Is Re-Roofing Considered ''repair'' or ''Maintenance'' ?
In Kulzer Roofing, Inc. v. Department of Labor & Industry, 68 Pa. Commw. 642, 450 A.2d 259 (Pa. Cmwlth. 1982), the Court held the re-roofing of eight buildings to be repair rather than maintenance, subject to prevailing minimum wages, because the entire roof of each building was replaced, rather than partially overhauled or patched.
If the work was of "a manner as to effect a change in its size or type, the project would be repair work." Id. at 261.
The inverse implication of that holding, noted this Court, was that "maintenance work would occur when a facility was partially overhauled or patched." Id.