With the implementation of the 2026 Ninth Edition Florida Building Code (FBC) quickly approaching on December 31, 2026, Florida’s roofing industry, like many others, is trying to grasp the recent code changes and figure out just what impact they will have. Among the most concerning is the new requirement for hip and ridge flashing installation methods for metal roof coverings to be tested. This was added to the code after many reports of major damage caused by flashing failures at these locations, often during less than design wind speed events. To better understand the issue, let’s first look at the actual new code language shown in blue text and underscored both in the Building and Residential volumes.

2026 Florida Building Code, Building, Ninth Edition
CHAPTER 15 ROOF ASSEMBLIES AND ROOFTOP STRUCTURES
SECTION 1504 – PERFORMANCE REQUIREMENTS
1504.3.1: Other roof systems
1504.3.1.1 Metal hip and ridge covers.
Metal roof hip and ridge covers shall be tested for uplift resistance in accordance with ANSI/MCA FTS-1.

2026 Florida Building Code, Residential, Ninth Edition
CHAPTER 9 ROOF ASSEMBLIES SECTION R905 – REQUIREMENTS FOR ROOF COVERINGS
905.10: Metal roof panels.
R905.10.4.1 Metal hip and ridge covers.
Metal roof hip and ridge covers shall be tested for uplift resistance in accordance with ANSI/MCA FTS-1.

The code clarifies that when hip and ridge covers are made of metal they are flashing and must be corrosion resistant and comply with Table 1503.2 Metal Flashing Material, below.

2026 Florida Building Code, Building, Ninth Edition
CHAPTER 15 ROOF ASSEMBLIES AND ROOFTOP STRUCTURES
1503.2 Flashing.
Flashing shall be used to seal roofing systems, where the system is interrupted or terminated and shall be installed in such a manner to prevent moisture entering through the roof system and components at intersections with walls and penetrations through the roof system.

1503.2.1 Locations.
Flashing shall be installed at wall and roof intersections, at roof edges around roof openings, penetrations and where there is a change in roof slope or direction or a change of roof covering types. Where flashing or other components are metal, the metal shall be corrosion resistant with a thickness of not less than provided in Table 1503.2 or incompliance with RAS 111.

Exceptions:
1. This requirement does not apply to hip and ridge junctions on steep slope roof coverings (2/12 or greater) other than those made of metal.
2. This requirement does not apply where there is a change in direction or roof slope of less than 25 degrees in low slope roof coverings (less than 2/12).

 

Due to these code changes, we now have an additional requirement: to comply with ANSI/MCA FTS-1. In practice, metal flashings are often fabricated by or for the roofing contractor with profiles and dimensions that are adjusted depending on job conditions or desired functionality. Hip and ridge covers are often fabricated from metal flashing material (sheets or coils) according to manufacturer’s installation instructions. So, will this testing requirement change that? To understand what should be required it helps to look at the test method itself, which is included in the code as a reference standard. Below, only the portions applicable to hip and ridge are shown. (Note: I seldom dive into a test method to this degree. I hope this will help reinforce my concern.)

 

ANSI/MCA FTS-1-2019
Test Method for Wind Load Resistance of Flashings Used with Metal Roof Systems (portions of the test method)

 

1.0 Scope (portions of)
1.1 This test method evaluates the wind load resistance of flashings to be installed at the roof perimeter and roof plane transitions of metal roof systems by testing the flashing and its attachment to the supporting structure using line loads.

 

1.3 This test method provides a standard procedure to demonstrate wind load resistance under uniform line load. This procedure is intended to represent the effects of uniform loading on exposed elements on a building surface. Two methods of testing are provided:
1. Face Load and
2. Face Load and Top Load.

 

3.0 Terminology (portions of)
Failure – fracture, disengagement or unrestrained deformation of components, including fasteners, such that the specimen is not capable of resisting additional load.
Specimen – the entire assembled unit submitted for testing.
Sustained load – a load resisted for specified time.

5.2 The increments of load application shall be chosen so that results from a minimum of four sustained loads are recorded. If failure occurs before a minimum of four loads have been sustained, the test shall be deemed invalid.
6.0 Apparatus

To better understand the test method, see the ridge detail graphic and the photos on page 22 that were reproduced with permission of MCA, ATAS International, MBMA and Farabaugh Engineering and Testing; some of which are represented by the code modification’s proponent.

FRM

The Ninth Edition of the Florida Building Code takes effect December 31, 2026 and, while the tile and shingle trades have had the spotlight in most of the coverage so far, metal roofing contractors have their own set of changes to plan for – some of them significant enough to affect sourcing, pricing and jobsite documentation starting now, not on New Year’s Eve.

Corrosion Resistance Components

The single biggest change affecting exposed fastener metal panel installers is Table 1711.1 Corrosion Resistance of Fasteners and Connectors (see below). FRSA Technical Director, Mike Silvers, released a great article outlining these details in the August 2026 issue of Florida Roofing. The short version is that the fasteners, clips and connectors within the distances and conditions referenced in these tables may require corrosion resistance not previously required. This is not a punishment; this is just a good practice for these conditions and we, as roofing contractors, should be installing these corrosion resistant products already.

Two Key Notes to Keep in Mind

“Coastal shoreline” isn’t defined yet. There’s an active push for clarity on where the 300/3,000-foot measurements start, leaving a lot of room for interpretation. When in doubt, assume it’s within these setbacks and use the proper corrosion resistant products for your application needs.

Non-ferrous fasteners (copper, bronze, aluminum) aren’t addressed at all in the new language. If you’re specifying those, you’re relying on the referenced standards, product approvals or manufacturer instructions – not this new table.

Until fastener compliance is nailed down on paper, include language in your purchase orders specifying corrosion-resistance needs the fastener must meet, if you can’t confirm the requirement, default to stainless.

Metal Hip and Ridge Now Require Uplift Testing

New Sections 1504.3.1.1 (Building) and R905.10.4.1 (Residential) require metal hip and ridge to be tested for uplift resistance under ANSI/MCA FTS-1. To date, there has never been a requirement for this, which means all manufacturers selling in the state will now be required to have this testing completed for each of the system assemblies.

This too is not a punishment for the metal guys but a much-needed standard. Too often hip and ridge assemblies are not properly attached, resulting in these trims blowing off in wind events. By requiring a testing standard, all manufacturers will now properly prescribe how their systems must be installed to meet these requirements, resulting in a better roof system for your client and less callbacks.

The key take away is it has not yet been determined how the state or local municipalities will govern these tests. I expect that manufacturers will be scrambling to get products approved through FTS-1 testing over the next several months and especially when they announce how they will manage the requirement. Additionally, expect building officials to require detailed manuals or installation guides with permit packages to verify hip and ridge assemblies in the field if no clear direction is issued on how they will be managed. 

Clarity for Drip Edge on Metal Roofs

Section 1507.4.6.1 (and its residential twin, R905.10.6.1) spell out drip edge installation for metal roof panels in much greater detail than the current code:

■Minimum 3-inch lap between drip edge sections
■ Eave drip edges must extend 1/2 inch below the sheathing and 2 inches back onto the roof deck
■ Drip edge installed over the nailed underlayment
■ Self-adhering underlayment (ASTM D1970) is permitted over a primed drip edge flange
■ Mechanical fastening at a maximum of 4 inches on center

None of this is new but it’s the kind of thing that turns into a callback or a failed inspection when it’s assumed rather than documented. Update your installation specs and field checklists now so your crews aren’t relearning this in the field after December 31.

What to Do Between Now and December 31

The rule development process still has moving parts – a “glitch” and errata comment cycle runs through mid-October, and the final rule hearing date is yet to be determined. That means there’s still time to weigh in if any of this affects your business in a way you think the Florida Building Commission hasn’t fully considered.

In addition, FRSA and BOAF are partnering on four-hour CE seminars specifically on the Ninth Edition roofing changes and metal roofing fundamentals, including a side-by-side comparison of the Building and Residential roofing chapters. These seminars are available to roofing contractors as well and are a great opportunity for you to sharpen your knowledge and get to meet some of the building officials you may encounter in the field. For more information on these seminars, please visit the calendar section of FRSA’s website, www.floridaroof.com. FRSA members receive a discount on the seminars.

FRM

Bo Copeland has been in the metal roofing industry for over 13 years and has spent most of his career in metal roofing manufacturing, starting with Gulf Coast Supply as an Outside sales representative and later as inside sales manager. Bo then worked for integrity metals as business development manager, where his role was much broader, growing the company with sales, training, technical product and new product development. He teaches several CE accredited metal roofing courses and is a licensed roofing and building contractor. Bo recently started his own company, Hogtown Roofing and Construction. He serves on FRSA’s Board of Directors, as Secretary-Treasurer on the Executive Committee, is active on the Codes and Governmental Affairs Committees and is the chair of FRSA’s Educational Foundation. He’s also an Earl Blank Memorial Heart Award recipient.

I think we can agree that all roofs need to be replaced eventually. Exposure to the elements will make it necessary. I want to focus on when a new roof must be replaced, not because it isn’t performing or because it’s leaking, but because of a technical issue that has arisen and someone with the authority to do so, says it has to be replaced. It may be a building official, a judge, a manufacturer, your customer or your conscience. It is often a technical requirement such as a building code provision or manufacturers’ recommendations that weren’t met and have been discovered during or just after the installation, usually during an inspection by a building official or a potential expert witness. Often, it is not a condition the contractor purposely created but something they weren’t aware of and is clearly required.

Before we discuss some ways to hopefully avoid being faced with this very unpleasant circumstance, let’s look at the real cost of a mandated replacement. For this example, I will use a replacement cost of $10,000, which must be absorbed by the contractor. When a cost like this arises, it is usually paid for through earned or future profits. So how much work will need to be completed to earn that money back? Let’s assume that a company earns five percent net profit. This is after all expenses for the period: materials, labor, labor burden (matching social security and FICA and workers’ compensation) travel and all other overhead expenses (supervision, sales, all office personnel, physical location, vehicles, insurance, etc.). By the way, those costs all have to be applied to the replacement as well.

Based on this example, to earn $10,000 you will have to do $200,000 worth of future work. This is a daunting figure but remember, while you are doing that $200k worth of work and using the profit to pay for the replacement, you are not making profit from this work because it is already being absorbed. So, you must do future work to return those profits. As we can see, this can eat away at your bottom line for quite some time. This example will apply to small and big companies alike. Maybe a large company can more easily absorb this amount but bigger companies install bigger, more expensive roofs. The $10k example makes it easy to adjust this to a replacement of any amount.

Obviously being in this situation is something we know we want to avoid but looking at this example clearly indicates that avoiding it is critical to your company’s future success. Besides the monetary cost there is an untold loss to your reputation and possibly your future insurability if your insurer gets involved. Keep in mind that most liability coverages do not cover the actual cost of a roof replacement in these situations.

So how do we protect ourselves from this nightmare? It isn’t easy. Like so many things it comes down to knowledge. To consider how to avoid this situation, we will revisit and take a deeper dive into the two most common reasons for having to replace a new roof. Non-compliance with the building code or manufacturer’s
installation instructions, which, in many cases, is also noncompliance with the code. Where the code itself is the concern, it usually starts with unfamiliarity with its specific provisions. I sometimes hear a contractor say something along the lines of “I don’t worry about what’s in the code because I do more than it requires.” Not worrying about it indicates a lack of knowing its content and yet they somehow know that they exceed it: a good trick and a sure way to eventually end up in trouble.

Someone involved in your company’s project planning processes should not only be aware of the codes’ content about the roof systems that you install but, just as importantly, stay up to date with changes in the code and local interpretations. The license holder is expected to do so. In Florida, keeping up with these requirements can be difficult. We have two distinct roofing codes: one for two counties (Miami-Dade and Broward), referred to as the High Velocity Hurricane Zone (HVHZ), and the primary code sections for the other 65 counties. There are as many as 35 different municipal building departments in some counties, accounting for as many as 389 in Florida. Being aware of local interpretations in all 389 building departments is all but impossible.

Staying up on the code is difficult enough with the planned code revision process happening every three years but the legislature can also direct the Florida Building Commission to change the code during any of its sessions, typically once a year unless there are special sessions.

Working in an area where you are familiar with the requirements and expectations can definitely help but obviously it is not always possible. It is a good idea to make sure that your permit application explains the scope of the work clearly and concisely, whether the application form requires it or not. Include the correct product approval for the roof system. By providing this information at least you have a chance that a plans examiner or someone else reviewing your application might catch something that does not comply.

I suggest if your project isn’t located in Miami-Dade or Broward Counties that you do not use a Miami-Dade Notice of Acceptance (NOA), which brings in often confusing and complex Roofing Application Standards (RAS) and Testing Application Standards (TAS). These are so complex that they require a separate sub-code
volume that is almost 400 pages long. That is nearly half as large as the FBC Building volume’s 884 pages, which covers all non-residential construction, not just roofing. If you regularly work in the HVHZ, you should be familiar with these standards. For others, it may be perilous to voluntarily use them by selecting an NOA. I suggest that you use the state’s product approvals, indicating that they are for use outside the HVHZ. I would also strongly recommend that if you very seldom or have never done a project located in those two counties, you proceed with extreme caution. To say that the code there is different is a huge understatement. The same caution applies if you are not familiar with using and following NOAs.

With so many potential obstacles to overcome, surely if we lay out the project scope, bring the information to the building department in a permit application, have it accepted, a permit issued, arrange for inspections and possibly even receive a final inspection, you should be good, right? To answer that question, I point to the following code section, which in part states:

2023 Florida Building Code, Building, Eighth Edition
CHAPTER 1 SCOPE AND ADMINISTRATION
SECTION 105 PERMITS
105.4 Conditions of the permit.
105.4.1 Permit intent.

A permit issued shall be construed to be a license to proceed with the work and not as
authority to violate, cancel, alter or set aside any of the provisions of the technical codes,
nor shall issuance of a permit prevent the building official from thereafter requiring a
correction of errors in plans, construction or violations of this code.

Clearly, it is the contractor’s responsibility to comply with these technical requirements and, if you don’t, you may be forced to bring the work into compliance. Not every minor code deviation demands correction. To address which ones may, see the statute below that explains what is considered a material violation. If you look at the section that states: the term “ material violation” means a Florida Building Code violation that exists within a completed building, structure, or facility which may reasonably result, or has resulted, in physical harm to a person or significant damage to the performance of a building or its systems. Again, this leaves it open for interpretation as to what may result in physical harm or damage to the performance of the building or its systems. An issue like fire resistance could easily be seen as reasonably resulting in physical harm. A wind resistance requirement could reasonably be seen as damaging to the performance of a building. So, slight variations (nonmaterial violations) in these technical requirements may not rise to dictate a necessary replacement; many others certainly can.

To avoid this, you may want to limit the different types of roof coverings that you choose to install, allowing you to be more familiar with their specific requirements. You may also consider using product manufacturers you’ve become familiar with and those who provide strong technical support, including representatives
who are based near where the work is being performed or at least someone who is familiar with local requirements.

I know these are burdensome recommendations and you can apply them as you choose but considering the true cost of the replacement of a recently completed roof, it may be prudent to apply as many of
them as possible. 

FRM

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.

As promised, I’m back with another update in a series of Florida Building Code (FBC) 9th Edition (2026) roofing-related code change articles. The new code will go into effect on December 31, 2026. As you’re reading this article, please note that new code language is underscored.

Among the most discussed code changes is one dealing with the corrosion resistance of fasteners used on structures that are within 3,000 feet of the “coastal shoreline,” which also has additional requirements when the structure is within 300 feet of the same line. We will discuss the location of this “coastal shoreline” a little later.

The change we’ll focus on here was made to Building, Chapter 17 – Special Inspections and Test, which created a new Section 1711 Corrosion Resistance-Saltwater Environments. The same information was added to Residential, Chapter 3 – Building Planning by creating Section R332. We will refer to the sections from Building here. Much of the change is covered in the referenced Table 1711.1 and its footnotes, as well as several related code sections that describe the different levels of corrosion resistance required.

To assist in explaining these changes, we have recreated the table below and then created three additional tables using color coding to help track the requirements. In the first three tables we added highlighting to the Exposure Descriptions in the columns on the left. We also color-coded the level of corrosion resistance required in red or green text. See Table 1711.1 below.

The code sections that bring 1711 into Chapter 15 – Roof Assemblies and Roof Top Structure are in Section 1505 Materials in the following locations:
■ 1506.5 Nails
■ 1506.6 Screws
■ 1506.7 Clips

“Connectors and Metal Plates” are not referenced, so that column should not apply to roofing fasteners but may apply to roof-to-wall connectors. Table 2 (page 40) indicates the “exposure” definition in the footnotes from Table 1711.1 that correlates to each of the Exposure Categories.

The column on the right side of Table 3 (page 40) correlates to each roof covering type in Chapter 15 and which fasteners are appropriate for the Exposure Description.

We applied an appropriate analysis to assign specific fasteners in each of the appropriate exposures, which included reviewing not only the new code language but also the ICC 600 Document that the FBC changes were based upon (shown in the inset on page 44). They are also color-coded in the same manner as the other tables. The standard adds some additional information on how to apply the exposure description. So how did we apply them?

Referencing Table 3, Exterior-Partially Sheltered and Exterior-Open Exposed (yellow), we looked primarily at the term exposed. Exposed means not concealed, displayed for viewing. Clearly, fasteners in through fastened metal panels and trim or other visible roof fasteners fit this description. Some examples of additional types of fasteners where this exposure would apply are exposed fasteners in coping, metal edge, counter flashing and vents.

For Unconditioned Interior-Vented Enclosed (green), we looked at fasteners that are inside a part of the building (the roof covering), that also vent to the outside environment. So, fasteners that are under the roof covering but not encapsulated within moisture impervious roof membrane (referred to as "Sealed Overlay" in Table 3), such as concealed screws for metal panels and fasteners for attaching tile, clearly fit here. Shingle nails also fit this exposure category but the degree of corrosion resistance required is more complex and we’ll address this later.

For Unconditioned Interior-Unvented Enclosed (lavender), we looked at locations that are inside the building under the roof covering but are unvented and incapsulated within two layers of material with the upper being an exterior facing moisture impervious membrane.

Table 4 (above) links the two types of fasteners described (in red and green text) to the corrosion-resistance requirements. The color of the text correlates with the colored text in Table 1711.1 on page 38. Note: A code modification through the glitch cycle may add “or Type 410” to the types of acceptable stainless steel.

 

These new code sections do not address nonferrous (e.g. copper, bronze, aluminum) or plastic fasteners, which are often referenced in the code, referenced standards, product approvals or in manufacturers installation instructions. The changes do create a minimum standard for ferrous fasteners used on structurers that fit the requirement’s parameters.

 

What becomes clear in looking at this information is that the FBC’s existing corrosion resistance requirements for roofing fasteners are very robust and these new requirements will only change the fasteners needed in very few situations, primarily when buildings are in extremely close proximity to coastal saltwater locations. When your project is in these locations, in order to comply, make sure your selected fastener meets the appropriate requirements in 1711.1.1.1 or 1711.1.1.2; not every roofing fastener will.

 

Many galvanized shingle fasteners that are available to contractors for use beyond the 3,000-foot line may not meet these requirements. Until you can establish which specific fasteners comply, I suggest that your purchase order for these projects clearly reflect that the galvanized fasteners comply with one of the methods shown in 1711.1.1.2, specifically parts 2.1 through 2.4. If not, then use stainless steel fasteners complying with 1711.1.1.1.

 

When reference standards like the FRSA-TRI Florida High Wind Concrete and Clay Tile Installation Manual 7th Edition have more specific and stringent requirements such as “fasteners shall be corrosion resistant meeting a minimum ASTM A641 Class 1 and/or corrosion resistance equal (according to ASTM B117)” those will apply. Similarly, when the code contains a more specific and stringent requirement like this one from a High Velocity Hurricane Zone RAS, it will still apply:

 

ROOFING APPLICATION STANDARD (RAS) No. 120-20 MORTAR AND ADHESIVE SET TILE APPLICATION PART II—MATERIALS
2.01 Fasteners:
A. Tile Fasteners:
1. All roof tile nails or fasteners, except those made of copper, monel, aluminum, or stainless steel, shall be tested for corrosion in compliance with TAS 114 Appendix E, Section 2 (ASTM G85), for salt spray for 1000 hours. Tile fasteners used within 1,500 feet landward of the reach of the mean high tide shall be copper, monel, aluminum, or stainless steel.”

 

The information contained in this article is provided as a reference for those who are attempting to understand these new requirements. It was compiled with input from many industry stakeholders including the code modification proponent. The final decision on how these requirements will be interpreted will, of course, be made by the building official having jurisdiction based on the project’s location. The requirements may also be the subject of possible non-binding and/or binding interpretations as well as the subject of possible declaratory statements. One declaratory statement that may already be under consideration asks the following question: When considering the application of Section 1711 within 0-3000 feet of a “…saltwater coastline, or other areas subject to salt corrosion,” does this mean the 0-3000 feet distance include distances from saltwater and brackish inland rivers and canals which originate from the coastline? As some of you know, we have been asking for a way to define this and similar lines referenced in the code for some time. If the code expects us to measure from something like a “coastal shoreline,” shouldn’t the code define where it is?

 

This is an evolving issue so please continue to read this column for updates. Despite some of the complexities that come with these changes, one should keep in mind that they were meant to address a real issue: the corrosion of important critical structural components in our coastal environment. If properly implemented, this can be accomplished without the degree of disruption that some are concerned about.

 

FRM

 

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.

 

Is the Legislature the Best Forum for Modifying the Building Code?

Florida’s building code is produced and published over a three-year cycle. The upcoming 9th Edition (2026) takes effect on December 31. Draft versions of the new code became available in mid-May on Florida’s Building Code Information System (BCIS). The code development process can be altered at any time by the legislature, which can direct the Florida Building Commission to make code changes at any point in the process. Seldom do these legislative changes impact the code more than one of the most expansive bills passed and signed by the Governor this year. HB 803 became the gathering place for several construction related initiatives this session. I have already written about many of the items in the bill and predict that I will be writing about many more as the bill’s requirements are implemented. Most of that implementation will be done as changes mandated by the legislation are incorporated into the Florida Building Code.

HB 803, an act relating to building permits and inspections, was passed in March after its final reading in the Florida House. It was signed by the Governor in May and became effective July 1. Included in the bill are many significant reforms to building permitting and inspection procedures. I will concentrate on just a few of the changes.

HB 803 Roofing Exception to the $7,500 Permit Exemption

From the bill:
F.S. 553.79 Permits; applications; issuance; inspections. (1) (g)

1. A local government that issues building permits shall exempt an owner of a single-family dwelling
or the owner’s contractor from the requirement to obtain a building permit to perform any work valued
at less than $7,500 on the owner’s property.
2. The exemption under subparagraph 1., does not apply to any of the following: 
    a. Work on a propertythat is partially or entirely located in a flood hazard area as defined by the Florida Building Code.
    b. Any electrical, plumbing, structural, mechanical, or gas work performed on property containing a single-family dwelling.
    A construction project may not be divided into more than one project for the purpose of evading the requirements of this paragraph.
3. To qualify for the exemption under subparagraph 1., the owner or the owner’s contractor must submit a written request for exemption
to the local enforcement agency with a copy of the contract or other documentation demonstrating the nature and the value of the work to
be performed.
4. A local government has no legal duty to the owner, contractor, or successors or assigns thereof for exempted work performed under
this paragraph.

During final discussion on an amendment under consideration, Representative Alex Andrade asked Representative Toby Overdorf, the amendment sponsor, the following question. “Based on this amendment is it your understanding that roofing work and roofing repairs would be deemed as structural as defined or understood under the bill?” Representative Overdorf responded: “Roofing would be structural, yes.” Another unrelated question was discussed and then the amendment and the bill were passed unanimously.

Based on the discussion on the House floor and the unanimous vote afterwards, it seems very clear that the intent of the bill was not to allow roofing to be exempt from permitting and inspections even though the bill’s language does not clearly reflect that. How can we help make the intent clear to building owners, contractors and building officials? One possible way to accomplish this will be, when the bill comes to the Florida Building Commission for adoption into the code, to propose language that clearly reflects the legislative intent when the bill was passed. This approach will be difficult for several reasons. It is often frowned upon by some to make any clarifying changes in the statutory language, even though it has been done at times in the past. We would also be moving a position forward that roofing is structural but only in this one instance. Typically, we would prefer this not be a position that is applied to other circumstances.

A few other options will be reviewed if the code language to clarify intent fails to be adopted. We will of course help spread the information about the bill’s intent on the exemption. We will also consider requesting a binding interpretation or a declaratory statement from the Commission. Whether those options succeed or not we should pursue adding the term reroofing to the list of exceptions that apply to the exclusions, thereby making it clear that roof replacement or recovering requires permits and inspections.

One great improvement in the bill from earlier versions does require that in order to qualify for the exemption under subparagraph 1., the owner or the owner’s contractor must submit a written request for exemption to the local enforcement agency with a copy of the contract or other documentation demonstrating the nature and the value of the work to be performed.

The Commission Will Create a Statewide Uniform Permit Application Form

From my observations, not since the creation of the Florida Building Code has such a far-reaching dictate been assigned to the Commission. There will surely be some contention as the proposed forms are reviewed and produced.

Putting aside the difficulties in creating a form that will best encompass our dual roofing codes with one standard code for 65 counties and a separate High Velocity Hurricane Zone (HVHZ) code for two counties (Miami-Dade and Broward), the differences between Florida’s 67 counties and approximately 140 city building
departments make the task formidable.

Perhaps that explains the recent decision to hand this task to an advisory group formed by the University of Florida Engineering School of Sustainable Infrastructure and Environment (ESSIE). A report on the subject was presented to and accepted by two of the Commission’s Technical Advisory Committees (TAC) in May. According to the report, the Advisory Group is to include building officials, construction industry organizations and associations, engineers, architects, contractors and electronic permitting program vendors. Questions asked during that meeting concerning how members of the advisory group would be selected were not clearly answered. Since more building permits are pulled for alterations like reroofing, air conditioning, etc. than for new construction, these forms are critical to division two contractors. One can only hope that these contractors are properly represented.

We will monitor the makeup of the group in hopes that it includes the impacted trades and fairly represents all of Florida’s geographical locations. We hope that the Commission and its TACs (including the Roofing TAC) will play an important part in the development of this very important undertaking. We also hope to see the inclusion of a representative group of building officials, both in the size and the location of their departments. One can’t help but think that input from the two groups (contractors and building officials) that actually use the forms would lead to a better permitting process.

The Bill Establishes Timeframes to Process and Issue Building Permits

The bill creates new timeframes and deadlines for the issuance of permits. One that is the most important to roofing contractors includes the following:

F.S. 553.792 Building permit application to local government.
(1)(a) A local government must approve, approve with conditions, or deny a building permit application after receipt of a completed and sufficient application within the following timeframes, unless the applicant waives such timeframes in writing:

1. Within 5 business days after receiving a complete and sufficient application, for an applicant using a local government plans reviewer to obtain
the following building permits for an existing single-family residential dwelling if the value of the work is less than $15,000: structural, accessory
structure, alarm, electrical, gas, irrigation, landscaping, mechanical, plumbing, or roofing.

The Bill Contains Many Changes in How Private Providers are to be Addressed

Along with many other changes that are too extensive for this article are the way the bill deals with private providers. If you are currently using or planning to use private providers, you need to look closely at those changes. Just recently, this task has been handed over to an advisory group also formed by ESSIE.

Major Changes for Building Departments

For building departments, this bill is loaded with new regulations, requirements, mandates and restrictions and a thorough review of procedures impacted by the bill will be necessary by all building departments.

Florida’s code is often described as the best in the country, if not the world. Overall, our code modification process works very well, allowing licensed professionals who actually interpret and use the code to be those who primarily modify it. FRSA will continue to closely monitor the implementation and interpretation of these extensive new changes and report back to our members and the industry. Stay tuned.

FRM

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.

Occassionally, I hear from one of our long-time contractor members about the rapid pace of changes in our industry and why they don’t like a particular change that has been made in the code or other regulations. I understand, change is hard. Interestingly, those few that are most upset with a particular change are in an age group commonly referred to as “boomers.” Before anyone is offended by my use of this overused term, please understand that I am one, though I prefer to think of myself as mid-century modern. Younger folks may still be bothered by some of these changes but are more open to change overall. They have grown up in a world that changes at the speed of light and have learned to expect it. As a seasoned construction veteran, I understand why many others like me are overwhelmed but then I reflect on my own experiences and remind myself of just how much our industry has changed in the 60 years that I’ve been involved.

As an example, one of my earliest jobs (late 60s and early 70s) was maintaining the wide variety of equipment used to perform commercial roofing. Every good roofer had kettles for heating bitumen (asphalt or coal tar). To heat them, we used kerosene tanks bolted to the side of these heating vessels. Yes, they occasionally caught fire. Kerosene tanks are not naturally pressurized like those containing liquid petroleum gas (LPG) but still need to feed the combustible liquid to the burners. This was accomplished by a pump inserted into the tank powered by a manually operated “T” handle to pressurize the tank (picture a large bicycle tire pump) until a siphon was established by preheating coils in the burners. The seals used at the end of the pump piston were made from leather. Hot bitumen was transported to the roof in buckets by rope hoists often attached to the top of a ladder, leaving the hoist operator on the ground, almost directly under open containers of hot bitumen. On the roof, asphalt was most often applied with mops and pouring cans. They were used to install three, four and five plies of organic felt and often surfaced with aggregate or coating.

Technology quickly brought improvements to these systems. LPG fueled burners, pumper kettles and asphalt dispensers took the place of the old equipment. Reinforcing membranes changed from organic to fiberglass and polyester. Cap sheets became more prominent with many not requiring hot asphalt to apply. Eventually single-ply membranes became the prominent low-slope system with – in many cases – robots performing much of the seam sealing. This is an example of a just few of the many changes in just low-slope roof systems. I could use similar examples for any type of roof system.

So, why is it that those who have been doing this work for so long and have witnessed and adapted to so many past changes are having difficulty understanding that change continues to occur? If we can reflect with an open mind, some of it comes down to “I’ve been doing it this way for a long time and it worked, why do I have to change now?” That is often the sentiment expressed but is it realistic?

The forces influencing change in the roofing industries are numerous and varied. Materials, technology, workforce, insurance, safety, laws and building codes are just a few factors that impact change. The building commission will make changes with each cycle and the legislature will meet and pass laws that lead to new regulations with each session. Both will be influenced by a host of stakeholders. It is imperative that FRSA remains vigilant by being involved in these processes to influence the eventual outcome. We must be proactive. This is being accomplished through the efforts of our volunteer members, legislative counsels, legal counsel and FRSA staff.

The technical services staff are deeply involved in the development of roofing-related changes in the building code. We also assist with technical issues that arise during the legislative session. With all the attention on construction, codes and resiliency, this has been a continually active area. Through our collective efforts, we have and will continue to have a significant impact on these developments but there are many competing interests that are trying to do the same. We will prevail in moving our positions forward on most of the issues but we don’t win them all. I can assure you that it’s not for lack of trying.

One thing we can’t do is stop change from occurring. To quote the Greek philosopher Heraclitus, who lived 2,500 years ago, “There is nothing permanent in life except change.” So, if we understand that change is constant, how can we help overcome our resistance to change and make it less troubling? Most importantly,
we can let those affected by the changes know about them before they go into effect. FRSA is committed to keeping our members aware of changes that can have an impact on their companies and our trade. We do this by sharing knowledge through personal discussions, reports to committees and subcommittees, magazine articles and seminars. Hopefully, through these communications we can help people prepare for these inevitable changes and thereby help them adjust.

Clearly, I’ve been around a while but not long enough to have been there for Heraclitus. But I was around to hear this from a philosopher and poet of my era through his song. The words will always be applicable to the never-ending tides of change: "You better start swimming or you’ll sink like a stone, for the times they are a-changin” – Bob Dylan, 1964.

FRM

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.

We're in the third year of the Florida Building Code (FBC) triennial cycle, which, for us, is the education and training portion. The changes to the 2026 Florida Building Code Ninth Edition are close to complete but as of this writing they have not yet been published, which is typical of the cycle. Due to our involvement in the code development process, we have a clear idea of what changes have been made that will have an impact on the roofing industry. We know our members and the rest of Florida’s roofing industry need to know what to expect well before the new code takes effect on December 31, 2026. To help accomplish this, we began including many of the most important changes in a series of articles starting in the February issue of Florida Roofing magazine: code-based articles are also available on the homepage of FRSA’s website, www.floridaroof.com.

These articles will continue to be featured well into next year in order to highlight code changes. Presentations on the code changes usually begin during the Convention that precedes the code’s adoption. This year, FRSA’s Educational and Research Foundation offers a slate of 17 hours of continuing education seminars designed to help contractors understand the changes in the code. In addition, some of these will be presented at FRSA headquarters and at locations around the state. We will also present several in conjunction with the Building Officials Association of Florida (BOAF), not only for building department employees but for contractors too.

Shortly after the code takes effect, we will begin promulgating the next edition of the FBC by reviewing changes made in the International Building Code (IBC) that may be suitable for inclusion in the FBC. This process is referred to as step one. It will continue over the next year, with many meetings of the Florida Building
Commission and Technical Advisory Committees (TACs). Concurrently, FRSA holds meetings to establish our position on the IBC modifications and attempt to influence the outcome in a way that addresses our concerns. During this same period, FRSA begins developing code modifications that we would like to see included in the next code.

The second year of the cycle is where the public (including FRSA) can submit and then champion their changes and support other changes that we agree with for inclusion in the code. Just as importantly, we also try to amend or eliminate any modifications that we don’t view as favorable. Our success rate in achieving our goals is extremely high. Much of this success is based on reaching out to other stakeholders and working on a consensus before the changes are finalized. Another big part of our success is bringing forward clear positions that not only help the roofing industry but also Florida’s citizens and property owners.

More Florida Building Commission and (TAC) meetings take place while the changes are finalized. We are fortunate to have many roofing professionals on the TACs and the Commission that understand the positions. After two years, we find ourselves back at the education and training portion of our cycle.

During these cyclical processes, many other regulatory occurrences need our attention. Sometimes it is due to legislative changes that can override the code’s normal three-year cycle or other legislative changes that require our attention but are not directly related to the building code. A recent example of this is when our Governmental Affairs team was able to convince the Legislature to expand the scope of a roofing contractor’s license to include the ability to evaluate and enhance roof-to-wall connections. You may be surprised to know that for many years, the code for certain reroofs included requirements to evaluate and enhance any needed roof-to-wall connections. It also allows the building owner to opt out of doing so based on cost. To help you understand this licensing scope change and how it affects you, we are presenting a two-hour seminar to prepare roofing contractors who perform reroofing to properly expand into this type of work. Keep in mind that even if you don’t intend to expand into performing roof-to-wall connection enhancements, there are still requirements to address them when reroofing buildings that fit the parameters of the FBC’s mandated hurricane mitigation requirements.

When looking at the three-year code cycle, it is important to become aware of and understand code changes during the year that the code takes effect (2026, 2029, etc.). However, as I’ve explained previously, there are many ways that the regulatory environment can change outside of that introductory year. FRSA’s volunteers and staff work diligently to provide input during these regulatory processes and to bring this information to you. Please pay special attention to the technical, governmental affairs and legal articles in Florida Roofing magazine and attend FRSA’s seminars to stay aware of Florida’s ever-changing regulatory landscape.

FRM

As the industry pushes toward the final adoption of the 2026 Florida Building Code Ninth Edition, effective date December 31, 2026, roofing professionals and others from across the state have spent many long hours reviewing detailed revisions with the collective mission to make the nation’s toughest building code even stronger.

This cycle brings targeted restructuring and new clarifications across key sections, including Chapter 15 of the Florida Building Code – Building; Chapter 9 of the Florida Building Code – Residential and Chapter 7 of the Florida Building Code – Existing Building.

Below, code language appears in blue with new language underlined, some deleted language is shown in red and stricken through and my comments are in black. The code sections shown are for FBC Building. Similar sections exist in other code volumes. The changes discussed here represent only a portion of the new code changes and may be subject to change.

Stability in the Standards

The wind load provisions of the code are in a reference standard titled: Minimum Design Loads and Associated Criteria for Buildings and Other Structures ASCE/SEI 7-22 (ASCE 7), which will remain unchanged for this edition of the FBC. As a result, the FRSA-TRI Florida High Wind Concrete and Clay Roof Tile Installation Manual will see no revisions to its tables or other content during this code cycle. For contractors and designers, that continuity provides welcome predictability in a regulatory environment often defined by change.

Miami-Dade’s HVHZ Tile Changes

Meanwhile, staff in Miami-Dade County have been busy making updates to RAS 118, 119, 120, 127 and related TAS protocols that reflect significant changes by removing many of the prescriptive methods and inserting performance-based standards. These changes strengthen and better align the High Velocity Hurricane Zone (HVHZ) requirements for tile with those in the FRSA-TRI manual.

Corrosion Resistance: A Coastal Imperative

In a state surrounded by saltwater, corrosion should never be an afterthought. Significant corrosion resistance requirements have been added by referencing extensive new language in Section 1711 in the FBC Building.

2026 Florida Building Code, Building, Ninth Edition
Chapter 15 Roof Assemblies and Rooftop Structures
Section 1506 Materials

1506.5 Nails. Nails shall be corrosion-resistant nails conforming to ASTM F1667 or an equal corrosion resistance by coating, electro galvanization, mechanical galvanization, hot dipped galvanization, stainless steel, nonferrous metal and alloys or other suitable corrosion-resistant material, or corrosion resistance shall be demonstrated in accordance with TAS 114, Appendix E. In areas within 3,000 feet (914 m) of a saltwater coastline, nails shall comply with Section 1711.

1506.6 Screws. Wood screws conform to ANSI/ASME B18.6.1. Screws shall be corrosion resistant by coating, galvanization, stainless steel, nonferrous metal or other suitable corrosion-resistant material. The corrosion resistance shall be demonstrated through one of the following methods:

1. Corrosion resistance equivalent to ASTM A641, Class 1;
2. Corrosion resistance in accordance with TAS114, Appendix E; or
3. Corrosion-resistant coating exhibiting not more than 5 percent red rust after 1000 hours exposure in accordance with ASTM B117.

In areas within 300 feet (91.4 m) of a saltwater coastline, screws shall comply with Section 1711.

Section 1517 High Velocity Hurricane Zones – Materials

1517.5.1.1 Fasteners and connectors exposed to saltwater environments. Fasteners and connectors in areas within 3,000 feet (914 m) of a saltwater coastline shall comply with Section 1711.

The message is clear: Florida’s coastal environment demands metal components that remain functional as long as the roof systems that they secure.

Flashing and Drip Edge

For steep-slope roofs (2:12 and above), drip edge installation at eaves and gables is now firmly reinforced in both residential and building code sections for all roof covering types. The tile section changes are limited to those shown below.

Section 1507 Requirements for Roof Coverings

1507.3.9 Flashing. At the juncture of the roof Interruptions, terminations and penetrations of the roof system vertical surfaces, flashing and/or counterflashing shall be provided installed in accordance with the manufacturer’s installation instructions or the recommendations of the FRSA/TRI Florida High Wind Concrete and Clay Roof Tile Installation Manual, Seventh Edition where the basic wind speed, Vasd, is determined in accordance with Section 1609.3.1.

1507.3.9.1 Drip edge. Drip edge shall be installed at eaves and gables of steep slope roofs (2:12 and above). Drip edge shall be applied according to the FRSA/TRI Florida High Wind Concrete and Clay Roof Tile Installation Manual, Seventh Edition.

Section 1517 High Velocity Hurricane Zones – Materials

1517.6.2.3 Drip edge. Drip edge shall be installed at eaves and gables of steep slope roofs (2:12 and above). Drip edge shall be installed over the underlayment. Self-adhering underlayment complying with ASTM D1970 is permitted to be installed over a primed drip edge flange.

The changes shown above do not change tile installations but simply refer to the manual. The refinements made in many other steep-slope roof systems eliminate ambiguity and reinforce edge protection, one of the most vulnerable points during high-wind events.

Underlayment: Tested, Approved, Documented

For discontinuous roof tile systems, underlayment installation must strictly follow both Product Approval and manufacturer instructions.

Section 1523 High-Velocity Hurricane Zone – Testing

1523.6.5.2.1 Underlayment. All underlayments used in discontinuous roof tile systems shall be tested in compliance with TAS 110 Physical Property Requirements. TAS 103 and TAS 104, unless otherwise specifically listed in the applicable RAS. Uplift resistance of the tile underlayment shall be tested in compliance with FM 4474 or UL 1897. The uplift resistance shall be included in the Product Approval.

This emphasis on testing and documentation underscores a broader industry shift: performance must be measurable, not assumed.

2026 Florida Building Code, Test Protocols for the High-Velocity Hurricane Zone Ninth Edition
Roofing Application Standard (RAS) and
Testing Application Standard (TAS)
Roofing Application Standards No. 118, 119 and 120

A. Tile Fasteners
2. All roof tile fasteners shall be of sufficient length to penetrate through the roof sheathing or not less than 3/4 in. into the roof sheathing even when battens are used.

3.01 Underlayment Applications All underlayment systems shall be tested and have Product Approval for use as a roof tile underlayment, Product Approval to include uplift resistance values. Installation of underlayment system shall be in accordance with the Product Approval and the underlayment manufacturer’s installation instructions.

The following language and many other sections of these RAS have been deleted:

No roof material shall be fully or partially adhered (not to include mechanically attached) directly to a nailable deck.

The 2026 HVHZ test protocols expand the use of structured tables for determining the required underlayment resistance to uplift.

Roofing Application Standard (RAS) No. 127-20

Procedure for Determining the Moment of Resistance, and the Minimum Characteristic Resistance Load, and the Uplift Resistance of Tile Underlayment to Install a Tile Roof System on A Building of a Specified Roof Slope and Height Using Allowable Stress Design (ASD) in Accordance with ASCE 7
1. Scope. This standard covers the procedure for determining the Moment of Resistance (Mr) and Minimum Characteristic Resistance Load (F’) to install a tile system on buildings of a specified roof slope and height. Compliance with the requirements and procedures herein specified, where the design wind uplift pressures (Pasd) have been determined based on
Tables 1-3 or Tables 4-6, Tables 7-9 or Tables 10-12 of this standard, as applicable, do not require additional signed and sealed engineering design calculation. The roof tile underlayment must meet the applicable design wind uplift pressures. All other calculations must be prepared, signed and sealed by a professional engineer or registered architect.

Tables 1-3 are applicable to a wind speed of 175 mph, risk category II buildings with gable roofs, and Exposure Category C.
Tables 4-6 are applicable to a wind speed of 175 mph, risk category II buildings with gable roofs, and Exposure Category D.
Tables 7-9 are applicable to a wind speed of 175 mph, for Risk Category II buildings with hip roofs, and Exposure Category C.
Tables 10-12 are applicable to a wind speed of 175 mph, for Risk Category II buildings with hip roofs, and Exposure Category D.

However, roof tile underlayment must still meet design uplift pressures as shown in the product approval and any calculations beyond the scope of the standard must be prepared and sealed by a licensed professional engineer or registered architect. This approach balances efficiency with accountability, streamlining compliance without sacrificing structural rigor.

The Bigger Picture

The 2026 Florida Building Code tile roofing updates are not about dramatic reinvention. They are about refinement – aligning standards, strengthening corrosion requirements, clarifying installation practices and reinforcing Florida’s leadership in wind-resistant construction.

For an industry shaped by hurricanes and coastal exposure, that steady commitment to improvement ensures one thing remains constant: Florida continues to set the bar for roofing resilience nationwide.

FRM

Manny Oyola, Jr., is Owner of MOJR Consulting, Boca Raton and is working with FRSA as a Technical Advisory. He previously worked for Eagle Roofing Products as Technical Manager Eastern Region and has been a Florida licensed roofing contractor since 1982. Manny is also an instructor, who has worked with FRSA, offering training for many years. He is an FRSA Past President and Honorary Member.

One doesn’t have to look very far to see the many ways that the Florida Building Code (FBC) has been heralded as responsible for large improvements in the storm resistance of Florida structures. It is at the heart of control over ever-increasing property insurance premiums. Its provisions have helped keep thousands in their homes and places of business post hurricane.

Implementing all the changes since the FBC’s inception has been an enormous task for the construction industry as a whole and the roofing industry in particular. For those who are unfamiliar, the code changes every three years (a triennial cycle). With each new edition, many modifications are submitted to the Florida Building Commission for consideration. Many of these modifications are made in an effort to improve the resiliency of our structures. Florida Statutes prohibit any weakening of the code's windresistance provisions. So, with each new edition, the code can only get stronger in terms of wind-resistance. It has and the trend is likely to continue.

Producing a stronger code, however, is just words without the code’s requirements being properly applied when building, altering or repairing a structure. Through contractor licensure, permitting, inspections and training, Florida has done a good job of accomplishing this. Many conscientious contractors follow the code because they have an interest in doing things the right way regardless of enforcement. FRSA is fortunate that most of our members take this approach. However, we know there are many who present themselves as legitimate contractors but don’t hold themselves to this standard. The reality of failing an inspection that could result in a new roof being replaced, at the contractor’s expense, is a big part of getting this type of contractor to pay any attention to the code’s requirements and the quality of his or her work.

Losing the ability to pull permits in a jurisdiction due to previous poor work or other non-compliance can also be an incentive. If there isn’t any permitting or code enforcement – or fear of it – then only the conscientious contractors will comply. Eventually, it will leave only those, as mom use to say, “with larceny in their hearts” with a huge cost advantage, due to noncompliance of code provisions and thereby eventually driving someone following the rules out of business, leaving only the unscrupulous.

Make no mistake, a well-functioning building department is not only critical to maintaining the advances accomplished through the code but also in trying to maintain a somewhat level playing field for all contractors. Without permitting, who will confirm licensure? Building officials are a major part of the improvements that have been made.

So, why am I addressing this now? Unfortunately, there are some well-intentioned movements that could upset the balance of regulation and implementation that have made our work in the code so successful. A lot of new mandates have been and are being handed to Florida’s building departments. Think no further than the milestone inspections programs
implemented after the Surfside building collapse. Or new requirements to issue permits in shorter time frames than previously required. Many of these are good improvements and can be helpful but, as we all know, it is hard to do more with less.

Can permit fees alone support our local building departments? There are now calls for a statewide uniform building permit form that, while admirable, will require reconfiguring most building departments permitting computer software as well as significant staff training. Funding for local government appears to be undergoing significant changes. As these changes
are made, we need to keep in mind that funding our building departments is critical if we want to continue the implementation of the many important code provisions that so many have touted.

At the time of this writing, Florida’s legislature is in session. A bill SB 1234/ HB 803 has gotten legs and will probably have been passed and possibly adopted by the time you’re reading this. The bill has a lot of things that are very developer friendly, which, for the most part, we support but this language may present some challenges not only for licensed contractors but for building departments as well. The portion that most concerns me is below. On its surface, this may appear helpful but stick with me after reading the section below.

CS/CS/HB 803, 2026

(g) 1. A local government that issues building permits may not require an owner of a single-family dwelling or the owner’s contractor to obtain a building permit to perform any work that is valued at less than $7,500 on the owner’s property. However, a local government may require a building permit for any electrical, plumbing, structural, mechanical or gas work performed on property containing a single-family dwelling regardless of the value of the work. A construction project may not be divided into more than one project for the purpose of evading the requirements of this section.

2. For any work performed by a person other than the property owner under the exemption in subparagraph
1. the person performing the work must file a notice of permit exemption with the local enforcement agency that includes the name and license number of the person or entity hired to perform the work, the scope of the work performed, the property address at which the work was performed and the value of such work as proof that such work complies with subparagraph 1. A notice of permit exemption must be filed within 30 days after the date the work begins. A notice is not required for work performed personally by the property owner. A local government has no legal duty to the owner, contractor or successors or assigns.

So, if adopted, no permit or inspections can be required for most work on a single-family dwelling where the value is less than $7,500. Why do I foresee the price for smaller residential reroofs will become $7,499? This price may be sufficient for reroofs on small homes but could easily be used to exempt larger projects. Do we think it is above those who want to
skirt the permitting and code requirements by using this exemption as a hack on larger projects by hiding additional payments or costs hidden from view? What can the building department do when seeing a reroof being performed and when requesting a permit, those doing the work just say: "It’s less than $7,500, go away, permits and inspections aren’t required."

Building departments aren’t supposed to require contracts or job costs to establish permit fees, which is something we agree with. But with this new permit exemption, how can they confirm the price? If they do see a contract, the previously described deception could easily make it irrelevant. This will be a gift for those who wish to work without proper licensure. How does the bill address this? A contractor is supposed to file a permit exemption within 30 days after the date the work begins. Yes, that’s right, after work begins. Why would I be skeptical that filing the exemption would actually occur?

We attempted to have reroofing added to the type of work that would still need a permit but were told that roofing was already included in the “electrical, plumbing, structural, mechanical or gas work” language. I was perplexed but was told that the legislature was assured that roofing was structural. That struck me as odd because for decades, before the renailing of sheathing language was added to the definition of a roofing contractor, we were consistently told roofing contractors couldn’t do any structural work but now, somehow, all roofing is structural. The same applied to roof-to-wall connections when that was added. Opponents argued that it was structural, which it is but was specifically limited when it was
added to our scope to allow it to be done by roofing contractors. So now, it will have to be determined if roof coverings and systems are in fact structural. That decision could have far reaching consequences no matter which way it falls. Something tells me that many building officials will not see roof coverings as structural, so they may decide that they do not require permits and inspections on these jobs. You are supposed to be licensed to do this exempted work but without permits and inspections who will check? Hopefully, we will eventually get it added in future sessions. By making that simple change, repairs of less than $7,500 would be allowed under the exemption, while full reroofs (a term that covers roof replacement and recovering defined in the code) would still require a permit.

Our legislative team does a great job for us but this one got rolling like a boulder heading downhill: tough to stop or reason with. We will continue to monitor this development and try to apply a measure of reason to its interpretation. This may lead to some detrimental unintended consequences.

Note: “those with larceny in their hearts” refers to individuals harboring a deep-seated inclination toward dishonesty, greed and the theft of other people's property or wellbeing. Mom, the original AI (Actual Intelligence), was pretty wise!

FRM

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.

In my February article (Changes in the 2026 Ninth Edition of the Florida Building Code), I shared upcoming changes and noted that I would continue to discuss those changes over the next few months. It's important to note that these changes will not go into effect until December 31, 2026 but, for planning purposes, I want to provide you with a heads up. We
will offer a number of seminars that address the roofing-related changes in more detail, including during our 104th Convention, June 10-12 at Gaylord Palms in Kissimmee.

This month’s article will address changes and additions to the codes flashing requirements (italicized terms are those defined in the code). Please note: We will use the numbering from the Building volume in Chapter 15 here. The codes Residential sub-volume has similar sections in Chapter 9. Actual code language is in blue and my comments are in black.

2023 Florida Building Code, Building, Eighth Edition Chapter 15 Roof Assemblies and Rooftop Structures
Section 1502 Definitions.
1502.1 Definitions.
FLASHING. The roofing component used to seal roofing systems, where the system is interrupted or terminated.

Section 1503 Weather Protection.
1503.1 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 coverings shall be designed in accordance with this code, and installed in accordance with this code and the manufacturer’s approved instructions such that the roof covering shall serve to protect the building or structure.

1503.2 Flashing.
Flashing shall be used to seal roofing systems, where the system is interrupted or terminated and shall be installed in such a manner so as to prevent moisture entering the wall and roof through joints in copings, through moisture-permeable materials and at intersections with parapet walls and other penetrations through the roof plane.

TABLE 1503.2 – METAL FLASHING MATERIAL (below)
1503.2.1 Locations.
Flashing shall be installed at wall and roof intersections, at gutters, wherever there is a change in roof slope or direction and around roof openings. Where flashing is of metal, the metal shall be corrosion resistant with a thickness of not less than provided in Table 1503.2 or in compliance with RAS 111.
Exception: This requirement does not apply to hip and ridge junctions.

1503.3 Coping.
Parapet walls shall be properly sealed with weatherproof materials. When coping is used, it shall be of noncombustible material of a width no less than the thickness of the parapet wall. The approved modifications shown below will be part of the pending FBC changes (effective December 31, 2026). New language is underscored and deleted language is stricken-through, if neither is shown it is existing code language. There may be some slight changes when published.

2026 Florida Building Code, Building, Ninth Edition
Chapter 15 Roof Assemblies and Rooftop Structures
Section 1502 Definitions (flashing is defined as follows without any changes)

1502.1 Definitions.
FLASHING. The roofing component used to seal roofing systems, where the system is interrupted or terminated.

Section 1503 Weather Protection.

1503.2 Flashing.
Flashing shall be used to seal roofing systems, where the system is interrupted or terminated and shall be installed in such a manner so as to prevent moisture entering the wall and roof through joints in copings, through the roof system and components moisture-permeable materials and, at intersections with parapet walls and other penetrations through the roof plane system.

1503.2.1 Locations.
Flashing shall be installed at wall and roof intersections, at roof edges, gutters, wherever there is a change in roof slope or direction around roof openings, penetrations and where there is a change in roof slope or direction or a change of roof covering types. Where flashing or other components is of are metal, the metal shall be corrosion resistant with a thickness of not less than provided in Table 1503.2 or incompliance with RAS 111.

Exceptions:
This requirement does not apply to hip and ridge junctions on steep slope roof coverings (2/12 or greater) other than those made of metal.

This requirement does not apply where there is a change in direction or roof slope of less than 25 degrees in low slope roof coverings (less than 2/12).

Some areas addressing different types of roof covering have not previously included any specific language linking the general flashing requirements to a specific type of roof covering. These included:

1507.4 Metal roof panels.

1507.5 Metal roof shingles.

1507.6 Mineral-surfaced roll roofing.

1507.7 Slate shingles.

1507.8 Wood shingles. Added reference to Cedar Shake and Shingle Bureau

1507.9 Wood shakes. Added reference to Cedar Shake and Shingle Bureau

1507.10 Built-up roofs.

1507.11 Modified bitumen roofing.

1507.12 Single-ply roofing.

1507.16 Vegetative roofs, roof gardens and landscaped roofs.

1507.17 Photovoltaic modules/shingles.

1507.18 Solar photovoltaic panels and modules.
(Add “roof covering manufacturer” instead of “solar photovoltaic panel and module manufacturer” to list for this modification.) Each of the above roof covering types has an added requirement that reads:

Flashing shall comply with this Chapter and the(insert roof type from list above here)
manufacturer’s installation instructions.

As an example: Flashing shall comply with this Chapter and the metal roof panel manufacturer’s installation instructions.

Some sections have previously addressed flashing for different roof types; these are included here with any new changes:

1507.2 Asphalt shingles.
(Extensive flashing requirements with no modifications to the specific type of changes discussed here.)

1507.3 Clay and concrete tile.
1507.3.9 Flashing.
At the juncture of the roof interruptions, terminations and penetrations of the roof system, vertical surfaces flashing and/or counterflashing shall be provided installed in accordance with the manufacturer’s installation instructions or the recommendations of the FRSA/TRI Florida High Wind Concrete and Clay Roof Tile Installation Manual, Seventh Edition where the basic wind speed, Vasd, is determined in accordance with Section 1609.3.1.

1507.15 Liquid-applied roofing.
1507.15.4 Flashing.
Flashing shall be applied in accordance with Section 1507.15 and the manufacturer’s installation instructions.

A new section that involves flashing for Lightning Protection Systems (LPS) has been added.

1510.8.6.Installation on roof coverings and components.
Lightning protection system components directly attached to or through metal edge systems, gutters or roof covering shall be installed in accordance with this chapter, with compatible brackets, flashing, fasteners or adhesives, installed in accordance with the metal edge, gutter or roof covering manufacturer’s installation instructions. Flashing shall be installed in accordance with the roof covering manufacturer’s installation instructions and section 1503.2 and 1507 where the lightning protection system installation results in attachment to or a penetration through the roof covering. Lightning protection system component attachment methods shall be designed by a registered design professional to resist design wind loads.

Now that we have reviewed these modifications, let me explain why these changes were submitted and approved and what we hope it accomplishes. Because some roof covering types did not include a specific flashing reference while others did, some incorrectly argued that flashing was not required in the ones lacking a specific reference. By adding a flashing section for each roof covering type, we guide the user to the code’s Definitions and General sections and the manufacturers installation instructions. Since the definitions and general sections apply to the entire chapter, many of these requirements have been enforceable in the past. The additions and changes should help clarify that all roof coverings require flashing. Generally, drip edge and metal edge are considered flashing but due to the large number of changes to their requirements  during this code cycle, we will discuss those separately in future articles.

Understanding the changes in the code’s upcoming requirements should help with planning upcoming projects. Knowing what is changing in the building code allows roofing professionals to be proactive instead of reactive and better adapt to an ever-changing roofing landscape.

FRM

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.

At this stage in the development of the new 2026 9th Edition of the Florida Building Code, we have a good understanding of what will be changing at the end of the year. The code’s effective date of December 31, 2026, seems like a long way off but we all know how time flies. Knowing which changes lie ahead is important, particularly when you are involved in planning and estimating, which require one to look into the future and consider the circumstances that can occur while the job is being done. Some of these circumstances are unknown but others, like changes in the code, are absolute. So in my columns over the coming year I will address some of the changes that will take place at the end of the year. We will also be offering a number of seminars that address the roofing-related changes, including many being presented during our 104th Convention, June 10-12, at Gaylord Palms Resort.

When FRSA submits a code modification, it is usually to address an issue that has arisen or to accommodate new roofing methods or materials. The changes that we will be reviewing in this article deal with both. These changes will primarily apply to reroofing, which includes both Roof Recover and Roof Replacement (italicized terms are those that are defined in the code). The code defines reroofing as follows:

REROOFING. The process of recovering or replacing an existing roof covering. See “Roof recover” and “Roof replacement.”
ROOF RECOVER. The process of installing an additional roof covering over a prepared existing roof covering without removing the existing roof covering.
ROOF REPLACEMENT. The process of removing the existing roof covering, repairing any damaged substrate and installing a new roof covering.

The code also has a long-standing section titled Recovering versus replacement. It covers many different circumstances and conditions and gives the user guidance as to when each is or isn’t appropriate. Each of three code sub volumes (Building, Residential and Existing Building) have a similar section. We will review the changes to the section in Existing Building since it is the most inclusive and all reroofs occur only on existing buildings.

The approved modification below will be part of the pending FBC changes (effective December 31, 2026). New language is underscored and deleted language is stricken-through; if neither is shown, it is existing code language.

9th Edition (2026) FBC, Existing Building (pending)
CHAPTER 7 ALTERATIONS – LEVEL 1
SECTION 706 EXISTING ROOFING

706.3 Recovering versus replacement.
New roof coverings shall not be installed without first removing all existing layers of roof coverings down to the roof deck where any of the following conditions occur:

1. Where the existing roof covering or roof system components covering is are water soaked or has have deteriorated to the point that the existing roof or roof covering is not adequate as a base  for additional roofing.
2. Where the existing roof covering is wood shake, slate, clay, cement or asbestos-cement tile.
3. Where the existing roof has two or more applications of any type of roof covering.
4. When blisters exist in any roofing, unless blisters are cut or scraped open and remaining materials secured down before applying additional roofing.
5. Where the existing roof covering is to be used for attachment for a new roof system and compliance with the securement provisions of Section 1504.1 of the Florida Building Code, Building cannot be met.

Exceptions:
1. Buildings and structures located within the High-Velocity Hurricane Zone shall comply with the provisions of Sections 1512 through 1525 of the Florida Building Code, Building.
2. Complete and separate roofing systems, such as standing-seam metal roof systems, that are designed to transmit the roof loads directly to the building’s structural system and that do not rely on existing roofs and roof coverings for support, shall not require the removal of existing roof coverings.
3. Reserved. Where two roof covering applications exist and the upper roof system or roof coverings is removed, or the upper roof system and original roof covering are removed, leaving an existing or repaired substrate that is adequate for installation of a new approved roof covering or roof system.
4. The application of a new protective coating over an existing spray polyurethane foam roofing system shall be permitted without tear-off of existing roof coverings.
5. Roof Coating. Application of elastomeric and or maintenance coating systems over existing asphalt shingles shall be in accordance with the shingle manufacturer’s approved installation instructions. Where the existing roof assembly includes a vapor barrier or self-adhering membrane that is adhered to the roof deck, the existing membrane shall be permitted to remain in place and covered with an additional layer of membrane in accordance with Sections 1507 or R905.

Now that you have seen the modifications, let me discuss why each change was included and what we hope to accomplish by doing so.

■ Using roof covering or roof system in item 1 instead of roof or roof covering aligns the section with existing definitions and facilitates additional changes that come after.

■ Two relatively new roofing methods and material issues have arisen since this section was originally written. One was the evolution of high R-value rigid insulation being used regularly and then later being recovered. The other was the practice of pouring lightweight insulating concrete (LWIC) over an existing roof deck and roof covering and then installing a new roof covering over the new LWIC. In each of these cases, the existing requirement states:

New roof coverings shall not be installed without first removing all existing layers of roof coverings down to the roof deck where any of the following
conditions occur: Where the existing roof has two or more applications of any type of roof covering required removing all existing layers of roof coverings
down to the deck.

This included any insulation or the LWIC which was not in the case described the deck. By adding the following in Exception 3, we will facilitate the reuse of either the original high R-value insulation or the added LWIC if it is adequate as a base for additional roofing:

Where two roof covering applications exist and the upper roof system or roof coverings is removed, or the upper roof system and original
roof covering are removed, leaving an existing or repaired substrate that is adequate for installation of a new approved roof covering or roof system.

This respects the building owner’s previous investment, makes reroofing less labor intensive and much simpler and keeps usable bulky material out of the landfills.

■ Revising or inserting (depending on the sub volume) the language in Exception 5 to include:

Where the existing roof assembly includes a vapor barrier or self-adhering membrane that is adhered to the roof deck, the existing
membrane shall be permitted to remain in place and covered with an additional layer of membrane in accordance with
Sections 1507 or R905.

This provides a method to deal with existing membrane applied directly to the deck.

Removing the existing language contained in Recovering versus replacement in Exception 5 concerning coating of asphalt shingles was done since it does not involve either recovering or replacement and inserts that language into the more appropriate B1507.2.10 or R905.2.9 Asphalt Shingles sections (shown below).

1507.2.10 Coating of Asphalt Shingles.
Application of elastomeric and or maintenance coating systems over existing asphalt shingles shall be in accordance with the shingle manufacturer’s approved installation instructions.

R905.2.9 Coating of Asphalt Shingles.
Application of elastomeric and or maintenance coating systems over existing asphalt shingles shall be in accordance with the shingle manufacturer’s approved installation instructions.

Understanding the code changes in Recovering versus replacement that will take place at the end of 2026 should help with planning upcoming projects that will be done next year or anytime thereafter. This can be very important, especially when planning multi-building projects where the scope of work for reroofing may be planned decades in advance. Planning how a building or buildings will be reroofed going forward over its life is not only a service to the owners but also for the next roofer who needs to reroof the building. Knowledge of what is absolutely going to change (building codes), will allow roofing professionals to be proactive instead of reactive and better adapt to an ever-changing roofing landscape.

FRM

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.

I wrote my first column as FRSA’s Technical Director in January of 2018. It was titled " These Are Exciting Times for Our Industry." It discussed not only the damage caused by Hurricane Irma but the many challenges that awaited our industry.

Over the years we have accomplished so many important goals. Through the dedication of our volunteer members and staff, we continue to represent our trade as true industry professionals. In any given year some things remain constant:

■ The development of the Florida Building Code is truly triennial. As soon as the new code is adopted on the last day of the year, a new cycle begins.
■ The need to share code and technical knowledge through seminars, presentations and technical articles on issues that pertain to roofing with contactors, building officials, architects and others is constant.
■ Assisting the Governmental Affairs Committee and our Legislative Counsel during the legislative sessions.

Several items, however, are unique each year. A few examples from last year include:

■ The creation and implementation of a course addressing the changes to the scope of a roofing contractor’s license, which now allows them to perform roof-to-wall connection enhancements.
■ The roll out of the new Introduction to Roofing Technology instructor training course.
■ Beginning the development of the 8th Edition of the Florida High Wind Concrete and Clay Tile Installation Manual for the 9th Edition 2029 Florida Building Code using the new ASCE 7-27 as the basis for the wind uplift resistance tables.
■ The development of a new six-hour contractor training course.

These are far from an all-inclusive list of the issues and items we will be addressing in the coming year. We have accomplished so much together but there is still much work to be done. Happy New Year to all who make this endeavor possible!

FRM

Mike Silvers, CPRC is Owner of Silvers Systems Inc. and is consulting with FRSA as Technical Director. 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.

Over the last several months, I have spoken with several roofing contractors in different parts of the state who shared their concerns about a dwindling residential reroof market. They state that this work has not only been nearly non-existent for months but that, in general, there is little of this type of roofing work going on. Many of these are very well established companies with a history of performing projects at a high volume consistently for decades. They wonder what is causing this new disturbing phenomenon. They are familiar with the cycles that have always been part of being in the roofing business but this seems different. Usually, these types of downturns happen during recessions but according to economist we aren’t currently in one. Although financial apprehension is probably part of the issue, this feels deeper than just national economy concerns. Could it be more localized and, if so, why might it be happening? How can Florida be the hottest residential reroof market one day and the opposite a short time later? Is part of the answer captured in the last sentence?

I wrote an article titled “Are 'Free' Roofs Sustainable?” in March 2020. It discussed what I called the "free roof syndrome." The following is an excerpt.

So, what about the roofing industry, how isn’t this a win for us? Many roofing contractors take great pride in how long their roofs last. For that matter, so do many manufacturers. When someone sees a roof being replaced prematurely in their neighborhood, it not only reflects poorly on the contractor but also on that type of roofing product. Most won’t know why it’s being replaced; they only see a newer roof that didn’t perform well. This causes people to reach false conclusions and that reflects poorly on the entire industry.

Also consider that when a competitor (using the word lightly) convinces the majority of people in a neighborhood that they can get them a free roof, it interrupts the normal replacement cycle that provides work for contractors who would replace them over the years, when they actually need replacement. Many of these folks are much better at selling, than roofing.

At that time, I failed to fully grasp how broad the impact of "free roofs" could be. Insurers were running scared of lawsuits brought by attorneys working with some roofers and independent adjusters that were being awarded large settlements on questionable merits. The insurers were paying for roofs at a pace that had never happened before. For many roofers at the time, it seemed like a great opportunity to sell more work. Some manufacturers jumped on the bandwagon introducing contractors to attorneys who were actively pursuing insurers and started training contractors on how to take advantage of all this work. Word got out that the cash was flowing in Florida.

Companies came from all over the country to literally cash in and many companies were started just to respond. They would canvas neighborhoods with a gang of quickly trained salespeople who knew little about roofing but were armed with an offer of a free roof that was hard to turn down. They would go door to door using the well-worn approach that your neighbor took advantage of this opportunity, are you going to miss out? Some of these companies were selling (not necessarily doing) millions of dollars of work per week. It could be characterized as a gold rush but, as get-rich quick schemes usually do, what is left behind is usually badly depleted.

As if this wasn’t enough, on top of the free roof syndrome many areas of the state were battered by hurricanes that opened the roofing market to many with less than a long-term interest in providing their customers and communities with consistent, quality roofing services. The influx of those attempting to respond to the increased demand opened the door
for many businesses that, prior to the storms and the emergency orders that followed, were not permitted to perform reroofing because they didn’t have a Florida roofing contractor’s license. Many owners replaced roofs voluntarily and sometimes prematurely due to concerns about future storms.

On top of this, those same insurers that screamed for relief from “one way attorney fees” and got it in a big way by favorable legislation, made another big change. It seems that in their reviews of the previous massive roof purchases, they gleaned some new data indicating that older roofs were partially to blame. That data didn’t seem to reveal that one reason that older roofs were being replaced so often was the insurers’ previous policy of not repairing older roofs but, instead paying out for new ones; not necessarily because they weren’t viable but to avoid lawsuits and large settlements. Once they got relief from the state for the unequal claims’ settlements, they suddenly started demanding that the insured homeowner should replace any roof that was 10 to 12 years old to help reduce future claim exposure. Even when legitimate claims were filed, it was now easier to justify denying them. So, now that they have been relieved of a fear of lawsuits from their insured, why not insist homeowners spend their money by prematurely replacing viable roof coverings to possibly save the insurers money from claims in the future. If homeowner’s baulked, they were threatened with cancellation or non-renewal. In summary:
■ the free roof syndrome driving replacement of thousands of roofs
■ hurricanes causing roof replacements both from damage and perceived damage
■ insurers insisting on premature roof replacement paid for by owners
■ homeowners’ financial apprehension.
When one considers these factors, it is no wonder that the residential reroof market is off.

With all this in mind, one could wonder what the future of Florida’s reroof market holds. Roof replacements have always been cyclical. Roofs will continue to need replacement and just as it has slowed down, it will open up again creating new opportunities down the line as these systems age and require replacement. One indication that this will eventually happen
can be found in the number of companies being formed or consolidated by larger companies supported by venture capital, private equity firms, hedge funds and similar entities. These folks don’t typically invest in markets that are going to shrink over the long haul.

These slow cycles can wreak havoc for individual companies and the industry overall. Slow downs from recessions, pandemics and unusual market forces push good contractors and other roofing professionals to leave our industry. In a profession already short on experience, losing this talent takes a toll. As an industry, we need to work hard to keep these folks involved.

What can a contractor do to help offset the currently declining reroof sales? The following are a few possibilities to add to sales:
■ Expand your service department. Consider offering annual service contracts that provide owners with peace of mind that also generate current sales and future opportunities for contractors.
■ Expand your commercial reroofing involvement.
■ Possibly pursue or expand your company’s new construction options.
■ Expand your offerings by adding options like gutters, soffits, skylights, etc.
■ Take advantage of new opportunities to enhance roof-to-wall connections.
■ Consider different ways of advertising or marketing than you have previously used.

During my tenure with FRSA, I talk to contractors every day; both seasoned and those relatively new to running a contracting business. For the most part, I have great faith in those that I talk with and their ability to adapt and thrive. Keep your chin up and know how important the service you provide is. This lull too shall pass.

FRM

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.

The question above arises from time to time, usually when a building inspector discovers someone installing shingles that have no wrappers or very plain wrappers with little pertinent information on them. The inspector may wonder whether the shingles can be used in Florida and, if so, on what kind of structures.

To understand my answer to the question, we'll start by investigating what the Florida Building Code (FBC) states about building and structure classifications. It’s important to understand that one way the FBC deals with these classifications is through risk categories. These categories refer to the type of occupancy the building will be used for and how many people can occupy it. They also consider the civil importance of the building. The factors that determine the risk category of a building are shown in the Florida Building Code, Building (FBCB), Table 1604.5 Risk Category of Buildings and Other Structures. The table uses four different categories: I, II, III and IV with I being the least important and IV being the most important. You can see this in the table on the next page.

As the code sometimes does, a catch-all category is created for when factors that determine the other categories don't apply. In this case, it determines that if a building isn’t category I, III or IV, then by default it is category II, which is the most common risk category. For years, it has been a common perception that many code requirements do not apply to risk category I structures and, in a few cases, that is true. Specifically, the structural design requirements for risk category I are less stringent, particularly for resistance to wind loads. This is accomplished in the code through the ASCE 7 standard: its wind maps reduce the category I wind speed contours in most cases by 10 mph compared to risk category II. This can be seen below when you compare the category I (left map) and II (right map) wind speed maps from FBCB.

It is clear from the contours in the wind speed maps that structural design requirements for risk category I structures are reduced (left map below). What about roof coverings and, more specifically, asphalt shingles? Are the requirements for shingles different based on risk category? Looking at the following code sections, the answer seems to be clear and contrary to a common misperception. (Appropriately, the FBC Residential subcode only includes a risk category II map because the residential subcode only applies to that risk category. So, for our investigation, we will refer to the Building subcode not the Residential subcode.)

2023 Florida Building Code, Building, Eighth Edition
CHAPTER 3 USE AND OCCUPANCY CLASSIFICATION SECTION 301 SCOPE

301.1 General.
The provisions of this chapter shall control the classification of all buildings and structures as to occupancy and use. Different classifications of occupancy and use represent varying levels of hazard and risk to building occupants and adjacent properties.

CHAPTER 4 SPECIAL DETAILED REQUIREMENTS BASED ON OCCUPANCY AND USE

453.12 Roofing.
453.12.1 Class A materials.
All roofing materials shall be labeled Class A per ASTM E108 and shall be certified by a nationally recognized independent testing laboratory. All roofing systems shall be installed within the limitations of the test procedure for surfacing, deck cross slope, and combustibility.

CHAPTER 15 ROOF ASSEMBLIES AND ROOFTOP STRUCTURES
SECTION 1507 REQUIREMENTS FOR ROOF COVERINGS

CHAPTER 2 DEFINITIONS

FRM

Florida’s roofs have never been more important than they are today. They are the first line of protection from hurricanes and severe thunderstorms. By reducing water intrusion during hurricanes, their performance impacts more than just eliminating leaks. As industry professionals know, advantages include:

■ Keeping water out of a building interior, which has a dramatic impact on the cost of damage claims that insurers must pay out post-storm and thereby the cost of homeowner’s insurance premiums.
■ Reducing the disruption for homeowners, tenants and businesses by allowing them to continue to occupy their buildings.
■ Allowing people to remain in their buildings reduces the overall local and statewide economic impact caused by post-storm disruption.

Fortunately for Florida’s citizens, the roofing industry has a homegrown 104-year-old trade organization that has demonstrated a willingness and ability to help in this critical endeavor. Through FRSA, Florida’s roofing contractors have worked with our Legislators to facilitate meaningful changes that benefit our citizens. By promoting sound ideas and helping to move others along, we have helped to improve the overall resilience of Florida’s building inventory. Even when some of these changes have created hardship for our industry, we have risen to the occasion.

Prior to and since the inception of the Florida Building Code, FRSA has championed positions that improve the effectiveness of the code. We have submitted hundreds of code modifications and advocated for others that have made Florida’s roofing code the most robust in the country, if not the world.

Recently, we were instrumental in changes to Florida Statute 627.7011, titled Homeowners’ policies that provides homeowners an option to keep their current roof by having it inspected by an authorized inspector. Florida law states an insurer cannot refuse coverage or non-renewal of a homeowner’s policy based solely on a roof’s age if the roof is less than 15 years old. For roofs 15 years or older, a licensed inspector must determine if the roof has at least three to five years of remaining usable life to maintain coverage. Roofing contractors were included in the list of “Authorized Inspectors.” Despite this change, premature roof replacements have reportedly been forced on homeowners as well as other building owners who have met that requirement. These wasteful actions can impose many problems, such as:

■ Incentivizing the purchase of cheap roof systems with short life spans that add to the ongoing cost of maintaining a resilient roof. Why should a building owner buy a better, longer-lasting roof or properly maintain it if they are going to be forced to replace it before the end of its lifespan?
■ Requiring higher condominium reserves that are partially at the heart of today’s condominium issues. Premature roof replacement adds to the need for additional reserves by reducing the effectiveness and longevity of existing roof systems. They have similar impacts on owner cost for other buildings as well.
■ Producing an enormous amount of unnecessary debris that adds to Florida’s disposal issues and our ever-growing landfills or, should I say, land mounds.

Two other important initiatives that have been supported by FRSA recently can improve the roof structures on buildings built prior to the adoption of the FBC in 2002. These changes can improve the connections that hold a roof structure to the walls of the building. Failure of these connections can lead to catastrophic damage to the building and its contents. The changes include:

■ Expanding the type of buildings where code hurricane mitigation requirements apply. Originally, they only applied to certain site-built single-family structures. Now they apply to additional existing structures with a sawn lumber, wood plank or wood structural panel roof deck. This brought in many other types of buildings, including apartments, retail and manufacturing.
■ Allowing roofing contractors to evaluate and address the roof-to-wall connections during a roof replacement. This was accomplished by a change in the definition of a roofing contractor in Florida statutes. This is a logical change since a roof replacement (reroofing) permit triggers the need for the evaluation and, in Florida, only licensed roofing contractors can normally perform reroofing work.

So, we have clearly made strides in allowing those who know the most about roofing to have some impact in finding ways to improve their performance. However, a crucial part of the puzzle that will allow roofing contractors to be a part of the solution is still missing.

The existing OIR 1802 form – and a new proposed OIR 1802 (2025) form – that many insurers use to calculate discounts for homeowners’ policies require qualified inspectors to answer nine questions. Eight of the nine questions deal directly with items that fall under the scope of a roofing contractor's license. The ninth question partially involves roofing because skylights are included in the opening protection section. There is no one better qualified to answer those eight questions than a roofing contractor. Amazingly, there isn’t a way for us to directly lend our expertise to verifying the roofing questions on the form, unless requested by an insurer – not by the owner who paid for a roof replacement. Our customers expect those who can legally perform this work to provide them with a clear method of demonstrating that the work they have paid for will provide them with all the premium discounts they are entitled to receive. We need to find a way to correct this oversight, hopefully, before the new form is published.

Moving forward, our next step will be to attempt to maintain the progress made on these items by including the ability for roofing contractors to complete this very important form. More broadly, we will continue our efforts to bring all segments of our industry together to improve a building's ability to resist the impacts of Florida’s challenging environment.

FRM

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 who brings over 50 years of industry knowledge and experience to FRSA’s team.

Under statute 553.844 Windstorm Loss Mitigation; Requirements for Roofs and Roof Opening Protection, Florida mandates that the Florida Building Commission develop and adopt certain mitigation techniques that, among others, include improvements to roof-to-wall connections. Through its rule making authority and procedures, the Commission has adopted criteria that mandate when evaluation and possible improvements of the roof-to-wall connections are required by the Code. The Florida Building Code-Existing Building, Chapter 7 Alterations Level 1 states:

706.8 When a roof covering on an existing structure with a sawn lumber, wood plank, or wood
structural panel roof deck is removed and replaced on a building that is located in the windborne
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: Structures permitted subject to the Florida Building Code are not required to comply
with this section.

The reroofing of a structure located in the windborne debris region (WBDR) can trigger the need to address roof-to-wall connections, as well as the need for impact-resistant skylights, so understanding where these regions are and how they are defined is important to roofing contractors. Figure R301.2(4) below shows in blue the current locations of the WBDR.

In areas where the ultimate design wind speed, Vult, is 140 mph (63.6 m/s) or greater; or Hawaii.

Within 1 mile (1.61 km) of the coastal mean highwater line where an Exposure D condition exists
upwind at the waterline and the ultimate wind speed, Vult, is 130 mph (58 m/s) or greater.

As you can see, there are a lot of caveats in section 1. First, you need to confirm where the coastal mean highwater line is located. This line can be very difficult to locate or verify. Then you must establish if your job is within one mile of that obscure line. The narrow-dashed lines shown on page 12 in Figure R301.2(4) represent the locations along the coast between the 130 mph and 140 mph contour lines that are currently included in the WBDR. The location of inland WBDR in Figures 1, 2 and 3 would be even harder to establish if they were to be included in the code. Attempting to find the exact location of your job on these small maps is difficult at best.

Designated areas where the ultimate design wind speed, Vult, is 130 mph (58 m/s) or greater.

 

This definition would add areas in Central Florida and the Panhandle to the WBDR (compare Figure 4 below to Figure R301.2(4) on page 12 ) but eliminate the confusing language – "within 1 mile from the mean highwater line" – that, as we have said, is hard to verify. The tradeoff is a well-established, simple and verifiable WBDR boundary that will make contractor compliance much more straightforward.

 

 

During a July meeting of FRSA’s Codes Subcommittee, this issue was discussed and a decision was made to support the effort to simplify the WBDR requirements moving forward.

Note: Several figures used in this article were taken from a report titled: Investigation of the Windborne Debris Regions in ASCE 7-22, prepared by the Engineering School of Sustainable Infrastructure and Environment (ESSIE), University of Florida (UF) presented to and accepted by the Florida Department of Business and Professional Regulation, Florida Building Commission.

FRM

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.

Our members’ ongoing desire to remain up to date on building code issues is a testament to their professionalism. Our representation at the June Florida Building Commission’s Technical Advisory Committee (TAC) meetings in Gainesville demonstrates how serious our industry is about being part of the process.
We are fortunate to have five FRSA members who serve on the Commission, Roofing and Energy TACs and workgroups. Several members of FRSA’s Codes Subcommittee also joined us. This set of meetings was for the TACs to consider public comments or proposed code modifications submitted during the first
45-day comment period.

With the continued support of our leadership, committees and members, I have the privilege of presenting our positions both for approval or denial before the various TACs. It is just as important to block unfavorable changes as to include beneficial ones. Our positions have been previously decided on and approved by our Codes Committee and Board of Directors. Our positions prevailed in 142 of 150 of the modifications that the Association took a position on. Only a few of the eight that didn’t go our way are of any significance. Our Codes Subcommittee will meet and review our position on those and any others that need our attention. We will work with other stakeholders as needed to offer alternate language during the second 45-day comment period.

Any modification can be brought back for reconsideration by a public recommendation or by submitting proposed alternate language. Those changes will be either denied or approved by the TACs and then forwarded as the TACs recommendations to the Commission for its final decision. To receive a TAC recommendation for approval, a 66 percent threshold is needed and approval by the Commission requires a 75 percent threshold. So, there is still a lot of work to be done, presentations to be made and votes to be taken – nothing is etched in stone quite yet but, with that said, we now have a good idea of what the new code should look like. As the code progresses, we will share that information over the coming months and year through articles, meetings and seminars to prepare you for what changes to expect in the new 2026 9th Edition of the FBC that will become effective on December 31, 2026.

The success we’ve had with our positions has been aided by our collaboration with many other stakeholders, including TRI, ARMA, FHBA, BOAF, Miami-Dade
County and others. By communicating with them ahead of the meetings and explaining why we intend to take a particular position, we greatly increase our
chances of success. By including representatives from all segments of the roofing industry on our Codes Committee, we can offer proposals and take positions
that have been thoroughly reviewed and vetted, adding credibility to our positions.

We owe gratitude to those who graciously volunteer their time to serve on the Commission, TAC or workgroup capacity. We also want to thank the members of our subcommittee and all our dedicated members who help to steer our efforts in improving the code. FRSA is viewed as a group that finds solutions to code-related issues and has led the effort to make Florida’s roofing-related code requirements – by every measure – the most effective in the country. The consistency in which we have approached the challenges we have faced for our trade, our industry and, most importantly, Florida’s citizens, continue to elevate the overall perception of our trade and what our industry brings to the table.

Program Oversight Committees (POC) and Workgroups

(Underlined committees indicate FRSA involvement)

Program Oversight Committees (POC)
Product Approval POC
Education POC

Technical Advisory Committees (TAC)
Accessibility TAC
Building Administration
Building Structural
Building Fire
Electrical
Energy
Hurricane Research Advisory Committee
Mechanical
Plumbing
Roofing
Special Occupancy
Swimming Pools

FRM

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.

The definition of a “roofing contractor” was added to the Florida Statutes Chapter 489 in 1975. This established the services or scope of work that a roofing contractor could perform. Only once prior to May 19, 2025, has there been a major expansion in the services that roofing contractors can offer and perform. In 2008, the following was added to the definition of a roofing contractor in the statutes:

"The scope of work of a roofing contractor also includes required roof-deck attachments and
any repair or replacement of wood roof sheathing or fascia as needed during roof repair or
replacement."

Before that expansion, in many jurisdictions you had to be a Division I contractor to do any sheathing work because it was considered structural. For context, I’m paraphrasing FS 489.113:

"Contractors are subdivided into two divisions, Division I, Residential, Building and General
contractors as defined in paragraphs (a)-(c), and Division II, consisting of those contractors defined
in paragraphs (d)-(q): which includes (e) Roofing contractor."

This 2008 expansion wasn’t passed to make roofing contractors’ jobs easier, although it did, it was done to accommodate the desire to add fasteners to roof sheathing on homes permitted for construction prior to the implementation of the Florida Building Code (FBC). This was a part of the code’s extensive hurricane mitigation requirements. That change, however, made it clear to all jurisdictions in Florida that roofing contractors could do that work. This effort to address enhanced sheathing attachment has clearly worked with most of the applicable structures, having been addressed.

Now, for the first time in 17 years, another major change has once again expanded our scope of work. With the passage of HB 715 (an act relating to roofing services) along with the Governor’s signature on May 19, the following was added to the definition of a roofing contractor:

"and the evaluation and enhancement of roof-to-wall connections for structures with wood roof
decking as described in Section 706 of the Florida Building Code-Existing Building, provided that
any enhancement, which was properly installed and inspected in accordance with the Office of
Insurance Regulation uniform mitigation verification inspection form, the Florida Building Code, or
project specific engineering that exceeds these requirements, is done in conjunction with a roof
covering replacement or repair."

Yes, there is a lot there but, rest assured, it will benefit our trade in both obvious and not so obvious ways.

A roof replacement permit triggers the requirement to address many of the FBC’s hurricane mitigation sections. Yet many jurisdictions would not allow roofing contractors to evaluate, enhance or even provide estimates that addressed roof-to-wall (RTW) connections. This, when a roofing contractor is typically the only contractor who can perform roof replacement. Those days should now be behind us as the options to evaluate, provide pricing and enhance are all now available. The bill became effective when it was signed by the Governor. Make no mistake, this has real world implications for those who perform roof replacements.

On the not so obvious side, please note that the combined vote of both the House and Senate that allowed the bill to pass was 149 to 1. Yes, you read that right. Just a few years ago, when “roofers’” reputations were being trashed, linking us to fraudulent insurance scams, I’m not sure the vote might not have been the other way around. FRSA and the roofing industry have worked diligently to claw back much of our reputation that could have been permanently lost. The passage of this law now clearly states that a roofing contractor can address these RTW connections. For many contractors, the question should be, are we prepared and knowledgeable enough to jump into this complex work? If the work is not done right, our reputation will again be under attack and we could easily lose the ground we’ve gained.

A special note to all those involved in the preparation, planning, lobbying and, at times, even arm twisting that was provided by our Legislative Counsel, Chris Dawson and the whole FRSA team – my sincere thanks for making this happen.

FRM

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.

On May 19, 2025, Governor Ron DeSantis signed House Bill 715 (HB 715) into law, enacting significant updates to Florida’s roofing regulations. Effective immediately, the law introduces key changes for roofing contractors and residential homeowners, particularly regarding contracts executed during a declared state of emergency.

The following outlines the most notable changes introduced by the “Roofing Services” bill, highlighting new consumer protections for homeowners and tighter compliance requirements for roofing contractors – especially in the context of declared emergency situations.

What is the “Roofing Services” Bill / HB 715?

HB 715 reflects Florida’s ongoing commitment to hurricane preparedness and consumer protection by:
■ Allowing roofing contractors to perform critical roof-to-wall strengthening work,
■ Clarifying and tightening homeowners’ cancellation rights following emergencies and
■ Mandating clear insurance coverage notices in all residential roofing contracts.

In response to these changes, contractors should update their contract templates to include the new insurance notice and adjust cancellation language as required by HB 715 and also train their teams on the expanded scope of roofing work and updated compliance standards. Homeowners are encouraged to familiarize themselves with their cancellation rights and verify insurance coverage and policy terms with their providers before signing any roofing contract.

How are Roofing Contractors Impacted by HB 715?

Historically, licensed roofing contractors in Florida were not authorized to evaluate or improve roof-to-wall connections, commonly called “hurricane straps,” which are critical structural components that help protect buildings during high-wind events.

HB 715 changes that by expanding the definition of “roofing contractor” to include the evaluation and enhancement of roof-to-wall connections for structures with wood roof decking, as specified in Section 706 of the Florida Building Code. These enhancements must:
■ Be performed in conjunction with a roof covering replacement or repair and
■ Be installed and inspected according to the Florida Building Code, the Office of Insurance Regulation’s (OIR) uniform mitigation verification inspection form or project-specific engineering standards that exceed these requirements.

This revision provides greater flexibility for homeowners seeking to strengthen their homes against future storms and creates new business opportunities for licensed roofing contractors.

Who Benefits From HB 715?

Under previous law, homeowners who signed roofing contracts after a declared state of emergency could cancel the contracts within 10 days of signing or before work began. HB 715 keeps this 10-day cancellation right but clarifies the roofing contract must be signed within 180 days of the event that caused the emergency. This change aims to protect homeowners from rushed or opportunistic contracts after disasters while providing clearer rules around cancellation rights.

How Does HB 715 Affect Insurance Notices in Roofing Contracts?

To increase homeowner awareness, all residential roofing contracts must now include the following advisory in bold, 14-point font:

“If the proposed work is related to an insurance claim, you, the residential property owner,
should contact your insurance company to verify coverage for the proposed roofing work, including
any claims, deductibles, and policy terms, before signing this contract. By signing this contract,
you acknowledge that you have been advised to contact your insurance provider regarding
coverage and reimbursement of the proposed work.”

This new notice requirement aims to improve homeowners’ understanding of their insurance coverage, helping to prevent disputes and reduce the likelihood of denied claims.

What Contract Formatting Changes is HB 715 Requiring?

Previously, roofing contracts signed during a state of emergency had to include a cancellation notice in 18-point bold font. HB 715 lowers this to 14-point bold font, matching the size of the new insurance notice. This subtle change helps streamline contract formatting while maintaining the prominence of required disclosures.

Conclusion

HB 715 introduces important updates to Florida’s roofing laws, enhancing consumer protections and tightening contractor requirements. By expanding roofing contractors’ scope of work, clarifying homeowners’ cancellation rights and requiring clearer insurance notices, the law better supports both homeowners and contractors, especially during declared states of emergency. Contractors and homeowners alike should understand these changes to ensure compliance and promote stronger, safer roofing practices throughout Florida.

FRM

Chris Dawson is an Attorney and professional Lobbyist for GrayRobinson’s Orlando office and is licensed to practice law in both Florida and Alabama. He primarily focuses on lobbying and government relations for public and private sector clients at the executive and legislative levels of state government. He is credentialed as a Designated Professional Lobbyist by the Florida Association of Professional Lobbyists. Chris also holds two degrees in Civil Engineering and has experience in construction litigation and design professional malpractice defense.

When answering calls for FRSA, I never know what the primary topic of the conversation might be. Calls come from consumers, engineers, architects, building officials and others but primarily they come from our members: contractors, manufacturers and distributors. Some are easy to address and are repeated often. Others can be complex and may be the first time the question has arisen. I took one of the latter from a contractor a few days ago. He explained that he was about to start a new low-slope roof system installation. During a walk-through, he noticed that the internal roof drainage point didn’t have a roof drain, just a PVC pipe flush with the top of the metal deck. He inquired why this was the case and asked, “where is the roof drain?” The designer said that it wasn’t  required and then said, “show me where it says in the building code it’s required.” I get questions about where a specific requirement is located in the building code, often. As those who are
familiar with the code know, it is not presented in a question-and-answer format and only the simplest questions can be answered in a single section. More often, the answer is found by navigating a pathway that leads you to it. That was the case here.

Before diving into specific code sections, a little background information was needed. When an internal roof drainage system is routed through the interior of a building, it needs to be sealed. If there is any chance that the drain could back up, it must be sealed to resist leakage from a head of water or head pressure. The
pressure is created by water building up on the roof and in the leader as well. In cases where the seams in the drain leaders and downspout occur outside the building, a gravity seal or lap is acceptable. This arrangement was used often during mid-century construction that employed what we referred to as "porch tubes." These were typically used in buildings with overhangs and soffits. A porch tube is like a scupper except it flows straight downward – as opposed to a scupper that extends through a wall or mansard. It should be a sealed unit until it extends through the soffit. If the termination is left open and of sufficient size, blockage won’t occur. If it is run into a downspout and blockage does occur, the leakage from the laps will happen outside of the building envelope. It may only take one turn or elbow to eventually create a blockage. In a more typical drainage system routed through the building interior, there can be many reasons for the drain to stop flowing properly that including:
■ Clogging or restrictions from debris
■ Rainfall in amounts that exceed the flow rate of the system
■ Flooding that limits the outflow of the storm drainage system or outlets near the ground
■ A combination of two or more of the above often occur during hurricanes.

Most experienced roofers that provide repair services on low-slope roofs have come across the inverted lead boot or other similar arrangement, stuffed into a roof drain or the roof drain leader or piping. When heavy rain or blockage occurs, head pressure is created in the system and often causes severe water intrusion and interior damage. The drain at its flashing and any connections inside the structure must be sealed to resist this pressure. With a standard cast iron or PVC roof drain, this is accomplished by a clamping ring that uses the flashing material as a gasket between the drain body and the clamping ring. Other arrangements offer a flashing flange that can be stripped-in or heat welded to. The termination of these drains or flashing arrangements inside the leader must be sealed. Some of these use an inner expansion unit that expands through different mechanisms to create a seal to the inner part of the leader. When using these, the inside of the leader must be clean and relatively smooth: again, think of a gasket effect.

In my opinion, the following code sections lead us down a path to answer the question "are drains required?" We will not address all the sizing and
other drainage requirements in the code. They are voluminous. I do hope to demonstrate that drains are required in the circumstances described and they must accommodate the ability to be flashed in compliance with the roof covering manufacturer’s installation instructions. Note: For emphasis, I have bolded some of the text in tech code paragraphs below.

2023 Florida Building Code, Building, Eighth Edition Chapter 15 Roof Assemblies and Rooftop Structures

SECTION 1501 – GENERAL
1501.1 Scope. The provisions of this chapter shall govern the design, materials, construction and quality of roof assemblies, and rooftop structures.

SECTION 1502 – DEFINITIONS
1502.1 Definitions. FLASHING. The roofing component
used to seal roofing systems, where the system
is interrupted or terminated.

SECTION 1503 – WEATHER PROTECTION
1503.1 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 coverings shall be designed in accordance with this code and installed in accordance with this code and the manufacturer’s approved instructions such that the roof covering shall serve to protect the building or structure.

1503.4 Roof drainage.
Unless roofs are sloped to drain over roof edges, design and installation of roof drainage systems shall comply with Section 1503 and the Florida Building Code, Plumbing, Chapter 11.

1503.4.1 Secondary (emergency overflow) drains or scuppers. Where roof drains are required, secondary (emergency overflow) roof drains or scuppers shall be provided where the roof perimeter construction
extends above the roof in such a manner that water will be entrapped if the primary drains allow buildup for any reason. The installation and sizing of secondary emergency overflow drains, leaders and conductors shall comply with Sections 1106 and 1107, as applicable, of the Florida Building Code, Plumbing, Chapter 11.

SECTION 1506 – MATERIALS
1506.1 Scope. The requirements set forth in this section shall apply to the application of roof-covering materials specified herein. Roof coverings shall
be applied in accordance with this chapter and the manufacturer’s installation instructions. Installation of roof coverings shall comply with the applicable provisions of Section 1507.

SECTION 1507 – REQUIREMENTS FOR ROOF COVERINGS
1507.1 Scope. Roof coverings shall be applied in accordance with the applicable provisions of this section and the manufacturer’s installation
instructions.

2023 Florida Building Code, Plumbing, Eighth Edition
CHAPTER 11 – STORM DRAINAGE
SECTION 1101 – GENERAL
1101.1 Scope. The provisions of this chapter shall govern the materials, design, construction and installation of storm drainage.

1101.6 Fittings and connections. All connections and changes in direction of the storm drainage system shall be made with approved drainage-type fittings in accordance with Table 706.3. The fittings shall not obstruct or retard flow in the system.

1101.7 Roof design. Roofs shall be designed for the maximum possible depth of water that will pond thereon as determined by the relative levels of roof deck and overflow weirs, scuppers, edges or serviceable drains in combination with the deflected structural elements. In determining the maximum possible depth of water, all primary roof drainage means shall be assumed to be blocked. The maximum possible depth of water on the roof shall include the height of the water required above the inlet of the secondary roof drainage means to achieve the required flow rate of the secondary drainage means to accommodate the design rainfall rate as required by Section 1106.

SECTION 1102 – MATERIALS
1102.6 Roof drains. Roof drains shall conform to ASME A112.6.4 or ASME A112.3.1. Roof drains, other than siphonic roof drains, shall be tested and rated in accordance with ASME A112.6.4 or ASPE/IAPMO Z1034.

SECTION 1105 – ROOF DRAINS
1105.1 General. Roof drains shall be installed in accordance with the manufacturer’s instructions. The inside opening for the roof drain shall not be obstructed by the roofing membrane material. 1105.2 Roof drain flow rate. The published roof drain
flow rate, based on the head of water above the roof drain, shall be used to size the storm drainage system in accordance with Section 1106. The flow rate used for sizing the storm drainage piping shall be based on the maximum anticipated ponding at the roof drain.

1102.6 Roof drains. Roof drains shall conform to ASME A112.6.4 or ASME A112.3.1.

ICC Commentary
ASME A112.6.4 regulates the design and construction of roof drains. Roof drains must have either a dome or grate covering the opening. This helps restrict leaves and debris from entering the storm drainage piping and creating a stoppage. Because roof drains are exposed to extreme temperatures, it is common practice to install an expansion joint between the roof drain and the storm drainage pipe.

ASME A112.3.1 provides details for Types 304 and 316L stainless steel roof drains.

Conclusion

Based on these passages, it seems clear that the Florida Building Code assumes that roof drains are required when part of a storm drainage system. Regardless of the type of drain used, it is imperative that the attachment of the drain and the leader prevent undue movement where they intersect with the roof assembly. Most importantly, a pressure seal is required when a head of water could possibly occur in the drainage system. The code says that all primary roof drainage means shall be assumed to be blocked, so head pressure must also be assumed. It is also clear that the roof covering shall be installed according to manufacturer’s installation instructions which include roof drain flashing.

FRM

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.

Lisa Pate, FRSA Executive Director

At the end of March, FRSA held its third annual Roofing Day in Tallahassee, where a small group of members visited the Capitol to speak with legislators. The event mirrored NRCA’s successful Roofing Day in D.C. Spearheaded by Governmental Affairs Committee Chairs, Ralph Davis, Streamline Roofing & Construction Inc., Tallahassee and Tammy Hall, CFS Roofing Services LLC, Ft. Myers and organized by FRSA Legislative Counsel, Chris Dawson, the group held several successful meetings over the three-day event.

With the legislative session only a week in, some of the topics we addressed were just being presented to members of the legislature and were new to our group as well. Chris was able to schedule meetings with several key legislators who focused on business, education, building codes, workers’ comp and contractor fraud.

In order to cover as many meetings as possible, attendees broke into two groups. Meetings were held with Representatives Taylor Yarkosky, Dan Daley, Tom Fabricio, Jennifer Canady, Griff Griffitts, James Buchanan and Mike Redondo. Senators included Tom Leek, Stan McClain and Kristen Arrington. Top legislative priorities for the team included:

■ Supporting HB 715 and SB 1076 – Roof-to-Wall Connections – which has since passed both the House and Senate and is headed to the Governor to sign. If signed by the Governor, it will allow roofing contractors to perform roof-to-wall connections when reroofing. Currently, that function is outside the scope of a roofing contractor’s license. The bills also clarify the length of a State of Emergency for roof repair contract cancellation window available to consumers and limits the amount of time up to 180 days following the triggering event. Meaning that even if the Governor extends a State of Emergency, the cancellation contract language will only be required for 180 days per qualifying event.

■ Advocating for Protecting Consumer Choice and asking for support to keep asphalt shingles an approved roofing system. All roofing systems that meet the rigor of the Florida Building Code should be available to consumers without undue market influence from Tallahassee (Office of Insurance Regulations Commissioner Yaworsky). Premature roof tear-offs should be avoided to promote long-lasting, resilient roof systems of all types. Homeowners should be incentivized to invest in resilient roofing systems without fear of an arbitrary life span being imposed.

■ Support for HB 681 and SB 1458 – Apprenticeship and Preapprenticeship Program Funding. Early exposure to career opportunities in the trades will help students evaluate all postsecondary and career planning options. CTE dollars should be delivered in a student-first model, cutting down on bureaucratic waste.

■ Support for HB 1461 and SB 1452 – DBPR to Provide True Oversight of Employee Leasing Companies.

The meetings were all very productive and the team had the opportunity to provide additional language for consideration on some bills. Chris was able to keep us on task, focused and on time – no small feat. Special thanks to our sponsors
Eagle Roofing Products and the Southwest Roofing Florida Roofing Contractors Association (SWFRCA) for underwriting the expense.

FRM

Anyone doing a fair analysis of roof-related construction failures after high wind events knows that materials pulling through or over fasteners (pullthroughs), are often seen. From my observations, pull-through is far more often the failure mode than fastener pull out. There are many different types of roofing fasteners that are installed differently depending on the material being fastened. We see this pull-through condition with asphalt shingles, nailed underlayment and even sheathing.

I want to concentrate primarily on those materials that are fastened with nails and, most often, by pneumatic (air powered) nail guns. Shingle failures observed often demonstrate that the shingle has pulled over the fastener, leaving holes in the shingles found in debris piles and by the nails still present on the roof. When these are observed, the question comes to mind, did the uplift forces created by high winds pull the material over the nail head or is it possible that the fastener was driven at least partially through the shingle during its application? The answer is hard to determine after the fact but we do know that overdriven fasteners are regularly observed during shingle applications. Why is this seen so often? This condition is often blamed on improper air pressure being supplied to the nail gun. This does have merit but there may be more to consider.

Proper pneumatic tool performance depends not only on consistent pressure measured as pounds per square foot (psf) but also sufficient volume delivered to the tool measured as cubic feet per minute (cfm). In theory, the best way to provide both is with a compressor dedicated to a single tool or gun with a relatively short hose. In practical application, that arrangement is seldomly provided or used. Instead, one compressor will supply several applicators. The job set-up may include multiple fittings, connectors, manifolds or tees and several long hoses. Each of these will limit the cfm being delivered to the tool. When the tool is not in use a constant pressure is achieved throughout the set-up but when air is used, the pressure begins to drop. If sufficient volume (cfm) cannot be maintained, the pressure will continue to drop. One way to compensate for this is by starting with more pressure. However, this leads to overdriving the nail and will eventually lead to lower pressure. The problem of maintaining consistent volume and pressure also arises when multiple users stop and start using their tools, which occurs often when installing roof coverings.

Since the observed pull-through failures may often be caused by these air pressure and volume installation issues, it may be unfair to blame the product.

Why are overdriven fasteners observed more often during inspections than underdriven fasteners? An underdriven fastener will affect the application by causing an easily observed bump in the shingles. It will eventually create a hole in the shingle causing a leak and a call back. To avoid this, an applicator must stop and use a hammer to drive the nail flush with the material. So, if your job performance is judged by the quantity of material that you install which of these might you choose? Overdriven nails that go unseen and allow you to proceed unfettered or underdriven nails that interrupt the pace of your work every time they occur? Near perfection can be hard to obtain but, in this instance, one has to strive for proper roof covering performance.

Are there possibly other reasons nails applied with nail guns are so often overdriven? Overdriven nails were not a problem when nails were hand driven with a hammer. I’m not suggesting that we abandon nail guns but why weren’t overdriven fasteners a problem when hammers were used? One could think that hand driving would cause greater care in driving the nail but I can tell you that someone proficient in hand nailing shingles doesn’t tap them in until they are flush. Instead, they give the nail a tap to set it in place and to allow them to move their fingers from under the head and then drive the nail flush to the shingle in one hard hit. The nail can’t be overdriven, not because of strength (pressure) being applied but because the hammer head contacts the surrounding material and the fastener is then properly set.

A pneumatic nail gun has a driver or striker that drives the nail like a hammer head but, unlike a hammer head, it is smaller in diameter than the head of the nail it is driving. This allows the nail to be driven deep into the material, acting like a hole punch and eliminating or greatly reducing the ability of the nail head to prevent the shingle or other material from pulling through (or over) the nail. This reduces the ability of the applied material to perform properly.

This phenomenon is not limited only to roofing material. While presenting a report to the Florida Building Commission on the University of Florida’s mitigation assessment team findings from Hurricanes Helene and Milton, Dr. David Prevatt noted that roof sheathing pulling over the nails was observed by the team. This obviously causes serious water intrusion and sometimes catastrophic structural failure. The data wasn’t available to determine if there was a difference in performance because of oriented strand board (OSB) or plywood use. But one must wonder if fasteners being driven partially or totally through the sheathing is related to the failures.

Clearly, I’m not in the pneumatic nailer business. Having used, purchased and repaired dozens of them, I know that much hasn’t changed in their basic design in over 30 years. However, expectations for buildings, building components and claddings (roof coverings) certainly have changed. The wind resistance of roof coverings has never been more important and more scrutinized than they are now. Yes, I am aware that most things are easier said than done. I do, however, have great faith in our ability to solve problems, especially one that persists and is important to so many. Is a nail gun with a larger head or a depth sensor that eliminates over driven fasteners too much to ask for? Maybe so but it could go a long way towards increasing the wind resistance performance of many critical building components.

FRM

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.

The last several weeks have been extremely busy; maybe hectic would be a better word. We’re on the frontline on many issues – some that we’ve not faced before but are working with industry partners to ensure we can keep doing what we do best. Sadly, there are those that think they know more than we do about roofing systems we install every day.

Fortunately, FRSA’s had an opportunity to influence or offer additional language to make most of these items palatable for contractors. We do our best to stay in front of issues but at times, it’s challenging. This is especially true when the state Legislature is in session, the Florida Building Commission codes modification submission process is in full swing and several pressing issues coalesce at one time.

The Building Commission

Recently, we completed phase one of the code modification process that integrated changes made in the 2024 International Building Code (IBC) into the 2026 9th Edition Florida Building Code (FBC). Phase two is where members of the public (FRSA included) can propose modifications (mods) to be considered for incorporation into the new code. Submissions ended mid-February and, at the beginning of March, they were posted on the FBC website. I reviewed all 557 mods, looking for ones that merited our attention. FRSA proposed 39 modifications, all approved by our Codes Subcommittee and the Codes Committee. From mods proposed by other entities, I pulled 162 for review during several upcoming meetings with the Codes Subcommittee to determine whether we support or oppose each change. As time permits, we will also seek approval from the Codes Committee. In between quarterly committee meetings, FRSA’s Board of Directors has given the Codes Subcommittee the
authority to make decisions on FRSA’s behalf regarding these matters.

The group will present FRSA's positions to the Commission’s Technical Advisory Committees (TACs) during the first of two reviews scheduled for mid-to-late June. Moving forward, I will try to keep you informed on the progress of the changes – mods that we like and, just as importantly, those we don’t. This is a grueling process that takes most of the three-year code cycle to accomplish. We deeply appreciate the volunteers who devote their time and energy to make this process so successful. Often, we work with other industry partners to accomplish some of this work. Most recently, we’ve worked with the Asphalt Roofing Manufacturers Association (ARMA) on many of FRSA’s and ARMA’s modifications, as well as some submitted by others, that will continue to improve the performance of roof coverings in Florida. This is a process that we can take the lead on or one that is forced on us by folks – unhindered by their lack of experience and knowledge – who propose unreasonable and ineffective modifications.

Legislation Involving Technical Issues

Speaking of grueling processes, the legislature is in session and the ride is fast and can get a little bumpy at times. Much like the building code, it’s about looking at everything that can help and hurt you (a big job), taking positions and suggesting improved language. It is also a time when we can move our positions forward. I’ll mention a few of those positions here that have been on our radar recently. One thing we like and have been working on is adding the evaluation of roof-to-wall connections to the roofing contractor license scope including training enhancement for contractors who want to perform such work. One of the things we don’t like is the attempt by some in the government to place their thumb on the scale, so to speak, concerning which roof coverings we or homeowners can choose.

FRSA is collaborating with ARMA and other industry groups to keep all proven roof systems competing on a level playing field. Knowledgeable roofing industry professionals understand that there isn’t enough solid data on roof system failures to eliminate any roof type. We are extremely fortunate to have Chris Dawson, GrayRobinson, as our Legislative Counsel, doing great work on our behalf in Tallahassee. Also, a personal thanks to Ralph Davis, Streamline Roofing and Construction, Tallahassee for being available to testify on our behalf before the legislature. Because Ralph lives in Tallahassee, we often call on him last minute to testify on FRSA's behalf. He does an amazing job and represents us well.

I was recently in Tallahassee to be part of a panel for the Florida House Subcommittee on Industries and Professional Activities. The topic was on licensure and regulation affecting contractors. It was very interesting to hear where other professionals and the legislators stood on several issues at the meeting. I mentioned one item that is an impediment to new contractors is the availability and cost of insurance. A topic that most of the other panelists reinforced. The appearance also gave me a chance to pitch our roof-to-wall connection issue to the subcommittee that will be hearing it. So far, so good.

The Office of Insurance Regulation

In the last two issues of Florida Roofing magazine, I dedicated my column to the comments and actions on roof type selection by OIR an various House and Senate hearings mentioned above. These discussions have been the cause of the most recent roof covering issues. Since then, an attempt by OIR to rewrite the OIR-B1-1802 Adopted by Rule 69O-170.0155 wind mitigation form has been seen by many as a chance to push a self-serving agenda that would be misleading and harmful for Florida’s property owners. OIR’s attempts to make changes are clearly well intended but may be relying on slanted or incomplete information. FRSA will carefully monitor related activities and offer our opinions and relative information at every opportunity as this process moves forward.

FRSA Affiliates, RICOWI and Moving Forward

The roof covering issue has focused a lot of attention on the roofing industry, both locally and nationally. We have presented programs on the subject to some of our local affiliates and, more recently, at the Roofing Industry Committee on Weather Issues annual meeting held in Orlando. It will continue to be a hot topic during the coming months. FRSA will continue to make our presence known in the discussions that will influence this issue and many others going forward.

FRM

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.

Well designed and engineered products are critical to the construction industry and particularly the Florida roofing industry. The unique combination of environmental challenges in Florida has driven the creation of very specific products to handle the high wind events we experience. However, the significant investments
made in development, testing and market introduction of these high-performance products are all for naught if the product is not installed correctly.

Our industry further recognizes the importance of proper selection and installation of these high-performance products by adding a layer of third-party regulatory oversight known as permitting and the subsequent inspecting of the project. While day to day interactions between inspectors and installers can at times be tense, it is important to recognize that both parties (hopefully) share the same goal – ensure that the roof being installed will perform as designed to keep the homeowner secure and dry.

As a manufacturer of roof tile adhesive, we recognize the importance of clear instructions and training to the performance of the overall roof system. To that point, the product approvals for all roof tile adhesives require that the installers are factory trained and certified on the product.

In the 13 years I’ve been involved in the Florida roofing industry, it became apparent that an opportunity existed to make it easier for both the installer and the inspector to ensure that our roof tile adhesives are installed properly. We began by updating our instruction manual with clearer drawings and more specific instructions. This carried into our Florida Product Approvals utilized in the vast majority of Florida counties. However,
an opportunity remained in the High Velocity Hurricane Zone (HVHZ) with the Miami-Dade tile system NOAs.

As many who work in the HVHZ know, not only do the components need to have product approvals but each tile system also must have its own lab tested approval or NOA. The tile NOA’s are used in the permitting process where the required uplift for a specific roof is calculated and then compared against the uplift delivered in the lab testing. As manufacturers, we have several configurations and amounts of adhesive listed with different uplift values. It can be confusing in the field, for both installers and inspectors, to ensure that the correct system is being used. To that end, footnotes are added to the tile NOA table with the intent on clarifying these requirements.

Historically, the measurement of the correct amount of foam has been grams. I suspect this goes back to the beginning when two component adhesives were introduced. These require a small food scale as part of the calibration process, so utilizing grams may have begun with that. This is not the case with single component adhesives. It seems to me that grams are not a practical measure, especially on a roof. We explored the idea of using contact area as the key measure. This can easily be measured in the field. A tile can be removed right after being set in foam and
the contact area of the adhesive to the tile measured.

Last fall, we presented this information to the Miami-Dade product approval department with support of the Miami-Dade inspection department. We made a number of recommendations regarding the use of contact area and the information presented in the NOA.

I’m happy to report that Miami-Dade is now publishing the contact area of the foam to the tile in the same table with the grams of foam in the tile NOA. These updates will be made as the tile NOAs are revised. I believe this is a major step forward in ensuring that a tile roof is installed properly the first time. It provides a simple, measurable specification, that both the installer and inspector can agree upon, that ties directly to the lab testing data. On the previous page are examples of the previous table from a tile NOA. Above is the revised table from a recent NOA update.

Key Enhancements

■ The contact area is clearly stated with its corresponding uplift value.
■ Where there are “system” names of the adhesive placement, those have been added and correspond to the adhesive manufacturer's installation instructions. For example, ICP uses the terms “large paddy” and “medium paddy.” For Tile Bond, we use “interdependent” and “independent.”

The footnotes have been simplified to just refer the installer to the adhesive product approval that contains pertinent information from the manufacturer on how to install the product. The component product approval further refers the installer to the manufacturer’s installation manual. This is in place of attempting to add the installation details to the footnotes.

And if it couldn’t get any better, there are two proposed revisions from Miami-Dade County for the 2026 code cycle (12066 & 12067) that add the requirement of contact area measurement to the lab testing requirements for TAS 101-95, which is the test protocol used for tile system uplift testing.

I’d like to thank the folks at Miami-Dade for working with us on these revisions. Over the last few years, we have established a productive working relationship that is focused on the goal of ensuring that tile roofs are installed properly. When groups can find common ground and stay focused on this, great things can happen that benefit the industry and homeowners.

FRM

Tom Parker is the President of TCParker & Associates, a manufacturer’s representative for Dupont Tile Bond Roof Tile Adhesive. He opened his agency 13 years ago after a 33-year career at The Dow Chemical Company. Tom is a Registered Professional Engineer, is a member of TRIA and a member of FRSA serving on the Codes Committee.

Ventilation codes in roofing are often overlooked, misinterpreted or, in some cases, unenforced. This combination of issues can lead to a shortened roof life, voided warranties and even health complications from mold or viral particle accumulation. Ultimately, all of these concerns fall on the shoulders of our customers, the homeowners. As licensed roofing professionals, we strive to provide the best products at the best price, solving problems and fulfilling the needs of our customers. The purpose of this article is to equip roofing professionals with the information they need to confidently navigate the industry, resulting in better, stronger and longer-lasting roof systems.

In this article, I will cover the importance of ventilation, Florida Building Codes and the science behind why proper ventilation is essential for roof systems.

Ventilation plays a crucial role in protecting three key areas: the homeowner, our investments and our warranties and insurance. A common misconception about ventilation is that its primary purpose is to cool homes and reduce energy bills. While that is true to some extent, it is actually a secondary benefit of ventilation.
The primary purpose is much more critical to the longevity of the roof system and the health of the occupants.

Protecting Homeowners and Health

Research has shown that the average person generates approximately three-quarters of a gallon of water vapor each day through activities such as cooking, cleaning and simply perspiring. Without proper ventilation, this moisture accumulates in attic spaces, leading to the growth of mold and mildew. Mold and mildew are notorious for their rapid growth in warm, dark environments like attics. Left unchecked, they can spread quickly, leading to significant health risks for homeowners. Proper ventilation allows the necessary airflow to carry this excess moisture out of attic spaces, preventing the harmful effects of mold and mildew.

Protecting Investments

Proper attic ventilation also plays a role in preserving the energy efficiency and integrity of a home’s other investments. Homeowners are increasingly focused on energy efficiency and are making significant investments in upgrades like new doors, windows, insulation and solar panel systems. With new windows and doors, homeowners are often unknowingly tightening the building envelope, preventing moisture from escaping as it once did. This trapped moisture accumulates in the attic, where it can condense onto ceiling insulation, diminishing its R-value. Even if the insulation dries out, it does not regain its original insulating properties.

Protecting Warranties and Insurance

Another critical aspect of proper ventilation is its connection to roof warranties. Many manufacturers require adequate ventilation to validate their warranties. The reasoning behind this is simple: roof materials need to perform at their best to provide long-lasting protection. When a roof is improperly ventilated, heat buildup can cause shingles and underlayment to degrade, leading to issues such as blistering, curling and granule loss. These problems can shorten the life of a roof system, directly affecting homeowners and their wallets.

In addition, insurance companies are increasingly focused on roof integrity. Many are sending out nonrenewal notices or offering higher premiums for homes with older or improperly ventilated roofs. A properly ventilated roof system that is built to code lasts longer, gives insurers more confidence and reduces the likelihood
of nonrenewal.

Understanding the Code

To fully appreciate why adequate ventilation is necessary, it’s helpful to understand the science behind it. Two key concepts are convection and the Coriolis Effect. Convection is the process by which heat rises through air or water. In this case, heat from the attic floor needs a way to escape and proper ventilation allows this process to occur efficiently. The Coriolis Effect, caused by the rotation of the Earth, influences air movement, which helps heat rise and move out of the attic space.

The Florida Building Code specifies that for every 150 square feet of attic floor space, one square inch of net free ventilation area (NFVA) is required. This requirement includes all enclosed attic areas, such as garages and non-livable spaces. However, there are two exceptions to this code. First, some climate zones allow for a ratio of one square inch of NFVA for every 300 square inches of attic space, though this exception does not apply to Florida. The second exception requires that 40-50 percent of the ventilation be placed in the upper portion of the roof, three feet from the ridge, creating a balanced system. This balance is essential for ventilation to work effectively. A properly balanced system ensures that intake and exhaust vents align, creating a cross-breeze to facilitate airflow.

Conclusion

In Florida, meeting the 1/300 ratio with a balanced system is the most cost-effective and efficient way to comply with building codes while ensuring the longevity
of roofing systems. By doing so, we can validate manufacturer warranties, extend the lifespan of roofs and address the concerns of the insurance industry. The ultimate goal for all of us – builders, contractors, manufacturers and building officials – is to understanding and adhere to the proper ventilation code.

Through better ventilation practices, we can provide safer, longer lasting and more efficient roofs for our customers, all while protecting our own business interests and reputation. By taking these steps, we contribute to a stronger, healthier roofing system for everyone involved.

FRM

Dwight Cline is the Florida Sales Manager for O’Hagin LLC, where he specializes in technical and code training. Dwight is a member of FRSA’s Codes and Governmental Affairs Committees and the Young Professionals Council. He can be reached at dcline@ohagin.com.