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Code Changes Creating Concerns with Roof Drains

Roofing requirements, and more specifically, reroofing requirements, can be found in both the International Building Code (IBC) and the International Existing Building Code (IEBC). The IBC requires that roof drainage systems also comply with the International Plumbing Code (IPC). Roofing contractors must comply fully with either the IEBC or the IBC, but may not use portions of each. Further, different jurisdictions require the use of plumbing codes other than the IPC. This creates confusion as well as a number of difficulties for roofing contractors trying to abide by their jurisdiction’s building code.

A glaring example of an issue created by differences between the Codes is the requirement of secondary roof drainage or scuppers found in Chapter 15 of the 2009 IBC for reroofing. The requirement to add secondary roof drainage when reroofing was removed in the 2015 and 2018 versions of the IBC so long as the building did not have pre-existing secondary roof drainage installed. However, the current version of the IEBC does not contain the same exception and can be interpreted as to require reroofing projects to include secondary roof drainage.

Based on a review by the National Roofing Contractors Association (NRCA), roof drain manufacturers’ failure to include adequate design information to determine whether the IBC, IPC, and IEBC requirements for roof drainage are being met adds to the confusion. The best options for roofing contractors in dealing with these difficulties is to consult with their jurisdiction’s building and plumbing officials to determine which combination of the Codes are to be used.

Author’s note: The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation. Regulations and laws may vary depending on your location. Consult with a licensed attorney in your area if you wish to obtain legal advice and/or counsel for a particular legal issue.