If you own or manage a multi-unit property in San Francisco, there’s a local law you need to know about — and it goes beyond what SB 721 and SB 326 require.
San Francisco Housing Code Section 604, adopted in 2003, mandates that all exterior elevated elements on apartment buildings, condominiums, and hotels be professionally inspected every five years. Unlike the statewide balcony laws, Section 604 covers both wood and metal structures — including fire escapes — and requires 100% inspection of every element, not just a sample.
The initial compliance deadline was April 1, 2022. If your property hasn’t been inspected, you’re already out of compliance and may be facing daily fines.
In this article:
- Who Needs a Section 604 Inspection?
- How Section 604 Differs from SB 721 & SB 326
- What Gets Inspected Under Section 604
- Fines & Penalties for Non-Compliance
- The D&B Inspection Process
- The Section 604 Affidavit
- What Does a Section 604 Inspection Cost?
- Frequently Asked Questions
Who Needs a Section 604 Inspection?
Section 604 applies to three categories of San Francisco properties:
Apartment buildings with 3 or more dwelling units. Every exterior elevated element — from balconies and decks to metal fire escapes and exit corridors — must be inspected and documented. The property owner files the compliance affidavit with SFDBI.
Condominiums with 3 or more units. The HOA is responsible for filing the affidavit covering common-area structures. Individual unit owners must address any elevated elements attached exclusively to their unit. Both must be completed for full compliance.
Hotels with 6 or more guest rooms. All exterior elevated elements, including fire escapes and exit stairways, fall under the inspection mandate regardless of seasonal occupancy or vacancy rates.
Single-family homes, duplexes, and commercial properties without guest rooms are not subject to Section 604.
How Section 604 Differs from SB 721 & SB 326
Many San Francisco property owners assume that completing an SB 721 or SB 326 inspection satisfies all their obligations. It doesn’t. Section 604 is a separate local ordinance with broader scope and stricter requirements.
| Section 604 | SB 721 | SB 326 | |
|---|---|---|---|
| Jurisdiction | San Francisco only | All of California | All of California |
| Applies to | Apts 3+, Condos 3+, Hotels 6+ | Apartments 3+ units | Condos / HOAs |
| Metal structures | Yes | No | No |
| Fire escapes | Yes | No | No |
| Height minimum | None | 6 ft above grade | 6 ft above grade |
| % inspected | 100% | 15% sample | 95% sample |
| Cycle | Every 5 years | Every 6 years | Every 9 years |
| Who can inspect | GC, Architect, Engineer, Pest Control | GC, Architect, Engineer | Architect or Engineer only |
| Deadline | Apr 2022 (passed) | Jan 2025 (passed) | Jan 2025 (passed) |
The bottom line: if your building is in San Francisco, you may need to comply with all three laws simultaneously. D&B can handle Section 604, SB 721, and SB 326 in a combined inspection — reducing your cost and minimizing tenant disruption.
What Gets Inspected Under Section 604
Section 604 requires a thorough evaluation of every exterior elevated element — not a statistical sample. Our inspectors assess the following:
Wood decay and fungal growth. San Francisco’s marine climate accelerates moisture damage. We check all wood-framed balconies, decks, stairways, and landings for rot, fungus, and soft spots that indicate structural compromise.
Metal corrosion and fire escape integrity. This is where Section 604 goes beyond the state laws. Every metal fire escape, exterior stairway, and metal railing must be evaluated for rust, corrosion, weld failures, and load-bearing capacity. Many older SF buildings have fire escapes that haven’t been assessed in decades.
Guardrails and handrails. Attachment points, height compliance, baluster spacing, and resistance to lateral force. A guardrail that looks solid can fail under load if its anchoring has corroded.
Waterproofing systems. Membrane condition, flashing integrity, drainage slope, and evidence of standing water or moisture intrusion beneath walking surfaces.
Structural connections. Ledger board attachments, post-beam joints, joist hangers, and all fastener conditions — anywhere a structural element connects to the building or to another element.
Unpermitted modifications. DIY repairs, unauthorized alterations, and code-violating changes that may have weakened structural integrity over time.
Fines & Penalties for Non-Compliance
The April 1, 2022 deadline has passed. Property owners who haven’t filed a compliance affidavit with SFDBI are currently in violation of San Francisco Housing Code. Consequences include:
- Daily civil fines of $100 to $500 assessed by the SF Department of Building Inspection
- Property liens that can block sales, refinancing, and permit approvals
- Full personal liability if someone is injured on an uninspected structure
- Insurance complications — carriers may deny claims for incidents on non-compliant properties
Your 5-year re-inspection cycle doesn’t begin until your first compliant inspection is completed. Waiting longer only pushes your next deadline further out and increases your cumulative fine exposure.
The D&B Inspection Process
We’ve developed a streamlined process specifically for Section 604 compliance in San Francisco:
Step 1: Property review. We assess your building’s specifics — unit count, number and type of elevated structures, access requirements, and whether you also need SB 721 or SB 326 coverage. You receive a detailed quote within one business day.
Step 2: On-site inspection. Our qualified team inspects 100% of all exterior elevated elements. We use moisture meters, endoscopic cameras, and infrared imaging where visual inspection alone isn’t sufficient. Metal structures receive dedicated corrosion and load-capacity assessment.
Step 3: Report delivery. You receive a comprehensive written report including photographic documentation, condition ratings for each element, and prioritized repair recommendations when applicable.
Step 4: Affidavit preparation. We prepare the signed compliance affidavit formatted for direct submission to SFDBI — either by email to dbi.hissection604@sfgov.org or by mail to their office at 49 South Van Ness Avenue, 4th floor, San Francisco, CA 94103.
If repairs are needed, our construction team handles everything in-house — from targeted wood rot remediation to complete deck reconstruction and waterproofing. One company, start to finish.
The Section 604 Affidavit
Unlike SB 721 and SB 326, which require reports filed with local enforcement agencies or HOA boards, Section 604 requires a specific compliance affidavit submitted directly to the SF Department of Building Inspection (SFDBI).
This affidavit is a signed document confirming that:
- All exterior elevated elements on the property have been inspected
- The inspection was performed by a qualified professional
- Any identified deficiencies have been repaired or a repair timeline has been established
D&B prepares this affidavit as a standard part of our inspection service — no additional charge, no extra paperwork on your end.
What Does a Section 604 Inspection Cost?
Inspection costs depend on several factors specific to your property:
- Total number of residential units or hotel rooms
- Number and variety of exterior elevated structures
- Building height and access complexity (scaffolding, lift requirements)
- Whether you’re combining Section 604 with SB 721 or SB 326 inspection
Combined inspections typically reduce the per-law cost since we’re already on-site evaluating the same structures. Every D&B inspection includes the full written report, photo documentation, and affidavit preparation.
Contact D&B for a free estimate tailored to your San Francisco property.
Frequently Asked Questions
Do I need Section 604 if I already passed SB 721?
Yes. SB 721 and Section 604 are separate laws with different requirements. SB 721 only covers wood-framed structures over 6 feet above ground and samples 15% of elements. Section 604 covers all wood and metal structures at any height and requires 100% inspection. You need both.
Does Section 604 apply outside of San Francisco?
No. Section 604 is a local San Francisco Housing Code ordinance. It applies exclusively to properties within SF city limits. Properties in other California cities are subject to SB 721 and/or SB 326 but not Section 604.
What types of structures does Section 604 cover that SB 721 doesn’t?
Metal fire escapes, metal stairways, metal guardrails, and exit corridors. SB 721 only addresses wood or wood-based structural elements. Section 604 covers all materials — wood and metal — making it significantly broader in scope.
What happens if my building needs repairs after the inspection?
Your inspection report will identify any deficiencies and prioritize them by urgency. D&B handles repairs in-house — structural reinforcement, wood rot remediation, waterproofing, railing replacement, and deck reconstruction. We can re-inspect after repairs are complete and issue an updated affidavit.
How often do I need to repeat the Section 604 inspection?
Every 5 years from the date of your first compliant inspection. This is a shorter cycle than SB 721 (6 years) and SB 326 (9 years). If your building also requires those state inspections, you’ll need to track three separate timelines.
Can D&B combine Section 604 with SB 721 and SB 326?
Yes. For San Francisco properties that fall under multiple laws, we offer combined inspection packages. One visit covers all applicable requirements, saving you time and reducing the total cost. Call (916) 848-2728 to discuss your property’s specific needs.
Where do I submit the Section 604 affidavit?
By email to dbi.hissection604@sfgov.org or by mail to the SFDBI Housing Inspection Services Division at 49 South Van Ness Avenue, 4th floor, San Francisco, CA 94103. D&B prepares the affidavit for you — you just need to submit it.
Is there a height requirement for Section 604?
No. Unlike SB 721 and SB 326, which only cover elements 6 feet or more above grade, Section 604 has no minimum height threshold. All exterior elevated elements must be inspected regardless of their height above ground.