Episode 65 – Pushing Florida’s Building Envelope

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Florida insurance regulators have begun a once-every-five-year process to update the windstorm mitigation credits given to homeowners who harden their homes against storms.  Part of the process includes updating the inspection form used to evaluate and certify the construction features of the home, especially the roof.

Former Florida Deputy Insurance Commissioner Lisa Miller sits down with a disaster consultant and a roofing products manufacturer who suggest further enhancing the inspection form to recognize more specialized, effective techniques that will maximize credits, increase resilience, and reduce costly damage from hurricanes.

Darius Grimes, President and CEO, Disaster-Smart Consulting

James “Jimmy” Akins, Vice President of Technical Services, Warranty and Support, Polyglass


Show Notes

Joining Host Miller are Darius Grimes, President and CEO of Disaster-Smart Consulting, which provides inspection and consulting services, specializing in coastal risk, FORTIFIED Evaluations, and property-specific mitigation strategies; and James “Jimmy” Akins, Vice President of Technical Services, Warranty and Support for Polyglass, a large manufacturer of roofing products.  The discussion focuses on updating Florida’s wind mitigation inspection standards and improving roof resiliency through better underlayment technology. 

“Loss of roof covering is responsible for about 70% of all hurricane claims,” said Grimes, quoting data from the Insurance Institute for Business & Home Safety (IBHS).  “It’s not that the houses get blown away like they did in Hurricane Andrew.  It’s that you lose 20% to 50% of your roof covering, and water pours into the structure.  And then all of a sudden, you’ve got $40,000 or $50,000 worth of water damage to the interior of the home.  You can’t live in it.  There’s no power to dry it out, and you end up displaced from your home or displaced from your community.”  Grimes, with more than 30 years of experience in the construction industry, noted that when that happens, there can be a cascading effect on small businesses closing and loss of local tax revenue.

Regulatory Changes

Host Miller and her guests discussed the updates to Form 1802, an inspection form used by the Florida Office of Insurance Regulation (OIR) to certify home construction features for insurance discounts.  The updated form, effective April 1, 2026, now includes specific references to the IBHS FORTIFIED Standard, “which is considered the national gold standard of wind mitigation materials and construction techniques,” said host Miller.  She noted the updates generated concern among some stakeholders about whether the FORTIFIED Standard or the Florida Building Code should be the primary benchmark for mitigation.

Grimes said the only real difference on roofing between the Florida Building Code and the FORTIFIED Program is the requirement for re-nailing the deck.   IBHS requires the deck to be re-nailed four inches on center with ring shank nails, and the Florida Building Code is six inches on center, he said.

“As a test engineer, we discovered that if we reduce the nail spacing from six to four on a re-nailed deck, that we actually got an almost 100% increase in the uplift resistance.  In other words, your entire roof is going to come off before the decking is going to come off,” said Grimes.  He pointed to an Alabama study on Hurricane Sally damage showing that FORTIFIED homes were 50% less likely to have an insurance claim than a home built to strict building codes that, in many cases, mirror FORTIFIED’s requirements but FORTIFIED’s “stricter way to enforce the installation of that roof is key,” Grimes added.   Also, the FORTIFIED Standard in most wind zones now requires a Class H shingle, which is a little stronger than the Class F shingle required under the Florida Building Code.

The Form 1802 changes also include a roof slope section that classifies “high slope” roofs as requiring at least two-thirds of the main roof have a higher slope.

Roof Underlayment  

There are three major parts of a roof: the decking (which is attached to the house’s frame), the underlayment (which covers that decking to help keep it dry), and the covering (which includes shingles, metal, and tile).  The updated Form 1802 now includes a detailed section on “Sealed Roof Deck” and lists the four different types that an inspector can choose from during an on-sight evaluation.

Section from OIR Form 1802

Both Grimes and Akins, while noting this section is an improvement over the previous inspection form, agree that subtle, yet critical improvements are needed in a future update.

“It does actually allow for an inspector to identify the different types of roofing underlayments, which is great for data collection,” said Akins.  “But the entire mitigation credit mechanism does not take into account the underlayment types for the purpose of assigning different credits.  The self-adhering underlayments are referred to in the same category as mechanically attached or nailed anchor sheets.  So your synthetic membranes, your 30-pound felts, if you will, they are basically anchor sheets.  Provided they give a little resilience for water integrity, but they’re not waterproofing as a fully bonded, self-adhered underlayment is.  And Polyglass, along with all our other friends in the industry, make a lot of high-end products that are very affordable, that aren’t getting the credit they deserve.”  And as a result, Akins added, consumers choosing the better water-resistant underlayment won’t be given any enhanced credits toward reducing their insurance premium.

Current data limitations prevent OIR from assigning higher credits for self-adhered underlayments because claims data has not yet definitively proven a performance difference in loss relativity studies.  “However, in my experience, the peel and stick (self-adhering underlayment) is generally the superior and more user-friendly system,” said Grimes.  “But other assemblies can also meet those same performance requirements, especially when properly installed.  The key word here is ‘properly.’” 

Grimes said this is where there’s a significant gap between the Florida Building Code and the FORTIFIED standard.  “The problem you’ve got right now is, you have all of the different methods that you can use to achieve what we now call a ‘sealed roof deck’ in the updated inspection Form 1802, but you see the words ‘sealed roof deck’ nowhere in the Florida Building Code; it says ‘secondary water barrier’ and secondary water barrier really is nothing more than what Jimmy points to as just a nail-on underlayment sheet.  So we’re getting there.  We’re not quite there,” said Grimes, noting confusion exists in the construction and insurance industries between the terms.  “’Sealed roof deck’ begins to separate standard roofing underlayments from a system that is designed to survive even when the roof covering is lost.  The peel and stick, I have recommended that for years.  It is the absolute best system.”

“I would say, as the roofing industry, we need to be better with engaging IBHS on this issue and explaining the underlayments,” said Akins.  “I will say the FORTIFIED program on their own website defines a sealed roof deck as a sheet material installed between the roof deck and the roof covering. That very definition doesn’t clearly take into account what we know: that a self-adhered underlayment is not only superior for sealing the deck, but it’s really the only material that’s sealing the deck that’s providing you your watertight integrity.”

Akins and Grimes also discussed other benefits of the peel and stick or self-adhering underlayment.  It covers existing nail holes from previous roofs, whereas mechanically fastened (nailed) synthetics rely on precise installation that is rarely inspected.   “Working to truly seal the deck with materials that are not the roof covering would go a long way to limit storm damages,” said Akins.

Suggestions for Improving Credits

Host Miller noted the next step in this process is for the Office of Insurance Regulation to update the actual wind mitigation discount credits and the discount schedule that property insurance companies use to generate and communicate policy discounts for home hardening to Florida’s 7.6 million residential property policyholders. 

She and her guests discussed how policy and data collection must evolve to incentivize stronger construction.  Grimes suggested that once OIR collects more data via the new Form 1802, they may find that current credits for features like sealed roof decks are undervalued compared to their actual impact on reducing hurricane claims, again noting the Alabama study.

“I have some concern that what we’re going to see is that the Florida ala carte menu of credits for things like roof-to-wall connection and superior deck nailing are going to be found to be out of balance because I believe the sealed roof deck credit, which is only about 2% to 3%, is horribly low and is much more important than it’s being given credit for,” said Grimes.

Akins mentioned that House Bill 767 before the Florida Legislature this year would have changed the credit mitigation statute to allow insurance carriers to specifically provide a wind mitigation credit by an underlayment type.  Although the bill did not become law, he supports the idea going forward.  Akins said he’d also like to see future legislation provide tax incentives for self-adhered underlayments similar to existing exemptions for impact-resistant doors and windows.  “That’s a small tax savings at point of sale (but) believe it or not, it gets people thinking.  It gets them talking about sealing their deck and protecting their home.  So the tax policy really is pushing the resilience,” Akins said.

Host Miller noted that Texas Governor Greg Abbott recently directed the Texas Department of Insurance to require insurance companies to include whether a home’s roof meets FORTIFIED standards when calculating premiums.  

“I think what we want to think about for the purposes of this podcast is a call to action to my friends in the insurance industry,” said Miller, a former regulator.  “I know just by talking to them individually that they very much want roofs to stay on those homes and have that underlayment be very strong, so in case those shingles blow off, we have exactly what we need to keep that roof strong and that home strong.  Secondly, I know that when I talk to my friends in the regulatory arena, we talk about the new technology and even some of the new modern roofing technology that we’ve got to be encouraging Floridians to use, instead of some outdated materials that we used 50 years ago.  Why would we use materials that we know are not as strong?”

Links and Resources Mentioned in this Episode

Highlights of SB 7052 – Insurer Accountability of 2023 (Lisa Miller & Associates)

Uniform Wind Mitigation Verification Inspection Form (Form OIR-B1-1802)

Rule 69O-170.0155 (Florida Office of Insurance Regulation)

2024 Residential Wind-Loss Mitigation Study (Florida Office of Insurance Regulation)

OIR Workshop on Uniform Mitigation Verification Form Report (OIR-B1-600 with Inspection Form OIR-B1-1802) (Lisa Miller & Associates, May 19, 2026)

OIR’s Wind Mitigation Resources webpage (Florida Office of Insurance Regulation)

Performance of IBHS FORTIFIED Home Construction in Hurricane Sally (Alabama Department of Insurance and the University of Alabama Center for Risk and Insurance Research, May 5, 2025)

Guidance for Completing Florida OIR-B1-1802 Forms for Properties with FORTIFIED Designations (FORTIFIED Technical Bulletin FH 2026-02)

Texas Governor Greg Abbott Order to Texas Department of Insurance Including FORTIFIED standards when calculating premiums (August 24, 2026)  

Disaster-Smart

Polyglass

Episode 53 – Fortified Homes (Florida Insurance Roundup podcast, October 21, 2024)

FORTIFIED Program (Insurance Institute for Business & Home Safety)

Insurance Institute for Business and Home Safety

Miracle neighborhood that survived Hurricane Helene without a scratch (Daily Mail, October 2, 2024)

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The Florida Insurance Roundup from Lisa Miller & Associates, brings you the latest developments in Property & Casualty, Healthcare, Workers’ Compensation, and Surplus Lines insurance from around the Sunshine State.  Based in the state capital of Tallahassee, Lisa Miller & Associates provides its clients with focused, intelligent, and cost conscious solutions to their business development, government consulting, and public relations needs.  On the web at www.LisaMillerAssociates.com or call 850-222-1041.  Your questions, comments, and suggestions are welcome!  Date of Recording 8/11/2026. Email via [email protected]   Composer: www.TeleDirections.com  © Copyright 2017-2026 Lisa Miller & Associates, All Rights Reserved