September, 2008
News in Brief
Inspection News and Views from the American Society of Home Inspectors

Safety Glazing – ICC Provides Interpretation for Cabinets and Leaded Glass


Submitted by Garet Denise, 2007 ASHI Technical Committee chair

An article in the June 2007 issue of the ASHI Reporter discussed cabinets, including issues related to glazing. One of our members questioned some of the statements in that article, particularly whether glass in cabinet doors needs safety glazing and whether decorative leaded glass assemblies need to have safety glazing.

Because I was the chair of the Technical Committee in 2007 when the committee reviewed this article, our editor passed the questions on to me.

Since the answers to these questions are based in the building code, I asked the International Code Council for an official interpretation. The ICC will only accept requests for interpretation from its members — it’s one of the benefits of ICC membership.

To be considered for interpretation, the issue must be phrased as a ‘yes or no’ question and must include a reference to the relevant section of the building code.
Separate issues must be submitted as multiple questions (one issue per question).

To provide background for this article, IRC R308.4 provides 11 definitions of various locations for which glazing is subject to human impact (and therefore needs safety glazing), followed by 10 exceptions to those definitions. It’s not possible to fully understand how these definitions and exceptions interact without reading all of them, and the full text of the code is too lengthy to repeat here. I encourage you to read the full text of IRC R308.4.
Items 1 and 7 of R308.4 define hazardous locations as follows:

“1. Glazing in swinging doors except jalousies.

7. Glazing in an individual fixed or operable panel, other than those locations described in Items 5 and 6 above, that meets all of the following conditions:

7.1. Exposed area of an individual pane larger than 9 square feet (0.836 m2).

7.2. Bottom edge less than 18 inches (457 mm) above the floor.

7.3. Top edge more than 36 inches (914 mm) above the floor.

7.4. One or more walking surfaces within 36 inches (914 mm) horizontally of the glazing.”

The questions I submitted and the ICC’s answers are as follows.

Question 1: “As defined in Section R308.4, Item 1 of the 2006 International Residential Code, are cabinet doors considered a hazardous location?”

“No. The doors referenced in Item 1 are intended for use by people. The provisions in Section 308.4 do not specifically address doors as a part of casework or millwork. However, glazing located in an operable panel (cabinet door) is subject to the provision of Item 7.”

Question 2: “As defined in Section R308.4, Exception 2 of the 2006 International Residential Code, is leaded glass considered decorative glass?”


In reading the second interpretation, it’s important to keep in mind that Exception 2 for decorative glass applies to some, but not all, of the definitions of hazardous locations. Some of the locations for which this exception does not apply include locations adjacent to stairs and locations adjacent to tubs, showers, swimming pools and similar features. Again, you’ll want to read the complete text of IRC R308.4 to fully understand these requirements.

Editor’s Note: We thank Garet Denise for his persistence in obtaining an answer for the member who posed the question. As illustrated by the detail of this advisory, home inspection-related articles published in the ASHI Reporter cannot serve as building code references. Even with the help of ICC, it would be difficult to apply these interpretations to the original article.

New guidelines provide steps to prevent suction entrapment

A recent ABC News investigation on pool drain safety was reported July 23rd on Good Morning America. This and reports of two near-drownings in the preceding 60 days — one in Florida, the other in California — demonstrate the need for prevention of suction entrapment accidents in pools and spas.

The Pool Safety Consortium wants everyone to be aware of the simple steps that can be taken to prevent these tragic accidents. Fortunately, the Consumer Products Safety Commission  (CPSC) recently issued safety guidelines that all public pools and spas must be compliant with by December 20th.  

Suction entrapment is a terrifying occurrence caused when part of a swimmer’s body, clothing or hair becomes suctioned to a pool or spa drain. Once a swimmer is attached, the suction force caused by the powerful water circulation system can be incredible — about 500 pounds of force for a standard pump. Therefore, it is nearly impossible for an adult to free an entrapped swimmer, and all too often serious permanent injury or death can occur. Sadly, children can be particularly susceptible to suction entrapment.

The new federal law requires that all public pools or spas with a single main drain — other than an unblockable drain — must be equipped with at least one layer of protection to prevent entrapment by pool or spa drains, such as: safety vacuum release systems (SVRS), suction-limiting vent systems, gravity drainage systems, automatic pump shut-off systems or drain disablement.  Some of these systems, particularly suction-limiting vent systems and gravity drainage systems, are only practical for new pool construction. Others, such as SVRS and automatic pump shut-off systems, can be installed on existing pools for a reasonable price.

In addition, the new federal law requires that all public pools and spas be outfitted with safety drain covers that have been tested by an independent third party and found to conform to the 2007 ASME/ANSI A112.19.8 performance standards.

“While the new guidelines are only mandated for public pools and spas, we hope that private pool and spa owners will also take these simple precautions.  The potential to prevent one suction entrapment accident is well worth the minimal investment in time and money,” said Paul Pennington, a founding member of The Pool Safety Consortium, a nonprofit organization based in Washington, D.C.

For more information, visit the CPSC Web site at and search for Virginia Graeme Baker Pool and Spa Safety Act, or visit