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Reroofing Fire Rated Construction

July 12, 2003

6 • Interface July 2003
To avoid compromising a building’s original fire rated construction
when reroofing or recovering an existing assembly,
it is important to understand the positions of Underwriters
Laboratories (UL) and Factory Mutual (FM) and their relationship
to the prevailing building code on fire rated constructions for roof
assemblies. Navigating one’s way through published UL and FM
requirements and local building codes is only the beginning. It is
equally important to recognize how these published requirements
are interpreted by various authorities that have jurisdiction. This
paper will review the mechanics of using the UL Directory and current
UL and FM positions on the subject. Finally, the role of the
consultant in the process of securing necessary approvals will be
considered, and guidelines are offered for dealing with local field
representatives from UL, FM, and building code offices.
When reviewing the requirements of UL and FM, it is helpful
to keep in mind the distinction between the two organizations.
UL’s purpose in promoting fire rated construction is to ensure life
safety for building occupants. Because of this, codes rely heavily
on UL testing to certify a building’s fire resistant characteristics.
FM is an insurance organization. Therefore, their requirements
have been developed from the perspective of loss prevention.
Generally, it is only necessary to consider FM fire ratings when
working on an FM-insured facility or a facility designed to meet
FM criteria.
To maintain a building’s fire ratings during reroofing and recover,
one must first understand the original construction that
allowed the facility to achieve those ratings. So, before beginning a
discussion of reroofing and recover, it is worthwhile to consider
how the type and duration of fire protection required for a newly
constructed building are determined.
Determining the Type and Duration of Fire
Protection Required in New Construction
Building codes dictate the type and duration (hourly rating) of
fire protection required for a structure. The type of fire protection
and duration required are determined by the occupancy (or use),
the height and area limitations of the building, and the type of
construction used.
Building codes classify buildings into Use Groups based on
occupancy. Following is a list of occupancy categories and their
corresponding Use Groups. Sub-groups of each Use Group are
also defined by building codes.
Occupancy Use Group
Assembly A
Business B
Educational E
Factory and Industrial F
High Hazard H
Institutional I
Mercantile M
Residential R
Storage S
Utility and Miscellaneous U
The various types of construction that are acceptable for a
given Use Group can be determined based on the building height
and area. For example, Table 503 from the BOCA National
July 2003 Interface • 7
Building Code issued by the Building Officials & Code Administrators
International, Inc. (shown above) provides type of construction
information based on building height and building area for
the Educational Use Group.
The Types of Construction are defined as follows:
• Type 1 and Type 2 – Noncombustible materials must be
used for walls, partitions, structural elements, floors, ceiling,
roof, and exits.
• Type 3 – Noncombustible materials must be used for exterior
walls and code-approved materials for interior structural
elements.
• Type 4 – Noncombustible exterior walls with solid or laminated
wood for interior structural members or load bearing
walls, partitions, floors, and roofs of noncombustible materials.
• Type 5 – Code-approved materials must be used as structural
elements.
Having determined the type of construction, the specifier can
then find the fire resistance ratings of the structure elements
required by the code. BOCA National Building Code Table 602,
“Fire Resistance Ratings of Structure (sic) Elements,” defines the
hourly ratings that must be met for each structure element. The
portion of Table 602 shown below deals with roof construction.
The hourly rating requirement ranges from two hours to 0 hours,
depending upon the type of construction.
Achieving Required UL Hourly Fire Ratings
The building code defines the methods of achieving required
hourly fire ratings. These methods include active systems (such as
sprinkler systems, which are designed in accordance with principles
stated in NFPA 13, published by the National Fire Protection
Association) and passive systems (such as fire rated ceilings and
structural element protection provided by sprayed fireproofing,
intumescent coatings, and fire protection board). Combinations of
both active and passive fire protection may be used. The hourly
rating for a roof system being installed using passive fire protection
is clearly defined in the Underwriters Laboratories Fire
Resistance Directory.
UL publishes hourly fire resistance ratings for various roof
systems. These UL hourly fire resistance ratings are used to determine
the specific construction materials required to meet the prevailing
building code.
Underwriters Laboratories uses the ASTM E 119 fire test to
Table 503
Height and Area Limitations of Buildings
Height limitations of buildings (shown in upper figure as stories and feet above grade planem) and area limitations of one- or two-story
buildings facing on one street or public space not less than 30 feet wide (shown in lower figure as area in square feet per floorm).
See Note a.
Table 602
Fire Resistance Ratings of Structure Elements
Note a. For fire resistance rating requirements for structural members and assemblies that support other fire resistance rated members or
assemblies, see Section 716.1.
Copyright 1998, Building Officials and Code Administrators International, Inc., Country Club Hills, Illinois. Reproduced with permission. All rights reserved.
Copyright 1998, Building Officials and Code Administrators International, Inc., Country Club Hills, Illinois. Reproduced with permission. All rights reserved.
8 • Interface July 2003
investigate the
length of time a
roof system subjected
to fire can
support design
structural loads
and maintain its
structural integrity.
The results of this
test provide the
hourly fire resistance
ratings referenced
in building
codes. The hourly
ratings are intended
to allow time for
the public to exit a
burning building
and to protect firefighters
from structural
collapse. The
ASTM E 119 test
measures the
amount of time it takes for the structural support system of a
building to reach temperatures that may cause a loss of material
properties and structural failure. It also evaluates the exposed
surface temperature of the roof membrane to ensure it does not
exceed limits and ignite. Both the exposed roof membrane temperature
and the structural support temperature can limit the hourly
fire resistance value.
Hourly fire resistive constructions refer to assemblies having
an approved hourly fire rating when tested in accordance with
ASTM E 119 procedures. These ratings result in hourly fire resistance
listings for the specific test assemblies. All of these assembly
listings generally incorporate a rigid roof insulation or lightweight
insulating concrete over a steel deck or structural
concrete. Further, underside treatment may be required to achieve
the assembly rating. The assemblies are listed by design numbers
in the UL Fire Resistance Directory.
UL also lists roof systems that are “fire classified.” Fire classified
systems are only subjected to a spread of flame test, which is
conducted in a Steiner
Tunnel. This test determines
the rate of flame
propagation on the underside
of the structural deck.
It does not consider the
issue of temperature transmission
through the assembly or the structural performance, neither
does it provide any hourly fire resistance ratings. These A, B,
or C classifications appear as a part of the rated assembly
requirements and, further, are referred to by code officials in decisions
regarding reroofing applications.
Identifying the Proper UL Fire Resistive Designs
The UL Fire Resistance Directory lists fire rated assemblies.
Knowing how to use the directory is a necessity for new construction
circumstances. The ability to understand and evaluate the
assemblies upon which building life safety criteria are based is
essential in dealing with building code compliance issues. In new
construction, the building structure and architecture are based
on tested fire rated assemblies and built to be compliant with UL
tested assemblies to achieve local code requirements. In reroofing,
the need to accurately identify the existing roof assembly may or
may not be required, but the understanding of them is critical in
dealing with local authorities having jurisdiction. In either case, it
should not
be assumed
that roof
assemblies
designed to
meet a specific
fire
resistance
criteria and
installed during
building
construction
were
installed correctly
and
are in compliance with the actual tested assembly.
“As built” documents should always be verified by
field examination. Some of the primary items to
identify during field examination include the type
of insulation, roof membrane, steel roof deck, and adhesives.
Identifying the specific manufacturer of the components can also
help determine the existing assembly. The tendency to group similar
roofing insulation products together under generic names
(such as perlite board, isocyanurate, and lightweight insulating
concrete) should be avoided. Although they have a generic name
association, these products can be manufactured differently and
Please read information
contained in paragraph 2 on
page v and the number system
table for fire rated assemblies
on page 1 in Volume 1.
Table 3
Graphic 1. Reprinted with permission from
United Laboratories
have different material thermal characteristics and assembly ratings.
This information may be even more critical in the future, as
new formulations of products (such as the new generation of isocyanurates)
enter the marketplace.
It is also vital to identify what is underneath the roof assembly
in the interior of the building. Is there a suspended ceiling,
exposed ceiling, acoustical tile, or other component in the assembly?
These components contribute to locating and properly identifying
the correct roof ceiling assembly in the UL Fire Resistance
Directory. This information is important later, when determining
the UL type of constructions and corresponding numerical location.
Using the UL Fire Resistance Directory
The process of finding the correct fire resistant assembly in
the UL Fire Resistance Directory can be challenging and at times
frustrating. The UL Directory includes instructions to simplify this
process. These guidelines begin on the cover of the Directory.
The cover (Graphic 1) instructs the reader to go to page 1 and
refer to the number system table for fire rated assemblies. The
Directory is organized by the relationship between Groups of
Construction and Types of Protection. This is the base of the
alphanumerical classification of all listed assemblies (See Table 3).
The Groups of Construction are classified by different
sets of assemblies that contribute to the building structural
elements. These include columns, floors, beams,
walls, partitions, and – important from our perspective –
roof-ceiling assemblies. These constructions are designated
by an alphabetic prefix ranging from A to Z. Each letter
or grouping of letters is assigned to a construction
type (See Table 4).
The Types of Protections are defined by a numerical
numbering system. This system is broken into three
main categories: Membrane Protection, Direct-applied
Protection, and Unprotected. These three main categories
are sub-divided by specific protection types (See Table 5).
“Membrane protection” has the broadest range of
sub-categories with six numerical
sub-groups. “Unprotected”
has the narrowest with one
numerical sequence (See Table
6).
Most roof-ceiling assemblies
are found in the P series.
(Prefixes Q and R are not currently
used and are reserved for
future assemblies.) By reviewing
the types of protection and various
sub-categories, a consultant
will note some miscellaneous
listings of components ranging from grid systems to batts and
blankets. These additional interior components that comprise the
sub-categories under Types of Protection will determine the
numerical index number of the fire rated assembly. This is why it
is so important to identify what components are underneath the
assembly of membrane, insulation, and substrate. Without a
complete picture, the assembly and its rating can not be accurately
identified.
Mechanical screw-type fasteners are used frequently during
reroofing. It should be noted that these fasteners are not commonly
listed as components in UL roof-ceiling fire resistance
assemblies. For example, less than 20% of the assemblies in the
2002 UL Fire Resistance Directory P-800 series list mechanical
screw-type fasteners as a component. In the P-700 series, less
than 40% of the assemblies are approved with a mechanically fastened
rigid insulation.
Handling “Future Floor” Constructions
There are other roof ceiling assemblies that are not found in
the P-series. These can be found in the D-series or floor assemblies.
These assemblies are sometimes referred to as “future floor”
constructions. They are actually floor assemblies with a roof
installed on top. Some design criteria call for a building to be constructed
to a certain height. The master plan may require an
expansion at some later date to increase the height of the building.
This would require the original construction to have the top of
the building initially function as a roof assembly. The construction
would also require the flexibility at some later date to function
as a floor assembly when the building is expanded and
additional floors are added to the structure.
July 2003 Interface • 9
Table 4
Table 5
10 • Interface July 2003
Understanding FM Fire Resistance Ratings
Factory Mutual uses a calorimeter to determine the interior
fire resistance of all roof systems as part of its Class 1 approval
criteria. This test subjects a roof system sample (decking, insulation,
roof membrane) to a fire on the underside of the structural
deck. The amount of fuel generated by the burning roof system
sample is compared to the amount generated by a similar sample
made of noncombustible refractory materials. The difference in
the amount of fuel generated by the two samples provides the
amount of fuel generated by the roof system being tested. Class 1
approval is based on the maximum fuel contribution rate at various
time intervals. Therefore, the addition of more insulation or
more roofing membranes may cause a given roof construction to
contribute an amount of fuel exceeding the acceptable fuel contribution
rate for Class 1 approval.
Determining Acceptable Actions for Recover
Applications
If the information included in this paper followed its title,
“Reroofing Fire Rated Construction,” we could stop here. The fact
is, meeting criteria for fire rated construction when reroofing is
simple, because the roof system is being rebuilt from the deck up.
Therefore, as long as the new system is comprised of the same
materials as were in the original construction, all of the ratings
should remain intact. So, when dealing with new construction
and reroofing, the requirements for fire rated assemblies are fairly
clear. However, in the case of recover applications, what is allowable?
Both UL and FM have positions on the subject that can be
summarized quickly:
• Technically, UL does not allow recover applications for
hourly ratings. To maintain UL approval, the existing
assembly must be torn off and the facility reroofed with an
assembly defined in the P Series.
• Likewise, to achieve required FM ratings, the existing
assembly can be torn off and replaced with an approved
assembly. Alternatively, FM allows up to 1″ of additional
insulation in recover applications, if both the existing system
and overlay systems are FM Class 1 rated.
Those are the official rules. However, is that the reality? Of
course not.
There are levels of interpretation involved in determining
whether the design of a re-cover application will maintain both UL
and FM fire resistance ratings. These possibilities merit discussion.
The UL Position on Recover and Reroofing
Applications
UL does not make any provisions for recovering existing fire
rated designs. This is because the addition of a new roof, which
may require new insulation, will change the thermal characteristics
of the assembly. Insulation may be added during reroofing
Table 6: Numbering systems for Fire Rated Assemblies
Types of Protection
July 2003 Interface • 11
applications, but only as defined by the specific fire rated design
being replaced. Therefore, in reroofing applications, the insulation
thickness cannot exceed that listed and must be of the approved
type and by the approved manufacturer. If screws are used to
attach the insulation or roofing products, they must be listed in
the design.
The majority of in-place lightweight insulating roof deck systems
meet specific hourly fire rated designs. The simplest method
of reroofing a lightweight insulating concrete system is to remove
the old membrane and install a new roof membrane directly to
that surface. Seldom does the lightweight insulating concrete system
need to be replaced.
There are three ways to ensure that a recover or reroofing
design and its fire resistive qualities will be acceptable:
1. Reference the UL Directory, which would require tear-off of
the existing assembly.
2. Work with the manufacturer of the products listed in the
assembly to conduct an engineering study wherein UL will
determine the acceptability of the assembly. In some
cases, manufacturers may already have such studies.
3. Work with building code authorities. Even though UL does
not include recover applications with hourly ratings in the
UL Directory, building code authorities will often allow
such assemblies. Weight is the primary building code concern
with recover applications. Building codes will accept a
second roof system if it carries a fire rating equal to or
greater than that of the original system, as long as the
structure can carry the additional weight. In recover situations,
before ordering a UL engineering study, it can be
beneficial to check with the roof membrane manufacturer.
They may have an engineering study on a previously completed
recover project that could provide useful information.
The FM Position on Recover and Reroofing
Applications
As with UL, when recovering an existing system, there are
three options to ensure that the design will be acceptable to FM:
1. Leaving the membrane in place, FM will allow the introduction
of a maximum 1-inch thickness of additional insulation
into the system without testing if the existing system
is Class 1 rated. A second membrane may be added over
the insulation. Insulation additions greater than 1 inch
can only be employed if that specific recover assembly has
been tested by FM. If the original roof system has not been
fire tested and approved by FM, it can be assumed that
the assembly is Class 2 and will require the addition of a
sprinkler system or passive sprayed fire protection under
the roof deck.
2. If an insulation addition of greater than 1 inch is necessary,
check with the manufacturer to see if FM testing has
already been secured on such an assembly.
3. Work with an FM field engineer to have the assembly tested
and approved.
Substituting Materials
When reroofing and recovering, any materials used in substitution
must be included in the approved assembly listing for both
FM and UL constructions. In addition, all parts of the construction
must be installed as defined by the assembly listing.
Incorrect substitutions or incomplete constructions will negate the
assembly’s code approval.
Protecting a Building’s Fire Rating – and
Protecting Yourself
Although published UL and FM requirements and positions on
recover applications seem draconian, the reality is that the interpretation
of the data by FM field engineers and local building code
officials makes defining such assemblies a much more practical
matter. Design professionals should recognize that this room for
interpretation exists, but should not try to make those interpretations
on their own. Rather, it is advisable always to contact local
building code officials (and FM field engineers in the case of FM
insured buildings) for proper approval of designs for recover or
reroofing of fire rated assemblies. 
John Rose is a product manager for
Siplast/Icopal insulation systems.
His career spans over 25 years in the
roofing and fire protection industry.
Prior to joining Siplast in 1995, he
worked for W.R. Grace, involved with
fire protection products in marketing
and technical field services. Rose
received his bachelor’s degree in geology
from Penn State University. He is
a member of CSI as a Consultant
Document Technologist and serves
on the board of directors of the National Roof Deck Contractors
Association (NRDCA).
Hubert T. Dudley is executive director
of the National Roof Deck Contractors
Association (NRDCA) and the National
Fireproofing Contractors Association
(NFCA). He has over 39 years experience
leading research projects, creating
reports, and marketing products
to the construction industry.
ABOUT THE AUTHORS
JOHN ROSE
HUBERT T. DUDLEY
Come to Reno wiitth RCII iin 2 0 0 4