Thread: Perception

Time to draw on the wealth of experience and knowledge of this forum.

Attached is the City of Houston, TX Insulation & Air Leakage Fact Sheet

In particular note the first sentence after AIR LEAKAGE.

My question:

Light fixtures that have been independently tested to meet ASTM E283 (Less than 2 CFM leakage @1.57 PSI; 2003 IECC Energy Code)

The fixtures are marked with this information. They are also marked with applicable trims that do not require additional sealing. If open-type trims are used then it is the responsibility of the installer to seal between the ceiling opening and the fixture or they can purchase a kit specifically made that will accomplish this. (All stated in the installation instruction sheet)

An inspector (I don't know if it was Building Code enforcement or a Home Inspector) fails the installation of fixtures prior to the ceiling being installed because the fixtures do not include a gasket.

Resolution?

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Originally Posted by Joe Asta

The fixtures are marked with this information. They are also marked with applicable trims that do not require additional sealing. If open-type trims are used then it is the responsibility of the installer to seal between the ceiling opening and the fixture or they can purchase a kit specifically made that will accomplish this. (All stated in the installation instruction sheet)

Therein lies the problem.

An inspector (I don't know if it was Building Code enforcement or a Home Inspector) fails the installation of fixtures prior to the ceiling being installed because the fixtures do not include a gasket.

Resolution?

That is understandable as the recessed light fixture housing is, or is not (and that is what the inspection is keying in on) rated air-tight with trims UNLESS (also likely the inspectors key word) an OPTIONAL kit is used to seal open trims.

As there are no trims installed at framing, the inspector has no choice but to take the worst case scenario and presume that open trims COULD be installed and therefore would REQUIRE an OPTIONAL accessory kit, which may or may not be installed by the installed should open trims be installed.

Being as the inspector has no choice but to make sure that the fixture is sealed as required without the trim installed, he writes it up as needing correction.

Not sure if I explained it well from an inspectors point of view.

Now *IF* the only trims which were available for that recessed light fixture housing were closed trims which did not require an optional accessory kit to seal it up, then there would not be a problem.

Thus the problem arises only because of the option to not seal the recessed light in accordance with its listing and labeling.

How to solve that?

I can think of two ways, one is a gimme and the other is a probably.

First the Gimme Part A: Make the recessed light fixture housing accept only closed trims which are not required to make use of an optional accessory kit for sealing as necessary to achieve its listing and labeling requirement.

Second the Gimme Part B: Make the recessed light fixture housing meet the requirements of the air-tight cans without any trims, so that regardless of what trim is used, the recessed housing meets the listing and labeling requirements.

Third the Probably Part A: Have the trim and optional accessory opened and installed during the framing inspection, and non-returnable once opened. That will reduce the chances of installing a different trim later.

Fourth the Probably Part B: The inspector may still say "So? What about when someone changes the trim later? The recessed light fixture housing will no longer meet its listing and labeling. That's a no-go here, make that recessed light fixture housing meet the air leakage requirements by sealing it up, that way it does not mater what trim someone decides to install later, the recessed light fixture housing and trim will still meet its listing and labeling requirements.

Probably the best resolution is to provide a gasket on the bottom of the fixture to give the perception of an air seal.

Originally Posted by Joe Asta

Probably the best resolution is to provide a gasket on the bottom of the fixture to give the perception of an air seal.

But would that make the recessed housing meet the requirements of its listing if an open trim were installed without the optional accessories?

If so, then that should solve the problem, and the installation instructions would need to acknowledge that.

If not, then you are just trying to play "fool the inspector" and that may work once or twice, but when the inspector realizes what is going on, he will make it VERY HARD to allow those recessed light fixture housings to be installed in his AHJ in the future. You do not want to play "fool the inspector" ... and lose. The end result may well be never selling any more of those recessed fixtures in that AHJ area without a redesign and re-listing showing that the recessed housing meets the requirement trim or no trim, open or closed trim.

You've heard the expression "Don't fool with Mother Nature.", well "Don't fool with the inspector." is second only to Mother Nature.

Jerry,

I think the impasse here is that the installation determines final conformance to code.

Originally Posted by Joe Asta

Jerry,

I think the impasse here is that the installation determines final conformance to code.

Joe,

I completely agree "that the installation determines final conformance to code" and am pointing out that the installation instructions allow for a trim to be installed which could cause the recessed housing to be non-rated, and that an optional kit is available to make those trims (those open trims) complete the sealed system.

We also know that the optional kit is seldom going to be sold/bought and thus the installation of the open trims will violate the listing of the recessed lighting fixture (luminaire).

Now *IF* that optional accessory were part and parcel of the open trims, that would increase the chance of them being installed, however, if the open trims can be installed without those other pieces, we also know that those are pieces are going to be left in their bag and not used.

Thus the impasse really is that the recessed light fixture housing and its trims are designed and manufactured in such a way as to allow for their installation in a manner which is in violation it listing and labeling when those other parts are not installed. The inspector is addressing that impasse by saying, in effect, "No problem. SEAL it up NOW, then there will not be a problem when the open trim is installed without those other parts, which are not only "other parts" but must be purchased separately."

You know, as I know, and probably everyone here on this forum knows, that when the electrician calls up his lighting distributor and orders those fixtures he is only going to order the recessed housings first because that is what he is going to install first. Then he will order the open trims when he is ready to trim the job out.

See what is missing? What was NOT ordered? What is NOT going to be installed?

That inspector is seeing the same thing.

As these installations become more commonplace, a simple solution would be to offer the same fixture with trim listings that are only air tight under a different model number even though the fixture would remain unchanged.

Do you agree?

Originally Posted by Joe Asta

As these installations become more commonplace, a simple solution would be to offer the same fixture with trim listings that are only air tight under a different model number even though the fixture would remain unchanged.

Do you agree?

Agreed.

That way if any of the listed trims are installed, the installed unit meets its listing and labeling.

And if any non-listed trim is installed, well, like any other listed equipment or appliance it now becomes "not listed" or more accurately "not installed in accordance with its listing and labeling" which then becomes a code violation.