By Juken New Zealand Ltd (JNL) managing director Masa Ueki
You may have seen the recent media coverage regarding J-Frame. We are writing to provide information and reassurance to our customers in relation to this matter.
The Commerce Commission sent a compliance advice letter to JNL on June 9, 2017 (see sidebar story, opposite page). The Commission expressed its views on the interpretation of two standards, NZ 3640 and AS/NZS 1604.4, and how they apply to product labelling and promotional material for J-Frame.
After that letter was sent, a number of incorrect statements were issued by a competitor company.
Make no mistake, J-Frame is fit for purpose and meets the Building Code. This is confirmed by our CodeMark.
JNL’s certainty is based on a manufacturing process which includes the visual and ultrasonic grading of every veneer that goes into J-Frame, and Best Practice research by research institute Scion (Rotorua), and an ongoing independent audit of our manufacturing process by AsureQuality and the Engineered Wood Products Association of Australia.
The Commerce Commission’s investigation, which began in 2015, did not consider the performance of J-Frame. It was confined to product labelling and promotional material.
The Commission recognised that the standards regime in respect of LVL is complicated, and it acknowledged in its compliance advice letter that its view on interpretation is not universally held in the industry. JNL and BRANZ have also recognised this.
Given the standards are not clear, in June 2015, JNL decided to obtain CodeMark, an independent third party certification which is deemed to comply with the Building Code.
CodeMark confirmed what we have always known — that J-Frame is fit for purpose as a structural framing timber where Hl.2 is required.
The CodeMark is not affected by the Commission’s investigation and compliance letter.
We are disappointed by the unsubstantiated claims of the competitor company. Contrary to statements they made:
• J-Frame is labelled Hl.2 based on advice from the MBIE. Under its CodeMark, it is certified for use where Hl.2 applies.
• The compliance pathway is CodeMark which is the equivalent of an acceptable solution under the Building Act. Councils are required to accept the CodeMark as establishing compliance with the Building Code.
• Using J-Frame may require an onsite minor variation to a building consent if the building consent specifies solid timber rather than LVL. The Commerce Commission’s decision has not altered nor changed this position. Onsite minor variations between comparable products occur on all sites.
• J-Frame treatment is not simply envelope treated. It is treated with vacuum/pressure impregnation as defined by the Timber Preservation Association of Australia
(www.tpaa.com.au/timber-treatment). The boron is distributed throughout the sapwood in the interior and exterior veneers.
• JNL supports the supplementary protection of cut surface as Best Practice. However, the standards do not require this for hazard classes below H2. This applies to J-Frame LVL and solid timber framing.
• The competitive company has made an unsubstantiated complaint that the Scion research is based on samples that had been “specially treated to pass”. This is nonsense, and is readily disproved by the quality assurance testing regime in place at JNL’s treatment plant.
JNL has provided the results from nearly 3000 samples tested during its manufacturing process to the MBIE for comparison, and has no doubt that this complaint will be shown to be false.
JNL will continue to co-operate fully with the MBIE and assist in the development of standards. It is reviewing the Commerce Commission’s advice in relation to its promotion materials, and will keep the public informed via its web site.
However, that advice in no way changes J-Frame’s position as a premium product with a performance record that has made it a preferred solution in the New Zealand building industry.
The MBIE’s compliance advice letter
On June 9, 2017 the Commerce Commission issued a compliance advice letter regarding the labelling of J-Frame Laminated Veneer Lumber (LVL).
The Commerce Commission stated in that letter that J-Frame Laminated Veneer Lumber, manufactured by Juken New Zealand Limited (JNL):
• did not meet the requirements of NZS 3640,
• was incorrectly labelled as H1.2, and
• may not have complied with AS/NZS 1604.4 because it does not carry an “E” label signifying that it is an envelope treatment.
The Commission’s letter is about labelling, and makes no judgement about the durability and performance characteristics of Juken’s J-Frame product or whether it is fit for purpose.
This advice is intended to clarify the position of building consents involving J-Frame following the Commission’s compliance advice letter.
J-Frame has a BRANZ appraisal and a CodeMark certificate. These are unaffected by the Commerce Commission’s compliance advice letter.
This means that J-Frame is certified for use where the H1.2 hazard class applies. If J-Frame is specified in plans for a use in situations where the H1.2 hazard class applies, then a Building Consent Authority is obliged to accept this, on the basis of the product’s CodeMark certificate.
If consented plans specify “H1.2” and a Code Compliance Certificate has not yet been issued, then a minor variation to the consent will be needed if the builder uses (or proposes to use) J-Frame.
For further information, visit https://www.building.govt.nz/projects-and-consents/build-to-the-consent/making-changes-to-your-plans/minor-variations-guidance.