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Code narrative worthwhile for plans examiners?

P

princeofpen

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Question for the examiners. The firm I work for does complex projects and we always provide a summary of the project w/typicals such as building type, area,egress both load and capacities. Wondering if, in addition to, the summary I/we should provide an additional letter that might include scope of compliance of flammables use/storage or hazards. Recently submitted a vo-tech facility and ended up with a bunch of questions for their automotive repair and bodyshop areas. Also did a weed grow processing that needed electrical compliance and storage of hazards info beyond what I had submitted.
Also wondering if providing a letter signed by an MCP would be more of a negative than positive in the eyes of a reviewer.

Thanks for any help on the subject , I'd like input prior to running it up the flag pole
 
As a plan reviewer, my opinion is that general statements of the type I routinely receive ("Corridor walls Class B," etc) are totally worthless. An enumeration of the actual specified products and their ratings would be helpful -- if it includes a tabulation of where in the drawings or specs each product is actually specified. Remember, section 107.2.1 of the IBC says:

107.2.1 Information on construction documents.
Construction documents shall be dimensioned and drawn on
suitable material. Electronic media documents are permitted to
be submitted where approved by the building official.
Construction documents shall be of sufficient clarity to indicate
the location, nature and extent of the work proposed and
show in detail that it will conform to the provisions of this
code and relevant laws, ordinances, rules and regulations, as
determined by the building official.
Click to expand...

It comes down to what the code official thinks is sufficient detail to show code conformity. The IBC Commentary on 107.2.1 adds:

The construction documents are required to be of a
quality and detail such that the building official can
determine whether the work conforms to the code and
other applicable laws and regulations. General statements
on the documents, such as “all work must comply
with the International Building Code®,” are not an
acceptable substitute for showing the required information.
The subsections and sections indicated in the
commentaries to Sections 107.2.2 through 107.2.8
detail the information that must be shown on the submitted
documents. Where specifically allowed by the
building official, documents can be submitted in electronic
form.
Click to expand...

Statements such as "Class A" or "Class B" aren't much more specific than "All finishes must comply with the IBC." The problem is that such statements put the responsibility for code compliance on the contractor, who may or may not know enough to choose appropriate materials. The construction documents are supposed to spell out exactly what materials the contractor is supposed to use, and tell him how to install them. In an ideal world, a contractor should not have to know anything about building codes and should never have to think about opening a code book.

Also wondering if providing a letter signed by an MCP would be more of a negative than positive in the eyes of a reviewer.
Click to expand...

What's an MCP? Why would a letter signed by an MCP make any difference? If I look at the drawings and find that there isn't enough detailed information to demonstrate code conformity, if I see a letter from some sort of consultant purportedly attesting that the design meets code when I can see that there isn't enough information to make that determination -- I'm not going to be very happy with either the applicant or their consultant.
 
Master Code Professional. Basically someone with a gazillion ICC certifications. It would impress me as long as the plans were good. If I keep finding basic errors, I would be less impressed.

www.iccsafe.org

Master Code Professional Qualifications - ICC

CREDENTIALING Master Code Professional Designation Skip menu Navigation Home Certifications Certifications Exams Special Inspector Exams UST/AST Exams Reciprocity/Transitions Master Code Professional Combination Designations Exam Resources Exam Resources Journey Exam Overview...
www.iccsafe.org www.iccsafe.org
 
princeofpen said:
Question for the examiners. The firm I work for does complex projects and we always provide a summary of the project w/typicals such as building type, area,egress both load and capacities. Wondering if, in addition to, the summary I/we should provide an additional letter that might include scope of compliance of flammables use/storage or hazards. Recently submitted a vo-tech facility and ended up with a bunch of questions for their automotive repair and bodyshop areas. Also did a weed grow processing that needed electrical compliance and storage of hazards info beyond what I had submitted.
Also wondering if providing a letter signed by an MCP would be more of a negative than positive in the eyes of a reviewer.

Thanks for any help on the subject , I'd like input prior to running it up the flag pole
Click to expand...
"chemicals" and quantities is something that we seem to struggle with, height of storage and the "3D" stuff we don't normally get on a plan...any other "special" operations a narrative might be nice....
 
BN4537 said:
Master Code Professional. Basically someone with a gazillion ICC certifications. It would impress me as long as the plans were good. If I keep finding basic errors, I would be less impressed.

www.iccsafe.org

Master Code Professional Qualifications - ICC

CREDENTIALING Master Code Professional Designation Skip menu Navigation Home Certifications Certifications Exams Special Inspector Exams UST/AST Exams Reciprocity/Transitions Master Code Professional Combination Designations Exam Resources Exam Resources Journey Exam Overview...
www.iccsafe.org www.iccsafe.org
Click to expand...

I thought that might be it. I personally know five people with MCP certification. I still would not accept a letter from any of them in place of doing my own in-depth plan review.

What would be helpful from such a person would be an enumeration of fundamental code issues with a listing of where in the construction documents I can find that it shows compliance.
 
I required a code narrative from the RDP, see supplemental sheets at this link. https://www.townofcharlton.net/Docu...cial--application-with-supplemental-pages-PDF

I explained to RDP, if you think i may ask a question about it they should answer it and the easier the applicant make the submittal for me to find the answer the quicker you may get your permit.

Do I believe everything that is submitted, trust but verify.
 
princeofpen said:
Also wondering if providing a letter signed by an MCP would be more of a negative than positive in the eyes of a reviewer.
Click to expand...
How helpful such a letter might be depends on what it says, and how it says it. No letter from any consultant, even an MCP, remves MY responsibility/duty to review the construction documents.

IBC 2021:

104.2 Applications and permits. The building official
shall receive applications, review construction documents and
issue permits for the erection, and alteration, demolition and
moving of buildings and structures, inspect the premises for
which such permits have been issued and enforce compliance
with the provisions of this code.
Click to expand...

Commentary on the above:

The building official is obligated to receive applications,
review construction documents, issue permits,
conduct inspections and enforce the provisions of the
code. They are to provide the services required to
carry the project from application for the permit to final
approval. The building official is to accept all properly
completed applications and not refuse the receipt of an
application that meets the policy requirements. This
same principle holds for the review of the construction
documents, issuance of permits, inspections and
enforcement of the code’s provisions. The requirements
of the code must be met, and approval will be
granted only when compliance is verified.
Click to expand...

Reading a letter written by a person I've probably never met, who isn't a member of my department and who is being paid by the applicant, in no way constitutes verification.

Recent example (sort of): Last week I reviewed plans for installing a large solar array on a flat roof of a commercial building. Obviously, this adds weight on an existing roof. They submitted a letter from a licensed structural engineer attesting that the proposed solar array will not overload the roof structure.

Problem: The proposed solar array is to be held down with ballast, not by physically screwing through the roof membrane into the structure. The engineer's letter explicitly stated that his analysis did not include the weight of the ballast. I ran the numbers, and the weight totals I came up with were different from what the engineer stated. So I rejected it. He re-wrote the letter, to more clearly state that his analysis was only for gravity loads, that he did include the weight of the ballast, but that his analysis did not include uplift on the solar array.

On that basis, we're approving the project. My point here is that the original letter was not helpful, because it didn't say what it apparently intended to say.
 
Yankee Chronicler said:
I thought that might be it. I personally know five people with MCP certification. I still would not accept a letter from any of them in place of doing my own in-depth plan review.

What would be helpful from such a person would be an enumeration of fundamental code issues with a listing of where in the construction documents I can find that it shows compliance.
Click to expand...
It would carry no additional weight with me. I say this as an MCP...how many questions do I ask that demonstrate my knowledge is limited? I know plenty of non-MCP type folks who put me to shame. I know plenty of MCP type folks who make me ashamed. I would certainly read it, but not take any words in lieu of demonstrated compliance.

I have received my share of "opinions" about projects from code consultants with far more knowledge and experience than me. Sometimes I learn from them, sometimes I see other points of view, sometimes I see creativity I had not considered, sometimes I see the bias inherent in the desire to please a client.

I can say I appreciate any level of analysis beyond the cookie cutter. Most of the time the mere idea that they are looking at it hard enough might mean the level of effort they put forth gives me a little more confidence about things for which my knowledge is limited.

Many years ago I thought every certification would give me credibility. Now I KNOW credibility only comes with knowledge, reason and experience. A piece of paper or letters on a business card is not necessarily indicative of those things.
 
Yankee Chronicler said:
I thought that might be it. I personally know five people with MCP certification. I still would not accept a letter from any of them in place of doing my own in-depth plan review.

What would be helpful from such a person would be an enumeration of fundamental code issues with a listing of where in the construction documents I can find that it shows compliance.
Click to expand...
I'm not saying a letter in place of doing your job but rather more of an informative or interpretive of what's being proposed. Not every dept has depth of knowledge in complicated code issues. I do like your point of enumeration and location in construction documents showing compliance so a reviewer can get a better snapshot of what's proposed. I'm just thinking of pulling that info somewhere other than a basic summary section on plan to deal with specific issues to not have the summary become too busy. Examples being as I stated storage and use of flammables/combustibles but could also be egress study on auditoriums with/without smoke protected seating that could be provided as more in depth information outside drawing pages.
I spent 19yrs as head plans examiner and inspector so I get where you are coming from as far as information from a consultant or engineer. My question regarding an MCP is I don't know if it would be seen as a positive or negative if I added a signature line on supplemental paperwork provided with a submittal.
 
Sifu said:
It would carry no additional weight with me. I say this as an MCP...how many questions do I ask that demonstrate my knowledge is limited? I know plenty of non-MCP type folks who put me to shame. I know plenty of MCP type folks who make me ashamed. I would certainly read it, but not take any words in lieu of demonstrated compliance.

I have received my share of "opinions" about projects from code consultants with far more knowledge and experience than me. Sometimes I learn from them, sometimes I see other points of view, sometimes I see creativity I had not considered, sometimes I see the bias inherent in the desire to please a client.

I can say I appreciate any level of analysis beyond the cookie cutter. Most of the time the mere idea that they are looking at it hard enough might mean the level of effort they put forth gives me a little more confidence about things for which my knowledge is limited.

Many years ago I thought every certification would give me credibility. Now I KNOW credibility only comes with knowledge, reason and experience. A piece of paper or letters on a business card is not necessarily indicative of those things.
Click to expand...
Man I get you on that! I always equated being an MCP with when I earned 1st degree blackbelt. I was told "now your real training begins" and always have remained a student looking to know what I don't on the daily
 
princeofpen said:
Man I get you on that! I always equated being an MCP with when I earned 1st degree blackbelt. I was told "now your real training begins" and always have remained a student looking to know what I don't on the daily
Click to expand...
They said the same thing to me after my first degree, but then they said it after my second too. So then I realized you never stop learning (kind of the point), which is the way I try to approach everything.

It also explains why I am on THE forum almost daily.
 
princeofpen said:
I'm not saying a letter in place of doing your job but rather more of an informative or interpretive of what's being proposed. Not every dept has depth of knowledge in complicated code issues. I do like your point of enumeration and location in construction documents showing compliance so a reviewer can get a better snapshot of what's proposed. I'm just thinking of pulling that info somewhere other than a basic summary section on plan to deal with specific issues to not have the summary become too busy. Examples being as I stated storage and use of flammables/combustibles but could also be egress study on auditoriums with/without smoke protected seating that could be provided as more in depth information outside drawing pages.
I spent 19yrs as head plans examiner and inspector so I get where you are coming from as far as information from a consultant or engineer. My question regarding an MCP is I don't know if it would be seen as a positive or negative if I added a signature line on supplemental paperwork provided with a submittal.
Click to expand...

I think perhaps the narrative should wait until (or unless) the building department asks for it. My basic view of this is ... if you need a narrative to explain it, the architects who prepared the construction documents didn't do their job.

IBC 2021:

107.2.1 Information on construction documents.
Construction documents shall be dimensioned and drawn on
suitable material. Electronic media documents are permitted to
be submitted where approved by the building official.
Construction documents shall be of sufficient clarity to indicate
the location, nature and extent of the work proposed and
show in detail that it will conform to the provisions of this
code and relevant laws, ordinances, rules and regulations, as
determined by the building official.
Click to expand...

If someone has to hire an MCP to write up a narrative explaining how the design complies with the code, then the construction documents obviously do not "show in detail that it will conform to the provisions of this code." That's an explicit requirement of the code. If the construction documents don't satisfy that requirement, it means someone didn't do their job.
 
Yankee Chronicler said:
I think perhaps the narrative should wait until (or unless) the building department asks for it. My basic view of this is ... if you need a narrative to explain it, the architects who prepared the construction documents didn't do their job.

IBC 2021:



If someone has to hire an MCP to write up a narrative explaining how the design complies with the code, then the construction documents obviously do not "show in detail that it will conform to the provisions of this code." That's an explicit requirement of the code. If the construction documents don't satisfy that requirement, it means someone didn't do their job.
Click to expand...
You're missing my point completely as I'm an on staff MCP for every project reviewing each step of the design process prior to submittal. I prepare the code summary that's included in all our drawings but wonder if providing further information about specific portions of the drawings would be beneficial. A narrative would be more for a reviewer who might not understand,for example, auditorium egress as I wouldn't include minutia of detail on seating and ramp slope etc. I would provide all of that in one place for the reviewer rather than multiple pages they'd have to gather that info. With a couple hundred page document it would clear the path so to speak
 
princeofpen said:
You're missing my point completely as I'm an on staff MCP for every project reviewing each step of the design process prior to submittal. I prepare the code summary that's included in all our drawings but wonder if providing further information about specific portions of the drawings would be beneficial. A narrative would be more for a reviewer who might not understand,for example, auditorium egress as I wouldn't include minutia of detail on seating and ramp slope etc. I would provide all of that in one place for the reviewer rather than multiple pages they'd have to gather that info. With a couple hundred page document it would clear the path so to speak
Click to expand...

I don't think I'm missing your point at all. My first reply stated that a document that provides a roadmap for where to find the required information in the construction documents could be helpful. Beyond that, I view any narrative explanation as an admission that the drawings don't provide the information required by the code.

In other words: The information needs to be in the construction documents. A document that makes it easier to find the information in the construction documents would be helpful -- and such a document doesn't have to be signed by an MCP, it can be signed by the janitor. If the narrative is for the purpose of trying to fill in gaps to provide information that's NOT shown on the construction documents, then it's not helpful, it's just a distraction.
 
In my experience, it is rare that a designer provides all the required or necessary information. Unfortunately, it seems that many designers do not truly understand all of the potential implications of their build.
Examples include:
- autobody shop. What chemicals are being used, stored, and how?
- public-access pool. Again, chemicals.
- tarp shelters and glamping domes: what are the freaking flame-spread ratings, and does the material meet appropriate ULC/CSA standards? (Hint: buying stuff off Teemu or whateverthefrig it's called probably means "no.")

I'm starting to become more concerned over things I ought not to be concerned about - like professional engineers using incorrect seismic data for construction. In one case, a design came in with the seismic specified at 60 per cent less than required. (!)

Half the time, designers seem to just specify "one layer type x 5/8 drywall both sides" without referencing to any established fire-rated assemblies or calculations ....and get pissy when I say "show your work."

Geez, if you can't show me your work, how do I know that you know what you're doing? For the love of Pete, part 9/ULC/Appendix D calculations are not freaking difficult... if you know what you're doing.

That said, I get giddy when I see a design where a designer has
- correctly done spatial separation calcs
- correctly referenced fire separations
- actually classified the freaking building (correctly)
- shown where the fire hydrant is on the site plan
- already calculated (and shown for verification) things like exit paths/distances, calculated exit widths.

I think that I've had one such plan in the last four years.
One.
 
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