Senate Bill 721 Inspection SOP

1. Inspection Guidelines

These guidelines are for inspection and certification requirements for exterior elevated elements.

2. SB-721 Scope

A. California requires inspection of weather-exposed exterior elevated elements(E3s) of buildings every six years, and it applies to buildings containing R-1 and R-2 Occupancies, as defined by the California Building Code.

B. If building owners believe their building is exempt from the program, they must file the Exemption Declaration form to be removed from the program’s inventory.

C. SB-721 applies to the following elements located more than 6 feet above adjacent grade, constructed of wood or steel, and accessible to occupants, known collectively in this document as exterior elevated elements (E3s):

  1. Balconies
  2. Exterior walkways
  3. Decks
  4. Exterior stairs and landings
  5. Guards and associated handrails serving any elements listed above

D. E3s whose structural system is constructed of reinforced concrete are exempt from the program. E3s featuring a concrete topping slab as a wearing surface are subject to the program if the topping slab is supported by wood or steel framing.

E. E3s located in areas accessible only to maintenance personnel, such as roofs, are not subject to the program. Figure 1 below is a sample illustration of E3s that are subject to the program.

3. SB-721 Purpose

A. The purpose of SB-721 is to safeguard public safety by maintaining the strength of structural
components supporting E3s. Inspection objectives include the following:

  1. Identify wood-framed E3s exhibiting significant deterioration due to wood-destroying organisms (fungal decay or insect infestation).
  2. Identify steel framed E3s exhibiting significant section loss due to corrosion.
  3. Ascertain whether the extent of deterioration or corrosion poses a significant compromise to the load-carrying adequacy of structural components supporting E3s.
  4. Attempt to locate the water source if wood-destroying organism infestation or corrosion is observed in wood framing or steel framing respectively.
  5. Remediate deficient components.

B. Before assessing the building’s E3s, confirm the applicability of the program to the building. If the building is not subject to the program, the building owner should file the Exemption Declaration form with the City. In this case, the city would not require assessment of the building’s E3s.

C. The inspection and condition assessment process is comprised of a screening evaluation and remediation. An overview of the screening evaluation and remediation procedures is illustrated in the figure below (Coming Soon)

4. Screening Procedure

The screening by a licensed professional is comprised of two components: condition assessment of E3s’ structural components and condition assessment of the waterproofing system.

A. Structural Screening

  1. Visit the site: visually review all E3s, and interior and exterior areas proximate thereto, as necessary.
  2. Develop an Investigative Program: In the case of E3s with soffit finishes, selectively identify at least 15% of locations for investigative openings to reveal concealed structural components. Finish removal needs only be the minimum amount sufficient to ascertain whether or not wood structural components have suffered decay due to wood-destroying organisms or whether or not steel structural components have suffered corrosion. Inspections should be conducted at the most probable locations where water intrusion may occur, for example at the intersection of horizontal and vertical assemblies, guardrail penetrations of the element assembly, floor drains where present, or other similar locations.
  3. Create Investigative Openings: Selectively create investigative openings to reveal at least 15% of concealed structural components and conditions. A building permit is not required for the selective removal of finishes associated with investigative work.
  4. Determine if Wood Destroying Pests, Organisms or Corrosion are Present: If wood-destroying organisms are identified on wood components or corrosion is identified on steel structural components, initiate structural evaluation as recommended below.
  5. Patch Investigative Openings: If no significant presence of wood-destroying organisms or corrosion is identified, patch the openings to match the existing surface. The owner may wish to install vents and/or access openings to provide easy access for future inspections. Be mindful that the affected areas may be components of a fire-rated assembly when located close to side or rear property lines and therefore subject to certain building code requirements.

Note: A building permit is not required for patching of selectively removed finishes in-kind.
Note: A building permit is required for the installation of vents and/or access openings.

B. Waterproofing System Screening

  1. Practically assessing the adequacy of the waterproofing system is difficult in many instances. The waterproofing barrier is often concealed by a wearing surface topping, in the case of balconies and walkways, or wall finish. At a minimum, the screening of the waterproofing system ought to include a visual review of readily observable exposed surface areas, including topping membrane if surface-applied, and flashings for signs of active water intrusion. It is not necessary to replace the waterproofing system if it is performing adequately.
  2. If minor waterproofing defects are observed, but have not caused water intrusion or triggered an Evaluation and Remediation, these defects should be reported to the building owner with recommended maintenance measures.

C. File Certification Form

If no significant presence of wood-destroying organisms, corrosion or water intrusion is identified and after investigative openings are patched, file the Certification form with the City’s Housing Code Enforcement office.

5. Evaluation and Remediation Procedure

A. Methods of Evaluation and Remediation

When the screening determines that wood-destroying organisms, corrosion or water intrusion are present, further evaluation and/or remediation are required. This process may consist of the replacement of damaged components in-kind, an engineering analysis assessing whether or not the damaged components are structurally adequate, modification of the existing components to repair the damage, or any combination thereof. Analysis of, and modifications to, existing structural components requires a licensed structural or civil engineer or architect.

B. Search for Documents

Consider searching for the original building design drawings. Inquire about availability with the building owner and/or local municipality.

C. Evaluation and Remediation

  1. Structural Evaluation and Remediation: Evaluate the original element design and extent of damage to determine the most practical and economic means of remediation. In some cases, it would be advantageous to have a licensed engineer or architect perform a structural evaluation of the damaged components to determine their adequacy. In some circumstances, for example, when the damage is significant or easily observable, the complete removal and replacement of damaged components can be a possible solution. The following types of remediation require a licensed engineer or architect:
    1. Modifications to existing structural systems, for example, alterations to cantilever framing members that are not a complete replacement in-kind.
    2. Complete removal and replacement of E3s.
    3. Complete removal of E3s with the associated restoration of the building façade.
      Note: Replacement or retention of original materials and the use of original methods of construction is permitted provided such materials or methods complied with the building code provisions in effect at the time of original construction. Complete replacements will require conformance to current code requirements.
  2. Waterproofing Remediation: If water damage or signs of active water intrusion are observed, the licensed professional will make a reasonable attempt to locate the source(s) of water and remediate it before completion of the Certification Form. The exact method of determining leakage is up to the licensed professional; it may or may not include the following:
    1. Review of available original and prior modification construction documents.
    2. Review slope to drain at surface and membrane levels.
    3. Review drain/gutter/downspout function.
    4. Review conditions at penetrations, fenestrations, changes in plane, etc. (e.g., door threshold, deck-to-wall flashing).
    5. Review the function of existing concealed space ventilation if present.
    6. Perform water testing, thermal imaging, and/or electronic leak detection (as appropriate for the existing building conditions).
    7. Determine the moisture content of materials.
    8. Perform invasive testing to observe the condition of the concealed membrane system. Invasive testing may include isolated borescope openings or selective demolition of larger areas.

D. Prepare Remedial Design

Develop the remediation design, prepare construction drawings, and file a building permit application. Some forms of maintenance-based remediation, for example, application of preservatives or sealants, may not require a building permit.

E. Execute Remediation Work

Perform the remedial work, restore building finishes, and final building permits, as applicable.

F. File Certification Form

After the remedial work is completed, file the Certification form with the City Code Enforcement office. One certification form must be filed for each separate building and a single professional must be responsible for certification of all E3s on the building.

G. Written Report

  1. The documentation of the current condition shall include photographs, any test results, and a narrative sufficient to establish a baseline. The condition of the components inspected can be compared to the results of subsequent repairs and inspections. In addition to the evaluation required by this section, the report shall advise which, if any, exterior elevated element poses an immediate threat to the safety of the occupants. The written report will include expectations of future performance.
  2. It is not necessary to submit this report to the city unless requested to do so. The California Health and Safety Code Section 17973 requires inspectors to provide a written report of the evaluation stamped or signed by the inspector to the owner of the building or the owner’s designated agent within 45 days of completion of the inspection. Records of the SB-721 Inspection report will be retained for two cycles of six each.