Exterior Envelope Commissioning

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Author Message Di Ann Hassloch, CSI, CCS, CCCA, LEED AP Senior Member Username: dhassloch Post Number: 11 Registered: 07-2005 Posted on Wednesday, March 18, 2009 - 11:55 am:    Our city building code department has elected to require exterior envelope commissioning for all commerical structures with conditioned space of 50,000 square feet or more. The design professional is required to sign a statement indicating that detailed instructions have been provided in the construction documents. Does anyone else have any knowledge of an AHJ requiring this? We were given six months notice of this before it was implemented. Since most of our projects are on the boards for a year or so, this means that the cost of the code change is coming out of our pockets, or through our sweat. I would like to hear from others on the advisability of providing the commissioning plan as an architect. Also, any thoughts you might have on this code requirement. Has anyone written any envelope commissioning specifications? I am aware of the NIBS and the Ashrae guidelines. Thank you for your input. Jerry Tims Senior Member Username: jtims Post Number: 60 Registered: 04-2005 Posted on Wednesday, March 18, 2009 - 12:00 pm:    I would recommend discussing this whole issue with your attorney. Our attorney strongly advises us against "certifying" anything if at all possible. You may end up not having an option, but at least you'll have your attorney involved. Mark Gilligan SE, CSI Senior Member Username: mark_gilligan Post Number: 136 Registered: 10-2007 Posted on Wednesday, March 18, 2009 - 12:10 pm:    If all you are doing is saying that you have provided for this in the construction documents I do not believe that this should be a problem. It is no different from when you submit the drawings for permit. At that time your are implicitly stating that you have complied with the other code provisions consistent with the standard of care obligation. The need to address exterior envelope commissiong asside I do not see that the signed statement acomplishes anything. Bob Woodburn, RA CSI CCS CCCA LEED AP Senior Member Username: bwoodburn Post Number: 282 Registered: 01-2005 Posted on Wednesday, March 18, 2009 - 01:02 pm:    Phil Kabza mentions the NIBS Guidelines (337 pages) in the parallel thread "Building envelope commissioning specification," but then you say you're familiar with that, as well as the ASHRAE Guidelines they are meant to work with; see my comment there. (Colin: Could these two threads be merged? Seems as if they cover the same subject.) Anne Whitacre, FCSI CCS Senior Member Username: awhitacre Post Number: 866 Registered: 07-2002 Posted on Wednesday, March 18, 2009 - 03:05 pm:    well, the other thing is that it usually is advisable for the owner to hire a building commissioning agent, and since this was implemented by the AHJ after you started the documents, it shoudl be a legitimate change to your contract for services. if the project were starting now, the owner would have to pay for this, so its not unreasonable for the owner to pay for this now. (not that all owners are unreasonable) I don't think architects shoudl be on the line for commissioning, since we generally are not in the position of running the commissioning, or performing the tests required. this needs to be done by someone else. typically oh the projects I work on, the commissioning spec is written by the commissioning agent, but Masterspec does have commissioning sections that can be used as guidelines. And LEED implementation requires commissioning (performed by an outside entity) so this requirement isn't that unusual anymore. James M. Sandoz, AIA, CSI, CDT, LEED AP Senior Member Username: jsandoz Post Number: 46 Registered: 06-2005 Posted on Wednesday, March 18, 2009 - 06:24 pm:    Colin, I originated the other thread, "Building Envelope Commissioning Specification," and I agree with Bob Woodburn that the two should be merged. I had a phone conversation with Di Ann earlier today and, in our particular cases, we are dealing with the same code department on two different projects but with similar time horizons. To recap the issues: Di Ann has concerns about signing a statement of compliance and I share those concerns while finding Jerry Tims's recommendation to be appropriate. My problem is determining exactly what level of commissioning this particular code authority requires. Perhaps it is simply major components like curtain wall and other fenestration systems, exterior masonry and other "opaque" exterior cladding systems, and roofing assemblies. On the other hand it may be much more involved. I am hoping that someone else has come across this same requirement in another jurisdiction but where the objectives are clearly defined. Colin Gilboy Senior Member Username: colin Post Number: 173 Registered: 09-2005 Posted on Wednesday, March 18, 2009 - 06:55 pm:    There is no easy way to merge the discussions. The other discussion is here and I locked the thread and put a link here. http://discus.4specs.com/discus/messages/23/4373.html?1237342286 Colin Gilboy Publisher, 4specs.com 435.654.5775 - Utah 800.369.8008 J. Peter Jordan Senior Member Username: jpjordan Post Number: 317 Registered: 05-2004 Posted on Thursday, March 19, 2009 - 11:10 am:    The AHJ aforementioned has instituted this requirement (and one requiring commissioning of HVAC controls--not the system, the controls) without having any legitimate way to follow up. They do not accept specifications for review; they have not defined commissioning; they have not indicated specifically which systems are to be commissioned; and they have not indicated what type of submittal will be required to indicate that the requirement has been met. In fact, the AHJ requires that the construction documents indicate that commissioning is required; the AHJ does not really require commissioning. This is, IMHO, an excellent case of "green leech" bureacrats gone wild without their really understanding what the requirement means. I believe that this requirement may be met by bundling up the product data and testing results for building envelope components (which are usually already specified) along with a couple of reports from AHJ inspectors (who inspect for insulation in the walls). What I want to know is on which desk do we dump this stuff so that we can indicate the requirement has been met; I think the answer is that they don't want to see it. Huh! or duh... Ronald L. Geren, AIA, CSI, CCS, CCCA, SCIP Senior Member Username: specman Post Number: 748 Registered: 03-2003 Posted on Thursday, March 19, 2009 - 11:24 am:    Peter, did I read that right? The AHJ does "not accept specifications for review"? Do they specifically state this, or do they accept them when submitted and just ignore them during the review? Ronald L. Geren, AIA, CSI, CCS, CCCA, SCIP RLGA Technical Services www.specsandcodes.com J. Peter Jordan Senior Member Username: jpjordan Post Number: 318 Registered: 05-2004 Posted on Thursday, March 19, 2009 - 11:45 am:    Yes; I thought this was just a local thing, but evidently this is true for a number of AHJs around the country. It affects what goes on the Drawings and what goes in the specs and creates more questions when the AHJ wants information that is in the construction documents, but not on the Drawings. John Bunzick, CCS, CCCA, LEED AP Senior Member Username: bunzick Post Number: 1028 Registered: 03-2002 Posted on Thursday, March 19, 2009 - 11:51 am:    If there is a requirement for building envelope commissioning, why not start with the NIBS "Exterior Enclosure Technical Requirements for the Commissioning Process." This is used with the ASHRAE Guideline for Commissioning. Bob Woodburn, RA CSI CCS CCCA LEED AP Senior Member Username: bwoodburn Post Number: 283 Registered: 01-2005 Posted on Thursday, March 19, 2009 - 12:05 pm:    In a way, it makes sense. They're plan checkers, not spec checkers, so they're just staying within their area of professional expertise, as any professional should. Possible other reasons for the city's not accepting specs may be the perception that the main persons who read the specs around here are the attorneys, that they don't want to work for what a typical plan checker makes, and/or that the city doesn't want to pay them a third of the permit fee if they can prove that the spec is imperfect in some way... Bob Woodburn, RA CSI CCS CCCA LEED AP Senior Member Username: bwoodburn Post Number: 284 Registered: 01-2005 Posted on Thursday, March 19, 2009 - 12:18 pm:    As Phil Kabza wrote in the other thread, "The ARCOM/NIBS Division 01 section is available on the Whole Building Design Guide site, buried in this document: http://www.wbdg.org/ccb/NIBS/nibs_gl3.pdf" The suggested specifications are buried in Annex L (pp. 101-165 of 337), and checklists are in Annex M (pp. 166-209 of 337). Together, those may be a useful starting point. Mark Gilligan SE, CSI Senior Member Username: mark_gilligan Post Number: 139 Registered: 10-2007 Posted on Thursday, March 19, 2009 - 12:59 pm:    I have previously heard plan checkers state that they do not accept spcifications for review. The IBC clearly states that the specifications are part of the construction documents. Thus unless there is a local amendment the building department cannot legally refuse to accept the specifications. In some places like California this type of local amendments are not allowed but plan checkers will play this game any way. Alan Mays, AIA Senior Member Username: amays Post Number: 46 Registered: 02-2003 Posted on Thursday, March 19, 2009 - 01:30 pm:    I talked with a Head of Planning about this once. The reason that they gave was that they would have a huge cost in archiving it to microfilm. Lets say that you submit a set with 100 sheets, they still microfilm all records in many cities. The specs good easily be 1000 pages. Big difference. I agree that there new technology, but the records departments do not get the necessary funding to upgrade. Also, it might not be a good thing to go in and argue with them that they have to accept them. You will be surprised how your permit with slow down. Then you have a angry client. Ralph Liebing, RA, CSI Senior Member Username: rliebing Post Number: 964 Registered: 02-2003 Posted on Thursday, March 19, 2009 - 02:57 pm:    Hang on, folks! Both Mark and Alan have valid points and the combined crux of them is that there is a major issue here that needs to be aired out-- and ironed out-- and soon! Seems everybody is trying to get the design professionals to modify how they work and produce their documents-- BIM, and this issue for examples. BUT the professional fees from clients continue to diminish and cause added angst in the offices and proftiability [we ain't in this for glamour!!!] So those professionals are the least able to make continual modifications for each jurisdiction's demands. Suggest CSI mount a task force to sit with ICC and move a discussion to better understanding on BOTH sides and some mutual resolution [like you only need copy those spec pages you use in your review-- not all of the book!]-- Of course, there will ALWAYS be the strident, ill-advised, non-compliant AHJ who "has to flex muscle" and get it done only their way-- tough cookies but WRONG-headed! Lobbing verbal brick batts back and forth goes nowhere-- this needs attention and I think this is a good place to start Alan Mays, AIA Senior Member Username: amays Post Number: 47 Registered: 02-2003 Posted on Thursday, March 19, 2009 - 03:12 pm:    Well, we resolved it easily by adding what was required by the city from the spec onto the drawings. You will be surprised how little that really totals up to. Mainly door hardware and a few other things. Commissioning is something different. Maybe treat it like energy code requirements (Title 24 in CA) and literally put it on a sheet at the front of the documents. These are just a few ideas to address the needs of the plan checker. Take it from a foot soldier, a task force will not be needed. Sometimes all you need to do is just ask the Plan checker what they want and why. I discovered that they really do have valid reasons most of the time. Ronald L. Geren, AIA, CSI, CCS, CCCA, SCIP Senior Member Username: specman Post Number: 749 Registered: 03-2003 Posted on Thursday, March 19, 2009 - 03:47 pm:    I didn't mean to hijack the thread. Also, I don't want to divulge too much of my CONSTRUCT2009 presentation here, but ICC's own Plan Review Manuals do mention (albeit briefly) that specifications must be reviewed along with the drawings. Although I don't want to tick-off a building official, but if I received a comment that it's "plan" review and not "plan and spec" review, I'd be tempted to resubmit only the plan views of the drawing set--minus the elevations, sections, schedules, etc.--to see how they'd respond (It would likely be my last project in that jusidiction, though). Ronald L. Geren, AIA, CSI, CCS, CCCA, SCIP RLGA Technical Services www.specsandcodes.com Mark Gilligan SE, CSI Senior Member Username: mark_gilligan Post Number: 140 Registered: 10-2007 Posted on Thursday, March 19, 2009 - 03:50 pm:    The problem is not with ICC. The problem is with building officials and plan checkers. Part of the problem results from building officials who do not understand the role of specifications. The other part of the problem has to do with building officials who do not feel that they have to comply with the building code. I hear Alan's argument that we just give them what they want. I have done that when necessary. The problem is that it causes us to duplicate information or to put it in inconsistent locations. In addition I believe that there is the potential for problems when they state that the specifications are not part of the permit documents. Giving them what they want does not address the problem and allows the problem to fester and cause other problems. Putting the information they want on a sheet at the front of the documents would be equivalent to the General Notes sheet often used by structural engineers. I am aware of architects general opinion of this practice. The argument that they do not have the money to look in the specifications is irrelevant. As designers we are not excused from complying with the building code just because we are over budget. What may do some good is to publish an article in the ICC newsletter discussing the role of specifications and the relevant code provisions related to specifications. Wayne Yancey Senior Member Username: wayne_yancey Post Number: 173 Registered: 01-2008 Posted on Thursday, March 19, 2009 - 04:24 pm:    A few years ago I did assessment and rehab work on existing condominiums in Seattle. Seattle DPD offered a "Subject to Field Inspection" (STFI) building permit over the counter. One DPD requirements was the drawings contain the specification for the materials used in the rehab (water-resistive barrier, PT strapping, siding, roofing, sheet metal flashing and trim, sealants, windows, doors, etc). We were caught off guard by this requirement as we had prepared the usual project manual. The Specs in MSWord were cut and pasted into MTEXT in AutoCAD 2006 in column format. Not a big deal nor labor intensive. AutoCAD maintained 90% of the original formatting such as numbering, indents and hanging intents. Some manual reformattting was required. The drawings also contained language included in RCW 64.55.020 below. RCW = Revised Code of Washington. RCW 64.55.010 "Building enclosure design documents" means plans, details, and specifications for the building enclosure that have been "stamped" by a licensed engineer or architect. The building enclosure design documents shall include details and specifications that are appropriate for the building in the professional judgment of the architect or engineer which prepared the same to waterproof, weatherproof, and otherwise protect the building or its components from water or moisture intrusion, including details of flashing, intersections at roof, eaves or parapets, means of drainage, water-resistive membrane, and details around openings. "Stamped" means bearing the stamp and signature of the responsible licensed architect or engineer on the title page, and on every sheet of the documents, drawings, or specifications, including modifications to the documents, drawings, and specifications that become part of change orders or addenda to alter those documents, drawings, or specifications. RCW 64.55.020 (1) Any person applying for a building permit for construction of a multiunit residential building or rehabilitative construction shall submit building enclosure design documents to the appropriate building department prior to the start of construction or rehabilitative construction of the building enclosure. If construction work on a building enclosure is not rehabilitative construction because the cost thereof is not more than five percent of the assessed value of the building, then the person applying for a building permit shall submit to the building department a letter so certifying. Any changes to the building enclosure design documents that alter the manner in which the building or its components is waterproofed, weatherproofed, and otherwise protected from water or moisture intrusion shall be stamped by the architect or engineer and shall be provided to the building department and to the person conducting the course of construction inspection in a timely manner to permit such person to inspect for compliance therewith, and may be provided through individual updates, cumulative updates, or as-built updates. (2) The building department shall not issue a building permit for construction of the building enclosure of a multiunit residential building or for rehabilitative construction unless the building enclosure design documents contain a stamped statement by the person stamping the building enclosure design documents in substantially the following form: "The undersigned has provided building enclosure documents that in my professional judgment are appropriate to satisfy the requirements of RCW 64.55.005 through 64.55.090." (3) The building department is not charged with determining whether the building enclosure design documents are adequate or appropriate to satisfy the requirements of RCW 64.55.005 through 64.55.090. Nothing in RCW 64.55.005 through 64.55.090 requires a building department to review, approve, or disapprove enclosure design documents. RCW 64.55.020 All multiunit residential buildings shall have the building enclosure inspected by a qualified inspector during the course of initial construction and during rehabilitative construction. RCW.55.040 (1) A qualified building enclosure inspector: (a) Must be a person with substantial and verifiable training and experience in building enclosure design and construction; (b) Shall be free from improper interference or influence relating to the inspections; and (c) May not be an employee, officer, or director of, nor have any pecuniary interest in, the declarant, developer, association, or any party providing services or materials for the project, or any of their respective affiliates, except that the qualified inspector may be the architect or engineer who approved the building enclosure design documents or the architect or engineer of record. The qualified inspector may, but is not required to, assist with the preparation of such design documents. (2) Nothing in this section alters requirements for licensure of any architect, engineer, or other professional, or alters the jurisdiction, authority, or scope of practice of architects, engineers, other professionals, or general contractors. RCW 64.55.050 (1) Any inspection required by this chapter shall include, at a minimum, the following: (a) Water penetration resistance testing of a representative sample of windows and window installations. Such tests shall be conducted according to industry standards. Where appropriate, tests shall be conducted with an induced air pressure difference across the window and window installation. Additional testing is not required if the same assembly has previously been tested in situ within the previous two years in the project under construction by the builder, by another member of the construction team such as an architect or engineer, or by an independent testing laboratory; and (b) An independent periodic review of the building enclosure during the course of construction or rehabilitative construction to ascertain whether the multiunit residential building has been constructed, or the rehabilitative construction has been performed, in substantial compliance with the building enclosure design documents. RCW 64.55.060 Upon completion of an inspection required by this chapter, the qualified inspector shall prepare and submit to the appropriate building department a signed letter certifying that the building enclosure has been inspected during the course of construction or rehabilitative construction and that it has been constructed or reconstructed in substantial compliance with the building enclosure design documents, as updated pursuant to RCW 64.55.020. The building department shall not issue a final certificate of occupancy or other equivalent final acceptance until the letter required by this section has been submitted. The building department is not charged with and has no responsibility for determining whether the building enclosure inspection is adequate or appropriate to satisfy the requirements of this chapter. It is not uncommon for Architects in Seattle to create a sheet or series sheets with the Engry Code Analysis from the Energy Code Consultant. IMHO 99% of the Architects in Seattle are ill-equiped to perform exterior envelope commissioning. It is better left up to those professionals who specialize in this area of expertise, who are retained and paid for the the Owner. Wayne Mark Gilligan SE, CSI Senior Member Username: mark_gilligan Post Number: 142 Registered: 10-2007 Posted on Thursday, March 19, 2009 - 05:49 pm:    "Stamped" means bearing the stamp and signature of the responsible licensed architect or engineer on the title page, and on every sheet of the documents, drawings, or specification....." Did the Architect of Record really sign all pages in the specifications? Wayne Yancey Senior Member Username: wayne_yancey Post Number: 174 Registered: 01-2008 Posted on Thursday, March 19, 2009 - 06:33 pm:    No. As I mentioned at the beginning, the spec for these STFI projects were on 2 drawing sheets which have the stamp and signature same as other drawings. One of the general information sheets included a block of text that looks like a letter and included a similar statement to "The undersigned has provided building enclosure documents that in my professional judgment are appropriate to satisfy the requirements of RCW 64.55.005 through 64.55.090." Ralph Liebing, RA, CSI Senior Member Username: rliebing Post Number: 965 Registered: 02-2003 Posted on Friday, March 20, 2009 - 07:11 am:    Granted the problem is not with ICC, Mark, but ICC has a great deal of influence and can reach a great many code officals and plans examiners. As with their manuals [that Ron mentuoned] and through education they can lay ground work for proper review using all submitted docuemtas. There is an attempt to have ICC publish sn article but I am not sure where that stands. In any event. there will always be the strident code officals who does not understand and will do things for which there is authorization-- simply "that's the way we do it, here"! But to acqeuiese to every different jurisidiction when you practice nationwide is a messy and very time consuming situation. For years many bleated for one code-- so now we have it but the locals insist on modifications so in reality we still have numerous codes. Yet there is still one way to produce contract documents that is time proven and has been realtively free of trouble [except where not in compliance]. Now it is a problem, not of technical nature but one of process, administration and who has what busninss machine for processing. Surely it can be minimzed if not eliminated. There are wise and informed heads out there who need to prevail and bring along those we lack full insight and understanding. ken hercenberg Senior Member Username: khercenberg Post Number: 14 Registered: 12-2006 Posted on Friday, March 20, 2009 - 01:54 pm:    Would it be feasible to print out a copy of the Whole Building Design Guide document (double sided, of course) and present it to the AHJ for reference? This would not as part of any project doucmentation which requires duplication or recording, but rather with the request that designers be allowed to include that document by reference on the Code compliance sheet in the Drawing Set. Perhaps this can be combined with a copy of the ABAA sample spec and other, similar documents. A cover sheet explaining that A/E's are not qualified to generate a commissioning plan, even if they are LEED AP's, might help. To keep things in perspective, this document will presumably be used as the basis for contracts between Owners and their independent CxA's, so referencing this general information gives Owners choices without locking them in to a specific 'plan'. This may be a way to protect your clients as well as yourselves (and your fees). At least it may help establish some level of perspective for the AHJ since they presumably will otherwise have to review the lengthy documents that would ultimately be added to the drawings and would therefore require the review, recording, etc. AHJ's are legally responsible for content they approve, so they need to be careful about reviewing plans that are not in keeping with the intent of the law. Granted the WBDG document addresses numerous conditions, systems, components, and testing methods, at times referencing other documents. Granted this document is not project specific. Still, if the AHJ is willing to accept reference to this living document as being compliant with legal requirements "that detailed instructions have been provided in the construction documents" for exterior envelope commissioning, perhaps designers and Code Officials can both satisfy a vague law that neither entity asked for but still need to deal with. My guess is that most reasonable AHJ's would welcome an easy way to ensure that the laws are complied with while limiting their own exposure. I don't know of any AHJ's who have the time, resources, or expertise to conduct in-depth investigations into whether or not A/E's have created commissioning plans that meet all of the requirements appropriate for each project. With buy-in from the AHJ, these references might just allow everyone to rely on nationally recognized 'standards' while giving Owners some latitude when hiring CxA's. Mark Gilligan SE, CSI Senior Member Username: mark_gilligan Post Number: 143 Registered: 10-2007 Posted on Friday, March 20, 2009 - 02:32 pm:    I am of the opinion that non directive documents such as design guides do not belong in the contract documents. If you cannot agree on what is required you have no requirement. Why not retain a commissioning consultant, possibly paid by the Owner, to produce the commissioning plan to be placed in the construction documents. Is this really any different than is done with other diciplines where the design professional lacks the necessary expertise. J. Peter Jordan Senior Member Username: jpjordan Post Number: 319 Registered: 05-2004 Posted on Monday, March 23, 2009 - 11:55 am:    I think one of the problems is that "commissioning" is different from "inspection and testing." While they may seem the same, commissioning is an activity that takes place throughout the design and construction phases to verify that first the design (including drawings and specification) and then the construction is consistent with the design intent as stated in the Basis of Design. Inspection and testing for certain components is to ensure that inplace construction complies with construction documents generated by the design professional and code requirements established by the AJH. The differences may be subtle, but they are profound. When the AHJ requires commissioning, I think they probably mean a more complete inspection and testing of the building envelope. Commissioning would be a more complex activity. The requirement set in place by one of the local AHJs indicates to me more that they really don't understand what they want than anything else. Putting an indication that the owner/architect/contractor intends to comply with the requirements on the Drawings or in the Specs is really irrelevant.