First off I would like to say I have never seen the complete misinterpretation, false application, and blatant disregard for the proper use and understanding of code by so called “experts” like I have seen on this forum. At times, it is so illiterate, it almost seems Machiavellian. This is what frustrates me, that and being lumped into a category of individuals that I consider unwilling or even unconcerned enough to rise to the top of their profession. As Home Inspectors, we are on the same team.
Mr. Shishilla. Not to worry, you can still be “the man” on the forum as after this I am bowing out for a while. I told Marc I was doing so earlier this week so I guess that kind of makes me a liar of sorts. Sorry Marc. You have presumed that due to my license number I can be no greater educated or experienced than you….that somehow you attaining your licensed 8 months before me makes you superior in knowledge or experience.
Manny submitted photo documentation of seam-seal tape with his 1802 and was denied by his insurer the discount, this is not true? What other determination could one make from that statement? One thing is for sure, the roofer in question who submitted the affidavit now owns that roof should it leak. Look at it like this, if Manny makes a claim due to a leaking roofing system, who is the insurance company going after? So, with that in mind, what are they really insuring?
I do have one request, from here on out I would like to be referred to as “Mr. 3000”. I have a very thick skin and this is said in jest, I also have a very dry sense of humor and come across a certain way at times. Most of my responses that seem condescending to some are just me being equally assertive. Seek me out at the conference and talk to me, I’ll be glad to listen and talk your ear off……just ask Bill.
I’m going to do this one time and one time only, and I’m doing it because I want you guys to understand it the right way. Not because I think I’m better than anyone, or I think you guys can’t possible understand, but because you are being taught and educated falsely in the use and application of code fluently. I want you to understand its grace and simplicity, how it transcends from less of an instrument to be applied in a black and white arrangement to more of a living and breathing theology of sorts. So, here it goes:
The formulation is simple yet prescribed across multiple sections of the code, what we need to understand is that a secondary water barrier is integral with the complete roof assembly. The roof assembly includes the deck, underlayment, and any other application of roof coverings applied to the structure to complete the water resistant barrier. The definitions below are directly from the Florida Building Code: Residential (herein referenced as the FBCR) and are congruent with the HVHZ and outside the HVHZ, they are synonymous with the “roofing system”. I am providing them so as to simplify later classifications.
**ROOF ASSEMBLY. **A system designed to provide weather protection and resistance to design loads. The system consists of a roof covering and roof deck or a single component serving as both the roof covering and the roof deck. A roof assembly includes the roof deck, vapor retarder, substrate or thermal barrier, insulation, vapor retarder, and roof covering.
(HVHZ chapter 44) ROOFING **ASSEMBLY. **An assembly of interacting roofing components [includes the roof deck, vapor retarder (if present), insulation, and roof covering].
The roof covering is inclusive of the roof deck as the building code throws you back to roof assembly when defining as such. The HVHZ has decided to take this one step further and provide clarification, although pretty much jumping right back into the same pot with relation to the roof assembly.
ROOF COVERING. An assembly of multiple field-applied components or a single component designed to weatherproof a building’s top surface. A roof covering may be a roofing assembly or form a portion thereof.
The next process is to understand exactly what the purpose of the roof covering/assembly is, and not just a layman’s description but an actual specification of the intended function. In short, what it is required to be and what purpose it serves. We need to understand this specifically as to confirm, or substantiate, claims based upon real applications as listed in the code.
Remember, the code is not definitive and can be altered or changed where definite proof is provided to be in compliance with or meeting the approval of the building code. This is also referenced in the FBCR under chapter 1, as the Building Official can accept an alternate method that appears to be in violation of the code but must provide proof of compliance with minimal or equal standard.
R903.1 General.
Roof decks shall be covered with *approved *roof coverings secured to the building or structure in accordance with the provisions of this chapter. Roof assemblies shall be designed and installed in accordance with this code and the approved manufacturer’s installation instructions such that the roof assembly shall serve to protect the building or structure.
R4402.3.1 **General. **
Roof decks shall be covered with roof coverings secured to the building or structure in accordance with the provisions of this section. Roof coverings shall be designed, installed and maintained in accordance with this code and the manufacturer’s installation instructions such that the roof covering shall serve to protect the building or structure. All roof coverings, roof systems and roof assemblies shall be designed and installed to resist the wind load requirements of Section R4403 of this code.
Remember, any part of the roofing system, which is inclusive of the roof assembly, must provide protection to the building or structure to be in compliance with the code. If a system or component of the roofing system does not do so, it is in violation of the simplest form of the code. Period. With respect to seam-seal tape to an existing roof deck, no matter which zone the structure is located, it is in violation of the FBCR when the roof deck is not replaced. It is really that simple. When the option for a secondary water-barrier is taken, which is integral with the complete roofing system, it must at minimum conform to the requirements of the FBCR as described in R903.1 and R4402.3.1.
The existing roof deck is riddled with holes when it is recovered with a new roofing system that does not include replacement of the roof deck. Being that is it part of the roof assembly and required to provide protection to the structure, it is non-complaint and in violation of the FBCR. Bill was right, Manny’s roofing system does not qualify for secondary water resistance and the insurance company was right to deny his discount the first time. Manny’s roofing system is in violation of the simplest requirement of the code when it comes to roof assemblies with a qualifying secondary water resistant barrier
Now, let’s talk about the Florida Building Code, Existing building (herein referenced as FBCE) specifically section 611.727 inclusive of the attributes listed in the section. But first we need to determine what part of the code and attributes even apply to the situation. This will be denoted as “exceptions” and listed at the base or beginning of each attribute. We will take them section by section, attribute by attribute. Frist, when and where section 611.7.2 apply including attributes A & B. But, before even that, we need to determine if the FBCR applies as we are using those definitions to define components associated with the code.
611.1 General.
Materials and methods of application used for recovering or replacing an existing roof covering shall comply with the requirements of Chapter 15 of the *Florida Building Code, Building or Chapter 9 of the Florida Building Code, Residential. *Roof repairs to existing roofs and roof coverings shall comply with the provisions of this code.
The next part tells us when and where section 611.7.2 applies:
611.7
When a roof covering on an existing site-built single- family residential structure is removed and replaced, the following procedures shall be permitted to be performed by the roofing contractor:
(a) Roof-decking attachment shall be as required by Section 611.7.1.
(b) A secondary water barrier shall be provided as required by Section 611.7.2. **
Exception: **Single family residential structures permitted subject to the *Florida Building Code *are not required to comply with this section.
611.7.2 Roof secondary water barrier for site-built single family residential structures.
A secondary water barrier shall be installed using one of the following methods when roof covering is removed and replaced:
**Exceptions: **
- Roof slopes < 2:12 having a continuous roof system shall be deemed to comply with Section 611.7.2 requirements for a secondary water barrier.
- Clay and concrete tile roof systems installed as required by the *Florida Building Code *are deemed to comply with the requirements of Section 611.7.2 for Secondary Water Barriers.
Definition of “continuous roof system” for clarification only: CONTINUOUS ROOFING SYSTEM. An impervious roof covering, composed from a single or multiple layers, forming a homogenous membrane over the entire roof surface, applied to either a flat or pitched roof surfaces.
Essentially what we are looking at is roofing systems with a slope less than 2:12, and not clay or tile constructed before the adoption of the FBCR. That’s where the provisions of 611.7.2 apply, and no place else. The use of seam-seal tape in compliance with the FBCE is strictly for roofing systems with a slope less than 2:12 inclusive of clay and tile built outside of the FBCR!
The application of seam-seal tape to an existing roof deck that is not being replaced with the roof covering is in violation of the FBCR as the deck is compromised with the previous roofing system attachment removal.
Let’s move on to the use of seam-seal tape as a secondary water barrier for use with the OIR-B1-1802 (herein referenced as 1802).
Attribute A. All joints in structural panel roof sheathing or decking shall be covered with a minimum 4 inch (102 mm) wide strip of self-adhering polymer modified bitumen tape applied directly to the sheathing or decking. The deck and self-adhering polymer modified bitumen tape shall be covered with one of the underlayment systems approved for the particular roof covering to be applied to the roof.
This attribute is a violation of the FBCR in both chapters 9 and 44 unless the decking is being replaced, then the question becomes if the roof covering is being replaced and is therefore permitted to the FBC is it exempt per 611.7 of the FBCE? I think that’s a stretch, but I can see the argument being presented both ways as re-nailing and recovering would essentially make the roofing assembly in compliance with the Florida Building Code provided the existing roof deck was of sufficient thickness.
The next attribute speaks of a self-adhering membrane applied directly to the roof deck:
b) The entire roof deck shall be covered with an approved asphalt impregnated 30# felt underlayment or approved synthetic underlayment installed with nails and tin-tabs in accordance with Sections R4402.7.2, R4402.7.3, or R4402.7.4 of the *Florida Building Code, Residential. *(No additional underlayment shall be required over the top of this sheet.) The synthetic underlayment shall be fastened in accordance with the manufacturer’s recommendations.
This poses a different set of issues that are widely documented and were also referenced during the 2012 revision of the 1802, application of a self-adhering roofing membrane directly to the roof deck. This application is not only impractical but suspect to violation of the FBCR when the next roof covering is replaced. Due to the nature of the adhesion directly to the roof deck it becomes fused with the structural decking and non-removable without replacement of the decking inclusive of the coverings. This is extremely costly to the property owner and not practical.
It has been suggested that leaving the membrane in place and covering over it would be a solution, but this is also in violation of the building code as no roof covering can be applied over deteriorated roofing material or has two or more applications of any type of roof covering. It doesn’t take much to see this application is both impractical and suspect to violation of the FBCR.
611.3 Recovering versus replacement.
New roof coverings shall not be installed without first removing all existing layers of roof coverings where any of the following conditions occur:
- Where the existing roof or roof covering is water soaked or has deteriorated to the point that the existing roof or roof covering is not adequate as a base for additional roofing.
- Where the existing roof covering is wood shake, slate, clay, cement or asbestos-cement tile.
- Where the existing roof has two or more applications of any type of roof covering.
- When blisters exist in any roofing, unless blisters are cut or scraped open and remaining materials secured down before applying additional roofing.
- Where the existing roof is to be used for attachment for a new roof system and compliance with the securement provisions of Section 1504.1 can not be met.
As you can see, this application to leave the membrane in place is also in violation of the code after the first replacement and when removing the previous membrane without replacement of the decking.
**Conclusion:
**
Section 611, 611.7 and its attributes, are falsely represented as in compliance with the provisions of the practical and economic use of the FBCR when applied to the required specific application and not the general. The use of seam-seal tape in the HVHZ would only qualify if the entire roof deck was being replaced, making Bill’s statement correct. Per the code, it is nether required or applicable as the provisions of the code for secondary water barrier only apply to roof slopes less than 2:12 (any roof covering), any roofing system other than clay or concrete tile (which would be in violation of the code if installed on a roof pitch less than 2:12 so it’s a moot point), and anything built in compliance or permitted to the FBC.
I did not come to these conclusions by accident, I have done my research and continue to seek a better understanding of the code through studies and code certifications in the future. I do consider myself to be very fortunate when it comes to learning the application of code as I have befriended and talk to almost on a daily basis some of the most educated and experience code and home inspection experts in the business……in the world. They include, but are not limited to, Jerry Peck, Jeff Hooper, Ron Sabac, Burt Silver, Tom Glynn, and Mike Pearson. Jerry was actually part of your ranks and left, he helped develop many of the Associations and licensing for Home Inspectors.
Jeff Hooper was the Architect of the CMI program and the first member, although he would never claim that as the program is now not what he had envisioned. It’s now a cheap marketing program aimed at revenue generation and less about actual qualifications. Jeff was also past president of FABI and is a frequent attendee of the conferences. He is the best in the business, if you want to understand code and statute and how it applies to Home Inspections, he’s the authority!
I hope you guys read the entire post and consider what I’m saying. It’s here for all to take in and I hope my ramblings made sense of a sometimes difficult provision of the code to understand when taken in the singular context.