The Pros and Cons of EPDM Roofing

Commercial roofs can serve as critical workspaces for firefighters, police, rescue teams, maintenance staff, and contractors during emergencies. Ensuring safe passage across these surfaces is the primary focus of the Illinois Rooftop Safety for First Responders Act, which took effect on January 1, 2026. The Act creates safety requirements for certain low-sloped roofs, skylights, roof openings, roof edges, parapets, extended masonry, and guards.

Property managers, facility directors, and building owners should ensure that their project teams and roofing contractors fully understand the rooftop safety conditions covered by the Act before beginning any major roof renovation or replacement.

Why the Act Was Created

The law’s informal name is the Drew Price Act, after Chicago firefighter and EMT Andrew “Drew” Price. In 2023, Price died in the line of duty when he fell through an unguarded light shaft while fighting a fire on a restaurant rooftop.

The law aims to lower the chances of rooftop falls for first responders operating in smoke, darkness, severe weather, or unknown building layouts. These new rules make rooftop environments safer for anyone requiring access, including emergency personnel, maintenance workers, contractors, and building staff.

Which Roofs Are Covered?

The Act applies to low-sloped roofs. Under the statute, a low-sloped roof is a roof with a slope of less than 2 units vertical in 12 units horizontal, or a 17% slope.

Many commercial “flat roofs” fall into this category, including roofs on:

• Warehouses
• Retail centers
• Office buildings
• Industrial facilities
• Schools
• Municipal buildings
• Multifamily properties
• Healthcare facilities
• Grocery stores
• Auto dealerships
• Distribution centers
• Mixed-use buildings

If a building has a typical commercial flat roof, the Act should be reviewed before a reroof, roof replacement, or major renovation.

When Does the Act Apply?

The legislation outlines specific scenarios that trigger compliance for property owners and managers. The requirements apply to all existing buildings, new construction projects, new roof installations, and roof replacements. The rules also apply to renovation projects that increase the area of a home or business by more than 50 percent. Addressing these requirements during the planning phase of a project ensures a smoother process and prevents unexpected delays.

Key Definitions from the Statute

Understanding the specific terminology in the legislation is essential for determining how it affects a property. The Act provides clear definitions for covered building features:

• Low-sloped roof: A roof with a slope of less than 2 units vertical in 12 units horizontal, which represents a 17 percent slope.
• Shaft: A continuous vertical space substantially enclosed on all sides that extends for two or more floors. This includes elevator shafts, ventilation shafts, stairwells, and service shafts.
• Court: An open space on a lot, other than a yard or portion of a yard, that is unobstructed from its lowest level to the sky and bounded by abutting property lines, exterior building walls, or other enclosing devices.
• Parapet: A barrier that extends upward from the edge of a structure, such as a roof, balcony, walkway, or terrace.

The Two Main Areas the Act Addresses

The Act focuses on two main rooftop conditions: roof edges that border light shafts or enclosed courts, and skylights or other openings located in the plane of a low-sloped roof. Both can create serious fall hazards, especially for someone who doesn’t know the roof layout.

1. Roof Edges Near Shafts or Enclosed Courts

For low-sloped roofs, edges that adjoin a shaft or a court enclosed on all sides must be protected by a parapet, extended masonry, guard, or a combination of those systems meeting Section 1015 of the International Building Code.

The Act defines a shaft as a substantially enclosed vertical space extending for two or more floors. Examples include elevator shafts, ventilation shafts, stairwells, and service shafts.

It also defines a court as an open space, other than a yard or part of a yard, that is open from its lowest level to the sky and bounded by property lines, exterior building walls, or other enclosing elements.

Roof geometry matters. A roof may look straightforward from the surface, but edges near shafts, stairwells, light wells, or enclosed courts may require additional review.

2. Skylights and Other Roof Openings.

Unless an opening is otherwise required by law to remain open and unobstructed, the Act provides two compliance paths.

• Option 1: Load-rated glazing: The skylight or opening may use wired glass, plain glass, glass block, or polycarbonate plastic designed and constructed to withstand a minimum dynamic load test of at least 400 pounds.
• Option 2: Permanent protection: The skylight or opening may be protected by a parapet, extended masonry, guard, or combination of protective systems meeting International Business Code (IBC) Section 1015.

For older commercial buildings, the biggest issue may be documentation. A building may have skylights, but the owner may not have records showing whether those skylights meet the required load test. Some skylights may be original to the building; others may have been replaced during previous roofing work without clear product documentation.

Before starting a roof replacement, owners should identify every skylight and roof opening and determine whether additional review is needed.

Permanent Building Protection Versus Temporary Construction Safety

One common source of confusion is the difference between temporary construction safety and permanent building protection.

OSHA fall protection standards are generally intended to protect workers while work is being performed. The Rooftop Safety for First Responders Act, by contrast, is focused on permanent rooftop conditions on low-sloped roofs.

That means temporary OSHA guardrails used during construction should not be treated as a substitute for the permanent guards, parapets, or extended masonry required under the Act.

Why Building Owners Should Ask Roofing Contractors About the Act

For building owners and property managers, the Rooftop Safety for First Responders Act creates an important planning responsibility. You must make sure your roofing contractor understands how the law may affect the project before work begins.

A low-slope roof replacement is no longer only about membrane type, insulation, drainage, warranty, and price. If the building has skylights, roof openings, shafts, stairwells, ventilation shafts, service shafts, enclosed courts, parapets, extended masonry, or existing guards, those conditions may affect the scope of work.

That doesn’t mean a roofing contractor replaces an attorney, architect, engineer, code consultant, or local building official. It does mean the contractor should understand the Act well enough to recognize covered rooftop conditions, explain what is included or excluded from the proposal, and recommend further review when needed.

Before approving a commercial roof replacement proposal, owners and managers should ask:

• Does the contractor understand when the Rooftop Safety for First Responders Act applies?
• Has the contractor reviewed the roof for skylights and other openings in the roof plane?
• Has the contractor looked for roof edges adjoining shafts, stairwells, ventilation shafts, service shafts, or enclosed courts?
• Does the contractor understand the difference between temporary OSHA fall protection during construction and permanent guards or parapets required for long-term rooftop safety?
• Does the proposal state whether skylight upgrades, guards, parapet work, extended masonry, or other permanent protection items are included or excluded?
• Will the contractor identify conditions that may require review by an architect, engineer, code consultant, manufacturer, or local authority having jurisdiction?

Compliance Risks

Missed rooftop safety items can lead to change orders, project delays, inspection issues, contract disputes, or liability concerns. A proposal that only prices the roof surface may not address all conditions covered by the Act.

It’s important to ensure your roofing contractor understands the Act, documents visible rooftop conditions, communicates scope clearly, and helps address potential compliance issues early.

The Act also requires municipalities to survey buildings with skylights and other openings in low-sloped roofs by January 1, 2027, and every two years after that.

Survey results must be placed in a building inventory and shared with local police and fire departments. In counties with populations greater than 1,000,000, the information must also be stored in computer-aided dispatch systems.

This helps first responders understand potential rooftop safety risks before accessing a building. It may also create formal documentation of the building’s rooftop layout, making it more difficult for an owner to argue they were unaware of a documented hazard.

Schedule a Commercial Roof Assessment

If you own or manage a commercial building in Illinois, now is the right time to review your low-slope roof conditions.

Before your next roof replacement, reroof, renovation, or capital planning cycle, schedule a rooftop assessment with Reliable Roofing.

Schedule your free inspection today.

Our commercial roofing team serves the Chicago area and helps commercial property owners plan smarter, safer, and more compliant roofing projects.

FAQ: Illinois Rooftop Safety for First Responders Act

What is the Rooftop Safety for First Responders Act?

The Rooftop Safety for First Responders Act is Illinois Public Act 104-0121. It creates safety requirements for certain low-sloped roofs, roof edges, skylights, and roof openings to help reduce rooftop fall hazards for first responders.

When does the Rooftop Safety for First Responders Act take effect?

The Illinois General Assembly lists the effective date as January 1, 2026.

What is considered a low-sloped roof under the Act?

The Act defines a low-sloped roof as a roof with a slope of less than 2 units vertically in 12 units horizontal, or 17% slope.

Does the Act apply to existing buildings?

Yes. Section 10 states that existing buildings, new construction, new roofs, roof replacements, and renovation projects that increase the area of a home or business by more than 50% are subject to the listed requirements.

What does the Act require for skylights?

Skylights and other openings in the plane of a low-sloped roof must either use approved glazing designed and constructed to withstand a minimum dynamic load test of at least 400 pounds, or be protected with a parapet, extended masonry, guard, or a combination meeting IBC Section 1015.

Does the Act list fines or criminal penalties?

The text of Public Act 104-0121 does not include a separate fine schedule or criminal penalty section. However, noncompliance may still create permitting, inspection, insurance, safety, or liability concerns depending on the project and local enforcement.

Why should commercial building owners act now?

Roof replacements and major renovations require planning. Identifying skylights, openings, parapet issues, and roof-edge hazards early can help owners avoid project delays, change orders, and compliance surprises.