Understanding the Milestone Inspection and SIRS Process
Florida's SB 4-D legislation requires condominium buildings three stories and above to undergo structural milestone inspections and maintain adequate reserves through a Structural Integrity Reserve Study. This guide explains what happens at each stage of the process, who is responsible, and how FCS supports associations through remediation.
Phase 1 Inspection: Visual and Limited Examination
The Phase 1 milestone inspection is the initial structural assessment required under Florida Statute 553.899. It is a visual and limited-scope examination of the building's primary structural components, intended to determine whether substantial structural deterioration exists.
Who Performs Phase 1
The Phase 1 inspection must be conducted by a licensed Professional Engineer (PE) or a licensed architect -- not by a contractor. The inspection is an engineering assessment, not a construction evaluation. The association's board of directors is responsible for engaging and paying for the inspection engineer. FCS does not perform milestone inspections. We are the remediation contractor that enters the process after the engineer has completed their assessment and identified the necessary repairs.
What Phase 1 Examines
The inspector evaluates the building's load-bearing walls, floors, foundations, primary structural members, and other components that affect the structural integrity of the building. For Florida condominiums, common focus areas include:
- Concrete spalling and delamination on balconies, walkways, columns, and parking structures
- Reinforcing steel corrosion visible through cracking, rust staining, or exposed rebar
- Waterproofing system failures allowing moisture into structural elements
- Post-tension cable distress in parking garages and elevated slabs
- Foundation settlement or movement affecting structural stability
Timeline and Deadlines
Under the current statute, buildings must complete their initial milestone inspection based on when they received their certificate of occupancy:
Key Deadlines Have Passed
Buildings with certificates of occupancy issued before July 1, 1992 were required to complete their milestone inspection by December 31, 2024. Buildings with certificates issued between July 1992 and December 1994 had a December 31, 2025 deadline. Both deadlines have now passed. Buildings that have not completed their required inspections are non-compliant and face escalating consequences.
For buildings reaching 30 years of age after January 1, 1995, the milestone inspection is due by the end of the year the building turns 30 -- or 25 years for buildings located within three miles of the coastline. Subsequent inspections are required every 10 years.
Phase 1 Outcome
The Phase 1 inspection produces one of two outcomes:
No Substantial Deterioration
The engineer finds no evidence of substantial structural deterioration. The report is filed with the local building official, and the association's next inspection is due in 10 years. The building may still have maintenance needs, but no Phase 2 is required.
Phase 2 Required
The engineer identifies substantial structural deterioration requiring further investigation. A Phase 2 inspection must be initiated within 180 days of the Phase 1 report submission. This is where most associations begin engaging a remediation contractor.
Typical Phase 1 Cost
Phase 1 inspection costs typically range from $5,000 to $25,000 depending on building size, number of stories, and complexity. This is the inspection cost only -- it covers the engineer's time for examination and report preparation. It does not include any remediation costs. Larger buildings with parking structures, extensive balcony systems, or complex structural configurations will be at the higher end of this range. Associations should budget for this as a recurring expense every 10 years.
Phase 2 Inspection: Detailed Structural Examination
When a Phase 1 inspection reveals substantial structural deterioration, the statute requires a Phase 2 inspection -- a significantly more detailed and potentially destructive examination of the building's structural systems.
What Triggers Phase 2
Phase 2 is triggered when the Phase 1 inspector determines that substantial structural deterioration exists. "Substantial structural deterioration" means the building has damage or distress that affects its general structural integrity, as opposed to isolated or cosmetic damage. The determination is a professional judgment call made by the licensed engineer or architect who conducted the Phase 1 inspection.
What Phase 2 Involves
Unlike the primarily visual Phase 1 examination, Phase 2 involves detailed, often destructive testing methods to fully characterize the extent and severity of structural deterioration. The inspection engineer may:
- Core concrete samples for compressive strength testing and chloride content analysis
- Remove concrete cover to expose and evaluate reinforcing steel condition
- Ground-penetrating radar scans to map rebar location, post-tension cables, and voids
- Load testing on structural elements where capacity is in question
- Moisture and water intrusion testing on building envelope systems
- Post-tension cable evaluation including tendon force measurement and corrosion assessment
Timeline Requirements
The Phase 2 inspection must be initiated within 180 days of the Phase 1 report being submitted to the local building official. "Initiated" means the association has engaged an engineer and work has begun -- not merely that a contract has been signed. Given the complexity of Phase 2 testing, the inspection itself may take several weeks to several months to complete depending on building size and the extent of deterioration found.
Phase 2 Deliverable
The Phase 2 inspection produces a detailed report that includes specific findings for each structural system examined, prioritized repair recommendations, estimated repair costs, and a recommended repair timeline. This report becomes the roadmap for remediation -- it is the document that FCS and the association's engineering team use to develop the actual construction scope, schedule, and budget for the repair work.
Typical Phase 2 Cost
Phase 2 inspection costs typically range from $15,000 to $75,000 or more depending on building size, the extent of destructive testing required, and the number of structural systems being evaluated. The cost is substantially higher than Phase 1 because it involves laboratory testing, specialized equipment (GPR scanners, core drills), and significantly more engineering time. Some associations are surprised by this cost, but the Phase 2 report is essential for developing an accurate remediation plan and preventing cost overruns during construction.
Remediation After Phase 2: From Report to Repairs
Once the Phase 2 inspection report is complete, the association has a 365-day window to commence necessary repairs. This is where FCS enters the process -- we are the remediation contractor that executes the repairs the engineers have specified.
The 365-Day Clock
The 365-day remediation commencement deadline starts from the date the Phase 2 report is submitted to the local building official. "Commence" under the statute means actual construction work has begun. Given that the path from report to construction involves engineering design, permitting, contractor selection, and mobilization, associations that wait to start this process risk missing the deadline. Most remediation projects require 6 to 9 months of pre-construction work before the first repair begins on-site.
Who Does What During Remediation
The Structural Engineer
Prepares repair specifications, reviews contractor submittals, conducts progress inspections, and provides the final certification that repairs were completed per the Phase 2 report recommendations.
FCS (Remediation Contractor)
Executes the repairs specified by the engineer. This includes concrete removal and replacement, steel reinforcement repair, waterproofing installation, balcony reconstruction, and all associated construction work. We work alongside the inspection engineers, not independently of them.
The Association Board
Approves the remediation scope and funding, communicates with unit owners about timelines and assessments, and ensures the association meets its statutory obligations for compliance documentation.
Construction Planning and Phasing
Remediation construction on occupied condominium buildings requires careful phasing. Residents continue to live in the building during repairs, which means the contractor must manage noise, dust, access disruptions, and safety throughout the project. FCS develops phased construction plans that sequence work by building elevation, floor level, or structural system to minimize disruption. For example, balcony repairs might proceed one elevation at a time, while parking structure work is phased to maintain adequate resident parking throughout the project.
Threshold Building Certification
Upon completion of remediation, the structural engineer conducts verification inspections and issues the documentation required to demonstrate that the building has met its SB 4-D obligations. This "threshold building certification" is filed with the local building official and becomes part of the building's permanent compliance record. FCS coordinates with the inspection engineer throughout the construction process to ensure that all repairs meet the specifications and that the certification process proceeds without delays.
SIRS: Structural Integrity Reserve Study
The Structural Integrity Reserve Study is a separate but complementary requirement to the milestone inspection. While the milestone inspection evaluates the building's current structural condition, the SIRS evaluates whether the association has adequate financial reserves to fund future maintenance, repair, and replacement of major building components.
Who Needs a SIRS
All condominium associations with buildings three stories or higher must complete a SIRS. This is required regardless of building age -- it applies to newer buildings as well as older ones that also require milestone inspections. The study must be conducted by a licensed Professional Engineer, architect, or reserve specialist who is not affiliated with the association's management company.
Required Reserve Components
Under Section 718.112, Florida Statutes, the SIRS must evaluate the remaining useful life and replacement cost of these building components:
HB 913 Changes: Baseline Funding Plan
HB 913, signed into law in June 2025 and effective July 1, 2025, introduced significant changes to SIRS requirements. The most important is the baseline funding plan requirement: the association's reserve funding plan must demonstrate that reserves will never drop below zero at any point during the planning horizon. This prevents associations from underfunding reserves by deferring contributions to future years. Additionally, the deferred maintenance threshold was raised from $10,000 to $25,000, indexed to inflation, and associations must report SIRS results to the DBPR through an online portal.
The 2-Year Reserve Pause Option
Recognizing that some associations face the difficult situation of needing to fund both immediate repairs and long-term reserves simultaneously, HB 913 allows associations to pause reserve fund contributions for up to two fiscal years to prioritize immediate structural repairs. This is particularly relevant for buildings that received Phase 2 inspection reports requiring substantial remediation. The pause must be approved by the board and documented in the association's records. After the pause period, full reserve funding must resume.
SIRS vs. Milestone Inspection
These are separate requirements that serve different purposes:
Milestone Inspection
- Evaluates current physical condition
- Performed by PE or architect
- Triggered by building age
- Determines if remediation needed
- Required every 10 years
SIRS
- Evaluates financial adequacy of reserves
- Performed by PE, architect, or reserve specialist
- Required for all 3+ story condos
- Determines if reserves are funded
- Updated periodically per association policy
SIRS Deadline Has Passed
The initial SIRS completion deadline of December 31, 2025 has passed. Additionally, as of January 1, 2025, associations may no longer waive or reduce reserve funding for SIRS components. Buildings that have not completed their SIRS are non-compliant and may face difficulty obtaining insurance, financing unit sales, and meeting fiduciary obligations.
How FCS Supports the Inspection and Remediation Process
FCS is a remediation contractor, not an inspection firm. We enter the process after the structural engineer identifies what needs to be repaired. Here is how we help at each stage.
Pre-Inspection Consultation
Before the milestone inspection begins, we help association boards understand what to expect from the process, what the engineer will be looking for, and how to prepare the building for efficient access. We can identify areas of obvious concern that the board should bring to the inspector's attention. This is not an inspection -- it is construction-experienced guidance that helps the association ask the right questions.
Direct Access to Licensed Structural Engineers
FCS maintains relationships with dedicated engineering partners who specialize in Florida condominium structural assessments. When an association needs a qualified inspection engineer, we can facilitate introductions to licensed professionals with specific experience in the type of building being evaluated. The engineer works independently -- they are engaged by and report to the association, not to FCS.
Post-Inspection Remediation Planning
Once the Phase 2 report is complete, we work with the association and the inspection engineer to develop a comprehensive remediation plan. This includes detailed construction scoping, cost estimating, phasing plans for occupied buildings, and timeline projections. We translate the engineer's technical findings into a construction plan the board can understand and approve.
Remediation Construction Management
As the licensed general contractor, FCS manages all aspects of the remediation construction. We coordinate subcontractors, manage materials, maintain quality control, ensure safety compliance, and keep the project on schedule. We work alongside the inspection engineers throughout construction so they can verify that repairs are executed according to their specifications.
Threshold Certification Coordination
At project completion, we coordinate with the structural engineer for verification inspections and support the preparation of the threshold building certification. We compile complete project records including repair documentation, material certifications, quality control reports, and warranty information that the association needs for its permanent compliance files.
Applicable Florida Statutes
Florida Statute 553.899
Mandatory Structural Inspections for Condominium and Cooperative Buildings
Establishes milestone inspection requirements for condominium buildings 3 stories or higher. Phase 1 visual inspection at 30 years (25 years within 3 miles of coast), Phase 2 detailed inspection if substantial deterioration found, and 365-day remediation commencement requirement after Phase 2 report.
View F.S. 553.899 →Florida Statute 718.112
Condominium Association Powers and Duties -- Reserve Funds and SIRS
Requires Structural Integrity Reserve Studies for all condominium buildings 3 stories or higher. As amended by HB 913 (2025), reserves must follow a baseline funding plan that keeps balances above zero, the deferred maintenance threshold is $25,000 (inflation-indexed), and associations may pause contributions for up to 2 years to fund immediate repairs.
View F.S. 718.112 →Milestone Inspection & SIRS Process FAQ
Common questions about the inspection process, SIRS requirements, and remediation timeline under Florida's SB 4-D legislation.
The condominium association's board of directors is responsible for initiating and completing the milestone inspection. Individual unit owners have no direct obligation under the statute. The board must engage a licensed Professional Engineer or architect to conduct the inspection and must submit the completed report to the local building official. Board members who fail to initiate inspections by the applicable deadline may face personal liability for breach of fiduciary duty.
Yes. The licensed Professional Engineer or architect who conducts the milestone inspection may also prepare the repair specifications and oversee the remediation work. In practice, this is common and often beneficial because the inspection engineer already understands the building's specific conditions. However, some associations choose to engage a separate engineer for remediation design as a check on the original findings. The key requirement is that the inspector must be a licensed PE or architect independent of the contractor performing repairs -- FCS does not perform inspections, but works alongside the inspection engineers during remediation.
A milestone inspection is a structural assessment of the building's physical condition, conducted by a licensed engineer or architect. It evaluates whether the building has substantial structural deterioration. A Structural Integrity Reserve Study (SIRS) is a financial planning document that evaluates the remaining useful life and replacement cost of major building components, then determines whether the association's reserve fund is adequate to cover future repairs. Both are required under Florida law, but they serve different purposes: the milestone inspection asks 'is the building safe now?' while the SIRS asks 'can we afford to maintain it going forward?'
A Phase 1 inspection does not technically 'fail.' If the inspector identifies substantial structural deterioration, they are required to recommend a Phase 2 inspection, which involves more detailed and potentially destructive testing. The building is not condemned or declared unsafe based on Phase 1 findings alone. However, if the engineer determines there is an immediate life-safety concern, they must notify the local building official, who may take emergency action. In most cases, Phase 2 simply means a more thorough evaluation is needed before a remediation plan can be developed.
HB 913, effective July 1, 2025, allows condominium associations to pause reserve fund contributions for up to two fiscal years if the association needs to prioritize immediate structural repairs or remediation work. This provision was added because some associations faced the impossible situation of funding both urgent repairs and fully funded reserves simultaneously. The pause must be approved by the board, and the association must resume contributions after the pause period. This option is particularly useful for buildings that received Phase 2 inspection reports requiring substantial remediation -- it lets the association direct funding toward the repairs rather than a reserve account.
Under Florida Statute 553.899, the association must commence necessary repairs within 365 days of receiving the Phase 2 inspection report. 'Commence' means beginning actual construction work, not merely planning or permitting. Given that permitting, engineering, bidding, and mobilization can take 6 to 9 months, associations should begin engaging a remediation contractor and structural engineer immediately upon receiving the Phase 2 report. Failure to begin remediation within the 365-day window exposes the association to enforcement action by the local building official and potential liability for board members.
Discuss Your Building's Inspection Findings
Whether your building has received a Phase 2 inspection report or you're preparing for your first milestone inspection, our team can help you understand your obligations and develop a remediation plan.