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EPDM roofing in Silver Spring, MD: what Maryland's energy code says about the insulation under the rubber
An EPDM sheet keeps water out, but on a heated building the layer that carries the energy code is the insulation beneath it. This page reads the Maryland Energy Code 2021 text for roofs with insulation above the deck, the Maryland building code on polyisocyanurate board and roof tests, and a federal building-science guide. It states what the text says, where it is silent, and what a written scope for a Silver Spring EPDM roof should name.
- Montgomery County is climate zone 4A in the code table
- R-30ci for above-deck roof insulation, commercial table
- Two staggered layers of board in the commercial text
Zone 4A and the numbers that follow
Maryland's energy code is the 2021 International Energy Conservation Code with state amendments, and Montgomery County's permit office lists the 2021 edition on its master list of codes. The copy read here is the third-party UpCodes version, so confirm the edition and any county change with the Department of Permitting Services. Its climate zone table puts Montgomery County in zone 4A, and every figure below is the row for that zone.
Commercial part
R-30ci for roofs with insulation entirely above the deck, or U-0.032 as a maximum for the assembly.
Residential part
Ceiling U-0.024 as a maximum, or R-60 in the R-value table.
The code has a commercial part and a residential part. Apartment buildings, offices and shops are not read the same way as a detached house or townhouse, and the pages read here do not decide which part a given Silver Spring building falls under. That is a question for the county before any scope is written.
Residential and commercial values compared
| Part of the code | Value for zone 4 (except marine) | What it applies to |
|---|---|---|
| Commercial, R-value method | R-30ci, Group R and All other columns | Roofs with insulation entirely above the roof deck |
| Commercial, U-factor method | U-0.032 | The same roof type, as a maximum assembly value |
| Residential, U-factor table | Ceiling U-0.024 | The ceiling or roof assembly, as a maximum |
| Residential, R-value alternative | Ceiling R-60 | Insulation R-value as a minimum |
| Maryland alternative R-value | Ceiling R-49 | Only when combined with the code's additional energy package |
UpCodes copy of the Maryland Energy Code 2021, read October 20, 2026. The "ci" means continuous insulation, laid over the deck without gaps for framing.
The commercial text says continuous insulation layers are summed, and that cavity insulation does not count toward the continuous requirement. For a flat roof where the board sits above the deck, the thickness of every layer of board therefore adds up toward the listed number. For board above the deck, the residential text lets the R-value be labeled under the material standards in its roof insulation table.
What a re-roof triggers in the energy code
- Commercial replacement section C503.2.1 says a roof replacement meets the roof insulation sections where the existing roof is part of the thermal envelope and has insulation entirely above the deck.
- No step backward the same section says the R-value of the roof insulation may not be reduced, or the assembly U-factor increased, by a replacement.
- Recover and repair the existing buildings chapters list a roof recover among work not held to the new-construction values, and list roof repairs as repairs. Air barriers are not required for either when the rest of the envelope is untouched.
- Residential cavity roofs the residential text says a roof without insulation in the cavity, where the sheathing or insulation is exposed during reroofing, is insulated above or below the sheathing.
Read together, a tear-off to the deck on a building that already has board above it is a different question from coating or recovering. The text does not define the words for a given scope, and the county's Home Improvements page lists "Roof (covering only)" among work most likely to need no permit while saying exempt work still has to meet the code. Ask the county where your job falls. The Silver Spring hub sets out who signs in a house, a condominium and a rented building.
Polyiso boards, layers and thickness
Both Maryland texts say above-deck insulation must be covered with an approved roof covering and meet NFPA 276 or UL 1256. Their material tables name polyisocyanurate board under ASTM C1289, Type I or II, alongside cellular glass, expanded and extruded polystyrene, mineral fiber, perlite and others. EPDM is a thermoset sheet under ASTM D4637 or D5019 in the residential text, installed per the chapter and the maker's instructions.
The commercial energy text then shapes the board itself. Continuous board goes in not less than two layers with staggered edge joints. Where board is tapered to make slope, the R-value uses the average thickness. At the lowest point, whether gutter edge, drain or scupper, the board is not less than 1 inch thick.
Foil-faced polyisocyanurate
The Building America Solution Center says to put a protective cover board over it before the membrane.
Glass-fiber-faced polyisocyanurate
The same guide says this board can go in without a cover board. It is a residential retrofit guide and does not name EPDM.
The guide also says to offset seams in two directions between layers, run a sealant bead at the perimeter, tape the seams, and slope low-slope roofs to drains at not less than a quarter inch per foot.
Fastening through the insulation
A mechanically attached sheet is held to the deck by fasteners that pass through the board. The Maryland building code text read here does not give a fastener count. It says coverings that are mechanically attached or adhered to the deck are designed to resist the wind pressures set for components and cladding, and that fully adhered or mechanically attached single-ply systems are tested under FM 4474, UL 580 or UL 1897.
- The code text read here points to component and cladding wind pressures and gives no single figure for a given roof.
- A tested assembly is chosen whose layers match the job: deck, board, fastener, membrane.
- SPRI says its online Directory of Roof Assemblies lists low-slope systems tested for uplift, edge securement and impact, searchable by assembly composition.
- The scope then repeats that assembly, so the fastened layers on the roof match the layers that were tested.
This page does not give fastener counts or spacings, because no document opened here sets them. Ask for the tested assembly in writing.
Items to put in the EPDM contract
Roofers of Arlington installs, repairs and replaces roofs, including flat systems. To talk through a Silver Spring EPDM roof, book a phone consultation. On the call the questions would be the address, the building type, who owns the roof and what is visible. See also the EPDM guide, flat roofing, commercial roofing, roof replacement, materials and services.
- Which part of the energy code the county applies, and which value in the table the design meets.
- The board type and standard, the facer, the thickness of each layer and the number of layers with staggered joints.
- The thickness at the drains, scuppers and edges where board tapers.
- Whether a cover board goes in, and the membrane maker's written word on the pairing.
- The tested assembly record the fastened layers match, and who set the wind pressure.
- Whether the work is a replacement, a recover or a repair, in the county's words.
- Who else must approve: association, Takoma Park, the historic office.
- Owner
- The household, the council of unit owners or the landlord signs.
- Office
- Ask the county, your association and your engineer. Nothing here is legal or engineering advice.
Documents read on October 20, 2026
- UpCodes: Maryland Energy Code 2021, commercial chapters 4 and 5 and the residential chapter (third-party copy)
- UpCodes: Maryland Residential Code 2021, Chapter 9
- UpCodes: Maryland Building Code 2021, Chapter 15
- Montgomery County DPS: Master List of Building Codes and Standards
- Montgomery County DPS: Home Improvements
- SPRI: Five Codes, One Country
- Building America Solution Center: Re-Roofing and Adding Insulation over Flat Roof
Back to the Silver Spring roofing hub or all service areas.
Questions people ask
What insulation does Maryland's energy code list for a roof with insulation above the deck?
In the UpCodes copy of the Maryland Energy Code 2021, the commercial table lists R-30ci for roofs with insulation entirely above the roof deck in climate zone 4 except marine, in both the Group R and All other columns. The residential part lists ceiling values instead. Which part governs your building is a question for the county.
Which climate zone is Silver Spring in under the code table?
The code's climate zone table lists Montgomery County, Maryland, as 4A. The table is by county, so it gives no separate value for Silver Spring. The county Department of Permitting Services can confirm the edition and any local amendment in force.
Does a new EPDM membrane on an old roof mean new insulation?
The existing buildings chapter says a roof replacement must meet the insulation provisions where the existing roof has insulation entirely above the deck, and that the R-value may not be reduced. It lists a roof recover and roof repairs separately. Ask the county how it treats your scope.
Why does the code text talk about two layers of board?
The commercial text says continuous insulation board goes in not less than two layers with staggered edge joints, except where the board tapers to the deck at an edge, drain or scupper. It also sets a minimum thickness of 1 inch at the lowest point. The reason is not stated in that section.
Which polyiso standard does the Maryland code name?
Both the Maryland residential text and its building code name polyisocyanurate board under ASTM C1289, Type I or II, and require above-deck insulation to be covered with an approved roof covering and meet NFPA 276 or UL 1256. They do not say which board goes under EPDM.
Does the code say how many fasteners go through the insulation?
The pages read do not. The building code says mechanically attached or adhered coverings must resist the wind pressures set for components and cladding, and that single-ply systems are tested to FM 4474, UL 580 or UL 1897. The tested assembly record and the maker's instructions carry the fastener detail.
Does foil-faced polyiso need a cover board under an EPDM sheet?
A federal building-science guide says foil-faced polyisocyanurate needs a protective cover board before the roofing membrane and that glass-fiber-faced board can go without one. It is a residential retrofit guide and does not name EPDM. Ask for the membrane maker's written word on the pairing.
Who approves a re-roof on a Silver Spring condominium?
The county permit list says it leaves out municipality and association rules. The condominium declaration and bylaws say who decides on roof work to common elements. Ask your board before you ask any roofer for a scope.
Talk through your roof with Roofers of Arlington
Share the address, what you are seeing on the roof and the decision you need to make. We will tell you what to expect before anything is scheduled.