WMA Regulatory Affairs Update – March 2026
- Jessica Ferris
- Mar 10
- 3 min read
FBC 9th Edition Update: Side-Hinged Exterior Doors Not Subject to Limited Water Testing Requirements | WMA Regulatory Affairs Update
On March 13, the Florida Building Commission met virtually for their Rule Development Workshop where a clarification was asked regarding whether Limited Water (LW) testing as specified in AAMA/WDMA/CSA 101/I.S.2/A440 is required for side-hinged exterior doors in the modified overhang exception language of the 9th Edition of the Florida Building Code
(FBC), which was approved by the Commission last December. The good news is, based on the clarification provided, this new requirement does not apply to side-hinged exterior doors based on existing language that controls side-hinged doors in the FBC.
Background:
As WMA reported back in December, the Commission approved three code modifications for inclusion in the 9th Edition of the FBC despite WMA’s strong opposition to these mods as it relates to side-hinged exterior doors.
The approved modifications add Limited Water (LW) testing requirements for “door assemblies” when the overhang exception is used. Identical language was added to three sections of the FBC:
FBC–Residential, Chapter 6, Section 609.3 (mod S12170)
FBC–Building, Chapter 17, Section 1709.5.1 (mod S12167)
FBC–Building, Chapter 24, Section 2411.3.2.1 (mod S12171)
On February 24, 2026, Florida’s Structural Technical Advisory Committee (TAC) met to review three public comments submitted as part of the rule development workshop process which takes place after a new edition of the code is approved. These comments raised a potential correlation issue between modifications S12167 and S12171 regarding whether LW testing should apply to side-hinged exterior doors.
All three comments were denied by the Structural TAC on the basis that they went beyond editorial or correlational corrections and would instead constitute substantive code changes. One comment argued that side-hinged doors should be subject to LW testing, while the other two asserted that side-hinged doors are exempt.
WMA Position
The key issue here is that FBC Section 1709.5.2, which covers side-hinged exterior doors as identified in Section 1709.5.1, does not reference LW testing in its overhang exception language; this section was never modified to include LW as the other overhang exception sections were.
In preparation for the March 13 workshop, WMA’s Regulatory Affairs and Standards Development Committee (RASDC) met by conference call on March 9 to review the discrepancies raised in the three public comments denied by the Structural TAC on Feb. 24. The RASDC concluded that the approved code language does not impact side-hinged exterior doors, as Section 1709.5.2 retains its original overhang exception language and applies to side-hinged exterior doors.
Outcome of the March 13 Rule Development Workshop
During the workshop, the Commission approved all public comments recommended by the various Technical Advisory Committees. Public comments denied by the TACs are not considered by the Commission unless specifically requested by the proponents, which did not occur in this case. As a result, the three public comments related to LW testing and side-hinged doors were not taken up by the Commission.
However, near the end of the meeting, a commenter asked for clarification on whether side-hinged exterior doors must test and label to AAMA/WDMA/CSA 101/I.S.2/A440 for Limited Water (LW) in order to use the overhang exception. Staff from the Florida Department of Business and Professional Regulation (DBPR) responded that the controlling section for side-hinged exterior doors is Section 1709.5.2, which does not include a LW testing requirement.
This clarification aligns with the conclusion reached by WMA’s RASDC and confirms that the Limited Water (LW) testing requirement does not apply to side-hinged exterior doors, preserving the longstanding overhang exception under Section 1709.5.2.
The 9th Edition of the Florida Building Code is scheduled to go into effect December 31, 2026.
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Contact:
Jessica Ferris
Director of Regulatory Affairs & Standards Development
