The idea for this article was generated

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1 The idea for this article was generated by a phone call from an RCI member seeking guidance about permits and code compliance. The article will examine the requirements for permits and general roofing requirements in the 2012 edition of the International Building Code (IBC), the International Existing Building Code (IEBC), and the International Energy Conservation Code (IECC). Before construction begins on any project, one must determine if a permit is required, what type of permits are required, and how to obtain a permit. Before designing a project, check with the building department of the appropriate governmental jurisdiction. The building department should have permitting requirements in writing and available to the public. Speaking with someone in the inspection department is always a good idea to determine if a project needs permitting, what code is enforced, if there are state or local amendments to the code, etc. In addition to code requirements, there may be state statutes affecting roof projects. For instance, the state of Florida has statutes that govern residential roof covering replacement INTERNATIONAL BUILDING CODE Section 105 of the IBC, entitled Permits, states: Required. Any owner or authorized agent who intends to construct, enlarge, alter, repair, move, demolish, or change the occupancy of a building or structure, or to erect, install, enlarge, alter, repair, remove, convert or replace any electrical, gas, mechanical or plumbing system, the installation of which is regulated by this code, or to cause any such work to be done, shall first make application to the building official and obtain the required permit. Section of the 2012 IBC states as follows: Work exempt from permit. Exemptions from permit requirements of this code shall not be deemed to grant authorization for any work to be done in any manner in violation of the provisions of this code or any other laws or ordinances of this jurisdiction. Permits shall not be required for the following: Building: 1. One-story detached accessory structures used as tool and storage sheds, playhouses and similar uses, provided the floor area is not greater than 120 square feet (11 m 2 ) 2. Fences not over 7 feet (2,134 mm) high 3. Oil derricks 4. Retaining walls that are not D e c e m b e r I n t e r f a c e 1 9

2 over 4 feet (1,219 mm) in height measured from the bottom of the footing to the top of the wall, unless supporting a surcharge or impounding Class I, II, or IIIA liquids 5. Water tanks supported directly on grade if the capacity is not greater than 5,000 gallons (18,925 L) and the ratio of height to diameter or width is not greater than 2:1 6. Sidewalks and driveways not more than 30 inches (762 mm) above adjacent grade, and not over any basement or story below and are not part of an accessible route 7. Painting, papering, tiling, carpeting, cabinets, countertops and similar finish work 8. Temporary motion picture, television, and theater stage sets and scenery 9. Prefabricated swimming pools accessory to a Group R-3 occupancy that are less Turn your roof tops into beautiful, useful decks The PAVE EL Pedestal System Transforms flat roofs into attractive, maintenancefree, landscaped paver stone terraces. Elevates paver stones for perfect drainage. Levels paver stones and ensures their uniform spacing for an ideal roof terrace surface. Ideal for laying paver walkways in roof gardens. ENVIROSPEC INCORPORATED than 24 inches (610 mm) deep, are not greater than 5,000 gallons (18,925 L), and are installed entirely above ground 10. Shade cloth structures constructed for nursery or agricultural purposes, not including service systems 11. Swings and other playground equipment accessory to detached one- and two-family dwellings 12. Window awnings in Group R-3 and U occupancies supported by an exterior wall that do not project more than 54 inches (1,372 mm) from the exterior wall and do not require additional support 13. Nonfixed and movable fixtures, cases, racks, counters, and partitions not over 5 feet 9 inches (1,753 mm) in height What is the code saying? All work must meet the requirements of the code, whether a permit is required or not. Being exempted from the permitting and inspection process does not mean exemption from the code requirements. At first glance, it appears a permit is required for any type of roofing project; but read on to Section : Repairs. Application or notice to the building official is not required for ordinary repairs to structures, replacement of lamps, or the connection of approved portable electrical equipment to approved, permanently installed receptacles. Such repairs shall not include the cutting away of any wall, partition, or portion thereof; the removal or cutting of any structural beam or loadbearing support; the removal or change of any required means of egress, or rearrangement of parts of a structure affecting the egress requirements; nor shall ordinary repairs include addition to, alteration of, replacement, or relocation of any standpipe, water supply, sewer, drainage, drain leader, gas, soil, waste, vent or similar piping, electric wiring, or mechanical or other work affecting public health or general safety. It appears that no permit is required to do repair unless one is cutting walls, structural beams, etc. Since most roof repairs don t alter the structural system, it seems permits are not needed to do repairs unless one adds, alters, replaces, or relocates a standpipe, sewer, drainage, drain leader, vents, or similar piping. Electrical wiring or mechanical work is not a repair and does require permitting. In Chapter 2 of the IBC, a repair is defined as: REPAIR. The reconstruction or renewal of any part of an existing building for the purpose of its maintenance. Therefore, the IBC does not require a permit for ordinary repairs as long as there is no piping, electrical, or mechanical work performed or alteration to the structural system. What, then, is an ordinary repair? The code defines a repair as reconstruction or renewal of any part of any existing building for the purpose of its maintenance. If a building owner decides to replace part of the roof covering, is it a repair? The International Code Council s Commentary for the 2009 IBC says: As indicated in Section , the repair of an item typically does not require a permit. This definition makes it clear that repair is limited to work on the item, and does not include complete or substantial replacement or other new work. Language contained in the commentary is not enforceable, but it is there to provide guidance to both designers and inspectors. The language in the commentary suggests that roof covering replacement may require permitting. Remember, the requirements found in the code are minimum requirements. A local jurisdiction or state or local amendments may have more stringent requirements. That is why it is always a good idea to check with the local building official to determine the jurisdiction s requirements. There are a few more important definitions in the IBC: REROOFING. The process of recovering or replacing an existing roof covering. See roof re-cover and roof replacement. ROOF RE-COVER. The process of installing an additional roof covering over a prepared existing roof cover- 2 0 I n t e r f a c e D e c e m b e r

3 ing 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. As you can see from the definitions, two conditions are considered. The first is installing a new roof covering over an existing roof covering; and the second is removing the existing roof covering(s) and installing a new roof covering. These definitions apply to the roof covering only. As can be seen in the definition of roof assembly (below), all of the elements comprising the roof are considered the roof system. Roof coverings are the membrane, metal roofing, shingles, etc. The requirement for a permit will be determined by whether the project is exempt as specified in Section Here are more IBC definitions with which to be familiar: ROOF ASSEMBLY (for application to Chapter 15 only). A system designed to provide weather protection and resistance to design loads. The system consists of a roof covering and roof deck or a single component serving as both the roof covering and the roof deck. A roof assembly includes the roof deck, vapor retarder, substrate or thermal barrier, insulation, vapor retarder, and roof covering. ROOF DECK. The flat or sloped surface constructed on top of the exterior walls of a building or other supports for the purpose of enclosing the story below or sheltering an area to protect it from the elements, not including its supporting members or vertical supports. These definitions are used for application of the building code. They may be different from the definitions in the RCI Manual of Practice. When designing or constructing a project, the code enforcement official will use these definitions when enforcing the code. Chapter 15 of the IBC contains the technical provisions for roofing. Section 1510 addresses reroofing and contains the reroofing requirements for the various roofcovering materials 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 or roof covering is water-soaked or has deteriorated to the point that the existing roof or roof covering is not adequate as a base for additional roofing 2. Where the existing roof covering is wood shake, slate, clay, cement, or asbestoscement tile 3. Where the existing roof has two or more applications of any type of roof covering Exceptions: 1. Complete and separate roofing systems, such as standingseam 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. 2. Metal panel, metal shingle, and concrete and clay tile roof coverings shall be permitted to be installed over existing wood shake roofs when applied in accordance with Section 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. 4. Where the existing roof assembly includes an ice barrier membrane that is adhered to the roof deck, the existing ice barrier membrane shall be permitted to remain in place and covered with an additional layer of ice barrier membrane in accordance with Section This section says there are three conditions where one may not place a new roof Roof Testing CSA A Exp has been conducting tests since FM 4470 is no longer used as the basis for specifications for non insured buildings. CSA A has been based on NBC requirements since CSA A is likely to be included in the 2015 NBC. Get a customized waterproofing system that meets your actual needs, at a lower cost. Benefits such as increased service life of roof covering materials. Only laboratory of its kind in North America! Michel Desgranges, T.P. Director of Roofing & Waterproofing t : m : michel.desgranges@exp.com Drummondville, Qc J2C 7Y2 CANADA D e c e m b e r I n t e r f a c e 2 1

4 covering over an existing roof: when the roof is water-soaked, when the existing roof is wood shake, or where there are two or more roof coverings. There are several exceptions as shown above. The requirements for roof re-covering are similar and are found in Section INTERNATIONAL EXISTING BUILDING CODE The IEBC was created to encourage the use and reuse of existing buildings, as well as to provide adequate life safety. For existing buildings, the IEBC is an alternate path to compliance with the IBC. To be enforceable, the code must be adopted in the local jurisdiction. Not all jurisdictions have adopted the IEBC. If the IEBC has not been adopted by the local jurisdiction, the requirements of the IBC apply. This is another good reason to check with the local inspection department before beginning work. Note that the 2012 edition of the IBC no longer contains Chapter 36 for existing buildings. If a jurisdiction has not adopted the IEBC, but has adopted the 2012 edition of the IBC, check with the jurisdiction to see how existing buildings are treated. The IEBC states permits are required as follows (this is different from the IBC since it applies to existing buildings only): Required. Any owner or authorized agent who intends to repair, add to, alter, relocate, demolish, or change the occupancy of a building or to repair, install, add, alter, remove, convert, or replace any electrical, gas, mechanical, or plumbing system (the installation of which is regulated by this code), or to cause any such work to be done, shall first make application to the code official and obtain the required permit. Section states: Work exempt from permit. Exemptions from permit requirements of this code shall not be deemed to grant authorization for any work to be done in any manner in violation of the provisions of this code or any other laws or ordinances of this jurisdiction. Permits shall not be required for the following: BUILDING: [Editor s note: All building exemptions are identical to those listed under Section of the IBC, which may be reviewed on pages ] ELECTRICAL: Repairs and maintenance: Minor repair work, including the replacement of lamps or the connection of approved portable electrical equipment to approved permanently installed receptacles. Like to see a picture of your company s project gracing the cover of Interface? Give your company industry- wide exposure! We are looking for attractive, four-color, high-resolution, vertically oriented shots to illustrate our monthly themes. Submit original photograph or digital file (300 dpi, 8.5 x 11 in.) to: Kristen Ammerman, RCI, 1500 Sunday Drive, Suite 204, Raleigh, NC kammerman@rci-online.org Phone: Radio and television transmitting stations: The provisions of this code shall not apply to electrical equipment used for radio and television transmissions, but do apply to equipment and wiring for a power supply and the installations of towers and antennas. Temporary testing systems: A permit shall not be required for the installation of any temporary system required for the testing or servicing of electrical equipment or apparatus. GAS: 1. Portable heating appliance 2. Replacement of any minor part that does not alter approval of equipment or make such equipment unsafe 2 2 I n t e r f a c e D e c e m b e r

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7 MECHANICAL: 1. Portable heating appliance 2. Portable ventilation equipment 3. Portable cooling unit 4. Steam, hot, or chilled water piping within any heating or cooling equipment regulated by this code 5. Replacement of any part that does not alter its approval or make it unsafe 6. Portable evaporative cooler 7. Self-contained refrigeration system containing 10 pounds (5 kg) or less of refrigerant and actuated by motors of 1 horsepower (746 W) or less PLUMBING: 1. The stopping of leaks in drains, water, soil, waste, or vent pipe; provided, however, that if any concealed trap, drain pipe, water, soil, waste, or vent pipe becomes defective and it becomes necessary to remove and replace the same with new material, such work shall be considered as new work and a permit shall be obtained and inspection made as provided in this code 2. The clearing of stoppages or the repairing of leaks in pipes, valves, or fixtures and the removal and reinstallation of water closets, provided such repairs do not involve or require the replacement or rearrangement of valves, pipes, or fixtures As in the IBC, the IEBC requires all work to comply with the code, whether a permit is required or not. Exemption from permitting does not mean exemption from the code. Looking at this section, it appears roofing requires a permit, but read on to Section on repairs Repairs. Application or notice to the building official is not required for ordinary repairs to structures, replacement of lamps, or the connection of approved portable electrical equipment to approved permanently installed receptacles. Such repairs shall not include the cutting away of any wall, partition, or portion thereof; the removal or cutting of any structural beam or load-bearing support; or the removal or change of any required means of egress, or rearrangement of parts of a structure affecting the egress requirements. Neither shall ordinary repairs include addition to, alteration of, replacement or relocation of any standpipe, water supply, sewer, drainage, drain leader, gas, soil, waste, vent or similar piping, electric wiring or mechanical or other work affecting public health or general safety. This section is identical to the IBC and states a permit is not required for ordinary repairs, as long as there is no piping, electrical, or mechanical work performed or alteration to the existing structural system. Referring to the ICC Commentary for the D e c e m b e r I n t e r f a c e 2 5

8 2009 IBC, it states, As indicated in Section , the repair of an item typically does not require a permit. This definition makes it clear that repair is limited to work on the item and does not include complete or substantial replacement or other new work. When performing a project using the IEBC, it is more important to consult with the inspection department before beginning design. There are many trade-offs and nuances to the code that should be discussed with the inspection department so that there are no surprises later. Not all definitions in the IEBC are the same as the building code. Why not? The existing building code was created and is amended by a different committee than the building code. There has been an effort to make definitions consistent throughout the codes (as applicable), and some of those changes will be reflected in the 2015 editions of the International Codes. Of course, the IBC typically addresses new construction and the IEBC addresses existing buildings, so not all definitions can be the same. Section in Chapter 2, Definitions, states: Terms defined in other codes. Where terms are not defined in this code and are defined in the other International Codes, such terms shall have the meanings ascribed to them in those codes. The only term defined in the IEBC is repair, and it is defined as follows: REPAIR. The restoration to good or sound condition of any part of an existing building for the purpose of its maintenance. This definition is not the same as the IBC. The definitions of reroofing, roof recover, roof replacement, roof assembly, roof covering system, roof deck, and roof drainage are all as defined in the IBC. Unlike the IBC, the IEBC contains requirements throughout the code for repairs, including Chapter 6, Repairs. Make an appointment and sit down with the code official of your local jurisdiction to confirm code compliance before beginning work. INTERNATIONAL ENERGY CONSERVATION CODE The IECC is divided into two sections. One section is for commercial buildings; the other, for residential buildings. Each section of the code has its own scoping, definitions, and general requirements. As most consultants work with commercial buildings, I will focus on the commercial requirements Additions, alterations, renovations or repairs. Additions, alterations, renovations or repairs to an existing building, building system, or portion thereof shall conform to the provisions of this code as they relate to new construction without requiring the unaltered portion(s) of the existing building or building system to comply with this code. Additions, alterations, renovations, or repairs shall not create an unsafe or hazardous condition or overload existing Topping Off a Great Year of Retrofit Roofing Hug the Season - Hug the Reason Hug your Spouses and All your Mouses... Hug the Stripes and Stars and Brave Soldiers Gone Afar... And Our Special Wish of Hugger Cheer, For a Wonderful Holiday and a Great New Year! MEMBER ROOF HUGGER I n t e r f a c e D e c e m b e r

9 building systems. An addition shall be deemed to comply with this code if the addition alone complies or if the existing building and addition comply with this code as a single building. Exception: The following need not comply, provided the energy use of the building is not increased: 1. Storm windows installed over existing fenestration 2. Glass-only replacements in an existing sash and frame 3. Existing ceiling, wall, or floor cavities exposed during construction provided that these cavities are filled with insulation 4. Construction where the existing roof, wall, or floor cavity is not exposed 5. Reroofing for roofs where neither the sheathing nor the insulation is exposed. Roofs without insulation in the cavity and where the sheathing or insulation is exposed during reroofing shall be insulated either above or below the sheathing. 6. Replacement of existing doors that separate conditioned space from the exterior shall not require the installation of a vestibule or revolving door, provided, however, that an existing vestibule that separates a conditioned space from the exterior shall not be D e c e m b e r removed. 7. Alterations that replace less than 50 percent of the luminaires in a space, provided that such alterations do not increase the installed interior lighting power 8. Alterations that replace only the bulb and ballast within the existing luminaires in a space, provided that the alteration does not increase the installed interior lighting power It is clear that when reroofing and the sheathing and insulation are not exposed, you are not required to comply with the 2012 IECC. The definitions of other international codes apply to the IECC, with exception of the following: REPAIR. The reconstruction or renewal of any part of an existing building ROOF ASSEMBLY. A system designed to provide weather protection and resistance to design loads. The system consists of a roof covering and roof deck or a single component serving as both the roof covering and the roof deck. A roof assembly includes the roof covering, underlayment, roof deck, insulation, vapor retarder, and interior finish. RESIDENTIAL BUILDING. For this code, includes detached one- and two-family dwellings and multiple single-family dwellings (townhouses) as well as Group R-2, R-3, and R-4 buildings three stories or less in height above grade plane. ABOVE-GRADE WALL. A wall more than 50 percent above grade and enclosing conditioned space. This includes between-floor spandrels, peripheral edges of floors, roof and basement knee walls, dormer walls, gable end walls, walls enclosing a mansard roof, and skylight shafts. As can be seen, the definition of a residential building encompasses more than just one- and two-family dwellings and townhouses. Group R-2, R-3, and R-4 RCI Technical Articles Library Online Free access to technical articles and papers from RCI Interface technical journal articles RCI International Convention and Trade Show papers RCI Building Envelope Symposia papers Download Adobe Acrobat (.pdf ) files to your computer Keyword-searchable with Google New content added quarterly Current archive includes years rci-online.org/interfacearticles.html I n t e r f a c e 2 7

10 buildings less than three stories in height above grade-plane are considered residential buildings for the purposes of the IECC. Its definition of above grade-plane is different from the definition in the IBC. The National Roofing Contractors Association (NRCA), in association with the International Code Council (ICC), has produced two excellent publications to assist designers in complying with the IECC and the IBC. One is Guidelines for Complying With Energy Code Requirements for Roof Assemblies: 2009 and 2012 IECC, and the other is Guidelines for Complying With Building Code Requirements for Roof Assemblies: 2012 International Building Code. The ICC also publishes commentaries for each of the codes. In the commentaries, each section of the code is published along with a technical commentary for each code section. I have created a PowerPoint presentation based on the Guidelines for Complying with Energy Code Requirements for Roof Assemblies, and have presented it to several chapters. If you d like a copy of the presentation and/or would like a presentation to your chapter, please contact me at wedwards@ rci-online.org. In closing, permitting requirements are delegated to local jurisdictions and vary greatly from jurisdiction to jurisdiction. With the downturn in the economy and the slowing of construction, inspection departments struggle to provide services with fewer inspectors. The increased complexity of the building codes also contributes to interpretation of the codes. Designers who consult with inspection departments prior to starting work will find fewer headaches and problems during the construction phase. REFERENCES 2012 International Building Code, copyrighted by the International Code Council 2012 International Existing Building Code, copyrighted by the International Code Council 2009 International Building Code Commentary, copyrighted by the International Code Council Wanda Edwards is the senior director of technical services for RCI. Previous posts include director of code development for the Insurance Institute for Business and Home Safety; deputy commissioner Wanda Edwards, PE and chief engineer for the North Carolina Department of Insurance; and owner of a residential construction, design, and development company. In 2004, she was a Fulbright Scholar at the University of the West Indies, Trinidad, and Tobago, where she developed a training and certification program for building inspectors. She earned BS degrees in civil engineering and architecture from North Carolina State University and currently serves on various committees within ASTM, ICC, and NIBS. Roof Drainage Design Roof System Thermal and Moisture Design Roofing Basics Roofing Technology and Science I Roofing Technology and Science II Rooftop Quality Assurance Wind Design for Low -Slope Roofs - Part I: Understanding ASCE 7-05 Wind Load Calculations for Members Wind Design for Low -Slope Roofs - Part I: Understanding ASCE 7-10 Wind Load Calculations At your own pace, on your own time, at your fingertips... Wind Design for Low -Slope Roofs - Part II: FM Global Guidelines and Best Practice Considerations Online Educational Programs 2 8 I n t e r f a c e D e c e m b e r