Two layers of shingles Florida Building Code

Did a home inspection yesterday, There was two layers of architectural shingles. #30 Felt, old roof covering and then new roof covering.

I know this is incorrect especially down here in Florida with the heat and being in the high wind debris zone. This was down on the coastal section of Naples Fl according to the wind map this is 140mph,

I can’t find anything in the FBC on two layers. The shingles were laid three years ago. The shingles are starting to wave on top of the main gable peak.

I am trying to write the report and I need a good narrative and been searching on the forums and Google for hours with no luck.

Please help,

I do not know of anything that prohibits two layers of roofing.

Overlay allowed - 1 time.
Do you know or find a permit for it?

Haven’t looked yet. The seller didn’t have a copy at the time of inspection. Does it cut the life expectancy in half??

This is the narrative that I use,
“This roofing system has two layers of material. While this is acceptable under the Florida Building Code, it is the maximum number of layers allowable. When replacement is required, there will likely be an added expense in removal and disposal of the material.”
It’s not a deficiency, so I just give an informational statement.
The specific FBC that covers this is Section 1510.3.3.
Also, you may want to verify that you have a current wind map. The 2012 FBC wind map shows Collier county to be a 160mph and 170mph wind zone.

I cut 10yrs off the warranty life of the shingle for the second layer. Use Reece’s narrative for the replacement heads up to the buyer. Also, make sure the roofing nails used on the second layer are long enough to fully penetrate the roof decking if not dimensional lumber.

  1. 1510.3.3 is from the Florida Building Code, Building…you’re in the wrong code book.

  2. There are counties and municipalities that have adopted the provisions of the HVHZ for roofing syetem applications that are not located in that particular zone. Palm Beach and Martin Counties being just a few examples.

  3. roofing systems are REQUIRED to be installed per the manufacturer’s approval, this is part of the code that relates to “more stringent application shall take precedence”. When you find a manufacturer that warrantees this type of installation, over an existing layer of undetermined product, let me know.

  4. specifically, all roofing syetems located in wind-borne debris regions must meet uplift requirements, the following included…ASTM D3161, TAS, 107, ASTM D7158. This is listed in the Residential Building Code.

  5. If the roofing system was installed with an NOA, the Florida Building Code for the HVHZ applies…and that says:

R4402.10.4</B>

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


R4402.10.10</B>

If the recover roofing assembly is to be bonded to an existing roofing membrane, the existing roofing membrane shall be tested in compliance with TAS 124 for uplift resistance. The existing roofing membrane shall resist the design pressures calculated under Section R4403 of this code. Test results shall be submitted with the uniform roofing permit application.

In no case, can an existing roofing system be covered over without the original system being fastened in compliance with the current code. Good luck with that…

22010 Existing building code

6611.3 Recovering versus replacement.
New roof coverings shall not be installed without first removing all existing layers of roof coverings where any of the following conditions occur:

  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 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 is to be used for attachment for a new roof system and compliance with the securement provisions of Section 1504.1 can not be met.
    Exceptions:

  6. Buiuilding 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
    .

  7. 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.

  8. Reserved.

  9. 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.

  10. Roof Coating.
    Application of elastomeric and or main-tenance coating systems over existing asphalt shingles shall be in accordance with the shingle manufacturer’s approved installation instructions.

2010 Building Code

[FONT=serif]1521.5
**A roofing system shall not be applied over an existing roof or over an existing roof deck where the roof sheathing has not been fastened in compliance with this code or where the roof sheathing will not permit effective fastening or where sheathing is water soaked or deteriorated so that effective attachment is not possible. All areas of deteriorated sheathing shall be removed and replaced. The building official shall not be required to inspect the renailing of the sheathing under this section.

**

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2010 Existing building code

6**611.3 Recovering versus replacement.**New roof coverings shall not be installed without first removing all existing layers of roof coverings where any of the following conditions occur:

  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 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 is to be used for attachment for a new roof system and compliance with the securement provisions of Section 1504.1 can not be met.
    Exceptions:

  6. Buiuilding 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
    .

  7. 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.

  8. Reserved.

  9. 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.

  10. Roof Coating.
    Application of elastomeric and or main-tenance coating systems over existing asphalt shingles shall be in accordance with the shingle manufacturer’s approved installation instructions.

2010 Building Code

[FONT=serif]1521.5
**A roofing system shall not be applied over an existing roof or over an existing roof deck where the roof sheathing has not been fastened in compliance with this code or where the roof sheathing will not permit effective fastening or where sheathing is water soaked or deteriorated so that effective attachment is not possible. All areas of deteriorated sheathing shall be removed and replaced. The building official shall not be required to inspect the renailing of the sheathing under this section.

**
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Thank you for the correction, Good narrative by the way :slight_smile:

Thanks for your time clearing this up John.

Read the complete code to understand where and when it applies, some of the exact same information you are quoting is listed IN the Residential Code. When you reference a source, referece it correctly. The Florida Building Code Building and Residential both apply…with the exception that residential structures must meet inclusive requirements of the Florida Building Code: Residential.

2010 Florida Building Code, Building 101.2 Scope. </B>

The provisions of this code shall apply to the construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal and demolition of every building or structure or any appurtenances connected or attached to such buildings or structures. **

Exceptions:**

  1. Detached one- and two-family *dwellings *and multiple single-family *dwellings *(townhouses) not more than three *stories *above *grade plane *in height with a separate *means of egress *and their accessory structures shall comply with the Florida Building Code, Residential.
    **
    **
    You can’t pick and choose what sections to apply…this is how it works from the Existing code.

2010 Florida Building Code, Existing Building 611.1 General</B>.

Materials and methods of application used for recovering or replacing an existing roof covering shall comply with the requirements of Chapter 15 of the *Florida Building Code, Building *or Chapter 9 of the *Florida Building Code, Residential. *Roof repairs to existing roofs and roof coverings shall comply with the provisions of this code.

611.1.1

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

Again…you are in the wrong code book.

***2010 Florida Building Code, Existing Building ***
Reroofing: 611.1 General</B>.

Materials and methods of application used for recovering or replacing an existing roof covering shall comply with the requirements of Chapter 15 of the *Florida Building Code, Building *or Chapter 9 of the *Florida Building Code, Residential. *Roof repairs to existing roofs and roof coverings shall comply with the provisions of this code. **


**

Keep in mind that when the codes conflict with themselves you always take the most restrictive part of the code

Robert, I’m not sure if you’re an inspector or not.
FYI, on this message board, we tend to try to help each other out with things that we/they may have not ran into before.
We do not inspect to or for code compliance. We do, however, often look to code to confirm or strengthen our opinion on our findings.
As a licensed roofing contractor, I would not personally install a second layer of roofing (though I have in the past in special scenarios).
When I’m working in an unfamiliar county, like most smart contractors, I would find out how the AHJ interprets the code and what they want to see. Because at the end of the day, their interpretation is all that matters.
My point is don’t get hung up on the details. It’s not a deficiency at this time.

Hey Shawn,

Is there anyway to renail the roof deck, properly check the status (wood rot) of the deck without removing the shingles? I would just advise the client that the fact you can NOT renail and or replace decking without removing the orig’ layer of shingles, it COULD shorten the lifespan of the Roof covering… As Toye said

Call what you see and move on.

Respectfully, this statement is not accurate. AHJ are not the ones who decide how the code is interpreted, this is why we have “declaratory statements” issued by the DBPR and CILB along with the Florida Building Commision, they decide how your license is to be used and the commision decides the interpretation of code. You can find a list of these on the DBPR website that links you over. Or, simply google “CILB declaratory statements”.

Specifically…AHJ are ONLY allowed to change provisions of chapter 1, any other changes or interpretations would be required for review and addendum by the Florida Building Commision…no exceptions.

As for code, you will be held to your highest level of licensure, being that you are a CBC and Roofing Contractor you are required to be proficient in code and can be held accountable to that standard in your inspections. The same why you are licnesed to inspect roofing systems without requiring a HI license.

I wouldn’t expect you to take my word for this, contact a litigation specialist proficient in construction litigation for home inspectors…ask them what they think.

Your comment that we do not inspect to code or for code compliance is 100% wrong. Otherwise you would not write down things like condenser units that are not strapped to the pad, water heater relief lines not gravity fed, missing hurricane protection on newly installed windows, paint in electric boxes, and the list goes on.

Respect noted.