Issue: DS-2011-096. The Petitioner is requesting clarification whether their product, EPOX-Z cool roof coating meets the scope of 9N-3.

1) The EPOX-Z NRG cool roof coating product is a flexible, durable, 100% solids coating that only requires one coat and does not require a primer. It provides a highly effective barrier to the sun’s heat and ultraviolet (UV) rays. The product has high reflective properties cool roof surfaces and leads to a reduction of interior temperatures and air conditioning cooling costs.

Background:

Situation:

- The product is described as a non-structural roof coating maintenance product.

- The product is designed to increase energy efficiency, extend the life of a roof membrane “cool roof coating product”.

- The product is used to seal roofs for water-proofing and leak mitigation purposes.

The product is used on asphalt flood coats on built-up commercial roofs, modified bitumen, metal, concrete, BUR, TPO, EPDM, PVC, KEE, and Hypalon roofs.

2007 Florida Building Code, Building:

SECTION 1507 REQUIREMENTS FOR ROOF COVERING

1507.15: Liquid-applied coatings. The installation of liquid-applied coatings shall comply with the provisions of this section.

1507.15.1: Slope. Liquid-applied shall have a design slope of a minimum of one-fourth unit vertical in 12 units horizontal (2-percent slope).

1507.15.2: Material standards. Liquid-applied roof coatings shall comply with ASTM C 836, ASTM C 957, ASTM D 1227, or ASTM D 3468, ASTM D 6083, ASTM D 6694 or ASTM D 6947.

Rule 9N-3

9N-3.001 Scope:

(2) This rule applies to approval of products and systems, which comprise the building envelope and structural frame for compliance with the structural requirements of the Florida Building Code.

9N-3.002: Definitions:

(31) Structural component means any part or assembly of buildings that comprises the main wind force resisting system and components or cladding.

(33) Subcategory of product or construction system means a specific functionality:

(d) For roofing products: built up roofing, modified bitumen roof system, single ply roof systems, spray applied polyurethane roof system, roofing fasteners, roofing insulation, asphalt shingles, wood shingles and shakes, roofing slate, roof tile adhesives, cements-adhesives-coatings, liquid applied roof systems, underlayments, metal roofing, roofing tiles, waterproofing, roofing accessories that are an integral part of the roofing system and products introduced as a result of new technology;

Staff recommendation:

This product is described as a “non-structural roof coating” and is marketed as an energy barrier and water-proofing products.

Question: Does the EPOX-Z cool roof coating products fall within the scope of Rule 9N-3?

Answer:

(1) With regard to the product’s energy performance, the answer is No. The product in question does not fall within the scope of Rule 9N-3. However, as a cool roof coating product, the product in question is subject to the requirements of the Florida Energy Code as applicable.

(2) With regard to the product’s performance as water-proofing product, the product in question is an aftermarket product “maintenance product” which falls outside the scope of Rule 9N – 3.