Mike Silvers, CPRC, Owner, Silvers Systems Inc. and FRSA Technical Director - February 2026
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.
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.