Mike Silvers, CPRC, Silvers Systems Inc. and FRSA Director of Technical Services
Obtaining permits for reroofing projects seems to become more complicated every day. This is happening despite the fact that most
building departments are making a sincere effort to expedite their processes.
One issue that continues to cause confusion and thereby delays in obtaining permits deals with the hurricane mitigation roof-to-wall connection requirements of the code. The Florida Building Code (FBC) 6th Edition (2017) – Existing Building, Chapter 7 Alterations – Level 1, Section 706 Existing Roofing, 706.7 Mitigation, and specifically 706.8 state the following (underlining and bolding for emphasis):
706.8 When a roof covering on an existing site-built single-family residential structure is removed and replaced on a building that is located in the wind-borne debris region as defined in the Florida Building Code, Building and that has an insured value of $300,000 or more or, if the building is uninsured or for which documentation of insured value is not presented, has a just valuation for the structure for purposes of ad valorem taxation of $300,000 or more:
(a)Roof to wall connections shall be improved as required by Section 706.8.1.
(b)Mandated retrofits of the roof-to-wall connection shall not be required beyond a 15 percent increase in the cost of reroofing.
Exception: Single-family residential structures permitted subject to the Florida Building Code are not required to comply with this section.
706.8.1 Roof-to-wall connections for site-built single-family residential structures.
Where required by Section 706.8, the intersection of roof framing with the wall below shall provide sufficient resistance to meet the uplift loads specified in Table 706.8.1 either because of existing conditions or through retrofit measures. As an alternative to an
engineered design, the prescriptive retrofit solutions provided in Sections 706.8.1.1 through 706.8.1.7 shall be accepted as meeting the mandated roof-to-wall retrofit requirements.
Exceptions:
1. Where it can be demonstrated (by code adoption date documentation and permit issuance date) that roof-to-wall connections and/or roof-to-foundation continuous load path requirements were required at the time of original construction.
2. Roof-to-wall connections shall not be required unless evaluation and installation of connections at gable ends or all corners can be completed for 15 percent of the cost of roof replacement.
TABLE 706.8.1 (Table omitted for brevity)
706.8.1.1 Access for retrofitting roof to wall connections.
These provisions are not intended to limit the means for gaining access to the structural elements of the roof and wall for the purposes of retrofitting the connection. The retrofit of roof-to-wall connections can be made by access through the area under the eave, from above through the roof, or from the interior of the house. Methods for above access include removal of roof panels or sections thereof or removal of portions of roof paneling at selected locations large enough for access, viewing, and installing the retrofit connectors and fasteners.
Where panels or sections are removed, the removed portions shall not be reused. New paneling shall be used and fastened as in new construction.
The sections shown above certainly imply that unless certain roof-to-wall retrofits can be completed for 15 percent of the cost of roof replacement they shall not be required. If the work is not required then it is clearly up to the owner of the building if they chose to have the work done or not. If the owner is provided with a proposal that includes a clear scope of the work that in the opinion of the contractor, is needed to retrofit the roof-to-wall connections or for that matter, the cost of gaining access to the structural elements,
and the cost of that work exceeds 15 percent of the cost of roof replacement, then it should be up to the owner whether they proceed with the scope of the work, any additional work or requesting estimates for additional work.
All the mitigation work in this section is triggered when the roof covering is removed and replaced. A licensed roofing contractor is the only category in FS 489 that can remove and replace roof coverings. Since a roofing contractor is required to permit the work that triggers any additional work, they become the prime contractor unless the owner and the roofing contractor agree otherwise. A roofing contractor can make the decision on how the access to the structural elements is to be provided. To many it seems reasonable that since roofing work is the trigger, it could be assumed that access should be provided through the roof panels.
The cost to provide access can include demobilization after roof removal and dry-in, procuring engineering services, opening the roof covering and roof panels as needed for an engineer’s inspection in as many roof areas as the engineer chooses, temporarily replacing the panels and dry-in, procuring a residential, building or general contractor (GC) to do the connection work, opening the roof covering and roof panels for the GC’s work, replacing the roof panels and dry-in and remobilizing to complete the roof covering. During the progress of the work the roofing contractor may be responsible for maintaining the weather protection of the work and the associated liability that goes with it. If the roofing contractor chooses, he may also include the cost for the engineering and GC’s work as long as the roofing contractor subcontracts with a properly licensed professional if the owner decides to proceed with the roof-to-wall connection work. All additional work should be subject to mark up, overhead and profit. If any portion of this work exceeds 15 percent of the cost of the roof replacement, then it should clearly be the owners call on whether to proceed or not. All that should be needed to accept or decline is a clear scope of work to be done and an estimate showing the cost of that scope.
We recommend that hurricane mitigation retrofitting be strongly considered if the owner has the ability to afford it. But it seems clear that delaying needed roof replacement or by choosing a roof recover (that won’t provide the very important deck re-nailing or secondary water barrier that is mandatory with replacement) due to the cost of more extensive mitigation, was not the intent of these requirements.
If you have been denied a permit or are encountering delays due to this issue discuss it with your local Building Official. If I can be of service on this or other technical matters please contact me.
This opinion is only advisory, as the final decision is the responsibility of the designated authority charged with the administration and enforcement of this code.
Mike Silvers, CPRC, is owner of Silver Systems Inc., and is consulting with FRSA as Director of Technical Services. Mike is an FRSA Past President, Life Member, and Campanella Award recipient and brings over 40 years of industry knowledge and experience to FRSA’s team
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