# 10' from roof edge



## Rick18071 (May 5, 2011)

a existing roof top unit was already within 10' of roof edge and it is being replaced do they have to put a guard up?  IMC 304.10


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## rshuey (May 5, 2011)

Yes, or they can move the new on e over.


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## north star (May 5, 2011)

*% % % %*

According to Section 102.3 [ `06 IMC ], I will say "yes, required !"
Section 102.3:*Maintenance. *"Mechanical systems, both existing
and new, and parts thereof shall be maintained in proper operating
condition in accordance with the original design and in a safe and
sanitary condition........Devices or safeguards which are required
by this code shall be maintained in compliance with the code edition
under which they were installed..........The owner or the owner’s
designated agent shall be responsible for maintenance of
mechanical systems........To determine compliance with this provision,
the code official shall have the authority to require a mechanical
system to be reinspected. "

*% % % %*


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## rshuey (May 5, 2011)

They can "repair" the old one.....or move the new one over.....or install some guards....

the options are limitless!


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## RJJ (May 5, 2011)

I agree they need a guard or must move the unit!


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## mtlogcabin (May 5, 2011)

Agree with others

FYI we require the guards during a re-roof also. Roofers did not like it at first but now they are all on board.


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## fatboy (May 5, 2011)

Agreed, move or guards..................


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## Pcinspector1 (May 5, 2011)

Agree with the others, check to see if they have a WP GFCI service outlet while your up there on the roof? NEC210.63.

pc1


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## peach (May 5, 2011)

maybe.. or put the walkway on the upside of the slope..  (above the equipment)..  flat roof.. no


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## jar546 (May 5, 2011)

I think you guys are forgetting that the OP is in PA and all the contractor has to do is call and complain to a twp supervisor or borough councilperson and any requirements are waived by political intimidation.:devil


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## globe trekker (May 5, 2011)

The OP did not mention the locale.  Besides,  the political intimidation thingy is done in every

location in the world, to greater or lesser degrees.

The Forum members simply supplied Rick with the code section that requires it.

.


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## RJJ (May 6, 2011)

Jeff: That's why the State saying is" You Have A Friend IN Pennsylvania "


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## Rick18071 (May 6, 2011)

I failed it because it was only 6' from the roof edge without a guard. But I felt uncomfortable failing it because there was 20 other units on the same roof less than 10' from edge.


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## north star (May 6, 2011)

*& & & &*

Rick,  ..the difference is that the other 20 units are not
"new" construction / installation..........Once they remove
the old one and replace with a "new" one, the requirements
for "new" apply.......See the listed code section above.

BTW, which codes are you [  or the AHJ in question ] using ?

*% % % %*


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## pwood (May 6, 2011)

6' is o.k. in the umc. imc workers must stagger around a little more.


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## Rick18071 (May 9, 2011)

2009 IBC.  the BCO (my boss) told me to pass it.


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## steveray (May 9, 2011)

Rick18071 said:
			
		

> 2009 IBC.  the BCO (my boss) told me to pass it.


Sorry for that......I guess "You pass it!" is not an option?


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## mtlogcabin (May 9, 2011)

Rick18071 said:
			
		

> 2009 IBC. the BCO (my boss) told me to pass it.


Is he willing to put his initials on the approval?

He can delegate authority but he can't delegate responsibility.


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## Rick18071 (May 9, 2011)

He signs the C.O.


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## fatboy (May 9, 2011)

Sounds like it becomes his possible problem child in the future then!


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## Big Mac (May 11, 2011)

Unfortunately, it seems like one of the requirements of employment to fill the position of Building official is to have your genitailia and spine removed before assuming the position.


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## ARES (May 11, 2011)

Has anyone thought to see what the code required when the unit was originally installed? The code has not always required the 10' distance. In the 1981 Boca mechanical code the distance was 6' to the roof edge. You don't want to require something that would be considered retro-fitting.


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## mtlogcabin (May 11, 2011)

> You don't want to require something that would be considered retro-fitting.


Good point but I think requiring the gaurds during a unit replacement can justified through the current code lanquage.

EQUIPMENT, EXISTING. Any equipment regulated by this code which was legally installed prior to the effective date of this code, or for which a permit to install has been issued.

Once the equipment is removed it is no longer existing and the installation of new equipment is required to meet code.

Charging lanquage

301.1 Scope.

This chapter shall govern the approval and installation of all equipment and appliances that comprise parts of the building mechanical systems regulated by this code in accordance with Section 101.2.

Mandatory general requirements as listed in Section 304

304.1 General.

Equipment and appliances shall be installed as required by the terms of their approval, in accordance with the conditions of the listing, the manufacturer’s installation instructions and this code. Manufacturer’s installation instructions shall be available on the job site at the time of inspection.

Specific mandatory requirement

* 304.10 Guards**.*

*Guards shall be provided** where appliances, equipment, fans or other components that require service and roof hatch openings are located within 10 feet (3048 mm) of a roof edge or open side of a walking surface and such edge or open side is located more than 30 inches (762 mm) above the floor, roof or grade below. The guard shall extend not less than 30 inches (762 mm) beyond each end of such appliances, equipment, fans, components and roof hatch openings and the top of the guard shall be located not less than 42 inches (1067 mm) above the elevated surface adjacent to the guard. The guard shall be constructed so as to prevent the passage of a 21-inch-diameter (533 mm) sphere and shall comply with the loading requirements for guards specified in the International Building Code.*


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## fatboy (May 11, 2011)

I agree mt, we consider replacement = new for HVAC equipment. Service recepts, guards, clearances, the whole enchilada.


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## north star (May 11, 2011)

** * * **
*"I agree mt, we consider replacement = new for HVAC equipment. Service **recepts, guards,**clearances, the whole enchilada"*.
Does "your whole enchildada" include the structure upon which the
old one was mounted?...Inexact words, ...does the structure qualify
as part of the whole system?....Not just the HVAC equipment itself?

** * * **


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## Papio Bldg Dept (May 11, 2011)

north star said:
			
		

> Does "your whole enchildada" include the structure upon which the old one was mounted?...In
> 
> exact words, ...does the structure qualify as part of the whole system?....Not just the
> 
> HVAC equipment itself?


It should, at a minimum, compare the existing equipment weight to the new equipment weight, and verify that no increase would require structural modifications, IMO.


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## mtlogcabin (May 11, 2011)

> In exact words, ...does the structure qualify as part of the whole system?....


Yes. Found a few that a structural engineer had to be called in due to increased equipment loads.


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## north star (May 11, 2011)

** * * **

*If the HVAC equipment mounting structure is part of
the "whole enchilada", then would you still require a
guard if the "new" HVAC equipment is simply switched
out for the old one?.......The "whole enchilada" is
installed closer than 10 ft. to the edge.......This is
the crux of Rick's OP, me thinks.*

*Your thoughts!*

*& & & &*


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## fatboy (May 12, 2011)

northstar, as others have answered, yes, if there is a load concern, then yup. As far as a changeout, it is still a new installation, same reason load changes would apply.


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## north star (May 12, 2011)

*$ $ $ $*

*fatboy, ...**I agree that it is a "new" [ equipment ] installation !
I  even agreed on Topic Response # 3......In trying to think this
through, some might say that because the structural support for
said HVAC equipment has not moved / been altered,  that "the
whole enchilada" was not affected ( i.e. - "not new"  ), therefore
no guards would be required.........Rick's BO may have even
interpreted it this way.....No additional loading is an assumed
"given constant" in this equation for **discussion purposes.*

*$ $ $ $*


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## fatboy (May 12, 2011)

Yes, I could see that interp from the loading side. Reallistically, the new equipment most likely weighs less the unit being replaced, and I wouldn't be as concerned, unless I knew that for some reason, the new was upsized. But, replacement still = new for me, so other provisions would apply. JMHO, others obviously may disagree.

I was hoping for my first all-nighter of sleep since rotator cuff surgery last Wednesday........didn't happen......hello middle-of-the-night gremlins! (AKA-Pain!)


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## ARES (May 12, 2011)

I would not enforce the guards for a like for like replacement of an RTU. If I understand you correctly fatboy, if I replaced the old fixtures in a restroom with new fixtures you would consider this a new installation. So if during your inspection you find several accessibility issues you will make them correct these issues. How is this not considered retro-fitting?


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## north star (May 12, 2011)

** $ * $ * $ **

ARES,

The code sections listed above are [ IMO ] pretty clear regarding "new"

equipment installs.....I too am in the camp of requiring guards on "new"

equipment, regardless of the "like for like" replacement.

To me, if the structural support for said equipment was not installed in

a compliant location, under the code in which it was installed, that does

not negate the current code requirements.....Let's say that the equipment

*" Rick 118071 "* mentioned was installed under the 2006 codes....Then

by code [ specifically - Section 304.10 ], a guard IS required, ...unless

the powers-that-be overrule it.

Not trying to diss you or start an argument, ...just seems pretty clear,

to me anyway!   

*$ * $ * $ * $*


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## texasbo (May 12, 2011)

For those of you who would require guards for a replacement RTU, if it required climbing over a 30" obstacle, would you require compliance? If the existing ladder didn't meet code, do you require a new one to be installed? If it's on a roof with slope greater than 4:12 what do you do?

If it was a replacement attic unit, and the existing access didn't comply, would you make them enlarge it? If the unit was too far away from the access would you require a new access? If existing catwalk didn't comply, would you require replacement? If headroom was less than 30" would you require unit to be moved or roof to be raised?


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## Rick18071 (May 12, 2011)

Codes only started here in 2004. This building was built in the 70's


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## mtlogcabin (May 12, 2011)

I consider the guards a life safety issue And a BO could use the building code to require retro work

102.6 Existing structures.

The legal occupancy of any structure existing on the date of adoption of this code shall be permitted to continue without change, except as is specifically covered in this code, the International Property Maintenance Code or the International Fire Code , or as is deemed necessary by the building official for the general safety and welfare of the occupants and the public.

I believe a service tech would be part of the public.


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## davecarlson98 (Oct 11, 2022)

Hi All, new to this Forum!....doing an HVAC replacement on the flat roof of my Townhouse in Santa Monica that was built in 1997.  The roof is surrounded by a 2 1/2 foot Parapet wall.  The Condenser is closer than 10' to one parapet wall however the wall is not the edge of the building.  The exterior wall of the building is 22' away but one story down(another flat roof).  If the Condenser fell over the parapet wall, it would land on our flat roof one story below....do you think I would still need a guard rail?


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## e hilton (Oct 12, 2022)

The guard rail is for people, not equipment.  Have you read the applicable code sections?


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## davecarlson98 (Oct 12, 2022)

e hilton said:


> The guard rail is for people, not equipment.  Have you read the applicable code sections?


Thanks Bro, if I am reading this thread correctly, it applies to equipment after 2011.  Local Building Inspector brought it to my attention....do I have it wrong?  Hope so!    Code 304.1 Guards referenced above


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## ICE (Oct 12, 2022)

The minimum clearance to the edge of the roof is six feet….less than six feet requires a guard.


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## davecarlson98 (Oct 12, 2022)

ICE said:


> The minimum clearance to the edge of the roof is six feet….less than six feet requires a guard.


This is the code I'm referring to.... Do I have it wrong?


*304.10 Guards.

Guards shall be provided where appliances, equipment, fans or other components that require service and roof hatch openings are located within 10 feet (3048 mm) of a roof edge or open side of a walking surface and such edge or open side is located more than 30 inches (762 mm) above the floor, roof or grade below. The guard shall extend not less than 30 inches (762 mm) beyond each end of such appliances, equipment, fans, components and roof hatch openings and the top of the guard shall be located not less than 42 inches (1067 mm) above the elevated surface adjacent to the guard. The guard shall be constructed so as to prevent the passage of a 21-inch-diameter (533 mm) sphere and shall comply with the loading requirements for guards specified*


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## Mech (Oct 12, 2022)

1. Is the upper roof more than 30 inches above the lower roof?
2. Is the equipment within 10 feet of the upper roof edge?

If the answer to both questions is yes, then a guard is required.


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## ICE (Oct 12, 2022)

davecarlson98 said:


> This is the code I'm referring to.... Do I have it wrong?
> 
> 
> *304.10 Guards.
> ...


303.8.4 CMC requires 6’
303.8.4 Clearance. 
_Appliances shall be installed on a well-drained surface of the roof. At least 6 feet of clearance shall be available between any part of the appliance and the edge of a roof or similar hazard, or rigidly fixed rails, guards, parapets, or other building structures at least 42 inches in height shall be provided on the exposed side. _

1015.6 CBC requires 10’
1015.6 Mechanical equipment, systems and devices.
_Guards shall be provided where various components that require service are located within 10 feet of a roof edge or open side of a walking surface and such edge or open side is located more than 30 inches above the floor, roof or grade below. The guard shall extend not less than 30 inches beyond each end of such components. The guard shall be constructed so as to prevent the passage of a sphere 21 inches in diameter.
Exception: Guards are not required where personal fall arrest anchorage connector devices that comply with ANSI/ASSE Z 359.1 are installed._

1015.7 Roof access. 
_Guards shall be provided where the roof hatch opening is located within 10 feet of a roof edge or open side of a walking surface and such edge or open side is located more than 30 inches above the floor, roof or grade below. The guard shall be constructed so as to prevent the passage of a sphere 21 inches in diameter.
Exception: Guards are not required where personal fall arrest anchorage connector devices that comply with ANSI/ASSE Z 359.1 are installed._

Apparently Santa Monica has a 304.10 that I don’t have.


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## davecarlson98 (Oct 12, 2022)

Mech said:


> 1. Is the upper roof more than 30 inches above the lower roof?
> 2. Is the equipment within 10 feet of the upper roof edge?
> 
> If the answer to both questions is yes, then a guard is required.


Thanks bro, do you know which code calls out the 30" limit.... Thanks again, Dave


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## Mech (Oct 12, 2022)

davecarlson98 said:


> Thanks bro, do you know which code calls out the 30" limit.... Thanks again, Dave



I was interpreting the code section you provided.  I am not a California guy, so I do not know if that code section is accurate or correct.  Sorry.


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## steveray (Oct 13, 2022)

I think NFPA 54 gets you the 6'.....maybe where Cali gets it from in their CMC


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## davecarlson98 (Nov 12, 2022)

How do you engage a company/engineer to set up guardrails at a reasonable cost?  Thanks, Dave


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## Genduct (Nov 12, 2022)

rshuey said:


> Yes, or they can move the new on e over.


I think you may want to review the structural supports of this rooftop unit before you jump to that "solution"


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## rgrace (Nov 22, 2022)

Lots of discussion here, mostly in favor of guards for the replacement of a roof top unit. I have a different position, and it may only be a jurisdictional thing, since our state adopted Existing Building Code (VEBC) has undergone many changes. Current adoption edition is 2018.

I start in our adopted VEBC based on the scope of this work and that the work is to an existing building, in this case a like-for-like replacement of a roof top unit. The VEBC will send me to the other codes if it deems necessary (IBC, IMC, etc.) The scope of work is either alteration or repair. The definitions of _alteration_ and _repair_ are identical between the VEBC and the IEBC, so there is not much information there that can guide me, and it's not exactly crystal clear for this application. Jumping to VEBC Chapter 5, *Repairs*, the opening statement in Section 505.1 states "Repairs, including the patching or restoration or replacement of damaged materials, elements, _equipment_ or _fixtures _shall comply with the requirements of this chapter." Paraphrased, replacement of damaged equipment would qualify as a repair. If the roof top unit is being replaced, it is probably damaged in some fashion which requires a repair.

The second part of the VEBC that is relevant is Section 505.1 which states "Existing mechanical systems undergoing repair shall not make the building less conforming than it was before the repair was undertaken." The way I read that is if a roof top unit is being replaced in the same location is it removed, the work is such that it is not creating a situation where the building is less conforming than it was before the repair was undertaken. No guards before, no guards required now.


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## redeyedfly (Nov 22, 2022)

davecarlson98 said:


> Thanks bro, do you know which code calls out the 30" limit.... Thanks again, Dave


It's in the code snip you posted.


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## Genduct (Nov 22, 2022)

rgrace said:


> Lots of discussion here, mostly in favor of guards for the replacement of a roof top unit. I have a different position, and it may only be a jurisdictional thing, since our state adopted Existing Building Code (VEBC) has undergone many changes. Current adoption edition is 2018.
> 
> I start in our adopted VEBC based on the scope of this work and that the work is to an existing building, in this case a like-for-like replacement of a roof top unit. The VEBC will send me to the other codes if it deems necessary (IBC, IMC, etc.) The scope of work is either alteration or repair. The definitions of _alteration_ and _repair_ are identical between the VEBC and the IEBC, so there is not much information there that can guide me, and it's not exactly crystal clear for this application. Jumping to VEBC Chapter 5, *Repairs*, the opening statement in Section 505.1 states "Repairs, including the patching or restoration or replacement of damaged materials, elements, _equipment_ or _fixtures _shall comply with the requirements of this chapter." Paraphrased, replacement of damaged equipment would qualify as a repair. If the roof top unit is being replaced, it is probably damaged in some fashion which requires a repair.
> 
> The second part of the VEBC that is relevant is Section 505.1 which states "Existing mechanical systems undergoing repair shall not make the building less conforming than it was before the repair was undertaken." The way I read that is if a roof top unit is being replaced in the same location is it removed, the work is such that it is not creating a situation where the building is less conforming than it was before the repair was undertaken. No guards before, no guards required now.


I Agree and think you have just demonstrated a situation where you Discerned the INTENT of the Code and APPLIED IT ) You didn't INFLICT the Code)
Perhaps you could insert an Informational Sentence reminding the Permit Applicant that a tie-off for Fall Protection may be required by Other AHJ's ( like OSHA) as a "Friendly reminder" OR PUT THEM ON NOTICE.
 We should not forget we are all about SAFETY


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## klarenbeek (Nov 22, 2022)

In one of the earlier editions of the IEBC straight replacements were specifically listed as Level 1 alterations, and the service and access requirements (other than manufacturer's clearances) were NOT required. 2021 IEBC skips from repairs to level 2 alterations, which is actually making changes to the system.  Since Mechanical is no longer addressed in Level 1, I would put a like for like more in the category of a repair, not a reconfiguration.  as long as they are not making the situation worse, no rails required if they are not already there.


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## steveray (Nov 30, 2022)

klarenbeek said:


> 2021 IEBC skips from repairs to level 2 alterations,



QUE?....i don't see this in my books?

ALTERATION—LEVEL 1
602.1 Scope. Level 1 alterations include the removal and
replacement or the covering of existing materials, elements,
equipment or fixtures using new materials, elements, equipment
or fixtures that serve the same purpose.


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## steveray (Nov 30, 2022)

rgrace said:


> Lots of discussion here, mostly in favor of guards for the replacement of a roof top unit. I have a different position, and it may only be a jurisdictional thing, since our state adopted Existing Building Code (VEBC) has undergone many changes. Current adoption edition is 2018.
> 
> I start in our adopted VEBC based on the scope of this work and that the work is to an existing building, in this case a like-for-like replacement of a roof top unit. The VEBC will send me to the other codes if it deems necessary (IBC, IMC, etc.) The scope of work is either alteration or repair. The definitions of _alteration_ and _repair_ are identical between the VEBC and the IEBC, so there is not much information there that can guide me, and it's not exactly crystal clear for this application. Jumping to VEBC Chapter 5, *Repairs*, the opening statement in Section 505.1 states "Repairs, including the patching or restoration or replacement of damaged materials, elements, _equipment_ or _fixtures _shall comply with the requirements of this chapter." Paraphrased, replacement of damaged equipment would qualify as a repair. If the roof top unit is being replaced, it is probably damaged in some fashion which requires a repair.
> 
> The second part of the VEBC that is relevant is Section 505.1 which states "Existing mechanical systems undergoing repair shall not make the building less conforming than it was before the repair was undertaken." The way I read that is if a roof top unit is being replaced in the same location is it removed, the work is such that it is not creating a situation where the building is less conforming than it was before the repair was undertaken. No guards before, no guards required now.


Pretty spot on....and level 1 is the same...

701.2 Conformance. An existing building or portion thereof
shall not be altered such that the building becomes less safe
than its existing condition.


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## Rick18071 (Nov 30, 2022)

rgrace said:


> The second part of the VEBC that is relevant is Section 505.1 which states "Existing mechanical systems undergoing repair shall not make the building less conforming than it was before the repair was undertaken." The way I read that is if a roof top unit is being replaced in the same location is it removed, the work is such that it is not creating a situation where the building is less conforming than it was before the repair was undertaken. No guards before, no guards required now.


So now they would have to prove that guards were never there ever.


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## klarenbeek (Nov 30, 2022)

steveray said:


> QUE?....i don't see this in my books?
> 
> ALTERATION—LEVEL 1
> 602.1 Scope. Level 1 alterations include the removal and
> ...


Sorry, I didn't mean level 1 in general, but the section that was specific to mechanical.


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## davecarlson98 (Dec 8, 2022)

ICE said:


> 303.8.4 CMC requires 6’
> 303.8.4 Clearance.
> _Appliances shall be installed on a well-drained surface of the roof. At least 6 feet of clearance shall be available between any part of the appliance and the edge of a roof or similar hazard, or rigidly fixed rails, guards, parapets, or other building structures at least 42 inches in height shall be provided on the exposed side. _
> 
> ...


Thanks Ice, as you say, CBC requires 10', CMC requires 6'....Inspector is quoting CBC when in fact this is a 3 story Townhouse.   How do I politely let the Inspector know which should be using CMC instead?  Thanks in advance for any tips, Dave


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