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OSHA Violations

Posted By Darin Douglas, Lowe Roofing, Inc., Tuesday, September 25, 2018
The Occupational Safety and Health Administration (OSHA) was started in April 1971 with the goal of dramatically affecting workplace safety in the United States.  Anyone who employs others, runs a business, or operates on a construction site must comply with OSHA’s rules and regulations.  Those regulations are backed by a series of violation categories with fines attached to many of them, and it is important to be aware of these as you navigate the world of workplace safety.  Starting in January 2018, new fine amounts were announced by OSHA and are currently in effect.  There are six different categories within the violation structure OSHA has set up.



De Minimis Violation

    De minimis violations result from a technical violation of OSHA rules but carries no impact on the safety and health of workers.  Inspectors will not issue a citation or fine for this violation, but will instead inform the employer of the issues and list them within the inspection report.  An example of a de minimis violation would be not having standard-sized lettering on your worksite hazard signs.



Other Than Serious Violation

    Other than serious violations have a maximum fine amount of $12,934 attached to them.  Violations in this category are defined as acts not causing death or serious bodily injury.  Inspectors have a lot of say in this category and can reduce fine amounts up to 90% in some cases.  Failing to provide employees with copies of safety rules and regulations would be an example of an other than serious violation.



Serious Violation

    The serious violation category is defined as having a definite chance to cause serious injury or death.  OSHA expects that employers should be aware of the serious hazards associated with the work being performed and should provide adequate safety controls to protect workers.  This violation carries with it a maximum fine amount of $129,336, but as with the previous categories, inspectors can adjust fine amounts based on things like the seriousness of the violation, company history, company cooperation, and many other factors.  Failing to provide any fall protection for workers on a 6:12 roof slope would be an example of a serious violation.  



Willful Violation

    The willful violation is the harshest category within OSHA's penalty structure and is issued when an employer knowingly disregards employee safety and health by intentionally not following OSHA rules and regulations.  This violation carries with it a maximum fine amount of $129,336.  Fines can grow rapidly if a person is killed due to this intentional lack of safety, sometimes becoming a criminal offense accompanied by possible jail time.  



Repeat Violation

    Repeat violations carry with it a maximum fine amount of $129,336.  An inspector can issue a repeat violation if the employer has been cited for the same thing, or something very similar, before.  Employers who are issued too many repeat violations risk inspectors issuing a willful violation if they feel an employer is blatantly disregarding OSHA recommendations and repeatedly committing the same violations.  



The Failure To Abate Prior Violation

    A failure to abate prior violation is issued when an employer fails to correct a cited hazard in the time allotted within the citation literature.  This violation comes with a fine of $12,934 for every day the cited hazard is not corrected after the citation is posted.  Issued citations by OSHA will come with all the necessary information employers need to meet abatement expectations, so failing to abate a hazard will not go well for the employer if inspectors have to return to the site.   



OSHA violations carry with them a significant financial challenge, and can have a lasting effect on workplace safety and health within a company.  As an employer, if you are issued a citation, make sure to give the process its due diligence.  Inspectors take into account lots of different things, and if your company is well informed and accountable, it can have a significant impact on inspectors when they look at possibly reducing fine amounts.

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Reducing Falls During Residential Construction: Re-Roofing

Posted By Chris Alberts, Western States Roofing Contractors Association, Monday, September 24, 2018
Updated: Tuesday, September 25, 2018

Courtesy of: OSHA.gov

 

Re-roofing exposes workers to the hazards of demolition work at heights. With the proper fall protection, the risk of serious falls can be substantially reduced. This fact sheet highlights some of the hazards workers encounter during re-roofing and lists some practical methods employers can use to protect workers who replace roofs. The fall protection methods in this fact sheet may not be suitable in all situations. Employers are responsible for ensuring compliance with applicable OSHA requirements.

 

Risks During Re-Roofing

Workers replacing roofs risk permanent injury or death from falls while they demolish old roofs and install new roofing material (for example, shingles, tiles, or slate). Even experienced roofers are exposed to unpredictable fall hazards caused by uneven sheathing, sudden gusts of wind, loose roofing materials, and surfaces that become slick when wet. Taking appropriate fall protection measures reduces risks and saves lives.

The employer must provide a training program for each worker who might be exposed to fall hazards. The program must enable each worker to recognize the hazards of falling and train each worker in the procedures to follow to minimize these hazards. For fall protection training requirements, refer to 29 CFR 1926.503. In all cases, employers must evaluate the hazards and take measures to reduce the risk of falls.

More than one-third of fall deaths in residential construction are caused by falls from roofs.

 

Safe Roofing Practices: Important Steps

Before beginning the job, focus on identifying fall protection needs. Survey the roof to determine if there are pre-installed anchorages available that can be used. If not, then plan immediately to identify those systems needed to protect workers from falls and have them in place before the workers report to the job.

 

Reducing Risks: Determining Structural Integrity

Many workers have been injured when the roofs they were working on collapsed from under them. Employers must determine the structural integrity of the roof and take all necessary precautions to protect the workers before the job begins (29 CFR 1926.501(a)(2)). If workers notice signs of structural deterioration (for example, dry rot), a competent person should evaluate the area.

Other considerations for a safe construction site:

  • Guard against falls through skylights or other roof openings. Use a guardrail system, a personal fall arrest system (PFAS), or a protective cover that will support two times the weight that may be imposed on it at any one time. For additional information on protecting workers around skylight and other roof openings, refer to 29 CFR 1926.501(b)(4) and 29 CFR 1926.502(i).
  • Appropriate footwear is important personal protective equipment on any construction site, but it is critical during roof demolition. A nail or shingle-removal tool injury can cause a worker to lose concentration and fall.
  • Workers should be careful of air hoses and power cords for nail guns and other electrical equipment. If a worker steps on one, hoses and cords can slip underfoot and lead to falls.

 

Staging Material

Loose material and hand-held equipment can create tripping hazards on the roof surface. To minimize exposure to fall hazards, employers can stage materials so that workers on the roof have quick and safe access to them. While handling material on the roof, the worker should hold the material on the side of his or her body that faces the down-sloped edge to prevent being struck by the materials if they are dropped. Material can also be staged so it cannot slide off the roof edge and potentially strike a worker on the ground. Slide guards can help to keep material from sliding off the roof. Establishing a restricted area around the perimeter of the project can also keep workers out of the danger zone where debris, tools or materials may fall to the ground. The area should be posted with signs that warn of the potential hazard.

 

Protect Workers on the Ground

During the demolition phase, protect workers on the ground from falling debris by controlling how debris leaves the roof. Consider using an all-terrain forklift to elevate a disposal box to the roof level. This method makes cleanup after the job particularly easy.

 

Using the Right Equipment

Employers must provide roofers fall protection equipment that meets OSHA requirements whenever they work 6 feet or more above a lower level. There are fall protection systems available that can provide roofers the flexibility they need during demolition and roof installation. Some are more efficient than others because, in many cases, the employer can use the same system for both processes. Each phase of roof replacement has different challenges, but the risk of falling remains constant. Contractors may be able to protect their workers using the following equipment:

  • Personal fall arrest systems;
  • Guardrails; or
  • Ladders.

Note: Fall protection requirements for residential construction work performed on ladders are in Subpart X, not in 29 CFR 1926.501(b)(13).

 

Providing Fall Protection for the Whole Job

Personal fall arrest system: A PFAS is a tool available to roofers during replacement jobs. In fact, a PFAS is the system of choice for many roofers. However, a breakdown in any component of a PFAS could be disastrous for a worker. Always follow the manufacturer’s instructions on selecting, installing and using PFAS components correctly. Some PFASs include special elevated anchor assemblies that permit the system to protect workers even when they stand near the anchor locations. Certain anchorage assemblies rotate or offer extension arms to improve mobility and prevent lifelines from contacting the roof surface. This is particularly useful during roof demolition when a line could catch on a nail or debris.

Personal Fall Arrest System (PFAS)

A PFAS is designed to safely stop a fall before the worker strikes a lower level. It includes three major components:

  1. An anchorage to which the other components of the PFAS are rigged.
  2. A full body harness worn by the worker.
  3. A connector, such as a lanyard or lifeline, linking the harness to the anchorage. A rip-stitch lanyard, or deceleration device, is typically a part of the system.

Horizontal lifeline: An engineered horizontal lifeline system, when used as part of a PFAS, is another way to increase the area in which a worker is protected. Install the system following the manufacturer’s instructions and under the supervision of a qualified person. Horizontal lifelines must be designed to maintain a safety factor of at least two (twice the impact load). For requirements for horizontal lifelines, refer to 29 CFR 1926.502(d)(8).

Rope grabs: Instead of attaching themselves to a fixed anchor, workers may be able to use adjustable rope grabs, another available component of a PFAS. This inexpensive and very popular system is the fall protection system of choice for many roofers. Rope grabs allow workers to adjust the length of the lifeline and can be useful when workers are moving about the roof frequently. The anchored ropes can be as long as necessary, making this form of fall protection highly versatile. Roofers who use rope grabs need to constantly take up the slack out of the line. Too much slack could allow a worker to free fall more than six feet off the roof if they slip. Training and monitoring are critical to the safe use of rope grabs.

Fall Restraint: While fall restraint systems are not mentioned in OSHA’s fall protection rules, OSHA will accept a properly utilized fall restraint system instead of a personal fall arrest system when the restraint system is rigged so that the worker cannot get to the fall hazard. In effect, (if properly used) the system tethers a worker in a manner that will not allow a fall of any distance. A fall restraint system is comprised of a body belt or body harness, an anchorage, connectors, and other necessary equipment. Other components typically include a lanyard, and may also include a lifeline and other devices.

Always follow the manufacturer's instructions or consult a qualified person to ensure proper installation of anchor points. Fall restraint may be a viable way to provide fall protection in situations in which the employer has concerns about the adequacy of available anchorage points for fall arrest equipment.

Temporary guardrails: Removeable guardrail systems can offer roofers effective protection when installed around the roof perimeter. Always follow the manufacturer’s instructions or consult a qualified person, as defined by 29 CFR 1926.32(m), for proper guardrail installation. This person could be the owner, the supervisor, or any other worker who has extensive knowledge, training and experience with fall protection and is able to solve problems relating to fall protection. For requirements requirements for guardrails, refer to 29 CFR 1926.502(b)- Guardrail Systems.

Other considerations: Some employers have found success in eliminating fall hazards by using scaffolds and aerial lifts when site conditions permit their use. Fall protection requirements performed on scaffolds and aerial lifts can be found in 29 CFR 1926 Subpart L – Scaffolds.

 

Attaching Anchors

OSHA requires that anchors for PFASs be able to hold at least 5,000 pounds of weight per person or maintain a safety factor of at least two (twice the impact load) under the supervision of a qualified person. Always follow the manufacturer’s instructions or consult a qualified person when installing anchors to ensure they are strong enough to hold the sudden weight of a falling worker. OSHA believes that anchorages available on the market will meet the strength requirements if they are installed as per the manufacturer’s instructions, with the right number of properly sized nails or screws through the roof sheathing and into one or more roof trusses.

When choosing an anchor to use for fall protection, employers have a number of options; for example,

  • Peak anchor: At the top of the roof, peak anchors are typically solid, non-moving pieces secured to the trusses underneath.
  • Permanent D-rings: Inexpensive D-ring anchors can be attached to the truss frame; they can be left permanently on the roof for future use.

Install an anchor above the area being built: Choose an anchor that is appropriate for the type of roof and anchor location. Depending on the roof design, the best location might be at the peak of the roof, directly over a truss.

Consider leaving anchors in place: Where practical, employers may consider leaving anchors in place. This can make the current job simpler and reduce the burden for roofers in the future.

 

Written Fall Protection Plans

When working at heights of 6 feet or greater, if the employer does not use ladders, scaffolds, aerial lifts or fall restraint systems and can demonstrate that it is not feasible or would create a greater hazard to use conventional fall protection equipment (guardrails, safety nets or PFAS), the employer must develop a written site-specific fall protection plan in accord with 29 CFR 1926.502(k). The plan must be prepared by a qualified person. This person could be the owner, the supervisor, or any other worker who has extensive knowledge, training and experience with fall protection and is able to solve problems relating to fall protection.

The site-specific fall protection plan must document, for each location, why the use of conventional fall protection equipment is not feasible or will create a greater hazard. The plan must also describe the alternative methods that the employer will use so that workers are protected from falls. Workers and their supervisors must be trained on the proper use of those other fall protection methods.

Conventional fall protection equipment can reduce or eliminate the chances of a fatal fall. Otherwise, a written site-specific fall protection plan ensures that protection continues, even when conventional fall protection methods are determined to not be feasible.

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OSHA Standard:

29 CFR 1926 Subpart M – Fall Protection

Available online at www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10922.

OSHA Residential Fall Protection Web Page: www.osha.gov/doc/topics/residentialprotection/ index.html.

 

OSHA Compliance Guidance:

Compliance Guidance for Residential Construction – STD 03-11-002 (dated 12/16/2010)

Available online at www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=4755.

State Plan Guidance: States with OSHA-approved state plans may have additional requirements for Residential Roofing. For more information on these requirements, please visit:www.osha.gov/dcsp/osp/statestandards.html.

Help for Employers: OSHA's On-site Consultation Program offers free and confidential advice to small and medium-sized businesses in all states across the country, with priority given to highhazard worksites. On-site Consultation services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards and assist in establishing injury and illness prevention programs. To locate the OSHA Consultation Program nearest you, call 1-800-321-OSHA (6742) or visit www.osha.gov/dcsp/smallbusiness/consult.html.

Almost every OSHA area office has a Compliance Assistance Specialist to assist employers in complying with OSHA standards. To find the Compliance Assistance Specialist nearest you, call 1-800-321-OSHA (6742) or visit: www.osha.gov/html/RAmap.html.

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LEGAL  DISCLAIMER

All rights reserved.  All content (text, trademarks, illustrations, reports, photos, logos, graphics, files, designs, arrangements, etc.) in this Technical Opinion (“Opinion”) is the intellectual property of Western States Roofing Contractors Association (WSRCA) and is protected by the applicable protective laws governing intellectual property. The Opinion is intended for the exclusive use by its members as a feature of their membership. This document is intended to be used for educational purposes only, and no one should act or rely solely on any information contained in this Opinion as it is not a substitute for the advice of an attorney or construction engineer with specific project knowledge. Neither WSRCA nor any of its, contractors, subcontractors, or any of their employees, directors, officers, agents, or assigns make any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or any third party’s use (or the results of such use) of any information or process disclosed in the Opinion.  Reference herein to any general or specific commercial product, process or service does not necessarily constitute or imply its endorsement or recommendation by WSRCA. References are provided as citations and aids to help identify and locate other resources that may be of interest, and are not intended to state or imply that WSRCA sponsors, is affiliated or associated with, or is legally responsible for the content reflected in those resources. WSRCA has no control over those resources and the inclusion of any references does not necessarily imply the recommendation or endorsement of same.

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OSHA’S CONFINED SPACE STANDARD FOR CONSTRUCTION

Posted By Western States Roofing Contractors Association, Monday, September 10, 2018


By: Trent Cotney, Cotney Construction Law

8621 E Dr. MLK Jr. Blvd, Tampa, FL 33610
866.303.5868 | tcotney@cotneycl.com

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According to the Occupational Safety and Health Administration (OSHA), a confined space is one that is large enough for an employee to enter fully and perform assigned work, such space is not designed for continuous occupancy, and is limited or restricted in means of entry or exit. Some examples include tanks, storage bins, silos, and underground vaults to name a few. A confined space is determined to be a permit-required confined space if has one or more of the following: potential hazardous atmosphere; material with potential to engulf an entrant; can cause entrant to be trapped or asphyxiated by inwardly converging walls/floors sloping downward, or any other serious safety/health hazard.

In order to better understand the allocation of responsibility under OSHA’s confined space standards, it’s helpful to understand the definitions of the parties involved with the permit space.  A competent person is one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees and who has the authority to take prompt corrective measures to eliminate them.  A controlling contractor is the employer that has overall responsibility for construction at the worksite.  A host employer is the employer that owns or manages the property where the construction is taking place.  The entry employer, which is a new term to the standard, refers to any employer who decides that an employee it directs will enter a permit space; in other words, this may be a roofing contractor, whether a contractor or subcontractor.   An attendant is an individual stationed outside one or more permit spaces who assesses the status of authorized entrants and who must perform duties specified by section 29 CFR 1926.1209.  An entry supervisor refers to the qualified person responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required.

Before beginning work on a worksite, a competent person must identify all confined spaces and permit spaces.  If the worksite contains a permit space, the roofing contractor must inform exposed employees and the controlling contractor of the existence and location of, and the danger posed by, each permit space.  If employees will not be entering permit spaces, the roofing contractor must take measures to prevent those employees from entering.  If employees will enter a permit space, the roofing contractor must have a written permit space program.  The OSHA website provides an example program for reference.

Before operations begin, the host employer must coordinate with the controlling contractor and provide information about the location, hazards, and precautions taken with regard to the permit space.  The controlling contractor must communicate that information to and coordinate with each entity which may enter the permit space or whose activities may result in a hazard in the permit space.  The controlling contractor must ensure that multiple entry employers do not create hazards for each other.  The entry employer must inform the controlling contractor of the permit space program that it will follow and the foreseeable hazards in each permit space.

As part of the permit space program, each entry employer must:

CLICK HERE TO CONTINUE...

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Author’s note:  The information contained in this article is for general educational information only.  This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.

Trent Cotney, CEO of Cotney Construction Law, is an advocate for the roofing industry, General Counsel of Western States Roofing Contractors Association (WSRCA), Florida Roofing & Sheet Metal Contractors Association (FRSA), Roofing Technology Think Tank (RT3), Tennessee Association of Roofing Contractors (TARC), and several other local roofing associations. For more information, contact the author at 866.303.5868 or go to www.cotneycl.com. 

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Technical Bulletin 2018-S1: Ice Damming on Cold/Ventilated Water Shedding Steep-Slope Roofs

Posted By Chris Alberts, Western States Roofing Contractors Association, Tuesday, September 4, 2018
Updated: Monday, September 10, 2018

Greetings WSRCA Members:

BACKGROUND INFORMATION:

During the past few winters, WSRCA Member Contractors in varying areas of the western U.S. have reported an increasing number and intensity of winter-time icedam formation and resultant damage at various buildings in the western states.

INTRODUCTION:

This Bulletin’s discussion of ice-dams, along with guidelines and suggestions for mitigation of ice dams, is focused on steep-slope roof systems in general and primarily on ventilated (i.e., theoretically vented, so “cold-in winter”) watershedding steep-slope roof systems. These ventilated/cold watershedding steep-slope roofs are frequently, though not exclusively, found on single-family and multi-family residential construction. These ventilated steep-slope roofs are also found on light commercial (e.g., dental and medical clinics, etc.) and some institutional buildings (e.g., schools, community centers, etc.). This document also considers ice-damming on warm (i.e., non-vented, but compact insulated) watershedding steep-slope roofs, which are frequently found with cathedral-ceiling or vaulted-ceiling construction on multi-story townhouses, other split-level residential, smaller scale commercial, and on many churches, and some other institutional projects.

THE ICE-DAM CYCLE:

Ice-dams are the naturally occurring eave edge refreezing of snow-melt water, typically at or upslope from the exterior wall line of a building. The subsequent repetitive back-up and refreezing of snow-melt along downslope roof perimeters and eaves is typically the initiator of melt-water (i.e., snow and/or ice melt) intrusion through layer(s) of watershedding roofing systems.

Five (5) stages of ice-dam formation are depicted and explained on the following pages. For reader clarity, the roof type sometimes used in heavy snow and ice climates have large Field-built ridge vent systems as is depicted in the following drawing excerpted from WSRCA’s Cold-Weather Tile Manual, Detail No. CWT10.

Thus, during a sub-freezing spell, a primary key to minimizing ice-dams is the reduction of snow-melt, which in turn may be mitigated by keeping the entire roof system or assembly below freezing temperature(s).

CONDITIONS AFFECTING ICE-DAM FORMATION:

Several controlling elements should be deliberated when considering steep-slope roof design or reroofing and the mitigation or “control” of ice-dams. Among the numerous items to be considered are:

• The climate the project is located in;

• The roof slope;

• The type of roof assembly (e.g., cold-ventilated roof or warm-compact insulated roof);

• The primary roof covering (e.g., asphalt shingles, tile, metal roofing, etc.);

• The roof design and vented or non-vented;

• Component configuration;

• Insulation;

• Ventilation;

• The building heating system;

• Potential air infiltration;

• The roof’s details and the layout of the roof including the related roof transitions (e.g., valleys, clerestory roof elevation changes where drifting can occur, etc.) and intersections (e.g., chimneys, skylights, plumbing vents, other roof penetrations, etc.).

Climate Considerations:

While technical resources are available for estimating the likelihood of ice-dam formation in various geographic locations, an empirical indicator is the history of ice-dam problems in the climatic location and/or region of your project. The long-term weather and climatic data, the experience and knowledge of local contractors, experienced roof designers, workers and building departments are the start to anticipating ice-dams and the potential means and methods to mitigating icedams and their affects.

Other climate-related factors include the effect of night-time clear skies, which accelerate the rapid cooling of roofs and refreezing of daytime melt-water, the orientation of the project roof, local topography and anticipated snow depths. Clear night-time sky radiative cooling often causes refreezing of snow-melt when freezing temperatures may not otherwise occur or be as severe on overcast or cloudy nights. Roof slopes oriented to the south experience greater snowmelt due to day-time solar radiation. Conversely, ice dams on roof areas oriented to the north may endure longer and prolong ice-dam issues. Local topography and wind patterns affects depth of snowdrifts, or inversely, snow scour. Counterintuitively, snow has some insulation capacity so that deep snow cover may adversely ‘warm’ (i.e., 33 degrees F) the roof deck of warm/compact roof assemblies. In addition, deep snow may block individual roof vents and ridge ventilation openings of cold/ventilated roof assemblies, thus accumulating attic heat, melting the snow cover and contributing to ice-dam formation.

Roof System / Roof Assembly Configuration:

Roof Type – As noted above, two general types of steep-slope roof assemblies may be considered concerning ice-dams: Cold/ventilated roof systems; and Warm/insulated compact roof systems. The physics of heat in these two roof types affects ice-dam formation. Cold/ventilated roof assemblies, if sufficiently ventilated, may allow less snow-melt because the sub-freezing air temperature in the ventilated roof cavity or space (e.g., the attic) keeps the roof sheathing, underlayment and primary roof covering (e.g., asphalt shingles, etc.) below freezing also. Warm/compact roof assemblies, in contrast, despite thick insulation, eventually conduct enough heat to melt snow cover.

Roof Configuration – Complex roof layouts or configurations can make for complex behavior of ice-dams. Interestingly, valleys, hips, overhanging eaves, closed or open soffits, headwalls, sidewalls, skylights and other roof elements can contribute to the complex behavior of internal heat flow and air movement, the success of ventilation air pathways, heat conduction and snow depth, including the effects of wind-driven snow drifting, which all can affect ice-dam

formation and severity. Interior elements, such as vaulted or cathedral ceilings, chimneys, the location of heater and heat registers, and others, can also significantly affect heat conduction and ventilation and so affect ice-dam formation and severity.

Extensive overhanging eaves warrant special caution because of the increased probability of upslope melt-water refreezing over large eave areas and the consequent likelihood of widespread damage. Short eaves, such as where fascia project only an inch or two for a ventilation gap, are near to the building’s heat which tends to keep melt-water in liquid state. Reaching the gutters, melt-water tends to refreeze because of freezing air on three sides: above, outboard and below. Longer eaves, projecting as much as several feet beyond the heat of the exterior wall, are that much more removed from the building’s heat and enveloped in subfreezing air that causes refreezing, ice dam build-up, resulting in water intrusion and damage.

Some have observed the formation of ice dams at extended eaves located above dark color south facing walls where solar heat builds-up below the eave. At compact insulated roof assemblies, some have chosen to extend the insulation through the eaves in order to minimize daytime heat transfer to the snow pack above the eave. To the contrary, some roofing contractors have reported skepticism of the function of insulated eaves for compact insulated roof assemblies as they have observed ice dam problems occurring during more severe winters. The several variables of orientation, solar radiation versus cloud cover, amount of insulation, daytime versus nighttime temperatures, mild versus severe climate patterns, and ventilated versus compact roof assembly indicate the topic of insulated eaves may be a subject for further examination.

Heat and Insulation – Insulation does not prevent the conduction of interior-generated heat through roof assemblies or into roof cavities and attics, but rather slows down the transfer of heat into the roofing system. Thicker insulations and higher thermal resistance (i.e., R-value) may minimize ice-dam formation during shorter duration freezes, but eventually allows snowmelt during longer periods of exterior freezes. As noted above, thick snow, which is a mild insulator, may affect the location of the melting plane within a roof’s snow cover. For example: a foot of lightweight fluffy snow may add insulation value of R-10 to more than R-20, above the roof covering. As a result, on warm/compact roof assemblies, the 33-degree or higher melt temperature may occur within the snow cover rather than on the surface of the roofing. Thermal bridging through fasteners, sandwiched sheet metal flashing flanges, and other non-insulation components may also contribute to the duration and volume of snow-melt and/or refreezing affects.

Air Infiltration – Air mass is able to transport many times more heat than is typically conducted through insulation. Therefore, air “leakage” from interior spaces (e.g., through unsealed can lights, kitchen range and/or bathroom exhaust fan ducting air leaks, etc.) into attics and roof assemblies may have a greater effect than insulation on snow-melt. Air exfiltration from building interiors into roof assemblies is more likely a concern in older roofs and older buildings, which are less airtight. Newer roofs are more likely to be ‘tighter,’ some of which may include an air infiltration barrier or vapor retarder. Vapor retarders may also perform as air barriers.

Vapor permeability of roofing materials plays a lesser, indirect role regarding ice-dams. A lowperm (i.e., vapor permeability unit of measure) rated ice-dam protection membrane installed above well-ventilated and properly insulated attic likely presents little, vapor/condensation issues, but achieving the “well ventilated and properly insulated” is difficult with some buildings. A low perm, ice-dam protection membrane above a warm/compact roof assembly, however, is sequentially misplaced as a potential vapor trap, which may cause condensation within the warm/compact roof assembly.

BUILDING CODE REQUIREMENTS & RELATED DATA:

The 2018 International Building Code (IBC) and International Residential Code (IRC) requirements for ‘Ice Barrier’ read similarly. For water-shedding roofs, ice barrier is required in regions where there has been a history of ice forming along the eaves causing water backup. Roofing contractors, roof designers and building owners should confirm the specific requirements for ice barrier with their local building department.

Ice barrier, per both the IBC and IRC, is required from a line 24-inches upslope of exterior walls to the lowest edges (e.g., to the fascia) of roof surfaces. It is prudent roofing practice to base this 24-inch upslope measurement from the interior face of the exterior wall. While WSRCA prefers the term ice-dam protection membrane, contractors, designers and owners should be aware of the I-Codes’ synonymous term ‘ice barrier.’ Ice-barrier, as defined by ICodes, is a minimum of two layers of asphalt saturated underlayment cemented together, or “self-adhering” polymer-modified bitumen sheet membranes.

IRC Figure R403.3(2) Air-Freezing Index an Estimate of the 100-Year Return Period, a nationwide contour map of freezing temperatures, may help identify ice-dam prone regions. A footnote indicates, “It is used as a measure of the combined magnitude and duration of air temperature below freezing.” Thus, it might be used in conjunction with NRCA recommendations, below. IRC Table R403.3(2) Air-Freezing Index for U.S. Locations by County compiles similar data in tabular form.

Industry Benchmark Guidelines:

WSRCA recommends ice-dam protection membranes “in cold climates where snow and ice are common” and “in areas of significant snow accumulation.” WSRCA further recommends icedam protection membrane “should be installed in all potential ice damming locations such as along downslope eaves in valleys, around chimneys, crickets, around roof penetrations, and up rake edges. At downslope roof edges it is recommended to extend ice dam protection membrane upslope a minimum of 24-inches inside the interior face of the exterior wall.” This means covering more than just the lowest 24-inches of eaves upslope of the fascia or gutter. Rather, cover all roof areas from the fascia/gutter line, upslope across all overhanging eave areas and exterior wall areas, then continue upslope 24-inches measuring from the interior face of the exterior wall.

NRCA recommends that ice-dam protection membrane be installed in locations where the average temperature for January is 30 degrees Fahrenheit or less. NRCA provides a map of such areas. Further, NRCA recommends ice-dam protection membrane be installed a minimum of 36-inches upslope of the outer wall’s interior line when the roof slope is less than 4 in 12.

In all cases, conservative judgement should be exercised while conforming to, or exceeding, the most rigorous requirements or benchmarks, whether Code, WSRCA, NRCA or others.

SOLUTIONS:

Solutions to ice-dam problems may best be interpreted as ventilation, ice-dam control or mitigation rather than complete prevention of ice-dams. Because of the broad variety and types of the current steep-slope watershedding roofs, existing as well as those yet to be designed and constructed, in conjunction with the variety of [micro-] climate conditions, the industry should understand that there are no universal and absolute solutions to ice-dam prevention.

For new roof projects, detailed design attention should be given to ventilation, insulation, icedam protection membrane, the membrane’s extent (e.g., distance upslope, potential number of plies, etc.), and whether there are or are not overhanging eaves. For existing roofs and reroofing projects, ice-dam protection membrane is a practical strategy of ice-dam control or mitigation of moisture intrusion and damage. WSRCA members should encourage clients to consider several strategies in addition to ice-dam protection membrane: retrofit of ventilation, sealing and airtight taping of interior penetrations that would otherwise allow interior air and heat leakage into the roof cavity, and the need for insulation review and upgrade or retrofit, or replacement in addition to ice-dam protection membrane(s).

Ventilation – Optimal ventilation, with regard to ice-dam mitigation, keeps the roof deck and roofing system below freezing, during periods of exterior freezes, by flushing air through, and thus heat out, of the attic or roof ventilation cavity. Venting of attics and cathedral ceiling roof cavities, utilizing downslope and companion upslope venting is the most common means for ventilation of steep-slope water shedding roof assemblies.

Historically, attic ventilation requirements prescribed by building codes were based primarily on condensation-related concerns – for example, roofs with vapor retarders are allowed less ventilation (1:300 ratio) than those without a vapor retarder (1:150 ratio). Ventilation for ice-dam control, however, is grounded on larger openings and cavities for moving larger volumes of sub-freezing exterior air into downslope eave (e.g., intake) vents, through the roof cavity or attic and out upslope roof vents (e.g., exhaust) or ridge vents. Whether for ice-dam control or condensation control, it is good basic roof design practice to balance eave ventilation intake-air openings in approximately 50-50 ratio with ridge or upslope exhaust-air openings. (See WSRCA Bulletin concerning roof ventilation.)

Cathedral ceiling roof assemblies, with ceilings attached directly to the underside of sloped roof rafters or trusses, are special cases of ventilated roofs. Research concerning roof ventilation for effective control of ice-dams on cathedral ceiling roof assemblies (see references) indicates that the necessary vent opening size and vent space above the insulation is related to the amount of roof insulation, roof slope and length of the slope. The research indicates that much larger openings and larger cavity height above the insulation is necessary-beyond that required by codes—for effective condensation and/or ice-dam mitigation. Vented nail-base insulation panels, though conceptually similar to “vented” cathedral ceiling roof assemblies, typically do not provide nearly sufficient ventilation and air-flow for ice-dam mitigation and condensation control in all such roof configurations.

Warm/compact steep-slope roof assemblies conduct heat through insulation over time and narrow closed cavities or spaces are susceptible to condensation, and contribute to ice-dam formation. Properly sized ventilation cavities, such as can be constructed with over-framing assemblies, located above a compact insulated roof assembly, can provide the ventilation necessary to move sufficient air under the elevated roof sheathing and thus reduce the likelihood of snow-melt and mitigate ice-dams.

Ice-Dam Protection Membrane / Ice Barriers – Both the International Building Code (IBC) and the International Residential Code (IRC) indicate that a history of ice-dam formation is prudent criteria for deciding to install an ice barrier (the IBC and IRC term) or ice-dam protection membrane (WSRCA preferred term) in roof assemblies. The IRC, however, requires ice barrier if adopted or specifically specified by the local building department in Table R301.2(1) the Climatic and Geographic Design Criteria.

 

CLICK HERE FOR THE FULL DOCUMENT...

 

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REFERENCE DOCUMENTS:

• WSRCA/TRI Tile Roofing Manual for Cold Climates, 1998, Reprinted 2005.

• Air Vent Inc. Attic Ventilation: Tips and Answers from the Experts December 2016.

• CertainTeed Shingle Applicators Manual, January 2011.

• Fryer, Mark; Brown, E. Staples; Design of Ventilated Attic Spaces for Buildings in Cold Regions; State of Alaska Department of Transportation and Public Facilities Division of Planning and Programming Research Section 2301 Peger Road Fairbanks AK 99701, January 1986.

• State of Alaska Department of Transportation & Public Facilities; Roofing Standards Manual, February 1986.

• Tobaisson, Wayne; Tantillo, Thomas; Buska, James; Ventilating Cathedral Ceilings to Prevent Problematic Icings at Their Eaves; Proceedings of the North American Conference on Roofing Technology September 1999, Toronto, Ontario.

• Holladay, Martin; How It Works: Ice Dams; Fine Home Building, December 2015 / January 2016.

• Holladay, Marin; Preventing Ice Dams; Fine Home Building, May 2011.

• Rupar, Maciek; Ice Dam Busting: Eradicating Ice Dams Begins Below the Roof Deck; Professional Roofing, June 2012.

• Hoffman, Jeffrey; An Ice Dam Analyzed; Journal of Light Construction, March 2010.

• Ireton, Kevin; Venting the Roof; Exterior Finishing Fine Home Building, June 2010.

• WSRCA Steep-Slope Committee; Laminated Shingles & Water-Shedding Roof Systems for Lower Slopes, January/February 2010.

• ARMA Asphalt Roofing Residential Manual Pages 47-48 Eave Flashing for Ice Dam Protection, 2006.

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LEGAL  DISCLAIMER

All rights reserved.  All content (text, trademarks, illustrations, reports, photos, logos, graphics, files, designs, arrangements, etc.) in this Technical Opinion (“Opinion”) is the intellectual property of Western States Roofing Contractors Association (WSRCA) and is protected by the applicable protective laws governing intellectual property. The Opinion is intended for the exclusive use by its members as a feature of their membership. This document is intended to be used for educational purposes only, and no one should act or rely solely on any information contained in this Opinion as it is not a substitute for the advice of an attorney or construction engineer with specific project knowledge. Neither WSRCA nor any of its, contractors, subcontractors, or any of their employees, directors, officers, agents, or assigns make any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or any third party’s use (or the results of such use) of any information or process disclosed in the Opinion.  Reference herein to any general or specific commercial product, process or service does not necessarily constitute or imply its endorsement or recommendation by WSRCA. References are provided as citations and aids to help identify and locate other resources that may be of interest, and are not intended to state or imply that WSRCA sponsors, is affiliated or associated with, or is legally responsible for the content reflected in those resources. WSRCA has no control over those resources and the inclusion of any references does not necessarily imply the recommendation or endorsement of same.

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Trent Cotney and Cotney Construction Law Named Legal Advisors to WSRCA Membership

Posted By Chris Alberts, Western States Roofing Contractors Association, Thursday, August 23, 2018
Updated: Tuesday, August 28, 2018

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In our continuing efforts to provide Members with the highest level of cost-effective and cutting-edge benefits, WSRCA proudly announces our new legal partnership with Trent Cotney and Cotney Construction Law (CCL).

Led by Trent Cotney and a growing team of construction attorneys, Cotney Construction Law (CCL) is a progressive law firm dedicated to fighting for the roofing industry throughout the Western States and beyond. Nationally, CCL is recognized as a one-stop shop for roofers with legal experience in all areas of construction law. With the knowledge, experience, and passion to level the playing field for clients, most of their attorneys have backgrounds in construction, ranging from work as estimators for structural contractors, roofers, overseas manufacturers of construction products, and supply house distributors.

With nationwide offices and licensure in 18 states, Cotney Construction Law has developed into an industry leader throughout the country, participating in the construction industry on a policy and educational side, sharing information through events and resources, and uniquely representing the roofing industry as a legal and business partner.

Florida Bar board certified construction lawyer, Trent Cotney, president, established the firm in 2012. Growing up with a family who worked in construction and personal experience in the industry as he made his way through school, Cotney says his focus was on creating a business whose sole purpose was properly serving the customer, and specifically representing the industry side.

To ensure a unique and relevant understanding of the industry, most of the 19 attorneys the firm now employs, along with key staff, come from construction backgrounds. “When I sit across the table from someone at another firm who does construction law, I know they’re smart, but I also know that there are very few who have had their hands dirty so to speak, actually working in the field.”

Cotney specifically hires people with backgrounds in construction because they know the industry from a business side and can better relate to clients about the nuances of their business and legal matters. “Construction is in all of our roots. An ethic of hard work, an understanding of the people and of the work, it is part of who we are and will always be the basis under which we operate.”

The firm advocates for the industry and works as general counsel for Florida associations including the Florida Roofing & Sheet Metal Contractors Association (FRSA), Florida Refrigeration and Air-Conditioning Contractors Association (FRACCA) and the Florida Irrigation Society (FIS). Last year the firm donated more than $120,000 in pro bono time for industry-related work and has donated tens of thousands personally to construction associations.

Other support for the industry includes assisting with the formation of the National Women in Roofing organization that launched early in 2016 and whose members now number in the hundreds, and two scholarships established to support young people pursuing careers in the industry. “We try to give back to the industry personally and professionally, through time, talent and treasure,” says Cotney.

Cotney has developed and shares his expertise in OSHA (Occupational Safety and Health Administration) defense and has published an Amazon best-selling book titled OSHA Defense for the Construction Industry. The firm was also named Lawyer Monthly’s OSHA Defense Law Firm of the Year (2015-2017).

The team represents clients ranging from small, family-owned operations, to publicly-traded companies. Cotney speaks at various state and national construction association events on topics such as construction contracts, employment and immigration issues, contractor licensing and collecting payments on projects

The firm is a full-service construction law firm and handles all aspects of construction law, immigration and employment issues, business planning and formation, and creditor’s rights and bankruptcy. “We are fortunate enough to have been recognized by our peers and the industry for our service and professionalism,” says Cotney, referencing the lengthy list of honors and awards both he and the firm have won including the Gold Circle Award for service from the National Roofing Contractors Association (NRCA 2014), Lawyer Monthly’s OSHA Defense Law Firm of the Year USA (2015-2017), and Florida Super Lawyers Top 100 Lawyers (2016, 2017).

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A View From the Hill - Political News: OSHA's Regulatory Agenda

Posted By Chris Alberts, Western States Roofing Contractors Association, Monday, August 20, 2018

A VIEW FROM THE HILL: Political News

By: Craig Brightup, The Brightup Group LLC

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President Trump’s actions on federal regulations have worked so well that there’s basically been a freeze on new regulations while older ones are repealed or pared back.  But an exception is the Occupational Safety and Health Administration (OSHA), which has continued to pursue an Obama-era regulatory agenda.

One of the standards drafted under President Obama that went into effect in the Trump Administration is the silica rule.  This rule shouldn’t have become effective for construction last year, because the Permissible Exposure Limit and Action Level are too low and work requirements and engineering controls are unrealistic in many situations.  Thus, OSHA says it will publish a Request for Information to start fixing the rule, but the enforcement moratorium is over and OSHA inspectors are issuing silica citations.

Another dubious policy from OSHA is its proposed rulemaking to revise the electronic injury and illness reporting rule that was issued by the Obama Administration and formerly known as the Improve Tracking of Workplace Injuries and Illnesses rule.  OSHA’s recent Notice of Proposed Rulemaking (NPRM) would modestly lighten the reporting burden for employers, but is silent on issues that most concern the business community and actually adds a controversial new disclosure requirement.

OSHA issued the original Tracking of Workplace Injuries and Illnesses rule in 2016 and it required establishments with 250 or more employees to electronically submit to OSHA recordkeeping data on the 300A, 300 and 301 forms.  The rule also required certain establishments with 20 – 249 employees to submit their 300A forms based on a list sorted by the North American Classification System that includes construction.

In addition, OSHA added a “whistleblower” provision that employers must post a “reasonable” policy on how employees are to report their injuries and safety violations.  Furthermore, the rule’s preamble states that most safety incentive and post-accident drug testing programs would be considered “unreasonable” and in conflict with the statute’s anti-retaliation (whistleblower) protections.      

On July 8, 2016, the National Association of Manufacturers and other business groups sued OSHA, targeting the impact on safety incentive and drug testing programs under the whistleblower provision.  On Jan. 14, 2017, the U.S. Chamber of Commerce and another set of business groups filed a second lawsuit in the U.S. District Court for the Western District of Oklahoma seeking a permanent injunction of the entire rule.

Both cases are stayed to allow the Trump Administration time to determine how to respond and OSHA must submit updates every 90 days to the court in Oklahoma.  But OSHA’s new rulemaking is so minimal that plaintiffs might reactivate the lawsuits.

The NPRM would change reporting requirements for establishments of 250 or more employees to just 300A forms, but it’s silent on the whistleblower provision and scrubbing sensitive information from submissions before posting on the OSHA website.  And it would add a controversial new requirement that establishments must include their Employer Identification Numbers (EIN) on their submissions.

In the meantime, employers should have submitted 300A forms electronically to OSHA by July 1, 2018.  Also, on April 30, 2018, OSHA clarified that employers in state-plan states where the state has not yet issued a companion regulation still must meet the federal requirements.  Finally, in 2019 and annually thereafter, the 300A form must be electronically submitted by March 2.              

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A View From the Hill - Political News: OSHA's Regulatory Agenda

Posted By Chris Alberts, Western States Roofing Contractors Association, Monday, August 20, 2018

A VIEW FROM THE HILL: Political News

By: Craig Brightup, The Brightup Group LLC

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President Trump’s actions on federal regulations have worked so well that there’s basically been a freeze on new regulations while older ones are repealed or pared back.  But an exception is the Occupational Safety and Health Administration (OSHA), which has continued to pursue an Obama-era regulatory agenda.

One of the standards drafted under President Obama that went into effect in the Trump Administration is the silica rule.  This rule shouldn’t have become effective for construction last year, because the Permissible Exposure Limit and Action Level are too low and work requirements and engineering controls are unrealistic in many situations.  Thus, OSHA says it will publish a Request for Information to start fixing the rule, but the enforcement moratorium is over and OSHA inspectors are issuing silica citations.

Another dubious policy from OSHA is its proposed rulemaking to revise the electronic injury and illness reporting rule that was issued by the Obama Administration and formerly known as the Improve Tracking of Workplace Injuries and Illnesses rule.  OSHA’s recent Notice of Proposed Rulemaking (NPRM) would modestly lighten the reporting burden for employers, but is silent on issues that most concern the business community and actually adds a controversial new disclosure requirement.

OSHA issued the original Tracking of Workplace Injuries and Illnesses rule in 2016 and it required establishments with 250 or more employees to electronically submit to OSHA recordkeeping data on the 300A, 300 and 301 forms.  The rule also required certain establishments with 20 – 249 employees to submit their 300A forms based on a list sorted by the North American Classification System that includes construction.

In addition, OSHA added a “whistleblower” provision that employers must post a “reasonable” policy on how employees are to report their injuries and safety violations.  Furthermore, the rule’s preamble states that most safety incentive and post-accident drug testing programs would be considered “unreasonable” and in conflict with the statute’s anti-retaliation (whistleblower) protections.      

On July 8, 2016, the National Association of Manufacturers and other business groups sued OSHA, targeting the impact on safety incentive and drug testing programs under the whistleblower provision.  On Jan. 14, 2017, the U.S. Chamber of Commerce and another set of business groups filed a second lawsuit in the U.S. District Court for the Western District of Oklahoma seeking a permanent injunction of the entire rule.

Both cases are stayed to allow the Trump Administration time to determine how to respond and OSHA must submit updates every 90 days to the court in Oklahoma.  But OSHA’s new rulemaking is so minimal that plaintiffs might reactivate the lawsuits.

The NPRM would change reporting requirements for establishments of 250 or more employees to just 300A forms, but it’s silent on the whistleblower provision and scrubbing sensitive information from submissions before posting on the OSHA website.  And it would add a controversial new requirement that establishments must include their Employer Identification Numbers (EIN) on their submissions.

In the meantime, employers should have submitted 300A forms electronically to OSHA by July 1, 2018.  Also, on April 30, 2018, OSHA clarified that employers in state-plan states where the state has not yet issued a companion regulation still must meet the federal requirements.  Finally, in 2019 and annually thereafter, the 300A form must be electronically submitted by March 2.              

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Roofing Is A Team Sport

Posted By Western States Roofing Contractors Association, Monday, August 13, 2018

Courtesy of: Gregg Wallick, President & CEO, Best Roofing

Gregg Wallick, President and CEO of Best Roofing, who serves South Florida’s commercial, industrial, and multi-family housing communities, was invited to present at the Western Roofing Expo in Las Vegas in June.  As a first-time attendee, Gregg chose “Roofing is a Team Sport,” a presentation about the four predictable growth hurdles that every company will encounter and how to move your company from an idea to a reality. 

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Roofing is a Team Sport

As your business grows, you will need more people, more locations and bigger databases.  And, of course, you can never run out of cash!  But, as you go through the pains of growing, you will find predictable growth hurdles every company must transition through. As you approach each hurdle, remember to avoid the Vicious Circle

Plus, remember that the only constant is change!  

Hurdle #1 ($1M revenue and 10 +/- full time employees)

At first, you will think that being an owner is going to be fun -- and then you realize chaos and confusion becomes the norm and you start to feel that:

·       Nothing gets down unless you do it;

·       You become too sales focused;

·       You’re 100% people dependent;

·       You’re always chasing cash and, worst of all,

·       You are working 12 hour days,

·       You own the company and it doesn’t pay much!

The only way to get past the first growth hurdle is to learn how to delegate.  It takes skills like delegation and leadership to get your business to the next level.

 

Hurdle #2 ($10M revenue and 75 +/- full time employees)

The second growth hurdle is to build a management team.  Your team needs a complimentary set of skills in order to succeed.  You must hire a:

·       “Get Work” person (your sales leader)

·       “Do Work” person (operations leader)

·       “Administer Work” person (administrative leader)

As you build your management team, you need to build an organizational chart and define roles and responsibilities in an effort to bring order to your team.  Once these factors have been defined, departments start to take shape, business cards are ordered, and then formal compensation plans must become a reality. 

One of the most important things to remember is leadership positions require people who can solve complex problems.  Always consider promoting from within and beware of the “Peter Principle” (promoting someone to their level of incompetency).   Building a solid management team around sound company principles takes time.  Be patient and don’t get discouraged.    

 

Hurdle #3 ($30M revenue and 175 +/- employees)

The third growth hurdle is planning and administration.  In order to succeed and grow, disciplined processes and procedures must be clearly defined.  Once that is done, you will need to implement a multi-platform computer system and establish budgets.  And, most importantly, get serious about job costing to measure performance and hold people accountable.  When these factors are in place, profit sharing emerges.

Solid management teams use KPI’s (Key Performance Indicators) monitor performance and ensure everyone has a full understanding of what to do and not do.   Sharing management resource books will help grow and guide your leadership teams and manage their expectations.  Make sure you have a solid sales automation tool.  My favorite is FollowupCRm.com

Hurdle # 4 (every company always deals with this)

The fourth growth hurdle is “Transition” -- who is going to replace whom? 

Bench strength is a critical piece of the puzzle in growing your company.  Good leaders are talent arrangers.  If you always play, “what if” and cultivate talent, a smooth transition within the company can be achieved.  We must always be recruiting.  

So, how so do you get from idea to reality?  You will need to follow these four steps:

 

Step 1. Identify your hedgehog concept.  (Read “Good to Great” by Jim Collins)

Step 2. Paint your picture.  Take the time to spell out your dreams.  Be very specific about each department. 

 Step 3. Identify priorities – What gets measured gets done!  Pick 3-5 “must-do’s’”.  If these 3-5 tasks get done, you will see great progress.

 Step 4. Cascade communication into a rhythm by holding.  Nobody ever over communicates.

In summary, in order to get your idea to become a reality, you will need to:

·       Establish a rhythm of communications;

·       Identify and execute your top priorities;

·       Paint your picture and share your dream;

·       Get alignment of your culture and strategy; and

·       Identify your vision and concept.

 

Final thoughts as you start your journey, it is your responsibility to remember that:

·       A Leader sets the pace,

·       A Leader confronts the problem, and

·       A Leader never ignores the human factor.

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WSRCA Informational Bulletin 2018-II-2: Static Electricity and Roofing Adhesive Fire Risk

Posted By Chris Alberts, Western States Roofing Contractors Association, Monday, August 6, 2018
Updated: Tuesday, August 28, 2018

Greetings to Members of Western States Roofing Contractors Association:

 

Introduction:

WSRCA’s Industry Issues Committee is responding to reports from Member Contractors in the Western U.S. by preparing the following Information Bulletin regarding on-roof fires that have been caused by static electrical sparks during the application of single-ply membrane roofing using solvent-based adhesive.

 

Executive Summary:

Solvent-based adhesives may release fumes when their pails/containers are open and during application that can be a potential fire hazard during specific conditions and/or situations. A spark is all that is required, under certain conditions, to ignite such fumes. During dry outdoor ambient conditions, sparks can be caused by static electrical discharge. These three conditions can come together during a single-ply roofing installation and unexpectedly start a fire. Reports from the field indicate that this has been the case for more than one contractor recently, especially when weather conditions have been conducive to static electricity.

Reports from the field indicate that when relative humidity is very low, whether it be during cold, dry weather, or hot and dry weather, static electrical charges can build up during insulation roofing application. Most reports have involved steel roof decks and faced polyisocyanurate roof insulation and single-ply roofs. Static charges can be created when weather conditions are right and rigid foam insulation boards are slid or dragged across each other, when membrane sheets are moved over the installed insulation or over other thermoplastic roof membrane sheets, and just from walking on the insulation or insulated roof. If static charges have accumulated, spark(s) may occur when the metal bar of the adhesive roller or applicator handle touches the metal adhesive pail or container, or even when a worker’s skin or hand touches metal. Sometimes these sparks result in ignition of adhesive fumes and/or the adhesive itself during application. There are measures to be taken to help prevent the build-up of static charges, such as: by confirming that the existing building or building-under-construction is grounded, by taking care regarding how materials are moved and placed on the roof, wearing all cotton rather than synthetic clothing, walking carefully without shuffling, grounding equipment being used on the roof, just to name a few.

However, reports from the field where fires have occurred indicate that it is very important that the crew understand how to respond to and extinguish on-roof fires as soon as possible when they occur. It is also important for the contractor to be aware of the weather conditions that may ead to static build-up. Cold and dry winter weather is commonly associated with static build up, but if relative humidity is very low build up can also occur during hot, dry weather.

We note that this issue is not being discussed much in the roofing and waterproofing industry. However, please be aware that the issue of static-electric spark problems is mentioned by the manufacturers of adhesive application equipment, it is also referred to in OSHA bulletins, and has been mentioned in articles published in NRCA’s Professional Roofing magazine. Thorough descriptions of the problem as it relates to single-ply roofing, however, are lacking, and detailed solutions have not yet been presented.

Background Information:

This issue has come to our attention solely through reports from the field. To date, the information we have is mainly from three (3) different WSRCA Member Contractors working in the Western U.S. However, the popularity of insulated single-ply roof systems in the Western U.S. creates a growing potential for this problem to occur, and WSRCA wants to be sure it’s members are aware of the potential hazard and can then be better prepared to prevent the potential for fires on their projects, as well as be prepared to minimize the potential damage to persons, property and potential lack of calm-handling of the situation and/or potential injury to unaware roofing technicians.

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7 Legal Myths You and Your Advisors May Believe

Posted By Western States Roofing Contractors Association, Monday, July 30, 2018

By: Larry Oxenham, Senior Advisor, American Society for Asset Protection

 

There are many financial and legal myths that circulate through society. A belief in these myths may result in serious problems. In a commencement address at Yale University, President John F. Kennedy taught, “The great enemy of the truth is very often not the lie—deliberate, contrived, and dishonest—but the myth—persistent, persuasive, and unrealistic.” Mark Twain echoed this thought when he said, “It isn’t what we don’t know that kills us, it’s everything we know that ain’t so.”

 

Myth 1: I Will Never Get Sued

If you own a business, you have exposure to many types of lawsuits even if you personally have done nothing wrong. For example, if someone injures themselves on your property (even if he/she were trespassing), you as the property owner would be liable for damages through what is called premise liability. Last year the average premise liability verdict was $2,001,754—and an award of $2.5 million or more was just as likely as an award of $50,000-$99,999.

Businesses also have exposure to employee liability. You could be sued for workplace accidents, negligent entrustment, wrongful termination, gender bias, racial bias, sexual orientation bias, religious bias, sexual harassment, and racial harassment. A lawsuit for any of these items could result in a multimillion dollar judgment. For example, one employee received an award of $86.7 million to compensate him for an accident at work that left him paralyzed (Miraglia v. H & L Holding Corp.).

Owning a business and not having protection against lawsuits, would be like living in an earthquake, hurricane, or flood zone and not purchasing the necessary insurance to protect your assets. Once the disaster hits, it is too late to buy insurance. Likewise, once a lawsuit hits, it is too late to set up the needed legal structures. You need to have them in place before the disaster hits. Once a lawsuit is filed against you, the transfer of assets to protective legal entities may be interpreted as “fraudulent conveyance” and can be unwound.

Therefore, it is essential to have the legal structures for lawsuit protection and prevention in place before you are sued. If you are not properly structured, it only takes one lawsuit to lose everything.

 

Myth 2: I Should Operate My Business as a Sole Proprietorship

Many attorneys and accountants recommend that their clients operate their business as a sole proprietorship because of the simplicity it presents when they file their tax returns. However, there are two major problems with operating as a sole proprietor. First, while a sole proprietorship allows a person to deduct most business expenses, there are tax deductions and reduction strategies that apply to S-Corps and C-Corps which cannot be used as a sole proprietor. The second major problem is that a sole proprietorship provides little protection against lawsuits. If your sole proprietorship is sued, all of your business and personal assets could be taken to satisfy the judgment. Even if you are sued personally as a result of a car accident or injury at your home, all of your business assets are at risk of being taken.

 

Myth 3: A Corporation Protects My Assets from Lawsuits

The corporation is a good management and tax reduction tool, but it is a poor lawsuit protection tool. If your corporation is sued, all of the assets (with equity) owned by your corporation can be taken to satisfy the judgment. The corporation does provide some protection of personal assets with what is called the “corporate veil.” The corporate veil is supposed to prevent a creditor from going after personal assets to satisfy a business debt. However, the corporate veil is often pierced, enabling your personal assets to be seized to satisfy a judgment against your business.

 

Myth 4: Asset Protection is Not Possible

We live in a very specialized world. For example, doctors specialize in a specific area of medicine (orthopedics, radiology, cardiology, etc.). There is no difference in the legal world. There are specialists for every part of our legal lives. There are attorneys who specialize in patents, family law, bankruptcy, personal injury, prosecution, estate planning, etc. Asset protection is a highly specialized area of law. A survey by the American Bar Association showed that less than one percent of attorneys claimed asset protection as their specialty. As a result, most attorneys and accountants are unfamiliar with the strategies and tools available to protect 100% of your business and personal assets from being seized in a lawsuit.

 

Myth 5: I Should Put My Assets in My Lower-Liability Spouse’s Name

One of the strategies recommended by less-than-experienced advisors, is to put assets in a lower-liability spouse’s name. This may provide a modest amount of protection in the event of a lawsuit, but there are four significant drawbacks to this strategy. First, it must be realized that courts carefully scrutinize conveyances between relatives and can invalidate the transfer of property regardless of when the conveyance took place. Second, your spouse may be declared an implied officer in your business and be named in a lawsuit. Third, your spouse could get sued personally. For example, if your spouse were involved in a car accident and someone was killed, a lawsuit would most likely follow; and every single asset in the spouse’s name would be at risk. Finally, having assets in your spouse’s name can cause serious problems in the event of a divorce.

 

Myth 6: I Only Need a Single Entity (LLC or Corporation)

Typically, a combination of entities will be the best course to take, rather than the use of one corporation or LLC. Most advisors are unaware of how to gain the best tax advantages and ensure 100% asset protection through the use of multiple entities. To ensure your assets are protected, you must separate your safe and risky assets into separate legal entities. The strategy of using multiple entities will minimize taxes and protect 100% of your assets.

 

Myth 7: Liability Insurance Will Protect Me Against Lawsuits

You may feel you are protected from lawsuits because you have liability insurance; however, insurance is like a hospital gown—you only think you are covered. Liability insurance does provide some protection against lawsuits, but it is limited in its coverage. Juries often will award judgments in excess of liability insurance coverage. Exclusions in your policy may also result in your insurance company denying coverage and leaving you liable. As judgments have increased over the years, some advisors simply tell professionals to get more liability insurance. This is problematic, as larger policies are costly and often serve as homing beacons for trial attorneys, who look for the deepest pockets in which to reach.

 

Conclusion

The authors of the book The Millionaire Next Door did an extensive study of millionaires to find the determining factors that resulted in a high net worth. The research concluded that hiring high-grade financial advisors was directly related to the propensity to accumulate wealth. An attorney who specializes in asset protection is one high-grade advisor business owners need. An asset protection attorney will ensure you avoid the myths in this article and will ensure your assets are properly structure for lawsuit protection, tax reduction, and estate planning.

 

Larry Oxenham is presenting “What Every Insurance Agent Needs to Know about Lawsuit Prevent, Tax Reduction, and Estate Planning Strategies” on Tuesday, October 17th from 8:45 to 10:45 am at the IIABSC's Annual Convention at the Marriott Grande Dunes in Myrtle Beach. 

Tags:  LEGAL 

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Never Sign an OSHA Witness Statement

Posted By Western States Roofing Contractors Association, Monday, July 23, 2018

Courtesy of: Trent Cotney, Cotney Construction Law

Tel: 866.303.5868 | Email: tcotney@cotneycl.com

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Never Sign an OSHA Witness Statement

During any OSHA inspection, the Compliance Safety and Health Officer (“CSHO”) will more than likely take witness testimony from crew members that are on site. This CSHO will hand-write the interview answers and ask the employee to sign the witness statement. Most employers and employees do not understand their rights during an OSHA inspection and do not know that they are not required to sign witness statements. This article explores OSHA’s interviewing process, the use of witness statements by OSHA, and suggests alternatives to signing a witness statement.

 

Everyone has the right to counsel.

First and foremost, it should be noted that any member of management, including officers, directors, and owners have the right to have counsel present during any OSHA interview. In addition, any supervisory employee is also considered part of management, and therefore has the ability to have counsel present during the interviews. When OSHA inspects a job site, supervisory employees such as crew leaders, foremen, superintendents, and/or project managers should assert their right to have counsel present before giving any testimony to OSHA. In other words, the supervisor should state their name, position and assert the right to counsel. This will give the individual an opportunity to discuss the alleged violations with management and counsel prior to being interviewed. It will also allow management and counsel to be present during the interviews. Generally, these interviews occur at counsel’s office or OSHA’s area office rather than the job site, thereby limiting exposure to additional potential violations.

With regard to crew member interviews, management and counsel for management generally cannot be present during non-supervisory employee interviews. However, if the employee requests that counsel be present for the interview, OSHA must allow counsel to be present.

 

What will OSHA ask?

During the interviews, OSHA will ask a variety of questions regarding safety training and job site specific acts or omissions. For example, common safety training questions include how to properly tie off, use personal protective equipment (“PPE”), properly install anchor points, properly tie off ladders, knowledge about hydration and water breaks, knowledge regarding risks associated with swing radius, inhalation of chemicals and/or silica, as well as other potential hazards.

The job site specific questions will focus on the who, where, when, what, and how. In particular, employees will be asked questions regarding training they received and commands they received on the date of the incident. For example, the CSHO will ask whether employees were instructed to tie off on the date of the inspection, whether supervisory employees inspected the crew members during construction, and the reason(s) why employees were not tied off (even if they were). OSHA often asks whether employees were not wearing fall protection because they were told to complete work at an accelerated pace or to meet certain schedule obligations. If an employee answers in the affirmative, it could be damaging to the employer.

 

Written witness statement.

While the testimony is being taken, the CSHO will be drafting a witness statement, which generally contains self-serving declarations for purposes of prosecuting the employer. No one is required to sign a witness statement.  Both supervisory and non-supervisory employees can refuse to sign witness statements. This leaves the CSHO with only his or her own notes, which can still be used as evidence, or the CSHO can still contact the local Area Office and ask that it issue a subpoena requiring that the employee’s testimony be taken under oath. This delay in obtaining testimony may be beneficial for the employer because it will allow the employee to have the opportunity to think about his or her answers and be in a better mindset for purposes of providing testimony. It also gives the employee the chance to speak with counsel and/or management if he or she wishes to do so.

Obviously, regardless of when testimony is provided, all employees must always tell the truth. However, even a slight postponement in giving testimony can provide an employee with enough time to properly collect his or her thoughts, and ensure that he or she gives truthful testimony, while remaining alert enough to detect and avoid the onslaught of “Gotcha!” questions OSHA loves throwing at unsuspecting witnesses.

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Author’s note: The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.

Trent Cotney, CEO of Cotney Construction Law, is an advocate for the roofing industry, General Counsel of Florida Roofing & Sheet Metal Contractors Association (FRSA), Roofing Technology Think Tank (RT3), Tennessee Association of Roofing Contractors (TARC), and several other local roofing associations. For more information, contact the author at 866.303.5868 or go to www.cotneycl.com.

Tags:  LEGAL  SAFETY 

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Why Online Reviews Are So Important For Roofers

Posted By Western States Roofing Contractors Association, Monday, July 23, 2018

Courtesy of WSRCA Member: Broadly.com

As a roofing company, you are always looking for more ways to get more customers. Marketing for roofers can seem like a daunting task, especially when you are a one-man operation or your company doesn’t have a marketing person.

A lot of contractors across the Western United States will tell you that word of mouth marketing leads to some of the best customers. Now with the power of the internet, 84% of people trust online reviews as much as a personal recommendation.

This is the reason why getting online reviews can be such an important part of a roofers marketing strategy.

Below are tips on how to ask for online reviews and how to handle those reviews. If you have questions or need help managing reviews we are happy to show you a demo of our online review software.

Online Reviews For Roofers

Infographic by Broadly.com - Online Reviews for Construction

Tags:  BUSINESS 

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PARTY WHO PARTICIPATES IN ARBITRATION CANNOT THEREAFTER BACK OUT

Posted By Western States Roofing Contractors Association, Monday, July 16, 2018

By Kenneth S. Grossbart
Abdulaziz, Grossbart & Rudman

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The subject of Arbitration has been discussed by me in previous articles. This article again addresses the concept of Arbitration but with a twist.

Arbitration is an alternative form of resolving disputes. It is an alternative to the filing of a lawsuit and proceeding with your case through the court system. Arbitration is a very popular form of dispute resolution and oftentimes is faster and cheaper than going through the court system.

Arbitration is a consensual process which means in order for the parties to arbitrate a dispute all parties must consent to having the matter arbitrated. Oftentimes that consent comes in the form of an Arbitration Clause that is contained in the contract between the parties. In this set of facts, Company A signed an Advertising Insertion Order with Company B. The Order included an agreement to arbitrate all disputes. During the course of the relationship between Company A and Company B, Company A accumulated an unpaid balance with Company B. Company A filed a Demand for Arbitration seeking damages in the amount of the unpaid balance. Company B agreed that they signed the Order but claimed that the Order was unenforceable because Company A’s products were fraudulent. Regardless of the claims of Company B, Company B voluntarily participated in the Arbitration and in fact asked the Arbitrator to issue an Order requiring one of the parties to post a Bond. Company B later rescinded its participation in the Arbitration proceedings when the Arbitrator declined to issue the Order. The Arbitrator ultimately found for Company A and the trial court confirmed the Arbitration Award. Company B challenged the Arbitrator’s jurisdiction arguing that he did not consent to arbitrate the dispute.

The matter was reviewed and ruled upon by the appellate court. The appellate court confirmed the lower court’s ruling finding that the parties did in fact consent to Arbitration. The appellate court found that Company B’s conduct and participation in the Arbitration showed that he clearly and unmistakably consented to Arbitration. First Company B did not object to Arbitration, they willingly participated in the Arbitration proceedings, availed themselves of the Arbitrator’s authority when asked to have the Arbitrator rule upon the posting of a Bond and thereafter tried to rescind his voluntarily participation after the Arbitrator denied the request. Thus the court found that Company B’s actions constituted clear and unmistakable evidence that he consented to the Arbitration proceedings.

The take away from this set of facts is that if you challenge the jurisdiction of an Arbitration Tribunal, it must be done at the beginning of your case. You cannot temporarily participate in the Arbitration proceedings and then at some point in time when you don’t like how the Arbitration is proceeding attempt to back out. Courts will consider your participation to constitute a clear and unmistakable evidence of your consent to arbitrate.

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Kenneth Grossbart is recognized as one of the foremost authorities in California construction law. Over the past 35 years, Ken has become a respected speaker on Mechanic’s Liens and other construction related issues. Abdulaziz, Grossbart & Rudman provides this information as a service to its friends & clients and it does not establish an attorney-client relationship with the reader. This document is of a general nature and is not a substitute for legal advice. Since laws change frequently, contact an attorney before using this information. Ken Grossbart can be reached at Abdulaziz, Grossbart & Rudman: (818) 760-2000 or by E-Mail at , or at ksg@agrlaw.com

June / July ‘18

www.agrlaw.com

Tags:  BUSINESS  LEGAL 

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Reefer and Roofers – The Impact of Legalization of Marijuana

Posted By Chris Alberts, Western States Roofing Contractors Association, Monday, July 9, 2018
Updated: Tuesday, July 10, 2018

Courtesy of: Trent Cotney — Cotney Construction Law

 Tel: 866.303.5868 | Email: tcotney@cotneycl.com

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 Regardless of one’s opinion on the matter, it is becoming apparent that Marijuana is here to stay.  While many states have legalized Marijuana for both recreational and medicinal purposes, what is unclear are the potential liabilities for an employer whose employees are actively using the drug, particularly at work.  Questions arise such as can you require that your employees don’t use marijuana at all?  Due to the inherent dangers involved in the roofing industry, an employer has real and justified reasons for not wanting his or her employees to be under the influence while on the job.  Unlike alcohol, testing for marijuana has a way to go and as more and more states legalize the drug, the issues already present will only be further complicated.

Currently 30 states and the District of Columbia have legalized either recreational or medicinal use of marijuana. During the 2016 election cycle, California, Maine, Massachusetts and Nevada joined Alaska, Colorado, Oregon, Washington, and the District of Columbia legalizing marijuana for recreational use. Vermont is the first state to legalize recreational marijuana through state legislature and the law went into effect on July 1, 2018.

While certain states allow recreational and medicinal marijuana use, the drug is still illegal at the federal level. This divergence between state and federal law creates a variety of unique issues for employers.  Due to marijuana being illegal at the federal level, those working under a government contract or for a federal employer are prohibited from using marijuana in any way (even if it is for medicinal purposes). This prohibition extends to both on site use as well as off-site/at-home use. Accordingly, under federal law, the roofer employer has the ability to fire an employee for failing a drug test under the aforementioned federal work conditions.

If you’re an employer working under a federal contract, then the law is quite clear. Handling marijuana usage for roofers on private and state projects, however, is quite hazy (no pun intended). Two of the biggest issues still up in the air include: employees arriving to the job under the influence of marijuana, and zero-tolerance drug policies.  A number of other state courts have upheld employers’ right to continue to implement zero-tolerance policies. This results in employers likely being able to continue to enforce their zero-tolerance drug policies.

Since marijuana use impairs an individual’s motor functions, employers who have employees who operate machinery, vehicles, or other type of equipment will certainly not want them doing so under the influence of marijuana. Further, there is not presently a method for testing whether an individual is currently under the influence of marijuana. Drug tests simply show that the individual has used marijuana within the past 30 days (the length varies by different testing methods). These are further reasons to continue to drug test employees and enforce zero-tolerance policies when it comes to on-site safety.

While other state courts have upheld an employer’s right to discipline employees for failing a drug test for marijuana use, employers should still be wary of how courts will respond to the implementation of both recreational and medicinal marijuana laws. Further, state legislatures and other administrations have stated they will continue to provide updates and guidance on how marijuana laws will affect roofing employers/employees.

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Author’s note: The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.

Trent Cotney, CEO of Cotney Construction Law, is an advocate for the roofing industry, General Counsel of Florida Roofing & Sheet Metal Contractors Association (FRSA), Roofing Technology Think Tank (RT3), Tennessee Association of Roofing Contractors (TARC), and several other local roofing associations. For more information, contact the author at 866.303.5868 or go to www.cotneycl.com.

Tags:  BUSINESS  LEGAL 

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COTNEY CONSTRUCTION LAW ANNOUNCES NEW PARTNERS

Posted By Western States Roofing Contractors Association, Friday, June 29, 2018

Cotney Construction Law (CCL),a leading national law firm for construction, specialty trades, and OSHA law,is pleased to announce that Daniel Auerbach, Virgil Tray Batcher, Hilary Morgan, and Anthony Tilton have been named partners of the firm.

 

(Left-to-Right) Dan Auerbach, Virgil Tray Bather, Hilary Morgan, Anthony Tilton

 

“Each of these attorneys epitomizes the diverse talent our firm offers,” said Trent Cotney, CEO of CCL. “Not only have they demonstrated superb legal capabilities, but they have also shown that they are committed to both their clients and the construction industry as a whole.”

Daniel Auerbach’s practice areas encompass construction litigation and various transactional matters. Specifically, Dan focuses on contract review and drafting, contract negotiation, bond & lien law, building code violation defense, construction defense litigation, OSHA defense, bid protests, and contractor licensing defense. He currently serves as General Counsel for the Space Coast Licensed Roofers Association and the Treasure Coast Roofing and Sheet Metal Association.

Virgil Tray Batcher joined Cotney Construction Law in 2012 and represents clients in all aspects of construction law including lien law, bond law, construction defect litigation, OSHA defense, and licensing. Prior to becoming a lawyer, Tray worked in the construction industry as an estimator for a multi-million dollar structural contracting company. He currently serves as General Counsel for the Florida Refrigeration and Air Conditioning Contractors Association.

Hilary Morgan focuses her practice on all aspects of construction law, including lien law, surety bond law, litigation, arbitration, construction defects, contract review and drafting, delay claims, bid protests, design professional liability, corporate law, and administrative law. Hilary serves on Associated Builders and Contractors National Young Professional Committee and is currently General Counsel for National Women in Roofing.

Anthony Tilton practices in all areas of construction law. He works primarily on matters relating to OSHA and licensing defense. This includes the management and development of safety and health strategies. Anthony is also a Certified Building Contractor and has been involved in the industry his whole life – he has done framing, floor installation, remodels, site supervision, and served as safety officer for various construction companies. Anthony is General Counsel for the Tile Roofing Institute.

 

About Cotney Construction Law

 

Cotney Construction Law is a national law firm that provides representation for general, roofing, HVAC and specialty contractors. Experienced in the representation of businesses and professionals in construction disputes and transactions, Cotney is a well-known advisor and legal counsel in the construction industry. The firm’s practice areas include construction law, litigation, arbitration, contract review & drafting, immigration, employment, OSHA defense, licensing defense, bid protests, lien law, bond law and alternative dispute resolution. The firm has Florida offices in Tampa,Orlando, Tallahassee, Jacksonville, and Ft. Lauderdale, as well as locations in Denver, Grand Rapids, Houston, Mobile, and Nashville. For more information, visit www.cotneycl.com.

Tags:  MEMBERS IN THE NEWS 

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