The Penetration Record SOP

Purpose

Every new hole through a roof, a fire-rated assembly or an exterior wall ends up closed, covered and out of sight, and from that moment the only evidence of how it was done is whatever the shop wrote down. This SOP guarantees that each such penetration leaves a record that answers, years later and without the tech who did it: where it is, what condition the spot was in before the cut, which layers were cut through, what restored each one, and what it looked like before it was covered. Without it, a leak, a failed inspection or a warranty dispute turns into one person's memory against another's, and the shop that cut last usually loses that.

Scope

Covers: every new penetration, and every existing penetration whose seal you disturb, through a roof covering or deck, a fire-rated wall, floor or ceiling (including the garage-to-house separation and dwelling unit separations), an exterior wall, or a foundation wall below grade. It applies whichever trade does the work and whatever the size of the hole, including probe holes and abandoned pilots.

Does not cover: deciding whether a structural member may be cut, which belongs to The Structural Cut Approval SOP; the roof-specific closeout and water check, which belongs to The Roof Penetration Closeout SOP and uses this record as its input; and holes in interior non-rated partitions, which follow the shop's ordinary job notes.

Roles and responsibilities

Procedure

Step 1: Classify the penetration before anything is cut

On the work order, write which class the penetration falls in: roof, rated assembly, exterior wall, below grade, or none of these, and how you know (permit drawings, building type, a label, the homeowner, a code you recognized). Acceptance: one class written on the work order, with its basis, before the first cut; "none of these" is a valid entry only with a reason. Wrong looks like: "not sure if it's rated". Stop rule: an unknown rating is treated as rated, and the lead is called before cutting; a duplex ceiling or a garage wall under a bedroom is rated until shown otherwise. Hazard: none at this step; it is a decision made from paperwork and a look at the space.

Step 2: Photograph the spot before the cut, with a reference

Take two photographs: one wide enough to show where on the building the spot is, and one close with a tape measure in frame giving the distance from two fixed references (a corner, an eave, a floor, a window edge). Acceptance: two photographs, both with the date stamp on, and two dimensions written on the record that let someone find the spot from outside or inside without you. Wrong looks like: a close-up of siding with no tape and no landmark. Stop rule: retake before cutting; a pre-cut photograph cannot be taken afterward. If a customer declines photographs inside their home, write the refusal and photograph only the work area with nothing personal in frame. Hazard: at height, take photographs only with both feet on a rung below the top two and the ladder footed, or from a roof only under fall protection appropriate to the activity; never step back from a ladder to frame a shot.

Step 3: Read the condition where the assembly can hide damage

Where the assembly can hold water out of sight (EIFS, stucco, a roof deck, a crawl liner, a basement wall with efflorescence), take and record a condition reading at the spot: a moisture reading with the meter scale named, a deck that is firm or soft underfoot, a wall that is dry or damp. Acceptance: a value with its unit or an observed state written down, or "not applicable" with the reason. Wrong looks like: a reading with no scale named, or a reading taken on the cladding face instead of the sheathing. Stop rule: on EIFS or stucco, a reading above about 20 percent on the wood scale, or any visibly soft deck or wet sheathing, stops the cut and goes to the lead and the customer before work continues. Hazard: a moisture probe through EIFS is itself a penetration, so seal each probe hole with a compatible sealant before leaving; on a roof, a soft deck is a place not to stand, so keep weight on framing.

Step 4: Record each layer cut through and what restores it, before closing

List every layer the penetration passes through, outside to inside (for example: siding, WRB, sheathing, insulation, air barrier, gypsum), and against each one the method and product used to restore it, copied from the package, including any listed system number for a firestop. Acceptance: every layer has a restoring method named, and every product is suitable for that layer and assembly per its own label or listing. Wrong looks like: "foamed it" against a rated wall, or a sealant the cladding maker does not list as compatible. Stop rule: a product not approved or listed for the assembly means the penetration is not closed; the tech calls the lead, and the job waits for the right product rather than closing with the wrong one. Hazard: sealants, foams and firestop products give off solvent or isocyanate vapor in enclosed attics and crawlspaces; read the product's safety data sheet, ventilate, and wear the respiratory protection it calls for under the shop's written program per 29 CFR 1910.134.

Step 5: Photograph each layer as it is restored, before the next one covers it

Take one photograph of each restored layer, in order, showing the layer and its seal around the penetration. Acceptance: at least one photograph per layer listed in step 4, in sequence, each showing the restored layer itself. Wrong looks like: a single photo of the finished cover plate. Stop rule: if a layer was covered before it was photographed, the lead decides whether to reopen it; if not reopened, the record says "not photographed" against that layer, which is honest and still useful. Hazard: pulling attic insulation back for a photo puts glass fiber in the air and on skin; wear eye protection and long sleeves, and a filtering facepiece is voluntary use under 1910.134 Appendix D unless the exposure calls for more. Reopening a cut goes back to the hazards of the original cut.

Step 6: Take the final photograph and run the check the class requires

Photograph the finished penetration from the same spot as step 2, with the tape in frame. Then run the check for its class: a water check on an exterior or below-grade penetration, a visual of every seam for a rated one, a roof check per the roof closeout SOP. Acceptance: final photograph matching the step 2 framing, and the check's result written as pass or fail with what was observed. Wrong looks like: a check recorded as "good" with no observation. Stop rule: a failed check reopens the step it points to. Hazard: water checks run beside electrical equipment and service drops; keep the spray off the meter, disconnects and outdoor units, and on a roof the check follows the roof SOP's fall protection.

Step 7: File the record with the job within one business day

Upload the photographs and the completed record to the job, tagged as a penetration record, and the office reviews every field. Acceptance: record attached within one business day of closing the penetration, every field filled or marked not applicable with a reason, and the office's review initialed. Wrong looks like: photographs on the tech's phone a week later. Stop rule: any missing field goes back to the tech the same week, and a record that cannot be completed is marked incomplete with what is missing rather than quietly closed. Hazard: none at this step, provided it is done parked, not while driving.

The record this produces

One record per penetration, attached to the job and tagged so it can be found by address: the class and its basis; two location dimensions and the pre-cut photographs; the condition reading; the layer list with each restoring method and product; one photograph per layer; the final photograph and check result; names of everyone who cut or sealed, including another trade. The people who read it later are the office handling a callback or a warranty claim, the next tech at that address, an inspector, and, in a dispute, the shop's insurer or attorney. Keep it as long as the shop keeps job records, and no shorter than the workmanship warranty; many states let claims for construction defects run for years after completion, with statutes of repose commonly in the range of about 6 to 10 years, so confirm your own state's period.

Worked pass: a conduit through a garage-to-house wall

An electrician runs 3/4 in EMT from a garage subpanel through the common wall into a finished laundry room. The record as filed:

PENETRATION RECORD          Job 24-1187   Tech R. Okafor
Class: RATED - garage-to-house separation
  basis: attached garage, IRC R302.6 wall
Location: garage side, 41 in from NE corner,
  52 in above slab (photos 1, 2, pre-cut)
Condition: gypsum sound, dry; n/a moisture
  (interior wall, no water source)
Layers, garage side to house side:
  1 gypsum 1/2 in   -> fill, approved for R302.11
  2 stud cavity     -> no insulation present
  3 gypsum 1/2 in   -> fill, same product
  Step 4 FAIL 10:40: general foam on truck, not
    approved for separation. Lead (M. Diaz)
    called; job paused. Approved fill bought,
    applied 13:15. Old foam can not used.
Photos per layer: 3 (cavity, open),
  4 (house-side fill), 5 (garage-side fill)
Final: photo 6 matches photo 2 framing
Check: rated, all seams visual PASS, annular
  gap filled full depth both faces
Filed: same day 16:20; office review AK

The pass shows the exception path working: step 4's stop rule fired, the lead made the call, and the record says so with times rather than smoothing it over. Checked against the general section: step 2 asks for two dimensions and the record carries 41 in from the corner and 52 in above the slab; the class carries its basis, every layer in step 4 has a method, step 5's count of three photographs covers the three layers listed, and the record was filed inside one business day.

References

• International Residential Code, R302.5.3, R302.6 and R302.11, 2021 edition, as adopted by your jurisdiction.
• 29 CFR 1910.134, Respiratory Protection, including Appendix D.
• See related: The Structural Cut Approval SOP; The Roof Penetration Closeout SOP; Restoring What You Cut Through: The Closing Checklist; How to Coordinate a Penetration with the Trade That Owns the Assembly.