Mike Silvers, CPRC, Owner, Silvers Systems Inc. and FRSA Director of Technical Services
A contractor contacted me a few weeks ago hoping to get some help with a problem they had encountered. During a reroofing operation, they had penetrated a water line causing damage to the interior of the building and its contents. The damaged water line was located just under the deck. Certainly, there must be some type of minimum clearance that the line should have had below the deck. After all, it’s common knowledge that most mechanically attached (nailed or screwed) roof coverings or systems must penetrate the deck, so why would this line be allowed to be located there? I had to share some bad news pertaining to his immediate problem, but also some good news that will apply in the future.
The code definitely addresses the location and clearances for lines, pipes, conduit and cables in several of the different subcodes and in code references. Examples are shown below. Notice the addition of underscores to demonstrate the many locations in
the building that are addressed and the different types of equipment that are specifically covered and methods used to protect them. But the bad news, at least currently, is that the word “roof” doesn’t appear anywhere.
2023 Florida Building Code – Plumbing
8th Edition
CHAPTER 3 GENERAL REGULATIONS
SECTION 305 PROTECTION OF PIPES AND
PLUMBING SYSTEM COMPONENTS
305.6 Protection against physical damage.
In concealed locations where piping, other than cast-iron or galvanized steel, is installed through holes or notches in studs, joists, rafters or similar members less than 1-1/4 inches (32 mm) from the nearest edge of the member, the pipe shall be protected by steel shield plates. Such shield plates shall have a thickness of not less than 0.0575 inch (1.463 mm) (No. 16 gage). Such plates shall cover the area of the pipe where the member is notched or bored and shall extend not less than 2 inches (51 mm) above sole plates and below top plates.
Note: The 1-1/4-inch dimension was changed from 1-1/2 inches in the 2020 Florida Building Code – Plumbing 7th Edition and was carried over to the 8th Edition.
SECTION 308 (IFGS) CLEARANCE REDUCTION 308.1 Scope.
This section shall govern the reduction in required clearances to combustible materials, including gypsum board, and combustible assemblies for chimneys, vents, appliances, devices and equipment. Clearance requirements for air-conditioning equipment and central heating boilers and furnaces shall comply with Sections 308.3 and 308.4.
SECTION 404 (IFGC) PIPING SYSTEM INSTALLATION
404.4 Piping in solid partitions and walls.
Concealed piping shall not be located in solid partitions and solid walls, unless installed in a chase or casing.
404.7.1 Piping through holes or notches.
Where piping is installed through holes or notches in framing members and the piping is located less than 1-1/2 inches (38 mm) from the framing member face to which wall, ceiling or floor membranes will be attached, the pipe shall be protected by shield plates that cover the width of the pipe and the framing member and that extend not less than 4 inches (102 mm) to
each side of the framing member. Where the framing member that the piping passes through is a bottom plate, bottom track, top plate or top track, the shield plates shall cover the framing member and extend not less than 4 inches (102 mm) above the bottom framing member and not less than 4 inches (102 mm) below the top framing member.
404.7.2 Piping installed in other locations.
Where the piping is located within a framing member and is less than 1-1/2 inches (38 mm) from the framing member face to which wall, ceiling or floor membranes will be attached, the piping shall be protected by shield plates that cover the width and length of the piping. Where the piping is located outside of a framing member and is located less than 1-1/2 inches (38 mm) from the nearest edge of the face of the framing member to which the membrane will be attached, the piping shall be protected by shield plates that cover the width and length of the piping.
404.7.3 Shield plates.
Shield plates shall be of steel material having a thickness of not less than 0.0575 inch (1.463 mm) (No. 16 gage).
2023 Florida Building Code, Mechanical 8th Edition
CHAPTER 3 GENERAL REGULATIONS SECTION 305 PIPING SUPPORT
305.5 Protection against physical damage.
In concealed locations where piping, other than cast-iron or steel, is installed through holes or notches in studs, joists, rafters, or similar members less than 1-1/2 inches (38 mm) from the nearest edge of the member, the pipe shall be protected by shield plates. Protective steel shield plates having a minimum thickness of 0.0575 inch (1.463 mm) (No. 16 gage) shall cover the area of the pipe where the member is notched or bored and shall extend not less than 2 inches (51 mm) above sole plates and below top plates.
National Electrical Code (NEC)
Protection Against Physical Damage, NEC 300-4 NEC Article 300.4, sub-section D – Cables and Raceways Parallel to Framing Members.
In both exposed and concealed locations, where a cable-or raceway-type wiring method is installed parallel to framing members, such as joists, rafters, or studs, the cable or raceway shall be installed and supported so that the nearest outside surface of the cable or raceway is not less than 1-1/4 inches (31.8 mm) from the nearest edge of the framing member where nails or screws are likely to penetrate. Where this distance cannot be maintained, the cable or raceway shall be protected from penetration by nails or screws by a steel plate, sleeve, or equivalent at least 1/16 inches
(1.59 mm) thick.
As shown in the previous excerpts, the code clearly demonstrates concerns for the locations and clearances of lines, pipes, conduit and cables, all meant to reduce the possibility of them being damaged. It addresses locations that have a lower likelihood of being damaged compared to roofs that are roofed and then reroofed many times during the building’s life, each
time exposing mislocated items to potential damage. Unfortunately, this lack of consideration for such an important part of a building – the roof – is nothing new. Addressing these and other similar long-standing roofing-related oversights is just one reason it is so important that FRSA, along with our industry allies, stay involved in the codes arena. We need to continue to
make important changes to correct these oversights. Which brings me to the good news.
During the development of the 7th Edition Florida Building Code (2020), the Florida Roof Deck Association submitted a code modification to add new language to Section 1510 of the FBC Building titled “Cable and raceway-type wiring methods” that
is shown below. It deals primarily with prohibiting the installation of wiring between a metal deck and the roof covering. This installation method has been used in many instances within a Lightweight Insulating Concrete (LWIC) pour. This practice definitely has safety implications when using a roof cutter or when installing fasteners on that type of deck where concealed
wiring exists between the structural portion of the deck – steel or concrete – and the poured deck’s surface. The modification was accepted in the 2020 code and is included below as it appears in the 2023 code.
2023 Florida Building Code 8th Edition
CHAPTER 15 ROOF ASSEMBLIES AND ROOFTOP STRUCTURES SECTION 1510 ROOFTOP STRUCTURES 1510.11
Cable and raceway-type wiring methods. Cable- and raceway-type wiring methods installed on rooftops and not encased in structural concrete shall be supported above the roof system and covering. Cable- and raceway-type wiring methods installed in
locations under metal-corrugated sheet roof decking shall be supported so there is not less than 38 mm (1-1/2 in.) measured from the lowest surface of the roof decking to the top of the cable or raceway. A cable or raceway shall not be installed in concealed locations in metal-corrugated sheet decking–type roof. This change was strongly supported by FRSA and opened the door for us to request a modification for the 2023 code. During the latest code development cycle, FRSA submitted a modification (shown below) that was approved. It establishes a required clearance of 1-1/2 inches below the deck in almost all situations.
1510.12 Lines, pipes, conduit and cables under roof decks
Lines, pipes, conduit and cables installed below the roof deck shall have a minimum clearance of 1-1/2 inches from the lowest surface of the roof deck except where they penetrate the roof deck.
Exclusion: Lines, pipes, conduit and cables installed under structural concrete decks.
This new FRSA language establishes a foothold to include similar requirements in the other code sections (previously shown), where it has been overlooked in the past. This change will not eliminate these conditions where they currently exist, but it does help by establishing that some expectation of clearance is reasonable. It will apply to new construction and alterations including the installation of any new line, pipe, conduit and cable runs. The code increasingly requires fire sprinkler systems. These systems present a large potential for water damage – not only where the cause of activating the system occurs but throughout
the entire zone, such as an entire condo wing or floor. There are other similar issues that our Codes Committees should discuss for possible modification proposals. They include the far from clear sections in the code that address clearance, routing and protection of lines, pipes, conduit and cables above the roof. Roof mounted solar panels and modules and the related wiring in both residential and commercial applications are becoming more common. The issues encountered due to the proliferation of mechanical units and equipment on low-slope commercial and multi-family roofs are being further complicated by cellular communication equipment installations. If our industry and FRSA do not address these issues, they will continue to be overlooked.
Mike Silvers, CPRC is owner of Silvers 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 50 years of industry knowledge and experience to FRSA’s team.
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