The National Fenestration Rating Council (NFRC) turned 35 this year. Somewhat surprisingly, there is still considerable confusion over the purpose and value of the standards and resulting ratings. This confusion is not unique to NFRC, of course. Other organizations that maintain standards face similar questions. (See blog articles by the Association of Equipment Manufacturers as an example: 2021 blog and 2024 blog.)

Why Are There Standards?

Standards are not always recognized as necessary, even when it should be obvious. A prime example of how the lack of a standard resulted in a massive problem was the Great Baltimore Fire of 1904, which lasted for two days, causing 1,500 buildings to be lost, 1,000 more to be severely damaged, and 35,000 people to lose their jobs. One of the main reasons the fire wasn’t extinguished sooner—despite assistance from cities like Philadelphia, Washington, D.C., New York, and others, in the form of fire engines—was that the equipment wasn’t standardized. According to Wikipedia, “By 1903, over 600 sizes and variations of fire hose couplings existed in the United States. Despite efforts to establish standards being made since the 1870s, they had little effect: no city wanted to abandon its system, few saw any reason to adopt standards, and equipment manufacturers did not want competition.”

Over a hundred years later, and with true standardization in place, the reason to standardize is clear but even with immediate hindsight, there was a struggle to see the sense.

While safety standards may seem more necessary, the benefits of standardization apply to other areas as well, if for no other reason (though there are other reasons) than consistency of reporting and application of results.

Take standardization of units of measure—length, weight, volume, and time. It’s not hard to imagine how much confusion there could be when the units of measurement were “hands,” “feet,” or “barleycorn.” In the fenestration industry, prior to standard procedures, room for confusion came from some choosing to use R-value, others choosing U-value/U-factor, and everyone using their own methods to obtain and report results.

NFRC’s standards arose out of a need for consistent, reliable information that was being requested by people outside of the industry, resulting in scrutiny and the direct threat of regulation.

This prevention of regulation is one of the most forgotten elements of NFRC’s existence. In 1989, both the U.S. and Canadian governments were contemplating the creation of energy labels for fenestration products because of the lack of consistency. In 1989, it was noted that the window industry wanted to develop labels as soon as possible, to prevent the government from stepping in, developing its own system. It was then that a group agreed on the formation of NFRC.

Voluntary ≠ Law

It is true that NFRC’s standards and the data that is derived from them have opened doors for the industry’s inclusion in energy codes, Energy Star and other government programs, tax credits, and other areas; but it is important to remember that the standards themselves are not the regulations. The American National Standards Institute (ANSI) notes that “voluntary consensus standards are not the law; organizations choose to follow them to meet customer or industry demands. However, voluntary standards can be (and often are) incorporated by reference into laws or regulations, becoming mandatory.” Why? Because with the standards, consistent and verifiable data can be used to measure success, progress, and enhance competition.

NFRC’s voluntary program has several levels of consensus that help to keep the ratings fair, accurate and credible. Members and participants can assist in the review and maintenance of NFRC’s standards at the task group level with research, testing and discussion. NFRC membership, through subcommittees, committees, and a board of directors (which represent each category of interest in the industry), further debate, ballot and vote upon changes to NFRC’s standard procedures. As an ANSI-accredited standards developer, NFRC expands this process by soliciting feedback from any interested party globally, following ANSI’s requirements for “the use of a development process characterized by openness, balance, due process, consensus and the right to appeals.”

Closing the Circle with Due Process and Appeals

By having standard rules, and by applying them fairly, protection is added for all involved—NFRC’s reputation, the value of the result of NFRC’s standards (labels on products) and the investment that manufacturers have made in pursuing that label, and the trust in that information by the end user. NFRC’s Compliance and Monitoring Program was created to close the loop on the standards process and provide a means to ensure that the playing field remains level.

It is worth noting that the more recognized the NFRC label is, the more it is misused and the more requests for investigation are received. In 2023, only six credible complaints were received (four from consumers); in the first six months of 2024, 12 inquiries have been received (four from consumers, the remainder from within the industry or code officials). In addition, staff increasingly find counterfeit labels used on foreign websites seeking to sell products in the U.S. market.

Consensus Requires Involvement

Any standards organization benefits from a confluence of people and voices. For our part, the more that the results of NFRC’s efforts are recognized and called upon in the market chain, the more we hope the industry will contribute to ensuring that the standards and resulting ratings remain fair, accurate, and credible.

I’d invite anyone interested in participating to consider joining the NFRC Standards Committee, which oversees the process by which documents are submitted and approved through ANSI. An ideal balance of opinion is needed on this committee, with current openings available in the general interest category. Additional information can be found on the Standards Committee webpage or by contacting standards@nfrc.org.

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