Robin Jade Conde

PODCAST: Hazardous Locations for Glass

In today’s show, Tessa, Bill, and Reuben talk about the hazardous locations for glass windows. 

Reuben shares the hazardous places to install glass and discusses the use of tempered glass and safety film for glass. Bill confirms that using safety films is more cost-effective than replacing broken windows and sash. Tessa agrees that commercial establishments and other high-traffic areas should use tempered and safety glass. 

Reuben talks about the 4 criteria that must be observed in the installation. He mentions R308.4 of the International Residential Code includes the locations where safety glazing is necessary. They also talk about using glass windows in stairwells, patio doors, showers, and bathtub areas.

Tessa shares that home inspectors are not code officials. They highlight that these recommendations in inspection reports are not defects but optional safety upgrades.



The following is a transcription from an audio recording. Although the transcription is largely accurate, in some cases it may be slightly incomplete or contain minor inaccuracies due to inaudible passages or transcription errors.


Bill Oelrich: So Reuben, I wanted to put you on the hot seat today and help educate the greater public where we need to be concerned about windows from a safety perspective. Welcome everyone. You’re listening to Structure Talk a Structure Tech presentation. My name is Bill Oelrich, alongside Tessa Murry and Reuben Saltzman as always, your three-legged stool, coming to you from the Northland, talking all things houses, home inspections and anything else that’s rattling around in our brain. On today’s episode, we’re gonna dig in a Reuben’s brain about windows safety. And here’s where this came from, I was binging on The Maid recently. Now, this is a Netflix series which I find…


Reuben Saltzman: Wait, you said, hold on, Bill. The Maid? 


BO: The Maid, yes.


RS: Okay. Alright. I haven’t heard it, but thank you. Okay.


BO: My wife is completely into it, so we kind of did this together our little downtime while our daughter is out at theater class or whatever she’s got going on. So we’re watching The Maid and there’s a point kind of later in the series where the mom gets into this really manic episode, and she goes to break into a house that’s hers, and she punches her hand through a window and it just destroys her like arm, it’s a very gruesome scene. And I was starting to think that would have been helpful to have some tempered glass in that pane of window that she just put her hand through, so I know there’s guidance around windows safety and glass safety and all these sorts of things. So Reuben, I wanted to put you on the hot seat today and help educate the greater public where we need to be concerned about windows from a safety perspective. How does the general public prevent a grand kid or a dog or somebody going through a piece of glass that’s gonna hurt them in a big time way.


RS: I had my own experience with this. And now that I’m talking about it, I feel like I got deja vu. I wonder if we talked about this in a previous podcast, maybe years ago, but I had my own experience as a kid. I was running and I fell into a storm door and the glass was not tempered glass or safety glass, and this huge shard of glass went into my arm, and I probably should have got stitches. It was like we had to pull it out. And, yeah, it was nasty and I should have had stitches, but my mom was a nurse, and so if you’re a kids… If you’re the kid of a nurse, you don’t get stitches or go to the hospital for anything, you get a butterfly bandage.




BO: It’s funny.


RS: Yeah, so it healed just fine. But today, you wouldn’t have that anymore. Today, that would be considered a hazardous location for glass, and that’s the way our safety codes are written. As they say, when you’ve got a location where it’s a hazardous location to have glass, then you need to do something special with it. And typically, it means it’s gonna have to be tempered and doors would be one of those locations. And just so everybody understands, tempered glass means that if it breaks, it’s gonna break into a million little pieces. It’s not gonna be these big shards, it’s gonna…


RS: Well, it’s exactly what I said a million little pieces. And it’s funny, I’m thinking about this now, I’m gonna have to put this picture in our show notes, I might even share it on our Facebook page for Structure Tech. I was at a grocery store down in Florida, and one of the sliding doors, they got those automatic sliding doors that go open and shut constantly. Huge pane of glass on one of those doors have the spider web cracking going out from it. And I just kinda looked at it and then I did a double take and I just went, wait a minute, that ain’t right. Because if it’s tempered glass it’s not going to spider web, it’s gonna shatter into a million pieces. You’re not gonna have these big long crack. And I just thought to myself, “How in the world does this happen?”


Tessa Murry: How did they get away with that? Yeah.


RS: Yeah, well, you’ve got a commercial building, you’ve got a door, and it’s not tempered glass. I know about residential code requirements, I don’t know a whole lot about commercial establishments, but come on, help me out. Tessa, Bill, how could this happen? 


TM: Especially in a high traffic area like that, it’s really dangerous. Wow.


BO: Well, I think…


TM: It’s Florida so who knows [chuckle]? 


BO: I think upon further evaluation you’re probably going to find a very thick film on top of that glass. So even if it’s spider webbed out the way you saw it, it was contained by some other substance. And maybe it was just the fact that they couldn’t make the door, the size that glass was, maybe it couldn’t be constructed of tempered glass and they had to go some other angle. Something tells me that wasn’t wrong, ones and zeros in your mind as it relates to safety glass didn’t connect and you didn’t see.


RS: That’s really good Bill. I bet you’re right. That makes a lot more sense. ‘Cause there’s a blog post I did and I did a video on it too. Dustin helped me with this back when he was on the team, and we did one on safety film. I had bought the safety film and we put it on some windows just to see how it reacts, and it’s something that people can retroactively do. If you’ve got an old house and you’ve got windows and what’s considered now a hazardous location for glass, you could apply this film on your glass and give it about the same level of safety, and we did a bunch of testing where we were smashing it and dropping rocks on it and see how it holds together. And it worked really well.


RS: I got a bunch of old window panes and we drop stuff on there and eventually to get it to get it to really knock out of the glass, we had to drop something so heavy that it busted the whole piece of glass out of the frame, but it still held all the glass together, so yeah, I’d bet you’re right Bill. It must have been a film.


TM: Do you think that’s cheaper than replacing the glass itself, Reuben been doing that film? 


RS: Yeah, for sure. The film itself cost next to nothing, it’s the labor putting it on where all the cost is, ’cause Dustin and I did it and oh my goodness, how aggravating that was trying to get all the air bubbles out and get it cut to size, so it doesn’t look like you’ve got film on your window, I mean, that was a pain in the butt and professionals, they do charge a fair amount of money to get this done, but still it’s a fraction of the cost of replacing the actual glass.


TM: It feels like something kind of trying to put a screen protector on your phone, and I feel like I can never do that without getting chunks of glints still under there and you take that times a 100 and it’s almost impossible, I would think.


RS: That is a perfect analogy. Tessa Yes.


BO: So Reuben, I’m gonna ask you all the places where you need safety glass and why. So I’m gonna prep you for that. But this window film business, the only reason I know anything about it is because we put an egress window in our basement, and I went through all the proper channels, got all the permits, thought everything was cool, and the inspector was coming out to final the permit and he looked at the window and he said, “This isn’t tempered glass.” And I said, “Well, how can that… I don’t know what to tell you.” And he said, “This needs to be tempered glass,” and I asked him, “Well, what other options do I have?” And he said, “Well, sometimes you can put film on it, but it’s gotta be a certain thickness and… ” he gave me some laundry list of things.


BO: Well, now my window downstairs has film on it, and he actually did come back and make sure I put it on and inspected the material, it was interesting to say the least, but… So I know this stuff exists and Tessa to answer your question, which is less expensive film or I’m just replacing the sash, it’s film, I can’t tell you as a percentage, but it was film, so I went with film instead of putting a brand new sash in a brand new window.


TM: So I’m sure Reuben’s gonna get to this, but it must have been that that window was too close to the ground or something that it needed to be tempered. Do you remember what the reason was for that? 


BO: I’ll explain the location of it once Reuben can [chuckle]


RS: Okay well…


TM: Through the checklist.


RS: I think it would be a complete snooze fest if I went through the entire checklist. What I’m gonna do is I’m just gonna share kind of some of the most common things that we come across as home inspectors. Generally if you’ve got window inside of a bath tub area or really close to a bathtub, or someone could slip and go through, that would be considered a hazardous location. If you’ve got a window that meets all four of these requirements I’m about to list. And this is a critical part here is that it meets all four. So often, you get some old school home inspector saying, “Well, it’s too close to the ground it needs to be tempered.” No, no, no, no, no. It’s all four. If a window is within 18 inches of the ground, the bottom edge is within 18 inches of the ground, and the top edge is more than three feet off the ground, I’ll let you think that through, top edges more than three feet and the total glazed area, that chunk of glass, is more than nine square feet, we’re talking three foot by three foot.


TM: That’s a big window.


RS: A big big piece of glass. And now, this is an easy one, almost all windows have this and you gotta walk in surface within three feet of it, if it meets all four of these, then it’s considered hazardous location, but if one of those is missing… If the bottom edge is 19 inches above the ground, doesn’t matter if it’s 10 square feet of glass, it’s not considered a hazardous location. So that’s one that a lot of home inspectors and other professionals get tripped up on, and so I wanted to clarify that. But I mean, as far as all the rest of the requirements, Bill, I’ve got this book in my hand, it’s called Code Check, we love code check, put out by Skip Walker past guest on our show, Douglas Hansen, he needs to be a guest on our podcast.


BO: Yeah.


RS: I gotta get Douglas Hansen on this podcast. We will get him on the podcast now that we’re thinking about it. But they’ve got these series of books to help build in officials and home and inspection type people like us, get quick answers. Just stop. So I pulled out my flip chart here and I turned over to the section on safety glazing, and I’m holding it up for Bill and Tessa, it’s like…


RS: It is like a full page where it lists all the places where you need to have safety glazing. There’s a ton of hazardous locations, so we won’t bore anybody by listing them all. I’ll tell you, if you wanna figure it all out, you go to chapter three in the IRC, The International Residential Code, you turn to section A so it’s section 308.1 through four basically lists a ton of the locations. So that’s where you could go if you wanna read about it, but I’m not gonna put anybody to sleep today.


BO: I do have a question about walking surface isn’t any floor a walking surface? 


RS: I would say so. Yup.


BO: Okay, so then any window that’s closer to the floor than 18 inches begins this conversation? 


RS: Right.


BO: And if it’s higher than 18 inches, we don’t have a conversation? 


RS: That’s right yeah, but there’s all kinds of stuff that might trigger this, any wet areas, if it’s in a stairwell that’s considered a hazardous location, lots of other reasons for something to be hazardous.


BO: Okay, well, talk about the stairwell. Does the stairwell need that 18-inch to the floor criteria thing, or is that just a stand-alone…


RS: Yeah, we don’t even need to worry about any of that if it’s a stairwell. It’s basically like if it’s a stairwell, then that’s a hazardous location. Unless the glass, and I gotta find it where it says it on the sheet here, but going by memory, I think it’s a master glass is more than 60 inches above your walk-in surface. Once you’re more than five feet up, they say it’s okay to be in a stairwell without having it tempered. But less than five feet, that’s hazardous.


BO: Okay, now you’re peaking my interest. What’s a stairwell? 


RS: I don’t know, a stairway. It’s the enclosure for a stairway.


BO: Okay, you’re using specific words there, and this relates to me, and this is why I’m gonna keep pushing on this, so it’s an enclosure? Is this a landing where a step makes it like a 900 degree or 180 degrees or is it just where a stairway pores into a room? 


RS: Let me read what this says. It says, “If you have glass that’s less than 60 inches,” well, actually it says glazing, “glazing less than 60 inches horizontally from the bottom stair landing measured in a 180-degree arc from the lowest tread nosing and 36 inches above the landing” with some exceptions that we’re not getting into. So Bill, I don’t know what that means.


BO: Here’s what I got caught up in the mix, ’cause my window, our egress window, is that the base of our stairs, but it goes down and it’s on the wall where their handrail is, right? So the handrail goes down, the landing, the floor, the basement floor. And then there’s my window on the left side of you as you’re walking down. Like for me to go through that window, falling down my stairs, I would have to bounce off the basement floor, go up 38 or 42 inches with enough force to then break through the glass and fall out into my window wall, which is also…


RS: So, is this within three feet of the stairway of the steps? 


BO: Yeah, it is, it is. Yes.


RS: Well, I can’t… Alright, well, it’s considered a hazardous location, I can’t explain to you exactly how this fall is supposed to happen.


BO: I know. I need to get way more muscular than I am and have more tension in my body to be able to jolt up like that, but when I was talking with the inspector, he was kind of like, “Hey dude, this is my job. I noticed this, I gotta say something, I can’t just walk away.” I’m like, “Fine”. But it’s just, it’s ridiculous on the face that that’s a dangerous location, I mean…


RS: Objection noted.




BO: Okay, thank you. And I will say that the inspector who came to my house was a perfectly pleasant person. It wasn’t like he was trying to wheel the long arm of the laws so to speak. He just was like, “Call me when you do the film thing, I’ll come back and sign off on it.” I’m like, “Okay, sounds good.” But okay, patio doors. Is every single patio door tempered? 


RS: They should be. I assume that they always are. For the first, I don’t know, five, six, seven years of my home inspection career, I was very diligent about looking in the corners of the glass on every one of these doors because some instructor at some course told me that this is what I need to do as a home inspector, and after looking at, I don’t know, maybe a 1000 of them and not seen one that didn’t have it, I kinda quit looking for it. I just went, “What am I spending my time doing? I’ve got bigger fish to fry.” So as far as I know, all of them are tempered.


BO: And the most common spot, Tessa, you find these objectionable windows. What would you say? 


TM: Well, I think it depends on the age of the house, obviously, like I was just thinking, when we’re talking about windows and stairways, like an image of a house built in 1900 or 1920 comes to mind where they always have windows at the top of the landing, and windows along the stairway, and a lot of times too, there’ll be a window in a shower or above a bathtub enclosure in a house that age. And I have run across some old French doors in houses that are like 1920s that have glass that doesn’t appear to be tempered that are original French doors and storm doors and stuff. But you know, I’d say newer houses, I pretty much just kind of rely on the fact that builders are hopefully installing the correct kind of glass, and like Reuben said, I’m not checking every single little corner for the little sticker on every potential location where it should be, maybe I should be doing that, but I just kind of assume that they’ve installed it correctly.


BO: I think Reuben has already said now, don’t spend your time on that. [laughter]


RS: Yeah, it’s not on the doors. Now, one that we find wrong a lot of the time though, is in shower areas and bathrooms and those enclosures. A lot of the time we do find those wrong. That’s one I do always look for.


TM: Yeah.


BO: That’s wrong because there’s a window inside your shower, okay? [chuckle] I’m not… I hope, I don’t hurt anybody’s feelings, but can you think about a worse place to put a window? 


RS: No, Bill, no, I cannot but and I’m really not so much thinking about a shower, but I’m thinking about bathtub areas where you’ve got a bathtub and you’ve got a window above that.


BO: Well, I think what you just touched on, Reuben, is that they all started as bathtub areas and then as time, those are all old houses, and then as our lives became more modern and people added showers, they were just, “Well, we’ll build this around here and make it nice and watertight, we’ll put a shower curtain over this hole in your wall and that should keep all the water out,” right? 


RS: Right. Yes.


BO: There’s not many places that you have to be concerned about, so my whole thought process of pounding your hand through a window to unlock the house that you used to own but is now occupied by somebody else, that’s a pretty low level of concern for a home inspector. You’re not gonna look at those windows.


TM: Yeah, well, and also, I was just gonna add to… We’re home inspectors we’re not code officials, and so when we’re going through a house that’s built in 1920, and we find this untempered glass in these hazardous locations, we’re putting it in our report because it’s a potential safety issue, and so we make a recommendation to replace the glass with something that’s tempered or install this protective film, but it’s just a recommendation and it’s really a recommendation for an upgrade.


RS: Yes.


TM: It’s not ever anything that has to be done.


RS: Yes, that is so well put, Tessa. It’s not a defect.


TM: Right.


RS: This is a safety upgrade that you may want to do at your house, let people know what the risk is, and we’re not there telling them, “Hey, look, you have to do this.” It’s like, “Hey, here’s the risk. You fall through it, it’s gonna be a bigger injury, if you wanna make it a little safer, you could do this,” but it’s not like we’re coming down with the code book saying, “Look, here it says in IRC, blah, blah, blah for a new house, and now you must upgrade due to your 100-year-old house.” It’s like…


TM: Right, right.


RS: No, put this stuff in context, make people understand what’s really happening here.


TM: Yeah, wouldn’t that be a nightmare if you had to take a 1920 house and make everything up to code? Think about the stairway heights and clearances and outlet locations and GFC… All that stuff that you would have to rip out and redo. It’s ridiculous.


RS: Oh, I couldn’t imagine, couldn’t imagine.


BO: Well, as an owner of an old house, I think they just let you out of the hook. I mean, until you open up certain walls or you do certain construction, then they need you to do it, but… Reuben, you used to do time of sale inspections, TSIs in the big cities here. Is there any requirement for reporting on these glass in dangerous locations inside of a time of sale home inspection or time of sale inspection? 


RS: Bill, I have not done a truth in housing evaluation for so many years now. I’m still licensed in Minneapolis in St. Paul I’ll have you know though, but I’ve never…


TM: Does that license ever expire? How long is it good for? 


RS: No, it expires every year and I keep renewing it.


TM: Oh.


RS: I’m paying insurance for it, and I’m renewing my license. I don’t know why, Tess, I ought to just quit.


TM: Well, it’s not an easy license to acquire, if I recall.


RS: That’s why. Yeah, it was such a pain in the butt.


TM: Yes, yeah.


RS: But whom I’m kidding. When am I ever gonna go back out and do that again? Sorry, I’m getting side-tracked, Bill. I don’t know, that was like a long-winded answer saying, I don’t know, I don’t remember there ever being anything about it, I’m sure there’s nothing about it in any TISH guidelines, I’m sure of it, Bill.


BO: Okay, alright, well, some of this glass at the bottom of steps would probably be useful to know about, but again, it would be a burden to fix any of that. To fix it right would probably be really expensive, and then who’s gonna do it and how soon that couldn’t be a required repair, it would just be a nightmare for the city to have to manage. Okay, so there’s nothing to worry about if you… All you gotta know is 18 inches. It starts… It always starts from the floor, right? 18, 36, 9 squared feet and walking surface.


RS: You got it Bill.


BO: I passed the test.


RS: Yeah, well done.


BO: Awesome. Alright, I do pay attention. I do pay attention.


RS: You’re good, you’re good. [chuckle] You’ve got good retention.


BO: Yeah, alright, well, I think that’s gonna put a bow on this one, so thank you everybody for listening. You’ve been listening to Structure Talk, a Structure Tech presentation. My name is Bill Oelrich alongside Tessa Murray and Reuben Saltzman. We appreciate you. Any time you need window safety information, please check out Reuben’s blog.