Thank you Amir for your comments! You have hit the nail on the head.
ICC-ES is only interested in figuring out how to maximize income, not protect the public IMO.
Allowing non-rated deck coatings to be listed at ICC-ES will only cause confusion to the public, building officials and inspectors.
Comments on Criteria AC39.
Amir Rudyan
AVM Industries
818-888-0050
Comments:
I would like to comment on AC39, or more specifically that deck
coatings have 3 different levels of ICC approvals. Walking deck, roof
covering and 1-hour assembly. Furthermore, the walking deck does
not require quarterly inspections and is cheaper to test for and the
other two do require quarterly inspections and cost more to test. We
have the top rating on our deck coating (ESR-2125) that also
includes the fire rating. What we fear is that customers, builders,
building departments and inspectors get confused. After all, they
don't always read the fine print. So a competitor could easily submit
an ICC report with one of the two lesser ratings and get away with
it. (Many folkes simply ask whether you have an ICC approval, yes
or no and write down the ICC number. That puts the buildings and
the owners and tenants at risk due to confusion and puts us at a
disadvantage even though we developed a system that meets the
highest requirements. (It costs more to develope and test a system
that passes the highest testing requirements). You also have created
an incentive for companies to develope and test to the lowest
standards since you can save money buy not having to do as much
R&D, not as much testing and not have to do quarterly inspections
or any on-going inspections ever! I think this 3 tier standard should
be eliminated or at least re-visited. I would appreciate any
comments or feedback you may have on this issue. Thanks, Amir
Rudyan, President AVM Industries.
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Bill Leys
The Deck Expert
www.centralcoastwaterproofing.com Lic 890269
