What is Binding Interpretation No. 318?
It establishes that special inspections are required whenever a building’s structural system or structural loading is modified. Under this interpretation, window and door replacements are considered structural modifications, which means they trigger threshold inspection requirements.
Who issued Binding Interpretation No. 318?
Binding Interpretation No. 318 was issued at the state level by the Building Officials Association of Florida in coordination with the Florida Building Commission and the Florida Department of Business & Professional Regulation.
As this is a binding interpretation, it is law and must be followed uniformly across jurisdictions. It is not a local policy and is not subject to alternative interpretation.
What is a Threshold Building?
In accordance with Florida Statute, any building which is greater than 3 stories or 50 feet (15 240 mm) in height, or which has an assembly occupancy classification that exceeds 5,000 square feet (464.52 m2 ) in area and an occupant content of greater than 500 persons.
What types of projects are affected?
- Window/Door Replacements
- Exterior Shutters
Who can obtain a permit for Window/Door work on a threshold building?
The state has determined that a window replacement constitutes a modification to the structural system. As such, a CBC is not allowed to perform this work because it is classified as a structural modification.
- Florida Statute, 489.105(3)(a) “General contractor” means a contractor whose services are unlimited as to the type of work which he or she may do, who may contract for any activity requiring licensure under this part, and who may perform any work requiring licensure under this part, except as otherwise expressly provided in s. 489.113.
How does this affect the permitting process?
A new permit type has been created: Com Threshold Windows & Doors
Applicants must submit the following documents:
- General Permit Application (link to our form on website)
- Design pressures per Location of Building – engineered
- Florida Product Approval specification sheet
- Digital Floor plan (numbered locations)
- Structural Inspection Plan prepared by a licensed engineer or architect, as required by Section 110.8.1 of the Florida Building Code.
- Window Opening Control Devices (where required by code) WOCD – FBC Building 1015.8
Who prepares, and what is required on the Structural Inspection Plan?
It must clearly define the inspection procedures and requirements that the Special Inspector will follow throughout the project, in accordance with Section 110.8.1.
Who performs the Window/Door inspection?
The inspection must be performed by the Special Inspector. Local jurisdictions are not permitted to perform duplicate inspections on threshold buildings. After completing the inspection, the Special Inspector must email the report to the Building Official at gpcommercial@mygulfport.us