Role of Agencies in Shelter Quality Verification
Various agencies play a role in shelter quality. Yet none currently certifies shelters (see “Certification Misuse”) . The role and function of a number of agencies involved in the shelter industry is discussed in this section.
The Federal Emergency Management Agency (FEMA)
FEMA has produced performance criteria for storm shelters and published a couple of major publications on storm shelters. One is FEMA 320, Taking Shelter from the Storm: Building a Safe Room Inside Your House. The other is FEMA 361, Design and Construction Guidance for Community Shelters. These publications present performance criteria but are not consensus standards. FEMA criteria and publications are developed to guide the reliability of products including storm shelters. Units meeting such criteria can legitimately be advertised as meeting FEMA criteria. But questions arise as to who determines compliance and by what standard is compliance judged? The current available standard for storm shelters is ICC-500 the “ICC/NSSA Standard For The Design and Construction of Storm Shelters,” approved June 27, 2008 and published the same year to provide a means for determining quality and compliance with FEMA criteria. Verification of compliance with this Standard is a criterion for NSSA PRODUCER MEMBER status. Since few jurisdictions require verification, compliance is largely voluntary. ICC-500 is included in both the 2009 version of both the Internal Building Code (IBC) and the International International Residential Code (IRC).
Two primary performance requirements for storm shelters are (1) resistance to impact from wind-borne debris and (2) structural integrity to withstand wind induced pressures. The shelter designs presented in FEMA 320 were developed at Texas Tech University largely on the basis of resistance to debris impacts for which testing is required. Structural integrity can be reliably assured with analytical methods. FEMA 320 states on page 15 that “the connections between all parts of the shelter must be strong enough to resist failure, and the walls, roof and door must resist penetration by windborne missiles”. FEMA 361 has an entire chapter on the performance criteria for debris impact -Chapter 7. So debris impact testing is very fundamental to FEMA criteria.
Texas Tech University
For many years personnel at Texas Tech have tested shelters and components for debris impact resistance to develop the FEMA 320 designs and to assist manufacturers in developing reliable products. When tornadoes ravaged Oklahoma City in 1999 it triggered the first shelter incentive grant program. The ground rules were that shelters built from the prescriptive designs of FEMA 320 could be approved by the building inspector; those designs had been tested for debris impact and analyzed for structural integrity. Others had to be tested at Texas Tech for debris impact resistance and designs had to bear an engineer’s seal. Copies of designs and specifications were requested to establish a record of what was tested. The many quality issues that were observed led to the formation of NSSA.
Texas Tech continues to do debris impact testing for those requesting such services. But Texas Tech usually tests for debris impact resistance and static pressure only. It should not be implied that passing debris impact tests means meeting the many other performance criteria: that is the responsibility of NSSA-approved independent third-party engineering firm. Shelters bearing the NSSA seal have been tested and evaluated to be sure they comply with applicable standards.
The National Storm Shelter Association (NSSA)
In 2001, NSSA members wrote an industry standard to have criteria for admission to membership in the NSSA. Our rules say that the a shelter must be shown to meet debris impact criteria and that drawings and specifications for shelters must be submitted to a well qualified, NSSA-approved third party engineering company to assure compliance with all other aspects of the standard. Only after these requirements are met does the shelter producer join NSSA and earn the privilege of affixing a seal to the shelter. NSSA does not certify the shelter: the shelter producer certifies compliance with the standard. NSSA provides the procedure and process to validate the producer’s claim. So becoming a PRODUCER MEMBER of the NSSA gives validity to the claim by the shelter producer that a given shelter’s design and construction are in compliance with the Standard.
The presence of the seal distinguishes those shelters from all others whose compliance has not been verified. This is one of the major benefits of membership in NSSA. Other benefits include the satisfaction of knowing that you are producing a quality product and that you are supporting an organization fostering quality in the shelter industry. Should there ever be question of quality or litigation, the strongest argument the producer or installer can present is to be able to say that the product was built to comply with existing standards and our compliance was verified by a qualified, independent third-party engineering company. The presence of a storm shelter with a seal verifying standards compliance adds value to the house, initially and upon resale.
A strong industry organization is important to everyone involved in the industry. Those pioneers who have struggled to stay in business, producing quality-verified products, while at the same time spending an inordinate amount of time at their own expense to help write standards and promote the industry will be recorded by history as the heroes of the industry. Surely the public and everyone in the shelter industry is indebted to them.
Volume of sales, government procurement, or performance in low-intensity tornadoes or hurricanes do not imply quality or standards compliance. Although a justifiable source of pride to providers, the purchase of shelters by the Federal government cannot be regarded as validation of quality. What person involved with such procurement is capable of assessing quality of storm shelters or of verifying compliance with existing standards? It is good that numerous shelters met with success in the Moore OK tornado or in the 2004 hurricanes in Florida, but none was a design event. It should not be insinuated that the shelters without an NSSA seal are not of high quality, but rather that there is no indication that their quality has been verified by a qualified, independent engineering company. There would seem to be nothing to distinguish them from other shelters on the market claiming quality or certification whose quality has not been verified.
Standards and Codes
The National Storm Shelter Association Standard (NSSA) for the Design, Construction, and Performance of Storm Shelters, an industry standard first published in 2001, was the first standard available for storm shelters. Promising to produce only those shelters that comply with this standard and then having compliance verified by a third-party engineering company are prerequisites for PRODUCER MEMBER status in the NSSA. The NSSA Standard served as a basis for the ICC-500, International Code Council/National Storm Shelter Association (ICC/NSSA) Standard for the Design and Construction of Storm Shelters, published in late 2008. It was accredited by the American National Standards Institute. It is published by ICC and offered to building code jurisdictions. Upon adoption of the standard, compliance is mandatory, not voluntary. It will be up to the jurisdiction as to who verifies compliance with the standard. NSSA membership proves valuable because members have become familiar with the standard, have verified their compliance with it, and have built an image and reputation of producing quality shelters.
The PRODUCER MEMBER typically assumes total responsibility for the quality of the product, including installation. The NSSA Board of Directors approved another grade of membership – an Installer Member – where both the producer and the installer install seals, thus distinguishing the separate responsibilities for producing the shelter and installing it. The installer member is allowed to install only those shelters that have been verified to meet the Standard.
NSSA members would appreciate the opportunity to visit with those interested in participating in NSSA in any capacity. Information may be obtained by contacting [email protected] or calling 1-877-700-NSSACall: 1-877-700-NSSA (6772). Contact information for members may be obtained from the Producer Member Roster section of the NSSA web pages at www.nssa.cc.