FRSA Helps Clarify the 25% Rule - June 2021

Mike Silvers, CPRC, Owner of Silvers Systems Inc. and FRSA Technical Director

At the beginning of the year, after the adoption of the Florida Building Code (FBC) 7th Edition (2020), a fellow codes professional called me to voice a concern about an inadvertent deletion during a renumbering of Chapters 4, 5 and 6 in the FBC 7th Edition (2020) Existing Building might cause major changes in the way that Section 706.1.1, the 25 percent rule, was interpreted. I wasn’t surprised that something might go awry when someone decides to reorganize a section of the code. On a slide created a year ago in our “Roofing Related Changes to the FBC” seminar, I noted: “These major renumbering type changes usually have unforeseen consequences!” The section that was left out was from Chapter 5, Related Work in the FBC Existing Building 6th Edition (2017) Section 502.3 which stated: 

Work on non-damaged components that is necessary for the required repair of damaged components shall be considered part of the repair and shall not be subject to the provisions of Chapter 7, 8, 9, 10 or 11. 

Since the 25 percent rule was in Chapter 7 and because of Section 502.3, the 25 percent rule, previously did not apply to non-damaged components, the concern was that without the language in Section 502.3, it would be left up to whoever was doing the work to decide how much work to do – by including non-damaged components, they could push the work beyond 25 percent of the roof area which would prompt complete roof replacement. This has been a common approach when pushing insurers to approve a complete roof replacement instead of a proper repair even when the actual damage was minimal. Section 706.1.1 states: 

Not more than 25 percent of the total roof area or roof section of any existing building or structure shall be repaired, replaced or recovered in any 12-month period unless the entire existing roofing system or roof section is replaced to conform to requirements of this code. 

This language uses the term “roof area or roof section” and a “roof area” is not defined in the FBC but a roof section is defined in Chapter 2 as follows: Read More.