Mike Silvers, CPRC, Silvers Systems Inc. and FRSA Director of Technical Services
The Florida Building Commission (FBC) met in December to consider the Technical Advisory Committees (TACs) recommendations for final changes to the 8th Edition 2023 Florida Building Code. The code modification cycle is a long and arduous process that started immediately after the 7th Edition 2020 Florida Building Code became effective on December 31, 2020. Two FBC workgroups and three meetings of the TACs – with many steps in between – had brought us to this point. With the TAC’s recommendations available, the Commission made its final decisions on what changes will occur when the new code takes effect on December 31, 2023.
For this code modification cycle, FRSA developed 29 code modifications (mods) and took positions on 87 roofing related mods submitted by other entities. Of the 29 FRSA mods, 28 were approved and will be incorporated into the code and one was denied due to a conflict with similar code language that was passed in May by the Legislature during a special session and is now in statute and the current code. This modification addressed a “25% Rule” exception that the Legislature liked and modified. While property insurers were due for some much needed relief, I believe the changes unfortunately went a little too far. Of the 87 modifications submitted by others that we took positions on, the TACs and Commissioners agreed with FRSA’s position on nearly all of them.
These extraordinary results may make FRSA’s accomplishments appear easily attained. That perception, however, would be completely inaccurate. We succeeded thanks to the extended efforts by a group of dedicated volunteers who work on FRSA’s Codes Committee and Subcommittee, the FRSA-TRI Tile Manual Review Committee and especially those who serve on TACs and the Building Commission. In particular, FBC Commissioner Brian Swope, CPRC, Tampa Roofing Company, Roofing TAC Chair and FRSA Past President, was instrumental in moving our positions forward.
Some industry members described a group of our most important changes as “ambitious” and that is a fair assessment. We were attempting to:
Clarify the current five-page underlayment requirements for roof coverings other than tile and incorporate them into the HVHZ,
2. Bring the code’s weak HVHZ prescriptive tile underlayment methods into ASCE 7 compliance and
3. Standardize underlayment test methods.
This certainly proved challenging. At the same time, we were trying to convince the Board and Code Administration Division of Miami-Dade County Department of Regulatory and Economic Resources that providing a proper load path for tile and using self-adhering underlayment applied direct-to-deck (SAU-DD) was not some kind of a scheme on our part. As hard as we tried to engage Miami-Dade officials over the past year, our concerns continued to be dismissed. Their opposition to our changes – changes that were embraced by the roofing industry – seemed untenable, if not completely unreasonable. From our perspective, nothing we sought to accomplish should have been controversial.
The first change in this group of mods was simplifying and condensing the steep slope underlayment requirements. The modifications to accomplish this were produced with the assistance and input of Greg Keeler, Owens Corning, and Eric Stafford, IBHS. It was approved
by the Commission as part of the Roofing TAC’s “consent agenda” of approved recommendations. The next modifications brought the Miami-Dade sections of the code for tile underlayment up to the standards available for use in 65 of 67 Florida counties; this included the option to use a SAU-DD. These modifications were approved individually by the Commission after a request by Miami-Dade to pull them from the consent agenda.
At this last stage in the process, we needed to reach a vote threshold of 75 percent in order to have any of our modifications approved by the Commission – a very high bar to overcome but one we were able to achieve throughout the afternoon thanks to a very accomplished
group of FRSA volunteers (pictured or mentioned on these pages) who testified before the Commission on behalf of our positions. We also want to thank Aaron Phillips, ARMA, Eric Stafford and Milad Shabanian, IBHS, Scott McAdam, BOAF, and Mike Shubert, Palm Beach
County, who all offered important support at the meeting.
Other significant code modifications submitted by FRSA that were approved include:
■ Adding a method to install a new roof covering over an existing SAU-DD for tile, similar to methods we added to other steep roof coverings during the last code cycle. This important change last cycle set the table for the adoption this cycle of SAU-DD in all of Florida.
■ Adding industry standards for tile underlayment test methods to the code statewide.
■ Changing the definition of roof covering system to the industry recognized roof system and clarifying that a roof system does not include the deck. The deck is already defined as part of the roof assembly.
■ Updating and getting the FRSA-TRI Florida High Wind Concrete and Clay Tile Installation Manual re-accepted as a code reference standard twice. Once for ASCE 7-16 and then again for the newly adopted ASCE 7-22.
■ Improving the wind performance of asphalt shingles by requiring drip edge to be installed over underlayment with cement under shingles unless an SAU is used over primed metal flanges.
■ Adding a requirement for clearance of lines, pipes, conduit and cables from the underside of the deck.
■ Replacing important repair language that was inadvertently removed when the FBC adopted new language during a reorganization of the repair chapter to align with the International Building Code.
■ Changing the language “replaced” to “replaced or recovered” to clarify portions of the 25% Rule. This eliminates an interpretation that you could not recover more than 25 percent of a roof.
■ Adding secondary water resistance requirements to all wood structures with steep roofs, not just single-family residential structures.
■ Adding to the minimum deck flange for drip edge in the HVHZ to resist rotational forces created by wind. When one considers the 28-1 record we achieved, the other beneficial industry mods we helped across the finish line with our support and our opposition to unhelpful
mods that were eliminated, it is clear that FRSA, the roofing industry and, thereby, Florida’s citizens all fared exceptionally well from our efforts during this code modification cycle.
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