BY WILLIAM BRACKEN, PE, FRSE, SI
In January 2026, the Florida Building Commission, the Florida Department of Business and Professional Regulation, and the Building Officials Association of Florida issued a Florida Building Code binding interpretation (report number 318) stating:
The replacement of windows constitutes a modification of the building’s structural system. Accordingly, this work is required to comply with Section 110.8.1 of the Florida Building Code, Building, 8th Edition (2023).
Subsequently, the Florida Building Commission has issued two Declaratory Statements that provide further clarification on the installation of windows and doors; one regarding new construction of threshold buildings and one regarding existing threshold buildings.
Declaratory Statement DS 2026-024
The first of the two declaratory statements, DS 2026-024, addresses the installation of windows and doors within new construction of threshold buildings.
DS 2026-024 was issued in response to the question submitted by Paul Zillio of Bliss & Nyitray Inc. which asked: “Does Section 110.8.1 require that we list the inspection of windows in this new building as a mandatory inspection?”
The Florida Building Commission responded, “Pursuant to Section 110.8.1 of the Florida Building Code, Building (2023), the structural inspection plan for a threshold building must be prepared by the engineer or architect of record and reviewed and accepted by the enforcing agency. The design professional is responsible for determining the structural elements and related inspections to be included in the plan. The inclusion of impact windows in the structural inspection plan is dependent on whether they are part of, or critical to, the structural system or load path, as determined by the engineer or architect of record and subject to acceptance by the enforcing agency.”
Declaratory Statement DS 2026-025
The second declaratory statement, DS 2026-025, addresses the installation of windows and doors within existing threshold buildings.
DS 2026-025 was issued in response to the questions submitted by Paul Zillio of Bliss & Nyitray Inc. pertaining to a project that included the replacement of windows with non-impact-resistant windows in the same rough openings, the replacement of doors, and the replacement of louvers on an existing 12-story multi-family building.
Specifically, the Florida Building Commission was asked: “#1 For the project in question, does Binding Interpretation number 318 require the inspection of the replacement windows? #2 If yes, then does that mean that inspection is required for the doors and louvers as well?”
The Florida Building Commission responded, “#1 The answer to the Petitioner’s question is no. The replacement of impact-resistant and nonimpact-resistant windows, doors, and louvers with equivalent products within the same rough openings, where no structural members are modified, does not constitute work that modifies the structural system or structural loading of the building. Accordingly, the scope of work for the project in question does not require special inspection pursuant to section 110.8.1 of the Florida Building Code, 8th Edition (2023).”
The Florida Building Commission’s response to question #2 was “See answer to question #1.”
Summary
Regarding the installation of windows and doors within new construction of threshold buildings, it’s the design professional of record in conjunction with the enforcing agency that decides whether the windows or doors are part of, or critical to, the structural system or load path, whether they are to be included in the special inspection plan, and the extent to which they are to be inspected.
Regarding the removal and replacement of windows and doors within existing threshold buildings, as long as there are no alterations to the size of the openings or modifications to the structural framing members, they are not required to comply with the Threshold Building requirements found in Section 110.8.1 of the Florida Building Code, Building, 8th Edition (2023).
Mr. Bracken’s career has spanned nearly four decades and has centered on the practice of civil/structural engineering while specializing in its application in the fields of Design, Construction, Building Codes, and Standards of Care. He has served as the vice-chair and chair of the Florida Board of Professional Engineers, as an Urban Search & Rescue Structural Specialist, and currently works as a Technical Trainer for the International Code Council. Mr. Bracken is a recognized Fellow within the Structural Engineering Institute (SEI), the American Society of Civil Engineers (ASCE), and is a Board-Certified Diplomate and Fellow of the National Academe of Forensic Engineers (NAFE).