as written as approved by the
                            an NFRC label, label certificate and/or project certificate, which bears one or more energy performance ratings            Subcommittee in Minneapolis.
                            reported by NFRC-accredited Simulation and Testing Laboratories or Approved Calculation Entity and authorized for
                            certification by NFRC. Certification authorization may also be is issued by an NFRC licensed IA. Each of these
                            participants acts independently to report, authorize for certification and certify a rating. COMMENT: The language
                            in this section doesn’t make a lot of sense to me. The first sentence is extremely confusing and in this
                            sentence, authorization is always issued by an IA, not “may also be”. Who else would issue the
136                         authorization?
      MJT   N   1.3         Approved Component Library: an electronic database owned and maintained by NFRC which contains peer-                       P & S - peer review is no longer in the draft..
                            reviewed and approved glazing, spacer, and framing system component information. COMMENT: It is redundant
137                         to mention this here.
      MJT   N   1.3         Applicable Simulation Laboratory: NFRC 100, NFRC 101, NFRC 102, NFRC 200, NFRC 201, NFRC 300, NFRC                         P & S - Definition will be deleted because the term is not
                            301, NFRC 400, or any other calculation for the determination of the energy performance of fenestration products,          used in the current draft. {Comment: Terms specific to
                            adopted by the NFRC Board of Directors in addition to or in lieu of any computer software program for simulating the       CMA should be listed and then incorporated in master
                            energy performance rating of fenestration products, adopted by the NFRC Board of Directors, as each may be                 PCP document under CMA section}
                            amended, updated or interpreted from time to time, whether by action of the NFRC Board of Directors, the NFRC
                            Certification Policy Committee or the NFRC Accreditation Policy Committee. Comment: This definition covers
138                         both sim and test labs.
      MJT   N   1.3   Glass: the meaning as set forth and described in NFRC technical documents. COMMENT: This document                        P & S - defer to GANA and check current definition, add
                      should accept all definitions from 100 and other documents. Either a broad statement covering all terms in               if there is no conflict. Currently definition provided by Joe
                      100 (like in 200) should be included at the beginning of this section or the definition from 100 should be               Hayden is included.
139                   copied.
      MJT   N   1.3   Glazing Contractor: an entity that performs and completes the final assembly, erection and installation of a             NP - per NFRC policy, definitions are to listed in a single
                      fenestration system. COMMENT: This document should accept all definitions from 100 and other documents.                  document and not repeated in others. Eventually, all
                      Either a broad statement covering all terms in 100 (like in 200) should be included at the beginning of this             definitions will be moved to a separate Glossary
140                   section or the definition from 100 should be copied.                                                                     document.
      MJT   N   1.3   Manufacturer: any entity that produces assembled fenestration products either in a plant or, at a project site.          P & E - draft will be revised to include glass, spacer and
                      COMMENT: The term manufacturer is used for spacer, IG, and glass makers, but this definition does not                    frame products.
                      cover those manufacturers. I don’t think manufacturer needs to be defined, but if this specific definition is
141                   required I would use a more descriptive term, like fenestration manufacturer.
      MJT   N   1.3   NFRC 100: Procedure for Determining Fenestration Products U-Factors: NFRC 100, including all attachments                 P & S - Definition will be deleted because the term is not
                      thereto, as amended, supplemented or otherwise modified from time to time, which is a component of the Rating            used in the current draft.
142                   System. COMMENT: Why is this defined?
      MJT   N   1.3   Product: the meaning as set forth and described in NFRC technical documents. COMMENT: This document                      NP - per NFRC policy, definitions are to listed in a single
                      should accept all definitions from 100 and other documents. Either a broad statement covering all terms in               document and not repeated in others. Eventually, all
                      100 (like in 200) should be included at the beginning of this section or the definition from 100 should be               definitions will be moved to a separate Glossary
143                   copied.                                                                                                                  document.
      MJT   N   1.3   Product Line: the meaning as set forth and described in NFRC technical documents which is being applied to group         NP - per NFRC policy, definitions are to listed in a single
                      of fenestration products for which NFRC Product Certification Authorization is being sought. COMMENT: This               document and not repeated in others. Eventually, all
                      document should accept all definitions from 100 and other documents. Either a broad statement covering                   definitions will be moved to a separate Glossary
                      all terms in 100 (like in 200) should be included at the beginning of this section or the definition from 100            document.
                      should be copied. The additional language here is irrelevant and should be deleted.
144
      MJT   N   1.3   Quality Control Auditor: a Specifying Authority representative(s) who is responsible for the coordination of             P & S - Definition will be deleted because the term is not
                      production, fabrication, erection and installation to ensure the products meet the energy performance rating             used in the current draft. {Comment: Terms specific to
                      for which certification authorization has been granted. COMMENT: Definition should be deleted, as this                   CMA should be listed and then incorporated in master
                      term appears nowhere in this document.                                                                                   PCP document under CMA section}
145
      MJT   N   1.3   Rating Procedures: the NFRC Simulation Procedures for measuring energy performance rating characteristics of             P & E - corrections will be made to draft.
                      fenestration products, as supported by the Certification Program, and adopted by the NFRC Board of Directors from
146                   time to time. COMMENT: Procedures include both sim and test.
      MJT   N   1.3   Specifying Authority: architects and/or engineers who specify the fenestration products, systems and suppliers to be     NP - per Minutes of Minneapolis meeting.
                      used on a project in order to meet the design and performance requirements as designated by the building codes,
                      building owner/developer and enters into a license agreement with NFRC. This entity confirms that the individual
                      systems (glazing, spacer, and framing system) used to generate the whole product rating are those in the final
                      assembly. COMMENT: This responsibility needs to reside within the NFRC system, in some form or
                      fashion.The Specifying Authority is responsible for taking any corrective actions necessary if the final assembly does
                      not conform to the whole product rating.
147
      MJT   N   1.3   Simulation: any computer software program for the simulation of the energy performance rating of fenestration            P & E - add "the use of" to the beginning of the
                      products, adopted by the NFRC Board of Directors, as each may be amended, updated or interpreted from time to            definition.
                      time, whether by action of the NFRC Board of Directors, the NFRC Certification Policy Committee, or the NFRC
                      Accreditation Policy Committee. COMMENT: This definition does not describe a simulation, but rather a
                      simulation program. A simulation is typically the term used to describe either the use of the computer
                      programs or the output or results obtained from using those programs.
148
      MJT   N   1.3   Spacer manufacturer: the entity that produces the insulating glazing spacer, excluding all insulating glazing unit       P & E - corrections will be made to draft.
                      sealants which has been granted approval by a NFRC-IA and entered into the NFRC Component Database.
149                   COMMENT: Not required in the definition.
      MJT   N   1.3   Total Fenestration Product: the meaning as set forth and described in NFRC technical documents. COMMENT:                 NP - per NFRC policy, definitions are to listed in a single
                      This definition does not describe a simulation, but rather a simulation program. A simulation is typically the           document and not repeated in others. Eventually, all
                      term used to describe either the use of the computer programs or the output or results obtained from using               definitions will be moved to a separate Glossary
150                   those programs.                                                                                                          document.
      JS   N   Foreword    This section will need to be amended as required to reflect the final program.                                       P & S - Draft will be revised and be consistent with page
                                                                                                                                                2 of the flow chart and the revised frame language
151                                                                                                                                             approved by the working group.
      JS   N   1.2.2       Under either the web based procedure or the hard copy procedure of the Component-Based Fenestration Product
                           Certification Program, NFRC Licensed Specifying Authority is responsible for meeting the requirements in the PCP     NP - Only a licensed specifying authority is responsible
152                        including, but not limited, to the following functions:                                                              for following the PCP.
      JS   N   1.2.2       Provide the following information to an Approved Calculation Entity; required by NFRC software for calculation of    P & E - corrections will be made to draft.
153                        whole product fenestration performance
      JS   N   1.2.2       COMMENT: Excessive. Since this is a “software” based program, information regarding products and                     P & S - requirements will be revised to reflect the votes
                           manufacturers are established with component approval and should be adequately summarized on whole                   of the Subcommittee in the Minneapolis meeting and
                           system calculation. Project description/information should be limited to basic software input as well                pages 1 and 2 of the revised flow charts.
154
      JS   N   1.2.2.B     Provide the following information to an Approved Calculation Entity required by NFRC software for calculation of     P & S - requirements will be revised to reflect the votes
                           whole product fenestration performance.                                                                              of the Subcommittee in the Minneapolis meeting and
                             Detailed information on the construction of the insulating glazing unit(s); i.e., number of glass lites, glass     pages 1 and 2 of the revised flow charts.
                           type, glass thickness, glass coating type and location, spacer gap width and gas fill and percentage fill if
                           applicable.
                             Detailed information on the spacer system.
                             Detailed information of the framing system construction.
                             Identification of the insulating glass fabricator including name and contact information.
                             Identification of the spacer manufacturer including name and contact information.
                             Identification of the framing system manufacturer/fabricator including name and contact information.
155
      JS   N   1.2.2.C     Verifying that the insulating glass units used in the rated products are certified by a nationally recognized IG     NP - the draft will be revised to eliminate redundant
156                        Certification Program.                                                                                               wording but keep requirement.
      JS   N   1.2.2.D     Selecting and contracting with a Licensed Certification and an ACE or Inspection Agency (IA) for whole product       P & S - Draft will be revised and be consistent with page
                           rating specification data retention (Documentation-trail) and review, updates to the whole product data if the       2 of the flow chart and the revised frame language
                           review necessitates a revision, product verification, and in lieu of specifying Authority access to the              approved by the working group.
157                        components library, issuance of label certificates.
      JS   N   1.2.2.1.A   Participate in the NFRC Certification Program with more than one IA or ACE; and                                      P & S - Draft will be revised and be consistent with page
                                                                                                                                                2 of the flow chart and the revised frame language
158                                                                                                                                             approved by the working group.
      JS   N   1.2.3       Under the Certification Program, a Component Manufacturer/Supplier is responsible for meeting the requirements in    NP - by definition of the scope of the program
                           the PCP including, but not limited to the following functions:                                                       components are limited to glass systems, spacer
159                        COMMENT: Any component?                                                                                              assemblies and framing systems.
      JS   N   1.2.3.4.A   Submit framing systems for approval to appropriate default categoties, or Contracting with an NFRC                   P & S - Draft will be revised and be consistent with page
                           accredited simulation laboratory to have the framing system modeled. An Accredited Simulator may also model the      2 of the flow chart and the revised frame language
160                        framing system.                                                                                                      approved by the working group.
      JS   N   1.2.3.4.D   Submitting the simulation model and data for NFRC Expert Review. Expert Reviewer shall be an NFRC                    P & S - Draft will be revised and be consistent with page
                           accredited simulator.                                                                                                2 of the flow chart and the revised frame language
161                                                                                                                                             approved by the working group.
      JS   N   1.2.3.5     A framing system may be submitted without simulation and assigned to the appropriate generic frame                   P & S - Draft will be revised and be consistent with page
                           system category/group and use the default performance values associated with that category. NFRC shall               2 of the flow chart and the revised frame language
                           confirm the appropriate frame system category, and enter the framing system information into the Approved            approved by the working group.
                           Components Library.
                           or,
                           Multiple framing systems may be subject to simulation frame grouping rules where the grouped products
                           shall use the performance values of the simulated frame group leader.
                           Submission of frame systems to a frame grouping shall follow the requirements of section 1.2.3.4.
162                        COMMENT: 1.2.3.4 not defined.
      JS   N   1.2.4.C     Reviewing all submissions from the Specifying Authority, including whole product calculations, manufacturer          P & E - corrections will be made to draft.
                           data for product grouping, simulation reports and test reports for products that can not be simulated to determine
                           whether all data appears complete and in compliance with requirements of NFRC program;
163
      JS   N   1.2.4.E     Conducting Documentation-trail reviews/audit of selected whole product systems for verification and challenge        P & S - Draft will be revised and be consistent with page
                           purposes;                                                                                                            2 of the flow chart and the revised frame language
164                                                                                                                                             approved by the working group.
      JS    N   1.2.4.G    Requiring the Specifying Authority to submit documentation verifying that the label certificate was recorded             P & S - Draft will be revised and be consistent with page
                           in project site records.                                                                                                 2 of the flow chart and the revised frame language
165                                                                                                                                                 approved by the working group.
      MDE   N   1.2.2      The identity of the of the Specifying Authority is left vague. Although this section does a great job of what            P & E - corrections will be made to draft in accordance
166                        the SA does, it avoids teling who this entity is.                                                                        with wording submitted by M. Webb..
      MDE   N   1.2.2.E    Need to specify how registration is accomplished.                                                                        P & S - Language to be written in the LAP per Chicago
167                                                                                                                                                 discussions of Working Group..
      MDE   N   1.2.4.F    If records are going to be retained, two years is almost meaningless for a commercial product.                           P & E - Wording will be revised as indicated and the 2
                                                                                                                                                    year period retained because it represents the longest
168                                                                                                                                                 expected time to complete a project.
      MDE   N   1.3        Commercial Building : all buildings over three stories in height above grade or buildings, other than                    NP - use definition in Technical documents - reference
                           residential buildings, that are three stories or less in height above grade.                                             in PCP.
169                        Is an 8 story condo a commercial building?
      MKW   N   Foreword   3rd paragraph, mid-way:                                                                                                  P & E - corrections will be made to draft.
                           “Accredited Calculation Entity”, should be changed to read “Approved Calculation Entity.

                           This has been an on-going issue in the development of the PCP and is not consistent with the discussions of the task
                           group (see Atlanta meeting notes). The rationale for have an approved rather than an accredited entity is to allow for
                           manufacturers to perform in-house calculations providing they have taking the NFRC training on the calculation tool.
                           Accreditation bodies become a requirement if and when NFRC certification is required.

                           The Approved Calculation Entity (ACE) is not subject to the current LAP requirements as is the accredited simulation
                           lab. The current requirements under the LAP would exclude manufacturers from performing their own in-house
                           calculations for design / bid purposes.

                           This sentence is inconsistent with Section 1.1, Scope of the Component-Based Fenestration Product Certification
                           Program, 3rd paragraph. Or Section 1.2.1, Item D. “Approves Calculation Entities…”


170
      MKW   N   1.2.2.1    Specifying Authorities may:                                                                                              P & S - Sentence after "programs" will be deleted.

                           Item B. “Participate in other product certification programs not related to energy performance referencing NFRC
                           procedures.

                           This appears to be a restraint of trade.
171
      MKW   N   1.2.3.2    Spacer Manufacturer                                                                                                      P & S - Draft will be revised and be consistent with page
                                                                                                                                                    1 of the flow chart and the revised spacer language
                           Item C. “Submitting the spacer data for NFRC peer review in accordance with the procedures in NFRC {to be                approved by the working group.
                           developed).

                           Cannot approve a document that has procedures that still need to be developed.
172
      MKW   N   1.2.3.3    Spacer Grouping                                                                                                          P & S - Draft will be revised and be consistent with page
                                                                                                                                                    1 of the flow chart and the revised spacer language
                           Spacer grouping rules have not been developed. See previous comment regarding document approval.                         approved by the working group.
173
      MKW   N   1.2.3.5    Frame Grouping                                                                                                           P & S - Draft will be revised and be consistent with page
                                                                                                                                                    2 of the flow chart and the revised frame language
                           Frame grouping rules have not been developed. See comment on Section 1.2.3.2 regarding document approval.                approved by the working group.

174
      MKW   N   1.2.4     Role of the IA                                                                                                           P & S - Draft will be revised and be consistent with page
                                                                                                                                                   2 of the flow chart and the revised frame language
                          Item I. Accessing the NFRC components library database, as stipulated by NFRC, in order to upload the framing            approved by the working group.
                          system….

                          The IA is not part of the component approval procedure per the Visio Flow Chart identified as Draft IV, November 29,
                          2005
175
      MKW   N   1.2.5     Role of the Approved Calculation Entity                                                                                  P & S - Language to be written in the LAP per Chicago
                                                                                                                                                   discussions of Working Group..
                          {Comment: Need to create requirements for ACE}

                          This is a substantial issue and will affect the cost-effectiveness and timeliness of the process. I cannot vote to
                          approve the PCP document in it’s current form without the development of all requirements.
176
      MKW   N   1.2.6     Role of Accredited Simulator or Simulation Laboratory                                                                    P & S - Draft will be revised and be consistent with page
                                                                                                                                                   2 of the flow chart and the revised frame language
                          Item B. “Submitting to the IA the framing system simulation report upon the authorization of the framing                 approved by the working group.
                          manufacturer.”

                          IA is not part of the component approval procedure.
177
      MKW   N   1.3       Definitions                                                                                                              NG - this issue is resolved outside of the scope of the
                                                                                                                                                   PCP.
                          Approved Component Library: I believe the glazing library is the property of LBNL.
178
      MKW   N   1.3       Definitions                                                                                                              P & S - Draft will be revised and be consistent with page
                                                                                                                                                   2 of the flow chart and the revised frame language
                          Approved Calculation Entity: See comment on page 10, Section 1.2.5, Role of Approved Calculation Entity and              approved by the working group.
                          General Comment at the beginning of this document.
179
      MKW   N   1.3       Definitions                                                                                                              P & S - definition will be deleted because the term is not
                                                                                                                                                   used in the draft.
                          Family. What is the purpose of this definition?
180
      MKW   N   1.3       Definitions                                                                                                              P & S - definition will be deleted because the term is not
                                                                                                                                                   used in the draft.
                          Person. What is the purpose of this definition?
181
      MKW   N   1.3       Definitions                                                                                                              definition will be revised as discussed by Working
                                                                                                                                                   Group.
                          Specifying Authority. Should not be limited to architects and engineers.
182
      MT    N   1.2.3.3   Glazing Manufacturer will time frame for NFRC 302 submital and incusion into the database be accelerated to allow a      NG - Construction of laminated products are now
                          realistic time frame for new and/or unique glass type ( overseas Manufacturer laminated glass, etc.) that may            allowed, whenof recent approved revision to the
                          decided after award of contract. Will the construction of laminated products be allowed again in Optics.                 Technical documents are published if it meets the
183                                                                                                                                                requirements of the document
      MT    N   1.2.3.4   Framing Manufacturer: define Modeling Is this inputing the framing and gasket into THERM? If it is to include the        NP - Frame modeling is independent of specific spacer
                          spacer and glass does this not repeatthe procedure that the calculation entity is also doing what will be the time       or glazing. Uses default best and worst case per page 2
                          frame for this procedure? This will need to be rapid to allow for large commercial buildings and high rise residential   of the flowchart and wording developed by the Working
                          buildings that commonly utilizing an all new CUSTOM curtain wall that does not exist at time of project award.           Group..
184
      MT    N   1.2.5     Calculation Entity:Since this person is responsible for the whole product calculation, will ther be procedures to pass   P & S - Draft will be revised and be consistent with page
                          this information on to the framing manufacturer?                                                                         1 and 2 of the flow chart and the revised spacer and
                                                                                                                                                   framing language approved by the working group.
185
      LL   N    1.2.2 B     we have yet to consider any infill materials other than glass. We should anticipate spandrel panels, metal panels,          NG - althought these are good technical issues they are
                            stone and other types of infill as many commercial projects will include these types of materials. For this section, you    not permitted in the applicable Technical Procedures.
                            can simply state, “Detailed information on the infill used, including, but not limited insulating glass, spandrel panels,
186                         metal panels, stone.”
      LL   N    1.2.3.2.A   change die drawings, to “profile drawings”. Die drawings are relative to materials that are extruded. The term profile      P & S - Draft will be revised and be consistent with page
                            drawing would appropriate for all materials regardless of how they are formed.                                              2 of the flow chart and the revised frame language
187                                                                                                                                                     approved by the working group.
      LL   N    1.2.5 D     It appears that the requirements for the ACE are not complete. I feel we need to open this program up to make it            P & S - Draft will be revised and be consistent with page
                            usable by a larger group of people and this is one place to do it. If I understand what is written so far (i.e. that a      1 and 2 of the flow chart and the revised spacer and
                            manufacturer can employ their own ACE), then I am all for it. If not, or if this changes over the course of our             framing language approved by the working group.
                            discussions, I will have to vote negative. Also please note that in the Definitions Section 1.3, we state that “the
                            requirements need to be developed”. I can’t imagine approving something that isn’t ready for approval.
188
      BC   *N   Foreward    1st paragraph - …. ultra-violet (UV) performance, and comfort performance. {{Comment was received that the last             NG - language deleted in the ballot document.
                            sentence should be deleted because the document should not speculate on future developments.}}
189
      BC   *N   Foreward    "air leakage" should be removed from this component based certification program. To my knowledge, there is not a            P & E - corrections will be made to draft.
                            software tool to certify this performance. This program should be limited to what can only be computer simulated.
190
      BC   *N   Foreward    The forward describes a process in which numerous issues have yet to be decided. As a result I think it would be            P & S - Draft will be revised and be consistent with page
                            prudent to write the forward in accordance with the final agreed upon draft.                                                2 of the flow chart and the revised frame language
191                                                                                                                                                     approved by the working group.
      BC   *N   1.2.2.D     Provides the first reference to the "… whole product rating specification data retention (Documentation Trail) …".          P & S - Draft will be revised and be consistent with page
                            The requirements of the documentation trail and individual project requirements have yet to be defined. As we have          2 of the flow chart and the revised frame language
                            mentioned in numerous previous meetings, the contractural nature of the commercial construction industry and well           approved by the working group.
                            established documentration requirements of purchase orders, acknowledgements, shipping case tags, etc., are an
                            ongoing part of the commercial fenestration industry. The subcommittee needs to carefully consider the
                            requirements of the documentation trail. We strongly recommend a minimal audit program where a small percentage
                            of projects require submittal of a limited number of defined documents. (NOTE: The documentation trail is
                            mentioned in several sections of the draft and needs to be properly discussed and defined before the product
                            certification program moves forward for adoption.)
192
      BC   *N   1.2.3.2     I have deleted most of peer review, expert review by certified simulators, etc. tasks as unnecessary and complex. It        P & S - Peer Review has been deleted from the draft
                            is far more effective to have certified simulator perform simulation and upload information and be done with it, rather     per the decisions made by the Subcommittee at the
                            than developing the whole new Rube Goldberg type of process, where there are additional layers of bureaucracy and           Minneapolis meeting.
193                         oversight.
      BC   *N   1.2.3.2.B    I have deleted most of peer review, expert review by certified simulators, etc. tasks as unnecessary and complex. It       P & S - Peer Review has been deleted from the draft
                            is far more effective to have certified simulator perform simulation and upload information and be done with it, rather     per the decisions made by the Subcommittee at the
                            than developing the whole new Rube Goldberg type of process, where there are additional layers of bureaucracy and           Minneapolis meeting.
194                         oversight.]
      BC   *N   1.2.3.3.D   {review} Peer or expert?                                                                                                    P & S - Peer Review has been deleted from the draft
                                                                                                                                                        per the decisions made by the Subcommittee at the
195                                                                                                                                                     Minneapolis meeting.
      BC   *N   1.2.3.4.D   Expert Review.{{Peer review is used in the flow chart but expert review is also used at times, the committee should         P & S - Peer Review has been deleted from the draft
                            select one only.}}                                                                                                          per the decisions made by the Subcommittee at the
196                                                                                                                                                     Minneapolis meeting.
      BC   *N   1.2.3.5     The subcommittee needs to develop/finalize the frame grouping rules before this certification program moves forward         P & S - Draft will be revised and be consistent with page
                            for adoption. As we have expressed at numerous meetings, we strongly believe that the framing system grouping               2 of the flow chart and the revised frame language
                            represents a critical element of developing a product certification program that can be fair, accurate and cost             approved by the working group.
                            effective. Failure to recognize the ability to develop framing system grouping and pushing the program forward
                            without this aspect will dramatically affect the program cost, support, and acceptance by the commercial fenestration
197                         industry.
      BC   *N   1.2.3.5     Frame grouping rules have not been developed. Cannot approve a document that has procedures that still need to              P & S - Draft will be revised and be consistent with page
                            be developed.                                                                                                               2 of the flow chart and the revised frame language
198                                                                                                                                                     approved by the working group.
      BC    *N   1.2.3.5        New frame grouping rules need to be developed for the commercial market. It is essential that these rules be               P & S - Draft will be revised and be consistent with page
                                developed prior to the approval of this certification program. It is not feasible to require framing manufacturers to      2 of the flow chart and the revised frame language
                                model the thousands of options available within their product lines. I also believe that default values should be          approved by the working group.
199                             developed. A MFG could choose to use default values or simulate their own.
      BC    *N   1.3            Need to add EXPERT REVIEWER.                                                                                               NG - language deleted in the new ballot document, per
                                                                                                                                                           language developed by the working Group.
200
      BC    *N   1.3            Specifying Authority: Should not be limited to architects and engineers.                                                   P & E - corrections will be made to draft in accordance
201                                                                                                                                                        with wording submitted by M. Webb..
      BC    *N   1.3            Approved Calculation Entity - By requiring an ACE to meet NFRC requirements of the LAP, I believe you are limiting         P & S - Draft will be revised and be consistent with page
                                the ACE to be an Accredited Laboratory or Simulator. This is not acceptable.                                               2 of the flow chart and the revised frame language
202                                                                                                                                                        approved by the working group.
      DCC   N    1.2.2.D:       I disagree that there is a need for IA for whole product certification. I believe that this adds unnecessary layer of      P & S - Draft will be revised and be consistent with page
                                bureaucracy and additional cost. While I agree that it is necessary to have certified simulators and IAs involved in the   2 of the flow chart and the revised frame language
                                process of generating component level information (a.k.a. as buckets), there is no need to require certified simulators    approved by the working group. Language to be written
                                and IAs when whole products are generated from those components. The main reason why this is not necessary is              in the LAP per Chicago discussions of Working Group.
                                that there is extensive and sufficient information trail, which allows for checking if it is necessary. IA can review
                                limited number of submissions from each specifying authority and make sure that whole products are generated
                                correctly. This saves time and resources, while maintaining credibility.
203
      DCC   N    1.2.3.2.B, C   I disagree that peer review is right way to certify spacer components. Modeling spacers requires use of THERM              P & S - Peer Review has been deleted from the draft
                                software, for which it is necessary to have adequate knowledge and experience, in much the same way that it is             per the decisions made by the Subcommittee at the
                                required for frame components, except that these assemblies are smaller. It is also very cumbersome to have to             Minneapolis meeting.
                                peer review hundreds of spacer models, and it may violate manufacturers desire to maintain proprietary information.
204
      DCC   N    1.2.3.3:       This is not the place to describe details of spacer groupings. This should be described in NFRC 100 and 20o, or in a       P & S - Draft will be revised and be consistent with page
                                separate technical document.                                                                                               1 of the flow chart and the revised spacer language
205                                                                                                                                                        approved by the working group.
206   DCC   AC   1.2.6          Sub-numbering has A-D and then again A to B                                                                                P & E - corrections will be made to draft.
      DCC    N   1.2.6.B:        Accredited simulation laboratory shall be responsible only for certified simulations of components and submission of      P & S - Draft will be revised and be consistent with page
                                components to the component database. ACE is responsible for whole product calculations. This does not preclude            2 of the flow chart and the revised frame language
207                             accredited simulation laboratories to have ACEs on staff.                                                                  approved by the working group.
208   DCC   N    1.2.6.F        This is corrected numbering (see track changes). Add simulation of spacers.                                                P & E - corrections will be made to draft.
      DCC   N    1.2.6.G        Add task of inputting framing system and spacer information into the component database, upon the authorization of         P & S - requirements will be revised to reflect the votes
                                the framing and /or spacer manufacturer; including all necessary information, based on which IA can perform                of the Subcommittee in the Minneapolis meeting and
                                appropriate review                                                                                                         pages 1 and 2 of the revised flow charts.
209
      DCC   AC   1.3            Move to Glossary and Terminology Doc                                                                                       NP - per NFRC policy, definitions are to listed in a single
                                                                                                                                                           document and not repeated in others. Eventually, all
                                                                                                                                                           definitions will be moved to a separate Glossary
210                                                                                                                                                        document.
      TDC   N    2.3            A framing system may be granted NFRC approval for inclusion into the Components Library by complying with either           P & S - Draft will be revised and be consistent with page
                                the following procedure of section 2.3.1 or the procedure of section 2.3.2:                                                2 of the flow chart and the revised frame language
                                2.3.1 Framing system categories with precalculated performance                                                             approved by the working group.
                                values
                                A. A framing system may be assigned to the appropriate generic framing system category as defined in
                                NFRC 100 {default frame categories to be developed}, and use the precalculated performance values
                                associated with that category.
                                B. The manufacturer or supplier of the framing system shall
                                provide system assembly drawings and material
                                specifications to NFRC, along with the recommended
                                frame system category.
                                C. NFRC shall confirm the appropriate frame system category,
                                and enter the framing system information into the
                                Approved Components Library.
211                             2.3.2 Framing system simulation
      TDC   N   2.3.2 C   The NFRC accredited Simulation Laboratory shall submit a report to the NFRC Expert Reviewers. Expert Reviewer                   P & S - Draft will be revised and be consistent with page
                          shall be accredited to use THERM. Comment: Need to define Expert Reviewer, or reword with specifically who can                  2 of the flow chart and the revised frame language
                          review simulation (licensed IA or independent approved simulator). Some (but not all) manufacturers have expressed              approved by the working group.
                          concern that this should not be peerreview, because of the burden and the potential to expose some trade
                          secrets. Use of an IA is acceptable when doing simulations, as long as the ability to use default categories without
                          simulation is also preserved. On the other hand, an IA may not even be necessary if an independent sim lab is used.

212
      TDC   N   2.3.2.A   An NFRC Accredited Simulation Laboratory shall calculate the framing system values in accordance with NFRC                      P & S - Draft will be revised and be consistent with page
                          technical procedures,                                                                                                           2 of the flow chart and the revised frame language
213                                                                                                                                                       approved by the working group.
      TDC   N   2.3.2.B   The NFRC accredited Simulation Laboratory shall create framing system models using NFRC-approved software                       P & S - Draft will be revised and be consistent with page
                          tools. Framing systems submitted for peer review may be subject to the frame grouping rules of NFRC 100{New                     2 of the flow chart and the revised frame language
214                       framing grouping rules to be developed}.                                                                                        approved by the working group.
      TDC   N   2.3.2.C   The NFRC accredited Simulation Laboratory shall submit a report to the NFRC Expert Reviewers. Expert Reviewer                   P & S - Draft will be revised and be consistent with page
                          shall be accredited to use THERM.                                                               Comment: Need to                2 of the flow chart and the revised frame language
                          define Expert Reviewer, or reword with specifically                                                                             approved by the working group.
                          who can review simulation (licensed IA or independent approved
                          simulator). Some (but not all) manufacturers have expressed concern that this should not be peerreview, because of
                          the burden and the potential to expose some trade secrets. Use of an IA is acceptable when doing simulations, as
                          long as the ability to use default categories without simulation is also preserved. On the other hand, an IA may not
215                       even be necessary if an independent sim lab is used.
      TDC   N   3.1.C     If selected for a product certificate audit according to section 4.1C, the Specifying Authority shall select a                  P & S - Draft will be revised.
                          NFRC Licensed IA. The Specifying Authority shall select a NFRC Licensed IA at the time the Label Certificate
                          record is generated and issued. The Specifying Authority shall submit all system documentation identified in the
                          PCP (Documentation-trail files) to the selected IA within fifteen (15) business days of notification of the audit.
                          within ten (10) days of issuing the Label Certificate. The IA will maintain electronically all Documentation-trail
                          files associated with the fenestration system, as well as the full project files, for verification purposes for a period of
                          two (2) years. Comment: IA only audits a selected fraction of product ratings, so language changed to reflect that.
216
      TDC   N   3.1.D     Once the Approved Calculation Entity has performed the componentbased fenestration product calculation,                         P & S - draft will be modified to reflect independent ACE
                          IA has verified the Documentation work and determined conformance in accordance with the CAP {Sections                          requirements versus manufacturer ACE and match the
                          yet to be written}, the official Label Certificate shall be issued.                                           Comment: IA not   revised flow chart - Tom Culp to submit revised wording.
                          necessary to review whole-product rating calculation, issue CAR, or issue label certificate. These can be done
217                       directly by ACE.
218   CGC   N   3.1       Section B. i. - delete "(but not limited to)." If additional information is required add it to the list provided                P & E - Draft will be revised.
      CGC   N   3.1       Section B. ii. - delete "which is recognized by NFRC" since there are no guidelines under which a program can                   P & S _{Procedure for obtaining recognition is specified
                          become "recognized" by NFRC                                                                                                     in some means (check BOD procedures), list to be
                                                                                                                                                          provided on NFRC website} Bipin to revise.
219
220   CGC   N   3.1       Section B. iii. - delete "(but not limited to)." If additional information is required add it to the list provided.             P & E - Draft will be revised.
221   CGC   N   3.1       Section B. v. - revise to read "Identification of the framing system and the manufacturer."                                     P & E - Draft will be revised.
      CGC   N   3.1       Section B. vi. - delete the text as the details can be provided in the identification of the system in Section B. v.            P & E - Draft will be revised.
222
      CGC   N   3.1       Section C. revise last sentence to read "The IA will maintain electronic project and documentation-trail files for              P & E - Draft will be revised consistent with Revisions to
223                       audited projects for a period of two (2) years."                                                                                section 3.1.C.
      CGC   N   3.4       Details need to be developed regarding the use of the software tools by parties interested in using the databases and           NP - this is not a part of the PCP. Put language in the
                          calculation software tool for design & development purposes and/or for products/projects for which rating and                   forward. 'Use of the software other than for
224                       certification are not required.                                                                                                 certification…." (Tom Culp)
      TK   N   2.3       A framing system may be granted NFRC approval for inclusion into the Components Library by complying with the        P & S - Draft will be revised and be consistent with page
                         following procedure with either the procedure of section 2.3.1 or the procedure of section 2.3.2:                    2 of the flow chart and the revised frame language
                         2.3.1 Framing system categories with default performance values                                                      approved by the working group.
                         A. A framing system may be assigned to the appropriate generic framing system category from the list
                         below, and use the default performance values associated with that category.
                         [Placeholder for future list of frame system categories and the associated default performance values.
                         Alternately, refer to a new technical document, NFRC 304, which contains this information.]
                         B. The manufacturer or supplier of the framing system shall provide system assembly drawings and
                         material specifications to NFRC, along with the recommended frame system category.
                         C. NFRC shall confirm the appropriate frame system category, and enter the framing system information
                         into the Approved Components Library.
                         2.3.2 Specific framing system simulation and certification
                         A. An NFRC accredited simulation laboratory shall calculate the framing system values in accordance with
                         NFRC technical procedures using information submitted by the framing system manufacturer. This
                         information submitted includes, but is not limited to:
                         i. system assembly drawings/shop drawings
                         ii. system die drawings Page 21 of 54 06/16/2006 NFRC CB-PCP 2006
                         iii. glazing bite
                         iv. bill of materials
                         B. The NFRC accredited simulation laboratory shall create framing system models using NFRC-approved
                         software tools.
                         C. Multiple framing systems may be subject to frame grouping rules where the grouped products shall use
                         the performance values of the simulated frame group leader.
                         [Placeholder for future frame grouping rules. Alternately,refer to a new technical document, NFRC 304,
225
                         which contains this information.]
      TK   N   2.3       A framing system may be granted NFRC approval for inclusion into the Components Library by complying                 P & S - Draft will be revised and be consistent with page
                         with the following procedure:                                                                                        2 of the flow chart and the revised frame language
                         A. An NFRC Accredited Simulation Laboratory calculate the framing system values in accordance with                   approved by the working group.
                         NFRC technical procedures, including frame grouping rules, using information submitted by the framing
                         system manufacturer. This information submitted includes, but is not limited to:
                         i. system assembly drawings/shop drawings
                         ii. system die drawings
                         iii. glazing bite
                         iv. bill of materials
                         B. The NFRC accredited Simulation Laboratory shall create framing system models using NFRC-approved
                         software tools. Frame submitted for peer review may be subject to the frame grouping rules of NFRC
                         100{New framing grouping rules to be developed}.
                         C. The NFRC accredited Simulation Laboratory shall submit a report to the NFRC Expert Reviewers. Expert
                         Reviewer shall be accredited to use THERM.
                         D. The Expert Reviewers shall review all submitted information for accuracy and once approved enter the
                         framing system(s) into the Approved Components Library.
226
      BS   N   2.2.1     The manufacturer of the spacer shall submit for peer review according to the requirements of NFRC 100 {To be         NG - Samples no longer required.
                         developed}, the following:
                         A. Cross-sectional drawing(s) and one (6”) six inch physical sample of the spacer excluding any sealants necessary
227                      to incorporate the spacer into an insulating glass unit.
      BS   N   2.2.1.1   Spacers submitted for peer review may be subject to the spacer grouping rules of NFRC 100 {New spacer                NP - Peer review no longer required.
228                      grouping rules to be developed}.
      BS   N   2.3.A     An NFRC Accredited Simulation Laboratory calculates the framing system values in accordance with NFRC technical      P & E - Draft will be revised.
                         procedures, including frame-grouping rules, using information submitted by the framing system manufacturer.
229
      BS   N   2.3.B     Frame submitted for peer review may be subject to the frame grouping rules of NFRC 100 {New framing grouping         NP - Peer review no longer required.
230                      rules to be developed}.
      BS   N   2.3.C     The NFRC accredited Simulation Laboratory shall submit a report to the NFRC Expert Reviewers. Expert Reviewer        NP - Peer review no longer required.
                         shall be accredited to use THERM. (This makes no sense. “Expert Reviewer” is undefined – yet 1.2.3.4.D leads
                         one to believe that expert review is performed by a certified simulator. Is it reviewed by the Simulator in
231                      Responsible Charge for the sim lab, peer review or by staff?)
      BS    N    2.3.D       The Expert Reviewers shall review all submitted information for accuracy and once approved enter the framing               NP - Peer review no longer required.
                             system(s) into the Approved Components library. (Again, “Expert Reviewer” is undefined. Per Section 1.2.3.4.E, the
                             framing system is uploaded “by NFRC” [individual unidentified]. It also appears the IA is responsible for uploading the
                             framing system into the Components Library, per Section 1.2.4.I. This must be clarified.)
232
      BS    N    3.1.B       The Specifying Authority shall select and contract with an NFRC-Approved Calculation Entity and submit the                 NP - See Minutes from Minneapolis.
233                          following
      BS    N    3.1.B.ii    Identification of the IG Unit Fabricator. The IG unit construction as supplied by the fabricator shall be certified by     NP - per NFRC policy but rules will be addressed
                             nationally recognized certification agency which is recognized by NFRC                                                     {Procedure for obtaining recognition is specified in some
                                                                                                                                                        means (check BOD procedures), list to be provided on
234                                                                                                                                                     NFRC website} Bipin to revise.
      BS    N    3.1.B.iii   Detailed construction of the spacer system; i.e., (but not limited to)                                                     P & E - draft to be revised.
                             a. Identification of glass spacer system. (Improper use of Id Est, and a list needs to contain more than one
                             item.)
235
      BS    N    3.1.C       C. The Specifying Authority shall select a NFRC Licensed IA at the time the Label Certificate record is generated and      P & S - draft will be modified to reflect independent ACE
                             issued. The Specifying Authority shall submit all system documentation identified in the PCP (Documentation-trail          requirements versus manufacturer ACE and match the
                             files) to the selected IA within ten (10) days of issuing the Label Certificate. The IA will maintain all Documentation-   revised flow chart - Tom Culp to submit revised wording.
236                          trail files associated with the fenestration system,
237   BS    N    3.2          Approved Calculation Entity                                                                                               NP - See Minutes from Minneapolis.
238   BS    N    3.2.A       NFRC license is attainable to an Approved Calculation Entity                                                               NP - See Minutes from Minneapolis.
      BS    N    3.2.B       Only upon qualifying and signing a license agreement with the NFRC shall the Approved Calculation Entity                   NP - See Minutes from Minneapolis.
239
240   BS    N    3.3         Approved Calculation Entity Qualification                                                                                  NP - See Minutes from Minneapolis.
      BS    N    3.3.A       Qualification requirements for approval of an Approved Calculation Entity shall require that the ACE employ at least       NP - See Minutes from Minneapolis.
                             one full-time NFRC Approved Calculation Entity on staff. The Approved Calculation Entity shall be responsible for
241                          all component calculations
      BS    N    3.3.B       Upon signing an NFRC license agreement, the Approved Calculation Entity shall be registered to utilize the NFRC            NP - See Minutes from Minneapolis.
                             component library and shall be issued a licensee number. The licensee number authorizes the Approved Calculation
242                          Entity to generate the calculations for the Specifying Authority.
      BS    N    3.3.C       C. An Approved Calculation Entity shall…The licensee number shall be tied to both the individual staff and ACE.            NP - See Minutes from Minneapolis.
                             …no longer employed by the ACE. ...It shall be the responsibility of the Approved Calculation Entity
243
244   BS     N   3.3.2        Approved Calculation Entity Training                                                                                      NP - See Minutes from Minneapolis.
245   BS     N   3.3.2.A     A. Training shall be available to anyone seeking approval as a Approved Calculation Entity                                 NP - See Minutes from Minneapolis.
      PM    AC   2.3         2.3 Framing System Approval                                                                                                P & S - Draft will be revised and be consistent with page
                             A framing system may be granted NFRC approval for inclusion into the Components Library by complying with the              2 of the flow chart and the revised frame language
                             following procedure:                                                                                                       approved by the working group.
                             A. An NFRC Accredited Simulation Laboratory or accredited simulator calculate the framing system values in
                             accordance with NFRC technical procedures, including frame grouping rules, using information submitted by the
                             framing system manufacturer. This information submitted includes, but is not limited to:
                             i. system assembly drawings/shop drawings
                             ii. system die drawings
                             iii. glazing bite
                             iv. bill of materials
                             B. The NFRC accredited Simulation Laboratory or accredited simulator shall create framing system models using
                             NFRC-approved software tools. Frame submitted for peer review may be subject to the frame grouping rules of
                             NFRC 100{New framing grouping rules to be developed}.
                             C. The NFRC accredited Simulation Laboratory or accredited simulator shall submit a report to an the NFRC
                             Expert Reviewers. Expert Reviewer shall be accredited to use THERM.
                             D. The Expert Reviewers shall review all submitted information for accuracy and once approved enter the framing
                             system(s) into the Approved Components Library.
246
      JAH   N    2.2.1       The manufacturer of the spacer shall submit for peer review according to the requirements of NFRC 100 {To be               NP - Peer review no longer required.
247                          developed}
      JAH   N    2.2.1.1     Spacers submitted for peer review may be subject to the spacer grouping rules of NFRC 100 {New spacer                      NP - Peer review no longer required.
248                          grouping rules to be developed}.
      JAH   N   2.2.2.1    Peer reviewers shall be accredited by NFRC to use THERM. [This needs discussion. It seems overly restrictive             NP - Peer review no longer required.
                           to limit the Peer Review Committee members to just those who have been accredited on THERM. I can
                           foresee there being others who would be well qualified to be a reviewer but who have not been NFRC
249                        accredited.]
      JAH   N   2.3.B      The NFRC accredited Simulation Laboratory shall create framing system models using NFRC-approved software                NP - Peer review no longer required. Draft will be
                           tools. Frame submitted for peer review may be subject to the frame grouping rules of NFRC 100 {New framing               revised and be consistent with page 2 of the flow chart
                           grouping rules to be developed}.                                                                                         and the revised frame language approved by the
250                                                                                                                                                 working group.
      JAH   N   3.1.B      Identification of the IG Unit Fabricator. The IG unit construction as supplied by the fabricator shall be certified by   NP - This is part of the procedure and was discussed at
                           nationally recognized certification agency which is                                                                      several membership meetings.
251                        recognized by NFRC [are we truly ready to do this ???]
      JAH   N   3.3.1.A.   Qualification requirements for approval of an Approved Calculation Entity shall require that the ACE employ at least     NP - Simulators are certified, simulation laboratories are
                           one full-time NFRC certified simulator (???) on staff. The Approved Calculation Entity shall be responsible for all      accredited.
252                        component calculations
      CAR   N   2.3.A      An NFRC Accredited Simulation Laboratory or NFRC accredited Simulator calculate the framing system values in             NP - Draft will be revised and be consistent with page 2
                           accordance with NFRC technical procedures, including frame grouping rules, using information submitted by the            of the flow chart and the revised frame language
253                        framing system manufacturer. This information submitted includes, but is not limited to:                                 approved by the working group.
      CAR   N   2.3.B      The NFRC accredited Simulation Laboratory or NFRC accredited Simulator shall create framing system models                NP - Draft will be revised and be consistent with page 2
                           using NFRC-approved software tools. Frame submitted for peer review may be subject to the frame grouping rules of        of the flow chart and the revised frame language
254                        NFRC 100{New framing grouping rules to be developed}.                                                                    approved by the working group.
      CAR   N   2.3.C      The NFRC accredited Simulation Laboratory or NFRC accredited Simulator shall submit a report to the NFRC                 NP - Draft will be revised and be consistent with page 2
                           Expert Reviewers. Expert Reviewer shall be accredited to use THERM.                                                      of the flow chart and the revised frame language
255                                                                                                                                                 approved by the working group.
      MiT   N   2.3        COMMENT: Sim labs should submit to an IA ... remove sections C & D. New Framing grouping rules must                      P & S - Draft will be revised and be consistent with page
                           be defined before this program can be approved. What will be the anticipated time it takes to get data into              2 of the flow chart and the revised frame language
256                        the library?                                                                                                             approved by the working group.
      MiT   N   3.1        COMMENT: see earlier comments on SA. Is the "label certificate" described in C different than the "official              P & E - "label certificate" to be used exclusively
257                        label certificate" defined in D?                                                                                         throughout the draft.
      MiT   N   3.2.C      Comment: This section would limit the market's ability to obtain pre-bid performance numbers.                            NP - this is not a part of the PCP. Put language in the
                                                                                                                                                    forward. 'Use of the software other than for
258                                                                                                                                                 certification…." (Tom Culp)
      MJT   N   2.2        COMMENT: In general, peer review is not an appropriate way to handle this procedure. Peer review relies                  NP - Peer review no longer required.
                           on volunteer effort of qualified individuals in order to work. As detailed here, the Peer Review Committee
                           would consist mainly of accredited simulators with no vested interest in the accuracy of the models. Those
                           with interest (spacer manufacturers) would need to become accredited simulators to participate. This
                           process would also require manufacturers to turn over ALL important information concerning their product
                           to their competitors for review. I propose that this peer review process be replaced by an NFRC staff or
                           subcontractor process. In this process the manufacturer would submit direct to NFRC and pay a fee to
                           support the NFRC staffing / subcontracting required. This process would be fast, efficient, fair, and
259                        consistent.
      MJT   N   2.3.C      The NFRC accredited Simulation Laboratory shall submit a report to an NFRC Licensed IA the NFRC Expert                   NP - Peer review no longer required. Draft will be
                           Reviewers. Expert Reviewer shall be accredited to use THERM. COMMENT: The idea of an Expert Review                       revised and be consistent with page 2 of the flow chart
                           is not workable. The ”experts” in this field are the current simulation labs, and if any were to serve as                and the revised frame language approved by the
                           Expert Reviewers, they would need independence. The current IA review system has served well and can                     working group.
260                        easily and readily handle this process without any loss of integrity.
      MJT   N   3.1.B.ii   Identification of the IG Unit Fabricator. The IG unit construction as supplied by the fabricator shall be certified by   P & S _{Procedure for obtaining recognition is specified
                           nationally recognized certification agency which is recognized by NFRC. COMMENT: We need to detail who is                in some means (check BOD procedures), list to be
                           recognized in this document.                                                                                             provided on NFRC website} Bipin to revise.
261
      MJT   N   3.1.C       The Specifying Authority shall select a NFRC Licensed IA at the time the Label Certificate record is generated and               P & S - Draft will be revised and be consistent with page
                            issued. The Specifying Authority shall submit all system documentation identified in the PCP (Documentation-trail                2 of the flow chart and the revised frame language
                            files) to the selected IA within ten (10) days of issuing the Label Certificate. The IA will maintain all Documentation-         approved by the working group. Also "label certificate"
                            trail files associated with the fenestration system, as well as the full project files, for verification purposes for a period   to be used exclusively throughout the draft.
                            of two (2) years. COMMENT: This seems to indicate the Label Cetificate is issued before IA review. Below it
                            refers to the “official” Label Certificate. The intention needs clarification. I believe we should call this a
                            Temporary Label Certificate which has a limited lifespan before the “official” certificate is issued and
                            expires within some short timeframe.
262
      MJT   N   3.3.1.A     Qualification requirements for approval of an Approved Calculation Entity shall require that the ACE employ at least             NP - Per minutes of Minneapolis meeting. Also
                            one full-time NFRC Approved Calculation Entity Calculator on staff. The Approved Calculation Entity Calculator                   simulators are certified, simulation laboratories are
                            shall be responsible for all component calculations. COMMENT: It seems like we are using the ACE to describe                     accredited.
                            both the company and the individual. This makes it extremely unclear. I’d suggest that we use “Accredited
                            Calculation Entity” to describe the company and “Accredited Calculator” or something similar for the
                            individual. This change should occur anywhere else necessary in the document.
263
      MJT   N   3.3.2       Training shall be available to anyone seeking approval as a Approved Calculation Entity Calculator . Specific                    NP - Per minutes of Minneapolis meeting.
                            requirements for training and qualifications are set forth in the LAP {Section to be developed}. Training can be
                            obtained by either participating in a NFRC scheduled Component Library Database Training Course or by completing
                            a self-study and examination program on line, which includes online testing.
264
      JS    N   2.3         A framing system may be granted NFRC approval for inclusion into the Components Library by complying with the                    P & S - Draft will be revised and be consistent with page
                            following procedure:                                                                                                             2 of the flow chart and the revised frame language
265                         either the procedure of section 2.3.1 or the procedure of section 2.3.2:                                                         approved by the working group.
      JS    N   2.3.1       ADDED NEW SECTION. Framing system categories with default performance values                                                     P & S - Draft will be revised and be consistent with page
                                                                                                                                                             2 of the flow chart and the revised frame language
266                                                                                                                                                          approved by the working group.
      JS    N   2.3.A       An NFRC Accredited Simulation Laboratory calculate the framing system values in accordance with NFRC                             P & S - Draft will be revised and be consistent with page
                            technical procedures, including frame grouping rules, using information submitted by the framing system                          2 of the flow chart and the revised frame language
267                         manufacturer. This information submitted includes, but is not limited to:                                                        approved by the working group.
      JS    N   2.3.1.A     A framing system may be assigned to the appropriate generic framing system category as defined in NFRC                           P & S - Draft will be revised and be consistent with page
                            100, (default frame categories to be developed), and use the default performance values associated with that                     2 of the flow chart and the revised frame language
268                         category.                                                                                                                        approved by the working group.
      JS    N   2.3.A.i     system assembly drawings/shop drawings                                                                                           P & S - per revisions made by the Working Group at the
                                                                                                                                                             Chicago meeting and also draft will be revised and be
                                                                                                                                                             consistent with page 2 of the flow chart and the revised
                                                                                                                                                             frame language approved by the working group.
269
      JS    N   2.3.A.ii    system die drawings                                                                                                              P & S - per revisions made by the Working Group at the
                                                                                                                                                             Chicago meeting and also draft will be revised and be
                                                                                                                                                             consistent with page 2 of the flow chart and the revised
                                                                                                                                                             frame language approved by the working group.
270
      JS    N   2.3.A.iii   glazing bite                                                                                                                     P & S - per revisions made by the Working Group at the
                                                                                                                                                             Chicago meeting and also draft will be revised and be
                                                                                                                                                             consistent with page 2 of the flow chart and the revised
                                                                                                                                                             frame language approved by the working group.
271
      JS    N   2.3.A.iv    bill of materials                                                                                                                P & S - per revisions made by the Working Group at the
                                                                                                                                                             Chicago meeting and also draft will be revised and be
                                                                                                                                                             consistent with page 2 of the flow chart and the revised
                                                                                                                                                             frame language approved by the working group.
272
      JS    N   2.3.B       The NFRC accredited Simulation Laboratory shall create framing system models using NFRC-approved                                 P & S - Draft will be revised and be consistent with page
                            software tools. Frame submitted for peer review may be subject to the frame grouping rules of NFRC                               2 of the flow chart and the revised frame language
273                         100{New framing grouping rules to be developed}.                                                                                 approved by the working group.
      JS    N   2.3.1.B       The manufacturer or supplier of the framing system shall provide system assembly drawings and material         P & S - Draft will be revised and be consistent with page
                              specifications to NFRC, along with the recommended frame system category.                                      2 of the flow chart and the revised frame language
274                                                                                                                                          approved by the working group.
      JS    N   2.3.C         The NFRC accredited Simulation Laboratory shall submit a report to the NFRC Expert Reviewers. Expert           P & S - Draft will be revised and be consistent with page
                              Reviewer shall be accredited to use THERM.                                                                     2 of the flow chart and the revised frame language
275                                                                                                                                          approved by the working group.
      JS    N   2.3.1.C       NFRC shall confirm the appropriate frame system category, and enter the framing system information into        P & S - Draft will be revised and be consistent with page
                              the Approved Components Library.                                                                               2 of the flow chart and the revised frame language
276                                                                                                                                          approved by the working group.
      JS    N   2.3.D         The Expert Reviewers shall review all submitted information for accuracy and once approved enter the           P & S - Draft will be revised and be consistent with page
                              framing system(s) into the Approved Components Library.                                                        2 of the flow chart and the revised frame language
277                                                                                                                                          approved by the working group.
      JS    N   2.3.2         ADDED NEW SECTION. Framing system categories with default performance values                                   P & S - Draft will be revised and be consistent with page
                                                                                                                                             2 of the flow chart and the revised frame language
278                                                                                                                                          approved by the working group.
      JS    N   2.3.2.A       An NFRC accredited simulation laboratory shall calculate the framing system values in accordance with          P & S - Draft will be revised and be consistent with page
                              NFRC technical procedures, including frame grouping rules, using information submitted by the framing          2 of the flow chart and the revised frame language
279                           system manufacturer. This information submitted includes, but is not limited to:                               approved by the working group.
      JS    N   2.3.2.A.i     system assembly drawings/shop drawings                                                                         P & S - Draft will be revised and be consistent with page
                                                                                                                                             2 of the flow chart and the revised frame language
280                                                                                                                                          approved by the working group.
      JS    N   2.3.2.A.ii    system die drawings                                                                                            P & S - Draft will be revised and be consistent with page
                                                                                                                                             2 of the flow chart and the revised frame language
281                                                                                                                                          approved by the working group.
      JS    N   2.3.2.A.iii   glazing bite                                                                                                   P & S - Draft will be revised and be consistent with page
                                                                                                                                             2 of the flow chart and the revised frame language
282                                                                                                                                          approved by the working group.
      JS    N   2.3.2.A.iv    bill of materials                                                                                              P & S - Draft will be revised and be consistent with page
                                                                                                                                             2 of the flow chart and the revised frame language
283                                                                                                                                          approved by the working group.
      JS    N   2.3.2.B       The NFRC accredited simulation laboratory shall create framing system models using NFRC-approved               P & S - Draft will be revised and be consistent with page
                              software tools. Framing systems submitted for peer review may be subject to the frame grouping rules of        2 of the flow chart and the revised frame language
284                           NFRC 100 {New framing grouping rules to be developed}.                                                         approved by the working group.
      JS    N   2.3.2.C       The NFRC accredited simulation laboratory shall submit a report to the NFRC licensed IA chosen by the          P & S - Draft will be revised and be consistent with page
                              framing system manufacturer in accordance with NFRC LAP                                                        2 of the flow chart and the revised frame language
285                                                                                                                                          approved by the working group.
      JS    N   2.3.2.D       The NFRC licensed IA shall review all submitted information for accuracy and once approved enter the           P & S - Draft will be revised and be consistent with page
                              framing system(s) into the Approved Components Library.                                                        2 of the flow chart and the revised frame language
286                                                                                                                                          approved by the working group.
      JS    N   3.1.D         Once IA Sim Lab or ACE has verified the Documentation work and determined conformance in accordance with the   P & S - draft will be modified to reflect independent ACE
                              CAP {Sections yet to be written}, the official Label Certificate shall be issued.                              requirements versus manufacturer ACE and match the
                                                                                                                                             revised flow chart - Tom Culp to submit revised wording.
287
      MKW   N   2.2           Section 2. Component Approval                                                                                  P & S - Draft will be revised and be consistent with page
                              2.2 .1 Spacer Approval. Peer Review requirements to be developed. See General Comment on procedures to be      1 of the flow chart and the revised spacer language
288                           developed.                                                                                                     approved by the working group.
      MKW   N   2.3           Framing System Approval                                                                                        P & S - Draft will be revised and be consistent with page
                              B. {New framing grouping rules to be developed} – Once again, we should not be approving the PCP until all     2 of the flow chart and the revised frame language
289                           procedures have been developed and approved.                                                                   approved by the working group.
      MKW   N   2.3           D. Expert Reviewers – this term needs to be defining                                                           P & S - Draft will be revised and be consistent with page
                                                                                                                                             2 of the flow chart and the revised frame language
290                                                                                                                                          approved by the working group.
      MKW   N   3.1           Specifying Authority                                                                                           P & S - See Minniapolis meeting minutes
                              Item C – we need to determine what the documentation trail files are. No sense in burying the IA’s in paper.
291
      MKW   N    3.1         Item D. –{(CAP) Sections yet to be written) – See General Comment                                                         P & S - draft will be modified to reflect independent ACE
                                                                                                                                                       requirements versus manufacturer ACE and match the
                                                                                                                                                       revised flow chart - Tom Culp to submit revised wording.
292
      MKW   N    3.3.1       Qualification                                                                                                             P & S - Language to be written in the LAP per Chicago
293                          Item C – (For Additional Information, see the LAP {Section to be developed}) – See general comment                        discussions of Working Group..
      MKW   N    3.3.2       Approved Calculation Entity Training                                                                                      P & S - Language to be written in the LAP per Chicago
                             Item A – Specific requirements for training and qualifications are set forth in the LAP {Section to be developed} – See   discussions of Working Group..
294                          General Comment
      LL    N    2.2.1       This section appears to be incomplete as it is noted “to be developed”. I can’t imagine approving something that isn’t    P & S - draft will be modified to reflect independent ACE
                             written. Same for 2.2.1.1.                                                                                                requirements versus manufacturer ACE and match the
                             5. Section 2.3.B, Again, the frame grouping rules are not defined, therefore I cannot approve them.                       revised flow chart - Tom Culp to submit revised wording.
                                                                                                                                                       To be addressed by documenting in the meeting
                                                                                                                                                       minutes as an intent not to implemnt until all companion
                                                                                                                                                       document is completed.
295
      BC    *N   2.3         Sim labs should submit to an IA … remove sections C & D. New framing grouping rules must be defined before this           P & S - draft will be modified to reflect independent ACE
                             program can be approved. What will be the anticipated time it takes to get data into the library?                         requirements versus manufacturer ACE and match the
                                                                                                                                                       revised flow chart - Tom Culp to submit revised wording.
                                                                                                                                                       To be addressed by documenting in the meeting
                                                                                                                                                       minutes as an intent not to implemnt until all companion
                                                                                                                                                       document is completed.
296
      DCC   N    2.2.1       The manufacturer of the spacer shall submit for peer review according to the requirements of NFRC 100 {To                 P & S - Peer review no longer in draft. Draft will be
                             be developed}, the following: Sections 2.2.1.A and 2.2.1.B through Section 2.2.4 were also deleted. ADDED:                revised and be consistent with page 1 and 2 of the flow
                             drawings and bill of materials to the certified simulator for preparing THERM drawing of the spacer                       chart and the revised frame and spacer language
                             according to the requirements of NFRC 104 COMMENT: It makes no sense to assign number 302 to spacer                       approved by the working group.
                             document, since 300 series deals with solar-optical properties of transparent materials.
297
      DCC   N    2.2.1       NEW SECTION: The manufacturer of the spacer shall submit one physical sample, at least 1 ft. long.                        NP - revised spacer wording does not require sample.
298
      DCC   N    2.2.1       NEW SECTION: Certified simulator shall upload THERM model of the spacer to the spacer component                           P & S - Draft will be revised and be consistent with page
                             library and NRFEN shall notify IA that the spacer is pending approval.D. Spacers can be subject of grouping               1 of the flow chart and the revised spacer language
                             rules, as detailed in NFRC 104. Each spacer shall be assigned grouping category (automatically, based on                  approved by the working group.
                             the effective conductivity of the spacer assembly), which will allow manufacturer to later select either actual
299                          spacer performance or grouped spacer performance.
      DCC   N    2.3.C       The NFRC accredited Simulation Laboratory shall submit a report to the NFRC Expert Reviewers. Expert                      P & S - Draft will be revised and be consistent with page
                             Reviewer shall be accredited to use THERM. The NFRC accredited simulation laboratory shall upload the                     2 of the flow chart and the revised frame language
                             framing system model into the framing component library, and NRFEN shall notify IA of the pending review                  approved by the working group.
300                          and approval
      DCC   N    2.3.D       The Expert Reviewers shall review all submitted information for accuracy and once approved enter the                      P & S - Draft will be revised and be consistent with page
                             framing system(s) into the Approved Components Library. Frame systems can be subject of grouping rules,                   2 of the flow chart and the revised frame language
                             as detailed in NFRC 100. Grouping category shall be indicated for framing systems that are grouped.                       approved by the working group.
301
      DCC   N    2.3.E       NEW SECTION: After the IA has approved framing system, it is automatically assigned # sign indicating                     P & S - Draft will be revised and be consistent with page
                             approved status.                                                                                                          2 of the flow chart and the revised frame language
302                                                                                                                                                    approved by the working group.
      DCC   N    3.1.A       The specifying Authority seeking to obtain a Label Certificate that contains the energy thermal and solar-optical         P & E - draft to be revised.
                             performance ratings for fenestration products using the Component-Based Fenestration Product Certification
                             Program may do so upon entering into a license agreement with the NFRC, in accordance with the requirements of
303                          this Section.
304   DCC   AC   3.1.A       Replace “energy performance ratings” with “thermal and solar-optical performance ratings”                                 P & E - draft to be revised.
305   DCC   AC   3.1.B.i.b   Replace “copating type” with “glass manufacturer and model #”                                                             P & E - draft to be revised.
      DCC   N    3.1.B.iii.a   3.1.B.iii.a: “Glass spacer system” is non-existing terminology and there are several items missing here. This single       P & S - Draft will be revised and be consistent with page
                               line should be replaced with:                                                                                              1 of the flow chart and the revised spacer language
                               a. Spacer manufacturer and model #description                                                                              approved by the working group.
                               b. Secondary sealant details
                               c. Primary sealant details
306                            d. Spacer biteposition wrt. the glazing edge
      DCC   N    3.1.B.iv-vi   3.1.B.iv-vi: Replace items iv to vi with:                                                                                  P & S - Draft will be revised and be consistent with page
                               v.iv. Identification of Framing System Mmanufacturer and model #                                                           2 of the flow chart and the revised frame language
                               v. Fenestration product operator                                                                                           approved by the working group.
                               vi. Layout of framing system model #s for the fenestration product
307                            vii. Identification of the permit issuance agency and contact information
      DCC   N    3.1.C         3.1.C: This is very confusing! How can IA approve label certificate if it is going to receive files 10 days after the      P & S - Draft will be revised and be consistent with page
                               certificate has been issued? Let me expose how I see this process working; There are two potential scenarios, 1)           1 and 2 of the flow chart and the revised spacer and
                               new product line (PL) certification (equivalent to the present-day certification/re-certification, and 2) new product      frame language approved by the working group.
                               within the existing product line (equivalent to present-day addendums). In the first case, Manufacturer/Specifying
                               authority sends documentation (hard copy or electronically) to the IA, IA creates entry in the NRFEN for the new PL,
                               certified simulator uploads simulation data in NRFEN, test lab uploads test data in the NRFEN (all associated with the
                               entry for the PL that IA created earlier), NRFEN performs logical error check and if everything is OK, issues direction
                               to IA that PL needs approval (there is a firm deadline associated with this, so that IA can not unnecessarily hold
                               certification, IA reviews everything for all inconsistencies and errors, confirms documentation with the uploads and
                               approves PL. PL is given equivalent of # sign and after that ACE can issue label certificates involving this PL. In
                               the second scenario, ACE simply applies different glazing and spacer options to the approved PL. No further
                               interaction with IA is required. Certificates are issued on the spot to the ACE and forwarded to the Specifying
308
                               Authority. In case of errors or non-validation, NRFEN and/or IA issues notification to the ACE and Specifying
      DCC   AC   3.1           3.1: Where is it specified how is payment for the label certificate to NFRC handled                                        NP - Section 8 will specify the fee schedule but payment
                                                                                                                                                          conditions are contained within the License Agreement
309                                                                                                                                                       which is in the LAP.
      DCC   N    3.1.D         3.1.D: Replace with:                                                                                                       P & S - Draft will be revised and be consistent with page
                               Label Certificate is issued for approved Product lines to ACE by the component based software tool, which is then          1 and 2 of the flow chart and the revised spacer and
                               forwarded to the Specifying Authority, unless Specifying Authority is ACE itself, in which case forwarding is skipped.     frame language approved by the working group.
310
      DCC   N    3.3.1.B       3.3.1.B: ACE is a person, not organization. Change this paragraph as follows:                                              P & S - draft will be modified to reflect independent ACE
                               ACE shall be employed by a business n entity organization, further referred to as “organization” that maintains an         requirements versus manufacturer ACE and match the
                               official business license recognized by the State or Province in which its staff are employed and has Federal ID           revised flow chart - Tom Culp to submit revised wording.
                               number [I have small corporation business for 11 years, but I never obtained any “business license”]. The NFRC
                               licensee number shall be tied to both the individual staff and agencyorganization, where organization shall hold
                               organizational license, while individual shall hold individual license, in the form of a sub-license to the organziation
                               (e.g., Organization may hold License # CAR-000, while individuals would hold license numbers CAR-001, CAR-002,
                               and so forth). In the event that the individual originally obtaining the NFRC licensee number is no longer employed by
                               the agencyorganization, the organization shall provide replacement individual, subject to the completion of the course
                               and passing of the exam, and shall assign the same license number to the replacement individual. If the replacement
                               individual has not been provided in the allotted time frame, the license that individual number shall be deactivated. If
                               the organization is left without any ACE and has not provided any replacement in the allotted
                               time period, or if the business organization is no longer a legal entity, the organizational
                               license shall expire. both Organization and at least one ACE shall re-register with the NFRC
                               for a new licensee number in order to continue to perform calculations for specifying
                               authoritiesACE-related activities and issue NFRC-sanctioned reports. It shall be the
                               responsibility of the Calculation Agency organization to advise NFRC of any or all business
                               changes that would cause a licensee to re-register or to be de-listed. (For Additional
                               information, see the LAP)

311
       DCC   N   3.3.2   3.3.2: I think that this should not be in PCP. This is LAP language. However, wherever it is placed, replace existing        P & S - Language to be written in the LAP per Chicago
                         text with:                                                                                                                   discussions of Working Group..
                         A. Training shall be available to anyone seeking certification as an ACE and is employed by an organization Certified
                         Calculation Entity. Specific requirements for training and qualifications are set forth in the LAP. ACE shall pass
                         NFRC supplied exam. For additional details see LAP.
                         . Training can be obtained by either participating in a NFRC scheduled Component Library Database Training
                         Course or by completing a self-study and examination program on line, which includes online testing.
                          B. Upon the completion of the CMA software tool training and passing exam, ACE shall sign a license agreement
                         with the NFRC, after which ACE shall be qualified to generate bid and certification level reports.

312
      TDC    N   4.1.A   iii. selecting a NFRC-licensed IA;                                                                                           P & S - Draft will be revised and be consistent with page
                                                                                                                                                      2 of the flow chart and the revised frame language
313                                                                                                                                                   approved by the working group.
      TDC    N   4.1.B   iii. The Specifying Authority may either print out the label certificate from the website directly or may authorize the IA   P & S - Draft will be revised and be consistent with page
                         Certified Simulator or Accredited Simulation Laboratory or Approved Calculation Entity to do so. In either                   2 of the flow chart and the revised frame language
                         case, the Specifying Authority shall sign and execute the license agreement with NFRC before issuance of the label           approved by the working group.
                         and/or project certificate.                                                             Comment: Changed language to
314                      reflect that label certificate can be issued by sim lab or ACE.
      TDC    N   4.1.B   iv. If the Approved Calculation Entity is a manufacturer, an IA shall review the rating calculation prior to                 P & S - Draft will be revised and be consistent with page
                         either the Specifying Authority, Approved Calculation Entity, or IA issuing the label certificate.                           2 of the flow chart and the revised frame language
                         Comment: Manufacturing companies should also be allowed to act as an Approved Calculation Entity (ACE).                      approved by the working group.
                         Independence is maintained by having final review by an approved IA. If the manufacturer chooses to use an
315                      accredited simulation lab to be their ACE, then review by an IA is definitely not required.
      TDC    N           NFRC shall randomly select a fraction of product certificates, not                                                           P & S - Draft will be revised and be consistent with page
                         to be higher than 10%, for which the IA shall collect a The IA shall maintain D documentation trail, hard copy or            2 of the flow chart and the revised frame language
                         electronic storage (bill of sales, purchase orders, specifications, etc.) regarding the fenestration system and conduct      approved by the working group.
                         random audits of these systems to ensure that the system is accurately reflected in the label certificate issued,
                         and complies with the requirements of the PCP. The IA shall seek approval of NFRC prior to converting the
316                      Documentation trail documentation to electronic storage.
      TDC    N   4.1.E   E. Non-validation [Entire bullet]                                                                                            P & S - Draft will be revised and be consistent with page
                                                                                                                                                      2 of the flow chart and the revised frame language
317                                                                                                                                                   approved by the working group.
      TDC    N   4.2.3   may also include a graph or table, showing the curves of Ufactor,                                                            P & S - Draft will be revised and be consistent with page
                         SHGC and VT as a function of that system size.                                                                               2 of the flow chart and the revised frame language
318                                                                                                                                                   approved by the working group.
      TDC    N   4.3.B   The Project Certificate summarizes the performance of individual                                                             P & S - Draft will be revised and be consistent with page
                         products. The Project Certificate may, but is not required, to also                                                          2 of the flow chart and the revised frame language
319                      report an area-weighted average U-factor and SHGC for the project.                                                           approved by the working group.
      TDC    N   5.1.A   For product certificates selected for auditing according to section 4.1C, selected IA conducts Documentation                 P & S - Draft will be revised and be consistent with page
                         review/audit of Specifying                                                                                                   2 of the flow chart and the revised frame language
                         Authority’s fenestration system to ensure that the system is accurately                                                      approved by the working group. Draft will be revised to
                         reflected on the label certificate and complies with all PCP requirements.                                                   reflect that the ACE will contract with the IA and pay
                         The IA shall conduct the review within fifteen (15) days of the receipt of                                                   appropriate fees.
                         the “Documentation-trail” and shall notify the Specifying Authority of any
320                      discrepancies or missing information.
      TDC    N   5.2     If the IA determines any deficiency as regards to the submitted fenestration system, then the Specifying Authority           P & S - Draft will be revised and be consistent with page
                         shall be notified, as well as the code official (permit granting agency) about the deficiency, by issuance of “The           2 of the flow chart and the revised frame language
321                      notice of non-compliance".                                                                                                   approved by the working group.
      TDC    N   5.2     All costs related to the Documentation-trail audit shall be solely borne by the Specifying Authority. Incorporated           NP - Working Group has decided the ACE has the
322                      into the program participation fees.                                                                                         primary responsibility.
      CGC    N   4.1     Add A. vi. - "submittal of documentation trail materials for audited projects"                                               P & S - Draft will be revised and be consistent with page
                                                                                                                                                      2 of the flow chart and the revised frame language
323                                                                                                                                                   approved by the working group.
      CGC   N   4.1          Section A. iv. Change to read "selecting a NFRC Approved Calculation Entity." Based on guidance from the NFRC                P & S - Draft will be revised and be consistent with page
                             Board of Directors, the simulation and validation for a vast majority of products and systems will take place prior to       2 of the flow chart and the revised frame language
                             the materials being added to the databases, therefore, the Specifying Authority will not be dealing with these parties.      approved by the working group.
324
      CGC   N   4.1.D        Section C. IA Audits revise to read The IA shall maintain the documentation-trail materials from audited projects as         P & S - add the 5th bullet to the draft. Draft will be
                             follows:                                                                                                                     revised and be consistent with page 2 of the flow chart
                                                                                                                                                          and the revised frame language approved by the
                             - Copy of project specification sections for the glazing infill and framing system(s)                                        working group.
                             - Copies of any change orders affecting the primary glazing infill and framing system(s)
                             - Copy of the glazing contractor's primary purchase order for glazing infill and framing system(s)
                             - Copy of the glazing infill and framing system manufacturers' primary order acknowledgements
                             - Copy of the glazing infill and framing system manufacturers' material shipment documents
325
      CGC   N   4.1          Section C. IA Audits - Delete the last sentence "The IA shall seek approval of NFRC prior to converting the                  P & S - Draft will be revised and be consistent with page
                             Documentation trail documentation to electronic storage." Electronic submittal and storage is the most feasible              2 of the flow chart and the revised frame language
326                          means of submittal and retention.                                                                                            approved by the working group.
      CGC   N   4.1          Delete Section D. Physical Testing - Based on discussion with the NFRC Board of Directors, physical testing will take        NP - Contrary to draft being revised and be consistent
                             place prior to entry into the databases, therefore the information is not applicable in this section.                        with page 2 of the flow chart and the revised frame
                                                                                                                                                          language approved by the working group.
327
      CGC   N   4.1          Delete Section F. Non-validation - Based on discussion with the NFRC Board of Directors, physical testing will take          P & S - this section was deleted because it is not
                             place prior to entry into the databases, therefore the information is not applicable in this section.                        required in the CMA program which uses only testing
328                                                                                                                                                       when products cannot be simulated.
      CGC   N   5.1          Paragraph A. revise to read "Selected IA conducts random Documentation review/audit of fenestration systems for              P & S - Draft will be revised and be consistent with page
                             five percent of certified projects to ensure that the system is accurately reflected on the label certificate and complies   2 of the flow chart and the revised frame language
329                          with all PCP requirements."                                                                                                  approved by the working group.
330    BS   N   4.1.B.1      by the selected Approved Calculation Entity utilizing                                                                        NP - per minutes of Minneapolis meeting.
331    BS   N   4.1.B.2      through the selected Approved Calculation Entity,                                                                            NP - per minutes of Minneapolis meeting.
332    BS   N   4.1.B.2.ii   Laboratory or Approved Calculation Entity as applicable                                                                      NP - per minutes of Minneapolis meeting.
       BS   N   4.1.C        The IA shall retain all submissions from the Specifying Authority maintain Documentation trail, hard copy or                 P & S - Draft will be revised and be consistent with page
                             electronic storage (bill of sales, purchase orders, specifications, etc.) regarding the fenestration system and              2 of the flow chart and the revised frame language
                             conduct random audits of these systems to ensure that the system is accurately reflected in the label certificate            approved by the working group.
                             issued, and complies with the requirements of the PCP. The IA shall seek approval of NFRC prior to converting
                             the Documentation trail documentation to electronic storage.
333
334    BS   N   4.1.D        simulation tools shall be physically tested to determine NFRC ratings                                                        P & E - draft will be revised.
335    BS   N   4.1.E.i       The IA shall notify in writing the Specifying Authority, Approved Calculation Entity                                        NP - per minutes of Minneapolis meeting.
       BS   N   4.1.E.v      v. If no resolution is reached within the 610-calendar day period, the IA shall notify NFRC staff within one (1) business    NG - comment #1 - section has been deleted. NP -
                             week for assistance. The IA, Specifying Authority, Approved Calculation Entity                                               comment #2 - per minutes of Minneapolis meeting.
336
       BS   N   4.1.E        {(Comment: Discussion needs to be held regarding the testing requirement of the Component Based Non-                         P & S - Draft will be revised and be consistent with
                             Residential Product Certification Program.)}                                                                                 pages 1 and 2 of the flow chart and the revised spacer
                                                                                                                                                          and frame language approved by the working group.
337
       BS   N   4.1.G        Significant changes to components approved by the Peer Review and Eexpert Rreview process shall require re-                  NG - peer review has been deleted.
338                          approval
       BS   N   4.2.A.3      may also include a graph, showing the curves of U-factor, SHGC and VT as a function of that system size. (If not             NP - this is an option on the Label Certificate but per
                             NFRC Certified, then should not be part of NFRC Certification document.)                                                     NFRC label requirements it may not appear within the
339                                                                                                                                                       standard 4 x 4 label area.
340    BS   N   4.2.B.2      shall be calculated in accordance with NFRC 100 {To be developed},                                                           P & E - will be deleted.
       BS   N   4.3          Project Certification (Does not belong in mandatory section of                                                               NP - can be included in the mandatory section but
341                          document.)                                                                                                                   identified as optional.
342    BS   N   5.1          Documentation-Trail Audit (Component-Based Whole Product Verification)                                                       NP - per minutes of Minneapolis meeting.
       BS   N   5.1.A        The IA shall conduct the review within fifteen (15) days of the receipt of the “Documentation-trail” documentation           NP - per minutes of Minneapolis meeting.
343
       BS    N   5.1.D        If no corrective action is taken within fifteen (15) days of notification,                                                  NP - Balance is provided by notification and listing in the
                              then the Label Certificate shall be deemed null and void and this action                                                    CPD
                              shall be communicated to the appropriate authorities. (There is no benefit to the certification program by
                              conducting the review after certification is granted. Revocation of an inaccurate Label certificate does not
344                           infuse this certification program with credibility: it is counterintuitive.)
       BS    N   5.1.1        Section 6. (What is being revoked? The certificate is null and void                                                         P & E - draft will be revised (5.1.2 & 5.2.E) to indicate
                              after 15 days, so why “inform the appropriate authorities”? This                                                            that Label Certificate and values are being revoked.
                              must refer to the license agreement – in that case, only the
                              Specifying Authority and the IA would be notified of the license
345                           status change.)
       BS    N   5.2          All costs related to the Ddocumentation-trail audit shall be solely borne by the Specifying Authority                       P & S - Draft will be revised and be consistent with page
                                                                                                                                                          2 of the flow chart and the revised frame language
346                                                                                                                                                       approved by the working group.
      JAH    N   4.1.B        1. Label Certificates can be issued from the components library by the Specifying authority after a calculation report is   P & S - Draft will be revised and be consistent with page
                              generated by the selected Approved Calculation Entity utilizing the NFRC computer program, which calculates whole           2 of the flow chart and the revised frame language
                              product                                                                                                                     approved by the working group.
                              performance using the three components of the fenestration system (glazing, spacer, and frame system) into a whole
347                           product composite energy performance rati
      JAH    N   4.2.B.2      2. Component performance of the spacer, expressed in terms of keff, shall be calculated in accordance with NFRC             P & E - draft will be revised.
348                           100 {To be developed}, and using NFRCapproved software tools.
      JAH    N   4.2.B.3      3. Component performance for the framing and edge of glazing for the four Best/Worst case options shall be                  P & E - draft will be revised.
                              calculated in accordance with NFRC 100 and reported for each characteristic cross-section. For each cross-section,
                              there shall be three (3) numbers
                              for framing and three (3) numbers for edge of Formatted: Highlight Page 27 of 53 06/16/2006 NFRC CB-PCP 2006
                              glazing. The list of approved software tools is available from the NFRC website Given in the PCP.
349
       CAR   N   4.3.A        The Project Certificate pertains to more than one fenestration whole product systems within the group that may be           P & S - Draft will be revised and be consistent with page
                              defined as a project. The project may be the entire commercial building, or it may be portion of a building (e.g., a        2 of the flow chart and the revised frame language
350                           renovation project where only part of the fenestration system is being replaced).                                           approved by the working group.
       MiT   N   4.1.E.iii    Comment: The SA will not agree to bear the burden of these costs. Also ... who is responsible if the                        P & S - Draft will be revised and be consistent with page
                              software yields wrong ratings? The owner / architect will be looking for fault.                                             2 of the flow chart and the revised frame language
351                                                                                                                                                       approved by the working group.
352    MiT   N   4.1.E.iv     Comment: (Comment: Discussion needs to be ...) - Physical testing is not required at this point.                            P & E - comment has been deleted.
       MiT   N   5.1.B        Comment: It is not appropriate for the IA to notify the "code official (permit granting agency)".                           P & S - Draft will be revised and be consistent with page
                                                                                                                                                          2 of the flow chart and the revised frame language
353                                                                                                                                                       approved by the working group.
       MiT   N   5.2          Comment: Auditing expenses should be built into the ACE licensing agreement with NFRC. Random                               P & S - Draft will be revised and be consistent with page
                              samplings can be done on their certified projects. The market will not support SA's being responsible for                   2 of the flow chart and the revised frame language
                              paying for random audits.                                                                                                   approved by the working group. Working Group has
                                                                                                                                                          decided the ACE has the primary responsibility.
354
       MJT   N   4.1.A.iv     selecting a NFRC-certified simulator Accredited Simulation Laboratory and/or approved Calculation Entity                    P & S - Draft will be revised and be consistent with page
                              and/or testing lab Accredited Testing Laboratory ; and                                                                      2 of the flow chart and the revised frame language
355                                                                                                                                                       approved by the working group.
       MJT   N   4.1.B.ii     This web-based tool allows the Specifying Agency, through the selected Approved Calculation Entity, to go online to         P & S - Draft will be revised and be consistent with page
                              the Components Library database, calculate the energy performance ratings for the system, and generate a label              2 of the flow chart and the revised frame language
                              certificate. COMMENT: This section seems to duplicate the language from 3.1 C,D,E. Should it be removed?                    approved by the working group. Separate Licensing
                                                                                                                                                          requiremens and certification process language are
                                                                                                                                                          included in the respective sections.
356
       MJT   N   4.1.B.2.iv   The Official Label Certificate shall be issued following an IA review.                                                      P & S - Draft will be revised and be consistent with page
                                                                                                                                                          2 of the flow chart and the revised frame language
357                                                                                                                                                       approved by the working group.
       MJT   N   4.1.E        COMMENT: This section is incorrect. The validation test will take place before the system is an available                   P & S - Draft will be revised and be consistent with page
                              component for use in the database, so the scenario described cannot occur.                                                  2 of the flow chart and the revised frame language
358                                                                                                                                                       approved by the working group.
       MJT      N   4.1.G     COMMENT: Significant changes to a product would not indicate re-approval, but approval of a new system.                      P & S - Draft will be revised and be consistent with page
                              If new values are submitted, they will need to follow the established process to be entered into the                         2 of the flow chart and the revised frame language
359                           database, and any old data will need to be removed.                                                                          approved by the working group.
       MJT      N   4.2.B.3   COMMENT: 3 Numbers? Is this technically correct?                                                                             P & S - keep 1st sentence, delete 2nd sentence, change
360                                                                                                                                                        "in the PCP" to on the NFRC web site.
           JS   N   4.3.A     The Project Certificate summarizes the performance of individual products. The project certificate may, but is not           P & E - draft will be revised.
361                           required, to also report an area-weighted average U-factor and SHGC for the project
      MKW       N   4.1       Component-Based Fenestration Product Certification Process                                                                   NP - role of IA addressed in draft.

                              Item B-1, Generation and Issuance of Label Certificate

                              If this is the process then what does the IA add to the process?
362
      MKW       N   4.1       Item C, IA Audits                                                                                                            P & S - add the 5th bullet to the draft. Draft will be
                                                                                                                                                           revised and be consistent with page 2 of the flow chart
                              Need to set documentation requirements. The way this is written I’m glad I’m not an IA                                       and the revised frame language approved by the
363                                                                                                                                                        working group.
      MKW       N   4.1       Item E, Non-Validation                                                                                                       P & S - Draft will be revised and be consistent with the
                                                                                                                                                           flow chart and the revised frame language approved by
                              This clause assumes that products will be tested whereas testing requirements have not been determined for the               the working group.
                              CMA program. At the October 5, 2005 meeting in Atlanta, the task group agreed that testing would not be required
                              as it would drive up the cost of certification.

                              Item D, Physical Testing indicates that’s only products which cannot be simulated will be tested. Therefore the two
                              clauses are inconsistent with each other.
364
      MKW       N   4.1       Clause E, vi – which committee is responsible for the decision determining the values for certification?                     P & S - Draft will be revised and be consistent with
                                                                                                                                                           page 2 of the flow chart and the revised frame language
365                                                                                                                                                        approved by the working group.
      MKW       N   4.3       Project Certification, Item D, Project Reporting – See Appendix A                                                            P & S - Bipin will add task group draft for Label
                                                                                                                                                           Certificate to Appendix A.
                              Project Certificate has not been approved. Where is Appendix A.
366
      MKW       N   5         5.1, Documentation-Trail Audit (Component-Based Whole Product Verification                                                   P & S - Draft will be revised and be consistent with
                                                                                                                                                           page 2 of the flow chart and the revised frame language
                              The documentation trail requirements need to be established.                                                                 approved by the working group.
367
      LL        N   4.1 C     While I agree with the requirement of specifications, we need to set a limit. Many times a set of specifications can be      P & S - Draft will be revised and be consistent with page
                              anywhere from 1 to 5 (or more) volumes as thick as a telephone book! We should modify this slightly to state,                2 of the flow chart and the revised frame language
                              “Specifications relative to the thermal performance criteria for the product/project.” This will help us avoid placing the   approved by the working group.
368                           burden of finding the appropriate data by the IA
      DCC   N   4.1.B       4.1.B: Replace with:                                                                                                          P & S - Draft will be revised and be consistent with page
                            1. Label Certificates can be issued from the components library CMA software tool by to the Specifying Authority by           2 of the flow chart and the revised frame language
                            after a calculation report is generated by the selected Accredited Calculation Agency ACE utilizing the NRFC                  approved by the working group.
                            computer program, which calculates using the three components of the fenestration system (glazing, spacer, and
                            frame system) into a whole product composite energy performance rating the process specified in Section 2..
                            2. This web-based tool NRFEN allows the Specifying Agency, through the selected Calculation AgencyACE, to go
                            access component database online to the Components Library database, calculate the energy thermal and solar-
                            optical performance ratings for the whole productsystem, and generate a label certificate or bid-level report.
                            i. The Specifying Authority shall accept the NFRC terms of certification
                            ii. The certified simulator or accredited simulation laboratory or approved calculation entity as applicable shall be
                            contracted and authorized by the Specifying Authority to calculate the performance rating values of the specified
                            components.
                            iii. The ACE shall be contracted to generate bid-level reports or label certificates using NRFEN.
                            iiiiv. The Specifying Authority may either print out the label certificate from the website NRFEN directly or may
                            authorize ACE the IA to do so. In either case, the Specifying Authority shall sign and execute the license agreement
                            with NFRC before issuance of any the label and/or project certificates. The license shall be maintained with NFRC
                            subject to the periodic review by NFRC, but it shall not be necessary to re-sign license agreement prior to follow-up
369                         label certificate issuences
      DCC   N   4.1.E:      4.1.E: In the absence of physical testing for validation (4.1.D), there is no need for this section                           P & S - Draft will be revised and be consistent with page
                                                                                                                                                          2 of the flow chart and the revised frame language
370                                                                                                                                                       approved by the working group.
      DCC   N   4.2.B       4.2.B: This is repeat of things that were already covered earlier in the document. This should be deleted from here or        P & E - Check for repaet language and delete if
                            shortened with appropriate referencing of earlier material.                                                                   necessary - check for conflict with Technical documents.
371
      DCC   N   5.2         5.2: I don’t think that specifying authority shall be responsible for audit costs. I think that audit costs should be built   P & S - Draft will be revised and be consistent with page
                            into the program cost and charged once through the certificate fee                                                            2 of the flow chart and the revised frame language
                                                                                                                                                          approved by the working group. Working Group has
                                                                                                                                                          decided the ACE has the primary responsibility.
372
      TDC   N   6.2.B       Any product certification authorization issued by an licensed IA an Approved Calculation Entity or NFRC                       P & S - Draft will be revised and be consistent with page
                                                                                                                                                          2 of the flow chart and the revised frame language
373                                                                                                                                                       approved by the working group.
      TDC   N   6.3.A       A. A Challenge may be brought pursuant to Section 6.2 by delivering two originals of a written Statement of                   P & S - Draft will be revised and be consistent with page
                            Challenge, in a form prescribed by NFRC to the NFRC-licensed IA an NFRC-licensed IAused by the Specifying                     2 of the flow chart and the revised frame language
                            Authority of the product to be challenged. The Statement of Challenge shall be delivered by certified mail, return            approved by the working group.
                            receipt requested, or other method that provides evidence of, and a receipt for delivery.
374
375 TDC     N   6.3.1 F     Provide current reference                                                                                                     P & E - draft will be revised.
    TDC     N   6.6.2       The parties to a Challenge Appeal shall be the Challenger, the Specifying Authority of the fenestration product to            P & S - Draft will be revised and be consistent with page
                            which the Challenge Appeal relates, the Simulation Laboratory, Approved Calculation Entity which issued the reports           2 of the flow chart and the revised frame language
                            upon which the product certification authorization is based and the IA which was involved with the original                   approved by the working group. Check that IA doing
                            challenge. and the IA which issued or verified the product certification authorization for the fenestration                   challenge was not involved in audit.
376                         product. The Appellant may be any one or more of these parties.
      TDC   N   6.6.3.4     Check for redundancy with 6.6.3.1 above. Combine both into one?                                                               P & S - Draft will be revised and be consistent with page
                                                                                                                                                          2 of the flow chart and the revised frame language
377                                                                                                                                                       approved by the working group.
      TDC   N   6.6.3.4     Check for redundancy with 6.6.3.2 above. Combine both into one?                                                               P & S - Draft will be revised and be consistent with page
                                                                                                                                                          2 of the flow chart and the revised frame language
378                                                                                                                                                       approved by the working group.
      TDC   N   6.6.3.6     Check for redundancy with 6.6.3.3 above. Combine both into one? Check for info that IA should not be                          P & S - Draft will be revised and be consistent with page
                            responsible for because ACE issues certification.                                                                             2 of the flow chart and the revised frame language
379                                                                                                                                                       approved by the working group.
      CGC   N   8           While we have been repeatedly told that the fee schedules will be set by the NFRC Board of Directors, members of              NG - beyond the scope of the Working Group -
                            the organization should not be expected to vote on a draft product certification program without any information on           concerns will be conveyed to the BOD.
380                         the intended costs.
381    BS   N   6.2.B.iii   NFRC-Accredited Simulation Laboratory, or NFRC Approved Calculation Entity                                                    NP - See Minutes from Minneapolis.
       BS   N   6.2.B.vi    vi. Any Label product/project certificate issued by a Specifying Authority indicating NFRC certification                      P & E - change to Label Certificate/Project Certificate.
382
383    BS    N    6.3.1.F     Approved Calculation Entity which issued the calculated                                                                  NP - See Minutes from Minneapolis.
       BS    N    6.6.2       Approved Calculation Entity which issued the reports upon which the product certification authorization is based and     NP - See Minutes from Minneapolis.
                              the IA which issued or verified the product certification authorization for the fenestration product
384
       BS    N    6.6.3.1     Simulation Laboratory (Combine with 6.6.3.4)                                                                             NP - sections need to remain seaparate to address
385                                                                                                                                                    separate participants.
       BS    N    6.6.3.2     Calculation Entity (Combine with 6.6.3.5)                                                                                NP - sections need to remain seaparate to address
386                                                                                                                                                    separate participants.
       BS    N    6.6.3.3     Independent Certification and Inspection Agency                                                                          NP - sections need to remain seaparate to address
387                           (Combine with 6.6.3.6)                                                                                                   separate participants.
388    BS    N    6.6.3.5      Approved Calculation Entity                                                                                             NP - See Minutes from Minneapolis.
       BS    N    6.6.3.7.A   Calculation Entity selected by NFRC staff, which laboratory or entity shall not be the same laboratory or calculation    NG - section has been deleted.
389                           entity that issued the rating upon which product certification authorization was based.
       BS    N    6.6.3.7.C   Records indicating the number of units of the product subject to challenge distributed with NFRC labels or label         P & E - draft will be revised.
390                           certificate.
       BS    N    6.6.3.7.D   Records indicating the date that labeling of the product subject to challenge began. (Add the request for evidence       NG - new wording does not require submittal to IA.
391                           the label certificate was submitted to and approved by an IA.)
       MJT   N    6.3.1.C     COMMENT: I don’t believe this fee would cover NFRC’s costs for a challenge. The cost of challenge should                 NG - BOD jurisdiction for fees.
392                           be borne by the loser of the challenge.
       MDE   N    8           Need a fee schedule for each step of the process, at least a range.                                                      NG - beyond the scope of the Working Group -
393                                                                                                                                                    concerns will be conveyed to the BOD.
      MKW    N    6           Administrative Action and Challenge Procedure                                                                            NP - sections need to remain seaparate to address
                                                                                                                                                       separate participants. Issue will be referred to the PCP
                              This whole section is over written and unnecessarily bureaucratic. It does not need to be this complicated in order to   task group working on simplifying both PCPs. See
                              document the challenge procedure.                                                                                        flowchart from Steve Selkowitz.
394
      MKW    N    6.6.6       NFRC Board of Directors                                                                                                  NG - beyond the scope of the Working Group -
                                                                                                                                                       concerns will be conveyed to the BOD. MKW will send
                              I would like more discussion on the designation of the appointees. This should include balanced representation.          suggested approach to NFRC staff to be conveyed to
395                                                                                                                                                    the BOD.
      BC     *N   6           This whole section is over written and unnecessarily bureaucratic. It does not need to be this complicated in order to   NP - sections need to remain seaparate to address
                              have meaning.                                                                                                            separate participants. Issue will be referred to the PCP
                                                                                                                                                       task group working on simplifying both PCPs. See
                                                                                                                                                       flowchart from Steve Selkowitz.
396
       DCC   AC   6 and All   Numbering system is inconsistent and need to be fixed                                                                    P & E - numbering will be corrected when draft is
397                                                                                                                                                    complete.

				
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