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San Francisco Façade Inspection Ordinance

It was almost 25 years ago when a client called us and asked if we could stop by their building in downtown San Francisco—they had something to show us. When we arrived, the building engineer brought out a large piece of terra cotta masonry that was found on the sidewalk over the weekend. It matched their building’s exterior, and we could see a large void on the façade, like a missing tooth. Our subsequent conditions survey led to a stabilization project for the four facades of the client’s commercial structure. During the close-up inspection, at least two additional pieces of terra cotta came off in our hands. Many more were prevented from falling during the construction phase.

Although northern Californians may associate falling pieces of buildings with earthquakes, a far more frequent (and far less dramatic) cause is deferred façade maintenance. The potential of falling hazards due to deferred maintenance has been recognized in other U.S. cities for more than three decades. In fact, New York City’s façade inspection ordinance was, unfortunately, precipitated by the death of a Columbia University student who was struck by a falling piece of masonry in 1979. Many other cities in the U.S. have façade inspection ordinances, including Chicago, Illinois, and Columbus, Ohio.

San Francisco’s building officials have contemplated a façade inspection ordinance for several years. It will likely be implemented soon. The working group developing the ordinance has completed their draft, and it is currently being reviewed by the Code Advisory Committee of the San Francisco Building Department. It will affect virtually every building over five stories; some sooner than others depending on their dates of original construction.

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To involve the building community and design professionals in the development of the ordinance, the City’s Earthquake Safety Implementation Program (ESIP) formed a façade maintenance working group. I was a member of this group and represented the interests of the Building Owners and Managers Association (BOMA) of San Francisco’s members.

The group has produced two documents in the development of San Francisco’s façade inspection ordinance: (1) an administrative bulletin for building façade inspections and maintenance, and (2) the ordinance itself.

The bulletin establishes the policies for implementing the ordinance. It outlines which buildings in San Francisco are included in the ordinance, the required qualifications of the inspectors, the inspection procedures, the content of the inspection reports, and the special façade inspection requirements. The ordinance is the legislation that becomes part of the San Francisco Building Code, establishing the frequency of inspections, the types of buildings to be included in the ordinance, and the inspection and maintenance criteria for the affected structures.

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Although many buildings downtown and throughout the City are regularly maintained, others are not. The ordinance will require that all buildings that are five or more stories and that are of construction Type I, II, III, or IV undergo periodic façade inspections and necessary maintenance.

The initial inspection schedule requires that buildings constructed prior to 1910 be inspected by December 31, 2018. Buildings constructed between 1910 and 1925 must be inspected by December 31, 2020, and those built between 1926 and 1960 by December 31, 2022. After the initial inspection, buildings shall be inspected every 10 years.

The inspection schedule was developed to allow ample time for building owners and managers to comply with the new ordinance. Inspection procedures are broadly based upon standards developed by ASTM International (formerly known as the American Society for Testing and Materials) and issued in a document called ASTM E 2270, “Standard Practice for Periodic Inspection of Building Façades for Unsafe Conditions.” Industry stakeholders developed this standard through a rigorous consensus process.

There are three basic steps to the inspection procedure to be followed by the qualified professional retained to conduct the inspection. The first is to review any available information on the service history of the façade, such as permits for repair, past reports, or remedial repair drawings. The building engineer is frequently the best source of this information. The second step is an inspection of the property. The inspection involves a visual survey of the entire façade, followed by a close-range inspection of suspect areas if necessary. In extreme cases, the inspector may recommend a physical probe of the building cladding.

The third step to satisfy the façade inspection ordinance is for the inspector to analyze the findings of the site work and prepare a report that is submitted to the building owner, who in turn, submits the report to the San Francisco Building Department. Both the administrative bulletin and the façade ordinance reference the proper treatment of historic buildings and require the inspection professional to be conversant with the Secretary of Interior’s Standards for Treatment of Historic Properties.

If unsafe conditions are observed in the survey, the city is to be notified immediately and sidewalk protection or other measures taken to minimize falling hazards. Then the building owner is required to submit a plan and schedule for mitigating unsafe conditions within 72 hours.

Based upon my 25 years of conducting façade inspections and managing remedial repair projects for commercial structures, it is my opinion that the façade ordinance is not as onerous as it may first appear. Certainly, every qualified building manager realizes that routine maintenance of façades and roofs is a necessary expense and no different from servicing heating, ventilation, and cooling equipment. The most expensive exterior repairs are the result of conditions that have been left untreated for a significant length of time. This ordinance will help in the identification of maintenance and repair needs early, so that more costly repairs can be avoided down the road. For this reason, I believe the ordinance will save building owners money in the long run.

But the most important aspect of the façade inspection ordinance is that it will make our streets safer. The safety issues this ordinance seeks to address are real. We routinely observe falling hazards on buildings in San Francisco. Most of you involved with commercial property have a story to tell in this regard. The key to obtaining fair bids for remedial repairs is to allow adequate time for planning. I recommend not waiting until the end of the inspection period, when there will be a rush to comply with the ordinance. Begin the process reasonably soon, and you will be far more ahead.

An additional incentive: making sure your façades are in good shape soon means that everything is in order should you decide to sell the building. Anybody purchasing a large commercial property in downtown San Francisco is going to do some pretty serious due diligence, and they’ll want to know that the facade inspection ordinance’s requirements have been addressed.

The full text of ASTM E 2270 is available for purchase through ASTM International.